Terms, Conditions & Privacy: All Editions

Including Home Edition, Classroom Edition Addendum, and Kids View Edition Addendum

Original Effective Date: February 16, 2016; Last Amended: July 20, 2026

Classroom Edition Addendum Effective Date: July 20, 2026

Kids View Edition Addendum Effective Date: July 20, 2026

Laws of Attraction, LLC  •  A Colorado Company

privacy@smilesandfrowns.com  •  legal@smilesandfrowns.com

PART I — TERMS OF USE

Effective: July 20, 2016

Smiles & Frowns™ is a mobile application created by parents to help parents and teachers create positive behavior plans for their kids. We take your privacy and the security of your account information very seriously. We employ industry-standard security measures designed to protect your information, and we will never collect or share personal user data in inappropriate ways.     

Acceptance of Terms of Use

Please read these Terms of Use and our Privacy Policy very carefully. If you do not agree to any of the provisions set out in those documents, you should not use our App or any of the Services. By accessing or using the Platform, registering an account, or by viewing, accessing, uploading, or downloading any information or content from or to the Platform, you represent and warrant that you have read and understood the Terms of Use and Privacy Policy and will abide by them.

Changes to Terms of Use

We reserve the right to change, alter, replace or otherwise modify these Terms of Use at any time. The date of last modification is stated at the end of these Terms of Use. It is your responsibility to check this page from time to time for updates. When we make any updates to these Terms of Use, we will highlight this fact on our Website and the App. If you register an account and these Terms of Use are subsequently changed in any material respect, we will notify you in advance by sending a message to your account and/or an email to the address you have provided to us. Your continued use of the Platform after such notification constitutes your acceptance of the revised Terms of Use.

Description of the Platform

The App and related Services constitute a rewards chart mobile application that allows parents, teachers, and other people involved in a child’s life to create and manage behavior plans for the child. The App is based on a rewards approach based on the principle of Emotional Recognition. It also      introduces the 5 Cs of Positive Reinforcement™: Clarity, Consistency, Collaboration, Consequence and a sense of Challenge. This approach was developed through experimentation and personal experience. We make no clinical claim to the effectiveness of the 5 Cs, only that it seemed to work for us and helped guide the development of Smiles & Frowns™. We may, from time to time, release new tools and resources, new versions of our App, or introduce other services and features. Any new services and features will be subject to these Terms of Use as well as any additional terms we may release for those specific services or features.

CLASSROOM EDITION  The Classroom Edition introduces additional user types (teachers/TAs and champions) and additional use contexts (classroom and school settings). See the Classroom Edition Addendum in Part IV for terms specific to institutional use.

KIDS VIEW EDITION  The Kids View companion app allows children to view their behavior boards and track their progress on their own devices. Kids View can only be activated by a parent or guardian through a secure code-pairing process initiated from the parent’s Smiles & Frowns account. See the Kids View Edition Addendum in Part V for terms specific to child device use.

Account Eligibility

All Smiles & Frowns™ accounts — including Home Edition and Classroom Edition accounts — are created by and intended for adults aged 18 and older. Children and students do not create accounts in any edition of Smiles & Frowns™. Children may view behavior board data only through the Kids View companion app, which is activated and controlled entirely by a parent or guardian through their Home Edition account (see Part V). No registration or account creation by the child is required or permitted in Kids View.

CLASSROOM EDITION  Classroom Edition Creator, Teacher/TA, and Champion accounts must be held by adults aged 18 and older acting within the scope of their professional duties as educators. Educators who choose to add a parent as a Champion must have expressed consent from authorized school or district leadership. Students do not create accounts and do not interact with the Classroom Edition directly.

Your Smiles & Frowns Account

Access to the Apps and certain Services is only available to registered users. When you register, you will provide us with your email address and will choose a username and password. You must ensure that the email address you provide is and remains valid. You may choose any available username; you are not required to use your name or your child’s name, and choosing to use your child’s full name as a username is not recommended. You are solely responsible for maintaining the confidentiality and security of your username and password, and you will remain responsible for all activity emanating from your account, whether or not such activity was authorized by you.

