Connecticut Data Privacy Act (CTDPA) Compliance

Overview

The Connecticut Data Privacy Act (CTDPA), effective July 1, 2023, provides Connecticut residents with comprehensive privacy rights regarding their personal data. Kids on the Yard is committed to protecting the privacy of Connecticut residents and complying with all CTDPA requirements.

Applicability to Kids on the Yard

Kids on the Yard is operated by Limitless Virtue LLC, a Florida limited liability company headquartered in Miami Shores, Florida. Based on the applicability criteria of the Connecticut Data Privacy Act (CTDPA) described above, Kids on the Yard does not currently meet the criteria for direct application of this law, as the law's consumer-volume and data-sale thresholds are not currently met.

Although Kids on the Yard is not directly subject to the Connecticut Data Privacy Act (CTDPA) as a matter of statutory obligation, we have voluntarily adopted the rights, disclosures, and practices described on this page as a matter of best practice and out of respect for the privacy expectations of our families. The rights described above are honored by Kids on the Yard regardless of statutory applicability, through the contact procedures listed below.

If Kids on the Yard's circumstances change such that the Connecticut Data Privacy Act (CTDPA) does directly apply, the obligations described here will become legally binding rather than voluntary, and this section will be updated accordingly. Nothing in this voluntary framework limits or waives any rights you may have under the Connecticut Data Privacy Act (CTDPA) in the event the law does directly apply to Kids on the Yard.

What is the CTDPA?

The Connecticut Data Privacy Act is a comprehensive privacy law that grants Connecticut consumers fundamental rights regarding their personal data and requires businesses to implement responsible data protection practices. The law applies to businesses that conduct business in Connecticut or produce products or services targeted to Connecticut residents and meet specific data processing thresholds.

CTDPA Amendments (2024-2026)

Note on dates. Several amendments to the CTDPA have taken effect since the original July 1, 2023 effective date. The Neural Data category was added by SB 1356, signed in 2025 with an effective date of October 1, 2025 (not 2026). The CTDPA threshold reduction (from 100,000 consumers to 35,000 consumers, plus a sensitive-data trigger) takes effect July 1, 2026, also under SB 1356. (Effective July 1, 2026)

Connecticut has enacted significant amendments to the CTDPA that take effect on July 1, 2026. Kids on the Yard is prepared for these enhanced requirements.

Expanded Sensitive Data Definition

The 2026 amendments expand the definition of "sensitive data" to include:

Enhanced Minor Protections

Prohibition on Minor Data Sales:

• Controllers may NOT sell personal data of consumers they know are under 16
• Controllers may NOT process minor data for targeted advertising
• These prohibitions apply regardless of consent

Social Media Account Requirements:

• Children cannot be required to create social media accounts to exercise privacy rights
• Alternative methods must be provided for minors

Strengthened Consent Requirements

• More explicit consent required for sensitive data processing
• Enhanced disclosure requirements before consent
• Clearer opt-out mechanisms required

Data Minimization Enhancements

Controllers must:

• Limit data collection to what is strictly necessary
• Implement privacy-by-design principles
• Regularly review data retention practices

Our Compliance with 2026 Amendments

Kids on the Yard has implemented:

• Updated consent flows for sensitive data
• Enhanced protections for all minor users
• Neural data policies (we do not collect neural data)
• Strengthened data minimization practices
• Privacy-by-design in all new features

Your Rights Under the CTDPA

As a Connecticut resident, you have the following rights under the CTDPA:

Right to Confirm and Access

You have the right to confirm whether we are processing your personal data and to access such personal data. This includes the right to obtain:

• Categories of personal data we collect about you
• Categories of sources from which personal data is collected
• Business or commercial purposes for collecting or selling personal data
• Categories of third parties with whom we share personal data
• Specific pieces of personal data we have collected about you

Right to Correct

You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes for processing such data.

Right to Delete

You have the right to delete personal data concerning you, subject to certain exceptions including:

• Completing the transaction for which personal data was collected
• Complying with legal obligations
• Exercising free speech or ensuring the right of others to exercise free speech
• Engaging in public or peer-reviewed scientific research in the public interest

Right to Data Portability

You have the right to obtain your personal data in a portable and readily usable format that allows you to transmit the data to another business without hindrance from us.

