Privacy Policy

Top Achievers — Privacy Policy

Effective Date: 07/02/2026

1. Introduction

Top Achievers (“Top Achievers,” “we,” “us,” or “our”) is committed to protecting the privacy of the families we serve, including our student participants and their parents or legal guardians. This Privacy Policy explains what information we collect through our website and program enrollment/profile system, how we use and share it, and the choices and rights available to you — especially where our participants are children under the age of 13.

This Policy applies to information collected through topachieversplano.org and any related registration, profile, or program-management tools (the “Services”). By using our Services, you agree to the practices described here. If you do not agree, please do not use the Services or contact us at the information below to discuss alternatives.

2. Who This Policy Covers

• Parents/Guardians who create an account, register a child, or otherwise interact with our Services.
• Participants (children and youth) enrolled in Top Achievers programs, including those under 13.

Because some of our participants are under the age of 13, this Policy is designed to comply with the Children’s Online Privacy Protection Act (COPPA) and its implementing regulations (16 C.F.R. Part 312), as amended effective 2025–2026. For participants age 13 and older, COPPA’s specific requirements do not legally apply, but we extend the same data-handling commitments described in this Policy to all participants regardless of age.

3. Information We Collect

3.1 From Parents/Guardians

• Name and contact information (email, phone number)
• Highest level of education completed
• How you heard about Top Achievers
• Any information you provide when communicating with us (e.g., emails, program feedback)

3.2 About Participants (Children)

• Name and date of birth (month and year only)
• Race/ethnicity (self- or parent-reported, used for demographic reporting to funders and program planning)
• School, District, grade level, and other program-relevant information
• Photos, videos, or testimonials, only where separate written consent is obtained
• Attendance, progress, and program participation records

3.3 Automatically Collected Information

If our Services are accessed online, we may automatically collect limited technical information such as IP address, browser type, and pages visited, through standard web server logs or analytics tools. We do not use this technical information to build advertising profiles of children, and we do not use behavioral tracking or targeted-advertising cookies on pages directed at children.

3.4 Information We Do Not Collect

We do not knowingly collect more personal information from children than is reasonably necessary for them to participate in our programs, consistent with COPPA’s data minimization requirement.

4. How We Use Information

We use the information described above to:

• Register and enroll participants in Top Achievers programs
• Communicate with parents/guardians about enrollment, events, and program updates
• Administer and improve our programs
• Prepare aggregate, de-identified reports for funders, grantors, and community partners
• Ensure the safety and appropriate supervision of participants
• Comply with legal, accreditation, or grant-reporting obligations

We do not sell personal information belonging to children or adults, and we do not use children’s personal information for third-party targeted advertising.

5. Children’s Privacy (COPPA) — Additional Protections

5.1 Parental Consent

Before we collect personal information from a child under 13, a parent must authorize that their child is allowed to create an account with Top Achievers. Consent for this is obtained when the parent authorizes the child to create their own account and self-register for events.

5.2 Use of Information Without Excess Collection

Participation in Top Achievers programs is not conditioned on a child disclosing more personal information than is reasonably necessary for that activity.

5.3 Disclosure to Third Parties

We do not disclose a child’s personal information to third parties except:

• To service providers who help us operate our programs (e.g., program management software), under confidentiality obligations
• To school partners or program collaborators directly involved in providing services to the participant
• To funders or grant agencies, only in aggregate or de-identified form unless otherwise required
• As required by law, court order, or to protect the safety of a child

Where a disclosure is not integral to providing the Services (for example, third-party marketing), we will seek separate, additional verifiable parental consent before making that disclosure, consistent with the FTC’s 2025 COPPA Rule amendments.

5.4 Parental Rights

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

• Review the personal information we have collected from your child
• Request that we delete your child’s personal information
• Refuse to permit us to collect, use, or further collect information from your child, and request the discontinuation of your child’s participation in related Services
• Revoke your previously given consent at any time

To exercise any of these rights, contact us using the information in Section 9. We will respond and verify your identity as the parent/guardian before fulfilling the request.

5.5 Data Retention and Deletion

We retain children’s personal information only for as long as reasonably necessary to fulfill the purpose for which it was collected (e.g., duration of program enrollment plus any period required for grant/funder reporting or legal recordkeeping), and we do not retain it indefinitely. When information is no longer needed, we securely delete or de-identify it, consistent with 16 C.F.R. § 312.10.

6. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, or disclosure. No system is completely secure, and we encourage parents to contact us promptly at 469-573-0928 or gro.onalpsreveihcapotobfsctd-44fc0f@ofni if you believe your account or your child’s information has been compromised.

7. Sharing and Disclosure (All Users)

Beyond the children’s-data protections in Section 5, we may share information generally with:

• Service providers and vendors who support our operations (e.g., hosting, program management, email) under contractual confidentiality terms
• Funders, grantors, and government agencies, generally in aggregate/de-identified form, or as required for compliance reporting
• Legal or safety authorities where required by law or necessary to protect the safety of a participant or others

We do not sell personal information.

8. Your Choices

• You may decline to provide information (by selecting “Prefer not to say / Decline to Answer”) without affecting your child’s core eligibility for enrollment, unless that information is required for a specific funding or reporting requirement, in which case we will tell you.
• You may update or correct your family’s information at any time by contacting us or through your account, where available.
• You may withdraw consent for photo/video use at any time, prospectively.

9. Contact Us

If you have questions about this Privacy Policy, or want to exercise the rights described above, contact:

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will post the revised Policy with an updated “Last Updated” date, and where changes materially affect how we handle children’s information, we will provide notice to parents/guardians and, where required by law, obtain renewed consent.