Storage of Usage Data

A necessary part of our Service is to store all information inputted into the Platform to create a history of behavior that users can review and share. While we will use commercially reasonable efforts to maintain our systems and preserve data as long as your account remains open, electronic systems can fail and we are not responsible for any lost data. We highly recommend that you export this data frequently.

Your Use of the Platform

Subject to your strict compliance with these Terms of Use, Laws of Attraction grants you a limited, personal, non-exclusive, revocable, non-assignable, and non-transferable right and license to use the Platform to create and share behavior plans, track behavior pursuant to a plan, and help manage plans shared to you by other users.

You agree not to:

  • copy or capture content from the Platform;
  • adapt, republish, or distribute Platform content without authorization;
  • employ scraping or aggregation techniques;
  • alter or remove trademarks or legal notices;
  • reverse engineer or decompile any part of the Platform; or
  • upload content that is offensive, infringing, illegal, or harmful.

Violation of these conditions may result in account termination and, where appropriate, legal action.

Reporting Infringements

If you discover content on the Platform that you believe infringes your copyright or other rights, please contact us at legal@smilesandfrowns.com with a description of the allegedly infringing content, the URL where it appears, your contact information, and a good-faith statement that the use is not authorized by the rights holder.

Third Party Websites and Services

The Platform may provide access to third-party websites, databases, networks, or services (“External Services”). Laws of Attraction does not control External Services and is not responsible for their content, operation, or use. You use External Services at your own risk and are advised to review their applicable terms and privacy policies.

Disclaimer

THE PLATFORM IS PROVIDED “AS IS” AND “AS AVAILABLE.” LAWS OF ATTRACTION MAKES NO WARRANTIES OF ANY KIND REGARDING THE PLATFORM, INCLUDING WITHOUT LIMITATION ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT. WE DO NOT WARRANT THAT THE PLATFORM WILL BE UNINTERRUPTED, ERROR-FREE, OR FREE OF HARMFUL COMPONENTS THAT MAY BE INTRODUCED BY UNAUTHORIZED ACCESS OR OTHER EXTERNAL THREATS.

Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, LAWS OF ATTRACTION SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES ARISING FROM YOUR USE OF OR INABILITY TO USE THE PLATFORM, REGARDLESS OF THE CAUSE OF ACTION OR THE THEORY OF LIABILITY. THIS LIMITATION APPLIES EVEN IF LAWS OF ATTRACTION HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

Indemnification

You agree to indemnify, defend, and hold harmless Laws of Attraction, its officers, directors, employees, agents, and successors from any claims, damages, losses, and expenses (including reasonable attorneys’ fees) arising out of your violation of these Terms of Use or any activity related to your account.

NOTICE:  Institutional Procurement Notice: The Classroom Edition is currently offered directly to individual educators. School districts or educational institutions seeking to deploy the Classroom Edition through a formal procurement process or requiring a Data Processing Agreement (DPA) with supplemental indemnification terms should contact privacy@smilesandfrowns.com to discuss institutional licensing and compliance requirements.

Governing Law and Arbitration

These Terms and any dispute arising out of or relating to them or the Smiles & Frowns™ platform shall be governed by and construed in accordance with the laws of the State of Colorado, without regard to its conflict of law principles. Any dispute, claim, or controversy arising out of or relating to these Terms shall be finally resolved by binding arbitration administered by JAMS in accordance with its applicable rules. The arbitration shall take place in Denver, Colorado, unless the parties mutually agree to conduct the proceedings remotely or in another location. Judgment on any arbitration award may be entered in any court of competent jurisdiction.

Disclosures

The services hereunder are offered by Laws of Attraction, LLC, a Colorado company. For more information, contact legal@smilesandfrowns.com.

PART II — PRIVACY POLICY

Effective Date: February 16, 2016

1. Introduction

1.1 Purpose of Policy

Laws of Attraction, LLC (“Laws of Attraction,” “us,” “we,” or “Company”) is committed to respecting the privacy rights of its customers, visitors, and other users of the Smiles & Frowns™ mobile application and services (the “App”). This Privacy Policy applies to the App and is intended to give you confidence in how we collect, use, and protect your information.

