COPPA Compliance

Our Commitment to Children's Privacy

Model Communicator is a communication tool built for people of all ages, including young children. Many of our users are children who rely on augmentative and alternative communication (AAC) to express themselves. We take our responsibility to protect these users seriously.

We comply with the Children's Online Privacy Protection Act (COPPA), which sets requirements for how services must handle the personal information of children under 13 years of age in the United States.

Intended Audience

Model Communicator is an AAC tool designed for individuals of all ages who need communication support. This includes toddlers, school-age children, teenagers, and adults. We do not restrict access based on age because communication is a fundamental need at every stage of life.

Because our audience includes children under 13, we apply COPPA protections to all users by default. We do not offer separate "child" and "adult" experiences -- the same privacy protections apply to everyone.

Parental and Guardian Consent

Model Communicator can be used without creating an account. The core communication features -- tapping symbols, building sentences, and speaking with text-to-speech -- work immediately with no sign-in required.

If a parent or guardian chooses to create an account (to save custom grids and sync preferences), authentication is handled through Google Single Sign-On (SSO). Google's own policies require parental consent for accounts belonging to children under 13, through their Family Link program.

We rely on the parental consent mechanisms built into Google's account system. A child under 13 cannot create a Google account without a parent or guardian's involvement, and by extension, cannot create a Model Communicator account without parental consent.

What We Collect from Child Users

When a child uses Model Communicator without an account (the default experience), we collect nothing. No personal information of any kind.

When a parent creates an account on behalf of a child, the only personal information we receive is:

• The email address associated with the Google account (which is the parent's email or a parent-managed child email)
• Custom grid data that the parent or child creates and saves
• Application preferences (grid size, voice, language)

That is the complete list. We do not collect anything beyond these items.

What We Do NOT Collect from Children

We want to be completely clear about what Model Communicator never collects from any user, including children:

• Names of children
• Physical addresses
• Phone numbers
• Photos or images of children
• Words, sentences, or utterances they speak
• Which symbols or tiles they tap
• Communication patterns or frequency data
• Location or geolocation data
• Behavioral tracking or profiling data
• Contact lists or device identifiers

We do not use behavioral tracking, device fingerprinting, or any technique designed to build a profile of a child user. The communication content processed by Model Communicator stays entirely on the user's device.

No Advertising, Ever

We believe that a communication tool -- especially one used by children -- should never be a vehicle for advertising. Model Communicator is funded independently and will remain ad-free permanently.

Parental Rights

As a parent or guardian, you have the right to:

• Review the personal information we have collected about your child's account
• Request deletion of your child's personal information and account
• Refuse further collection by deleting the account at any time
• Request changes to any data associated with your child's account

To exercise any of these rights, please contact us at jim@modelcommunicator.com. Include the email address associated with the account, and we will respond within 30 days.

You can also delete custom grids directly within the Model Communicator application at any time without needing to contact us.

School Use and FERPA

Many schools use Model Communicator as a communication tool for students. When Model Communicator is used in an educational setting, the Family Educational Rights and Privacy Act (FERPA) may apply to student records maintained by the school.

Important notes for schools and educators:

• Model Communicator can be used without creating accounts, so schools can provide the tool to students without collecting any personal information through Model Communicator.
• If a school creates accounts for students, the school acts as the consenting party under COPPA in place of parents, as permitted under the COPPA school consent provision.
• Because Model Communicator does not track communication content or build student profiles, it does not create student education records that would be subject to FERPA.
• Any records that a school or teacher creates about a student's use of Model Communicator (such as progress notes) are the school's records, not ours, and are governed by FERPA accordingly.
• Model Communicator does not share student data with AI tools. Schools whose policies restrict AI use can read exactly where AI is and is not used on our Use of AI page.

If your school district needs additional documentation for compliance review, please contact us and we will be happy to provide it.

Contact Us

If you have questions about our children's privacy practices, or if you are a parent who wishes to review, modify, or delete your child's information, please contact us:

Email: jim@modelcommunicator.com
Project: Model Communicator
Location: Michigan, USA