Trust
Parental Consent
How we obtain and verify consent for processing photos of children under 13.
Overview
SmilePlease is designed to help parents create beautiful school-style portraits of their children. Because we process photos that may include children under 13, we comply with the Children's Online Privacy Protection Act (COPPA) and require verifiable parental consent.
Only upload child photos if you are the parent, legal guardian, or otherwise have the authority and consent needed to use those photos with SmilePlease.
When consent is required
- You are a parent or legal guardian at least 18 years old.
- You upload one or more photos of a child under 13 years of age.
- The child's image will be processed by our AI system (Google Gemini) to generate portraits.
- The child's image will be shared with our print fulfillment partner (Finerworks) for printing.
What we collect
For children under 13, we collect only uploaded photos and generated portraits. We do not collect names, email addresses, or other personal information directly from children. All account and payment information is collected from the parent or guardian.
How to provide consent
Option 1: Credit Card Verification
During checkout, your payment card is verified as belonging to an adult. By completing a purchase for prints containing your child’s portrait, you are providing verifiable consent for processing and fulfillment.
Option 2: Email Consent Form
Email privacy@smileplease.app with subject "Parental Consent Request" to receive a consent form. We will verify your identity by matching the email to your account and may ask security questions.
Option 3: Government ID Verification
For additional verification, you may submit a copy of government-issued ID. Email privacy@smileplease.app with subject "ID Verification for Parental Consent" for instructions.
Option 4: Signed Consent (Organizations)
For schools, daycares, or organizations, we offer a signed consent form option. Email privacy@smileplease.app for details.
Biometric consent (Illinois residents)
When you upload photos, our AI system may analyze facial features to generate portrait variations. This processing may constitute collection of biometric data under the Illinois Biometric Information Privacy Act (BIPA).
Illinois residents: By uploading photos and initiating AI generation, you provide written consent under BIPA to the processing of facial features. We do not create or store facial templates, face prints, or biometric identifiers beyond what is necessary to generate your portraits. Uploaded photos are deleted within 10 days of generation. Generated portraits are deleted within 30 days (or 12 months if you purchase and opt in).
Separate consent for sharing
Per COPPA requirements, we obtain separate consent before sharing your child's photo with third parties:
You may use our service for AI generation only (without ordering prints) if you prefer not to share with our print partner.
- AI Processing (Google Gemini): By uploading photos and initiating generation, you consent to the photos being processed by Google’s Gemini AI.
- Print Fulfillment (Finerworks): By completing a print order, you consent to the generated portrait being shared with our print partner for production and shipping.
Your rights as a parent
As a parent or legal guardian, you have the right to review, delete, refuse, and withdraw consent. To exercise any of these rights, email privacy@smileplease.app with the subject "Parental Rights Request." We will respond within 48 hours.
- Review: Request a copy of any photos or data we have collected about your child.
- Delete: Request immediate deletion of your child's photos and data at any time.
- Refuse: Decline further collection or use of your child's data.
- Withdraw consent: Revoke your consent at any time, and we will stop processing and delete the data.
Data retention and deletion
- Uploaded source photos are automatically deleted within 10 days. Preview portraits are deleted within 30 days, and purchased portraits are retained for 12 months unless a longer period is required for security, legal, fraud-prevention, or transaction records.
- You may request deletion at any time while the data is still retained.
- If you have downloaded digital copies, those remain in your possession after deletion from our servers.
- Order records (without images) are retained for legal and tax purposes as described in our Privacy Policy.
Our commitment
- We never use children's photos for advertising or marketing.
- We never sell children's data to third parties.
- We never use children's photos to train AI models.
- We collect only the minimum data necessary to provide the service.
- We use industry-standard security measures to protect all data.
Consent timeline
- Email consent requests: Processed within 24 hours.
- Parental rights requests: Responded to within 48 hours.
- Deletion requests: Completed within 24 hours.
Questions?
If you have questions about parental consent or COPPA compliance, contact privacy@smileplease.app.