1.2 Notice Concerning Information of Children

Laws of Attraction offers applications intended for use by families, including shared use between children and their parents and caregivers. Our applications may collect information from children in connection with user accounts and behavior tracking features. We have taken measures to comply with the Children’s Online Privacy Protection Act (COPPA) and its implementing Rule. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.

CLASSROOM EDITION  The Classroom Edition is specifically designed for use with children by educators in school settings. Separate provisions governing student data in educational contexts are set forth in the Classroom Edition Addendum (Part IV) and are incorporated herein by reference.

KIDS VIEW EDITION  The Kids View Edition is a companion app through which children may view behavior boards created by their parents or guardians. Because children interact directly with the Kids View app on their own devices, specific COPPA compliance provisions — including our verifiable parental consent mechanism — are set forth in the Kids View Edition Addendum (Part V) and are incorporated herein by reference.

1.3 Registration

During the registration process, we may ask users to provide certain information including a parent or guardian’s email address, a username, and a password. We strongly advise users never to provide personal information in their usernames. We will not require a child to provide more information than is reasonably necessary in order to participate in an online activity. Consistent with the requirements of COPPA, for any child-targeted feature or where we determine a user is under age 13, we will ask for a parent or guardian email address before collecting any personal information from the child. We will not use parent emails provided for parental consent purposes to market to the parent unless the parent has expressly opted in.

1.4 When Information Collected from Children Is Available to Others

We may share information with service providers if necessary for them to perform a business, professional, or technology support function for us. We may disclose personal information if permitted or required by law, including in response to a court order or a subpoena, or if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety, or protect the safety of a child using our application.

2. Information Collection Practices

2.1 Basic Information Collected

In operating the App, we may request registration information and other information through online forms, including name and email address.

2.2 Additional Information Collected

Automatic Collection: Our servers automatically recognize visitors’ domain names and IP addresses. The App may also gather anonymous traffic data helpful for marketing purposes or improving our services.

Cookies: We may use standard cookies on our website to store a small piece of data about your activity on our App. Cookies help us learn which areas of the App are useful and which need improvement. You can disable cookies in your browser settings, though doing so may diminish certain features.

3. Use and Sharing of Information

3.1 Personal Information

We will not share your personal information with any third parties without your consent, except as necessary to provide you with the services offered by us or to comply with the law. We may use your personal information to verify your identity, follow up with transactions initiated on the App, or inform you of changes to the App.

3.2 Anonymous Information

We use anonymous information to analyze App traffic. We do not examine this information for individually identifying information. Traffic and transaction information may be shared with business partners and advertisers on an aggregate and anonymous basis.

3.3 Disclosure of Personal Information

We may disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to conform to applicable law, protect and defend the rights or property of Laws of Attraction or users of the App, or act under exigent circumstances to protect safety.

CLASSROOM EDITION  For student data collected through the Classroom Edition, Laws of Attraction will NOT disclose student personal information to third-party advertisers or use such data to build advertising profiles. See Part IV, Section 3 for the complete Student Data Non-Disclosure Commitment.

KIDS VIEW EDITION  For data collected through the Kids View Edition, Laws of Attraction will NOT disclose children’s personal information to third-party advertisers or use such data for advertising or marketing purposes. See Part V for the complete Kids View data protection commitments.

4. Security

The App has security measures in place to prevent the loss, misuse, and alteration of information we obtain from you. While we strive to use commercially acceptable means to protect your data, no method of transmission over the Internet is 100% secure.

CLASSROOM EDITION: Classroom Edition      requires Student Data to be encrypted before it leaves the user’s device. The user’s device encrypts Student Data before transmission to Laws of Attraction’s servers, and encrypted Student Data remains encrypted in transit and at rest on Laws of Attraction’s servers. The board creator creates and controls the decryption code, which is not transmitted to or stored by Laws of Attraction, and Laws of Attraction cannot read encrypted Student Data without that code. See Part IV, Section 6 for the complete Security and Encryption Disclosure.    

