Tennessee Information Protection Act (TIPA) Compliance

Overview

The Tennessee Information Protection Act (TIPA), effective July 1, 2025, provides Tennessee residents with comprehensive privacy rights regarding their personal data. Kids on the Yard is committed to protecting the privacy of Tennessee residents and complying with all TIPA requirements.

What is the TIPA?

The Tennessee Information Protection Act is a comprehensive privacy law that grants Tennessee 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 Tennessee or produce products or services targeted to Tennessee residents and meet specific data processing thresholds.

Your Rights Under the TIPA

As a Tennessee resident, you have the following rights under the TIPA:

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
• Purposes for processing your personal data
• Categories of sources from which personal data is collected
• 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
• Detecting security incidents and protecting against fraudulent or illegal activity
• Complying with legal obligations
• Exercising free speech rights or ensuring others can exercise free speech rights
• 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 TIPA

Data Protection Principles

Kids on the Yard complies with TIPA through:

Data Minimization and Purpose Limitation

• Limited Collection: We collect only personal data that is adequate, relevant, and reasonably necessary for disclosed purposes
• Purpose Specification: We process personal data only for disclosed, specific, and legitimate purposes
• Retention Limits: We retain personal data no longer than reasonably necessary for stated purposes
• Regular Review: We periodically assess data collection and retention practices

Transparency and Accountability

• Clear Privacy Notices: We provide accessible information about our data collection and processing practices
• Processing Records: We maintain comprehensive records of processing activities and purposes
• Data Protection Impact Assessments: We conduct assessments for high-risk processing activities
• Privacy by Design: We implement privacy considerations into our system design and operations

Consumer Rights Implementation

We have established robust processes to:

• Identity Verification: Authenticate requests using reliable verification methods to prevent unauthorized access
• Timely Response: Process verified consumer requests within 45 days of receipt
• Accessible Communication: Provide requested information in clear, understandable formats
• Non-Discrimination: Ensure no adverse treatment for exercising privacy rights
• Quality Assurance: Maintain high standards for response accuracy and completeness

Categories of Personal Data We Process

Under the TIPA, we collect and process the following categories of personal data from Tennessee residents:

Personal Identifiers and Contact Information

• Full name, email addresses, phone numbers, mailing addresses
• Account usernames, encrypted passwords, and security questions
• Government-issued identification numbers (when legally required)
• Emergency contact information and authorized representatives

Educational and Academic Information

• Student records, academic performance data, and progress tracking metrics
• Learning assessments, test scores, skill evaluations, and educational goals
• Tutoring session recordings, notes, recommendations, and curriculum data
• Parent/guardian communications regarding student progress and educational needs

Financial and Payment Information

• Payment card details, billing addresses, and payment method preferences
• Transaction histories, subscription details, payment records, and billing cycles
• Refund and billing dispute information, payment failure records
• Financial assistance information, scholarship data, and discount applications

Technical and Usage Information

• Device information, IP addresses, browser types, and operating system details
• Website navigation patterns, service usage data, and interaction logs
• Customer support communications, help desk tickets, and feedback submissions
• Platform preferences, account settings, and customization choices

Communication and Marketing Data

• Email correspondence, live chat conversations, and message histories
• Phone call records, voicemail messages, and communication preferences
• Survey responses, feedback forms, and product review submissions
• Marketing communication consent records and preference settings

Sensitive Personal Data Processing

When we process sensitive personal data as defined by TIPA (including precise geolocation, biometric data for identification purposes, health information, or data concerning children under 13), we:

Enhanced Protection Measures

• Explicit Consent: Obtain clear, informed consent for sensitive data processing
• Heightened Security: Implement additional technical and organizational safeguards
• Limited Processing: Restrict use to strictly necessary purposes with clear justification
• Enhanced Access Controls: Implement role-based access and audit trails for sensitive data access
• Special Handling: Follow enhanced procedures for sensitive data storage, transmission, and deletion

Opt-In Consent Requirements

For processing sensitive personal data, we:

• Clearly explain the specific purposes for processing
• Identify the categories of sensitive data involved
• Provide easy-to-use mechanisms to withdraw consent
• Regularly review and reconfirm consent as appropriate
• Maintain detailed records of consent and withdrawal