Right to Opt-Out

You have the right to opt out of:

• Processing of personal data for purposes of targeted advertising
• Sale of personal data to third parties
• Profiling in furtherance of decisions that produce legal or similarly significant effects

How We Comply with CTDPA

Responsible Data Practices

Kids on the Yard complies with CTDPA through:

Data Minimization

• Limited Collection: We collect only personal data that is adequate, relevant, and reasonably necessary
• Purpose Limitation: We process personal data solely for disclosed, specific, and legitimate purposes
• Retention Limits: We retain personal data no longer than reasonably necessary for stated purposes

Transparency and Accountability

• Clear Notice: We provide accessible privacy notices about our data collection practices
• Processing Records: We maintain records of processing activities and purposes
• Impact Assessments: We conduct data protection impact assessments for high-risk processing

Security Measures

• Technical Safeguards: Encryption, access controls, secure data transmission protocols
• Administrative Controls: Privacy training, data handling procedures, breach response plans
• Physical Security: Controlled access to facilities and data storage systems

Consumer Rights Implementation

We have established processes to:

• Identity Verification: Authenticate requests to prevent unauthorized access to personal data
• Timely Response: Process verified consumer requests within 45 days
• Accessible Formats: Provide requested information in clear, understandable formats
• No Discrimination: Ensure no adverse treatment for exercising privacy rights

Categories of Personal Data We Process

Under the CTDPA, we collect and process the following categories of personal data from Connecticut residents:

Contact and Identity Information

• Full name, email addresses, phone numbers, mailing addresses
• Account credentials and security information
• Government-issued identification (when legally required)
• Emergency contact information

Educational and Academic Data

• Student records, academic performance, and progress tracking
• Learning assessments and educational goals
• Tutoring session notes and recommendations
• Parent/guardian communications about student progress

Financial and Transaction Data

• Payment card information and billing addresses
• Transaction histories and subscription details
• Refund and billing dispute information
• Financial assistance and scholarship data

Technical and Behavioral Data

• Device information, IP addresses, and browser characteristics
• Website usage patterns and service interaction data
• Customer support communications and feedback
• Platform preferences and settings

Communication Records

• Email correspondence and chat conversations
• Phone call records with customer service
• Survey responses and feedback submissions
• Marketing communication preferences

Third-Party Data Sharing

We may share personal data with selected third parties for legitimate business purposes:

Service Providers and Processors

• Cloud hosting and data storage providers
• Payment processing companies and financial institutions
• Customer support and communication platforms
• Educational content and curriculum providers

Business Partners

• Technology integration and platform partners
• Analytics and performance monitoring services
• Marketing partners (with appropriate consent)

Legal and Regulatory Compliance

• Law enforcement agencies (when legally required)
• Regulatory authorities and government agencies
• Legal counsel and professional advisors
• Court-ordered disclosures

We do not sell personal data to third parties for monetary consideration.

Sensitive Personal Data Processing

When we process sensitive personal data (including precise geolocation, biometric data for identification, health information, or data concerning children), we:

• Obtain appropriate consent where required by law
• Implement enhanced security measures
• Limit processing to necessary purposes only
• Provide additional privacy protections

How to Exercise Your CTDPA Rights

Connecticut residents may exercise their privacy rights through multiple channels:

Submit a Request

• Online Portal: Visit our Privacy Request Center
• Email: Send requests to [email protected] with "CTDPA Request" in the subject line
• Mail: Send written requests to our business address

Required Information for Processing

To verify your identity and process your request, please provide:

• Your full legal name and contact information
• Email address associated with your Kids on the Yard account
• Proof of Connecticut residency (utility bill, driver's license, etc.)
• Specific details about the nature of your request
• Any additional information needed to locate your personal data

Response Timeline and Process

• Initial Acknowledgment: We confirm receipt of requests within 10 business days
• Response Period: We respond to verified requests within 45 days of receipt
• Complex Requests: May require up to 90 days with advance notification to you
• No Charge Policy: We provide responses at no cost up to twice per calendar year
• Additional Requests: May incur reasonable fees for excessive or repetitive requests

Appeal Process and Dispute Resolution

If you are not satisfied with our response to your privacy request:

Internal Appeal Process

1. Submit Appeal: Email [email protected] with "CTDPA Appeal" in the subject line
2. Include Information: Reference your original request and explain the basis for your appeal
3. Review Period: We will review appeals and respond within 60 calendar days
4. Appeal Response: We will provide written explanation of our decision

External Review Options

If unsatisfied with our appeal response, you may:

• Contact the Connecticut Attorney General's Office
• File a complaint with relevant consumer protection agencies
• Seek legal counsel regarding your privacy rights

Contact Information

For questions about our CTDPA compliance or to exercise your privacy rights:

Privacy Team Kids on the Yard Limitless Virtue LLC 9701 NE 2nd Ave, Suite #1069 Miami Shores, Florida 33138 U.S.A Email: [email protected] Phone: International: +1 786-382-2000

Last Updated: January 1, 2026

For more information about the Connecticut Data Privacy Act, visit: https://portal.ct.gov/AG/Sections/Privacy/The-Connecticut-Data-Privacy-Act