NOTICE:  Data Breach Notification: In the event of a data breach that affects the personal information of Home Edition or Kids View Edition users, Laws of Attraction, LLC will notify affected users without unreasonable delay and in no event later than required by applicable state and federal breach notification laws. Notification will be sent to the email address associated with the affected account. Where the breach affects data of a child using Kids View, the parent or guardian associated with the linked Home Edition account will be notified.

5. Third Party Services

The App may contain links to other websites. We are not responsible for the privacy practices or content of those other websites.

5.1 Analytics Providers

We currently use the following third-party services to monitor and improve App performance:

HOME AND CLASSROOM EDITIONS:

  • Amplitude Analytics     
  • Facebook (Meta) — No Analytics from Facebook/Meta are used in any of the apps. Home and Classroom offer Facebook Login which is implemented using Facebook Limited Login. This implementation communicates nothing to Facebook/Meta beyond what is required to authenticate the user on login.           
  • Google Analytics / Firebase               

               Both the Classroom Edition and Home Edition collect      anonymized operational analytics solely to support app performance and improvement. Analytics events transmitted to third-party platforms such as Amplitude are not associated with directly identifying information such as a name or email address. The database row key (an integer) may be transmitted along with the event data; this value is opaque to any party without access to our database, is not associated with directly identifying information such as a name or email address, and cannot by itself be used to identify an individual          . For a full description of data collected and third-party services used, see Part IV, Section 6.   

KIDS VIEW EDITION  No third party software is used within Kids View.      

Section 6 — Account Termination and Data Deletion

While a user account remains active, Laws of Attraction, LLC retains child behavior data only for as long as reasonably necessary to provide the service to meet a typical family’s needs – including reviewing behavior and performance over the course of a year, identifying longer-term behavior trends, generating reports, and assessing progress. Child behavior board structures may be retained for continued use by active accounts.

As a default, child behavior data is automatically deleted on a rolling 365-day basis, so that behavior records older than 365 days are removed in the ordinary course of operating Smiles & Frowns.

Child behavior data is also deleted upon account inactivity or account deletion, as follows:

  • An account with no login activity for 180 consecutive days may be treated as abandoned. After 150 consecutive days of inactivity, the account owner will receive a notice providing an opportunity to reactivate the account or to have it deleted. If the account owner does not log in before day 180, the child behavior data associated with the account are deleted.
  • If an account owner requests deletion of their account, Laws of Attraction will process the request in accordance with its account deletion procedures. Once the account deletion is completed, child behavior data associated with that account are deleted from active systems. Deleted data may remain in backups, logs, or archives for a limited period for security, legal compliance, disaster recovery, or ordinary backup rotation before being overwritten or deleted in accordance with our backup practices.     
  • Laws of Attraction, LLC will provide written confirmation of data deletion upon request.
  • Individual child behavior data may be deleted at any time upon written request by a parent or legal guardian without requiring full account termination.

In the event that Laws of Attraction, LLC ceases operations, is acquired, or becomes insolvent, we will make reasonable efforts to: (a) provide affected account holders with advance written notice where legally and practically possible; (b) make child behavior data available for export during any such notice period; and (c) ensure that any successor or acquiring entity is bound by the applicable privacy and non-disclosure commitments set forth in this Privacy Policy, or that child behavior data is permanently deleted if the successor entity cannot or will not accept those commitments.

Where circumstances beyond our control, including but not limited to insolvency proceedings, regulatory action, or other legal constraints, prevent advance notice or fulfillment of these commitments in full, Laws of Attraction, LLC will use commercially reasonable efforts to protect child behavior data and minimize disruption to affected account holders. In any acquisition or succession scenario where advance notice is possible, we will provide at least 30 days’ written notice.

7. Contact Information and Policy Updates

If you have questions about this Policy or wish to have your information removed from our database, contact us at privacy@smilesandfrowns.com. We reserve the right to update this Policy at any time by posting changes on the App. Changes are effective immediately upon posting. It is your responsibility to review this Policy periodically.