Third-Party Data Sharing and Processing

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

Service Providers and Data Processors

• Cloud hosting and data storage service providers with appropriate security measures
• Payment processing companies and financial institutions with PCI compliance
• Customer support platforms and communication service providers
• Educational content providers, curriculum developers, and assessment platforms

Business Partners and Strategic Alliances

• Technology integration partners and software platform providers
• Analytics and performance monitoring service providers with privacy commitments
• Educational research organizations and academic institutions (with appropriate approvals)
• Marketing partners and advertising platforms (with explicit user consent)

Legal and Regulatory Requirements

• Law enforcement agencies (when required by valid legal process or court order)
• Regulatory authorities and government agencies (as mandated by applicable law)
• Legal counsel, professional advisors, and external audit firms
• Litigation support services and court-ordered disclosures

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

How to Exercise Your TIPA Rights

Tennessee residents may exercise their privacy rights through multiple convenient methods:

Submit a Privacy Request

• Online Privacy Portal: Visit our secure Privacy Request Center
• Email: Send detailed requests to [email protected] with "TIPA Request" in the subject line
• Phone: Call our dedicated privacy hotline at International: +1 786-382-2000
• Mail: Send written requests to our business address listed in the contact section below

Information Required for Request Processing

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

• Your full legal name and current contact information
• Email address associated with your Kids on the Yard account (if applicable)
• Proof of Tennessee residency (utility bill, driver's license, voter registration, etc.)
• Specific and detailed description of your privacy request
• Any additional information that may help us locate and verify your personal data

Response Timeline and Procedures

• Initial Acknowledgment: We confirm receipt of all requests within 10 business days
• Identity Verification: Verification process typically completed within 5-15 business days
• Response Period: We respond to verified requests within 45 days of receipt
• Complex Requests: May require up to 90 days with advance written notification and explanation
• No Charge Policy: We provide up to two comprehensive responses per calendar year at no cost
• Excessive Requests: May incur reasonable administrative fees for repetitive or manifestly unfounded requests

Appeals Process and Dispute Resolution

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

Internal Appeal Process

1. Submit Appeal: Email [email protected] with "TIPA Appeal" in the subject line
2. Include Documentation: Provide your original request reference number and detailed explanation of your concerns
3. Review Period: We will thoroughly review appeals and respond within 60 calendar days
4. Appeal Response: We will provide a detailed written explanation of our decision and any corrective actions taken

External Review and Enforcement

If you remain unsatisfied with our internal appeal response, you may:

• Contact the Tennessee Attorney General's Office Consumer Affairs Division
• File a complaint with relevant state consumer protection agencies
• Consult with qualified legal counsel regarding your privacy rights under Tennessee law
• Explore other legal remedies and enforcement mechanisms available under applicable law

Data Security and Protection Framework

We implement comprehensive security measures to protect Tennessee residents' personal data:

Technical Security Controls

• Encryption Standards: Industry-standard encryption for data at rest and in transit
• Access Control Systems: Multi-factor authentication and role-based access controls
• Network Security: Firewalls, intrusion detection, and advanced threat monitoring
• Secure Development: Privacy and security by design in all system development

Administrative and Organizational Controls

• Privacy Training: Regular comprehensive training for all personnel handling personal data
• Policy Framework: Detailed data handling, retention, and deletion policies
• Incident Response: Established procedures for security incident response and breach notification
• Vendor Management: Rigorous security assessment and monitoring of third-party processors

Physical Security Measures

• Facility Security: Controlled physical access to data centers and processing facilities
• Media Protection: Secure storage and disposal procedures for physical media
• Environmental Controls: Climate control and monitoring systems for data storage areas
• Access Logging: Comprehensive logging and monitoring of physical access to sensitive areas

Contact Information

For questions about our TIPA 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

Tennessee Residents Privacy Hotline: Available Monday-Friday, 9 AM - 5 PM CST

Last Updated: January 1, 2025

For more information about the Tennessee Information Protection Act, visit: https://www.tn.gov/attorneygeneral/consumer-protection/privacy