PART III — GDPR PRIVACY POLICY

Effective Date: May 15, 2018  |  Last Updated: April 10, 2026

Laws of Attraction, LLC operates the Smiles & Frowns™ website and mobile application (the “Service”). This section informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service if you are located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, and the choices you have associated with that data.

Definitions

  • Service: The Smiles & Frowns™ website and mobile application.
  • Personal Data: Data about a living individual who can be identified from those data.
  • Usage Data: Data collected automatically from use of the Service or from the Service infrastructure.
  • Data Controller: Laws of Attraction, LLC, which determines the purposes and manner in which Personal Data is processed; provided that, for Student Data processed through the Classroom Edition, the responsibility framework set out in the Classroom Edition Addendum (Part IV) applies, under which Laws of Attraction, LLC does not assume the role of Data Controller for Student Data.
  • Data Processor / Service Provider: Any natural or legal person who processes data on behalf of the Data Controller.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide personally identifiable information including your email address, along with cookies and usage data. We may use your Personal Data to contact you with newsletters and promotional materials; you may opt out at any time.

Usage Data

We may collect information that your browser sends or that is generated when you access the Service via a mobile device, including IP address, browser type, pages visited, time and date of visit, and a vendor-scoped device identifier (on iOS, the Identifier for Vendors (IDFV)) that is unique to Laws of Attraction and cannot be used to identify the device across other companies’ apps. We do not collect, and do not permit third parties to collect, cross-app advertising identifiers such as the Identifier for Advertisers (IDFA).

To the extent a device identifier, internal database key, or similar identifier constitutes Personal Data under applicable law, we treat it as Personal Data and handle it in accordance with this Policy.

Legal Basis for Processing Personal Data

If you are from the EEA, UK, or Switzerland, Laws of Attraction, LLC processes your Personal Data because: we need to perform a contract with you; you have given us permission to do so; the processing is in our legitimate interests and not overridden by your rights; or we need to comply with the law.

NOTICE:  Legitimate Interest Clarification: Where we rely on legitimate interest as the legal basis for processing, we have conducted a balancing assessment to confirm that our interests are not overridden by your rights and freedoms. Our legitimate interests include: operating and improving the Service, ensuring platform security, and providing customer support. You have the right to object to processing based on legitimate interests at any time by contacting privacy@smilesandfrowns.com.

Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Policy, or as required to comply with legal obligations, resolve disputes, and enforce our agreements.

Transfer of Data

Your information, including Personal Data, may be transferred to and maintained on computers located outside your state, province, country or other governmental jurisdiction where data protection laws may differ. Laws of Attraction, LLC will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

NOTICE: International Data Transfers. Laws of Attraction, LLC is a U.S.-based company. If you are accessing the App from the European Economic Area, the United Kingdom, or Switzerland, your Personal Data will be transferred to and processed in the United States. We rely on the following mechanisms to lawfully facilitate these transfers:

  • Standard Contractual Clauses (SCCs): Where required, we rely on the European Commission’s Standard Contractual Clauses as a lawful transfer mechanism for Personal Data transferred from the EEA, UK, or Switzerland to the United States. Our third-party service providers, including analytics platforms, are selected in part based on their ability to provide adequate transfer mechanisms.
  • EU-U.S. Data Privacy Framework: Laws of Attraction, LLC is actively evaluating self-certification under the EU-U.S. Data Privacy Framework. We will update this notice promptly upon completing certification or upon determining that an alternative transfer mechanism is more appropriate for our data processing activities. The current status of our DPF certification may be confirmed at any time by contacting privacy@smilesandfrowns.com.

If you have questions about the mechanisms we use for international data transfers, you may contact us at privacy@smilesandfrowns.com.

Your Data Protection Rights Under GDPR

If you are a resident of the EEA, UK, or Switzerland, you have the following data protection rights:

  • The right to access, update, or delete the information we hold on you.
  • The right of rectification — to have inaccurate or incomplete information corrected.
  • The right to object to our processing of your Personal Data; however, because certain processing is necessary to provide the Service, objecting to that processing may mean we can no longer provide the Service to you.
  • The right to restriction of processing.
  • The right to data portability — to receive a copy of your data in a structured, machine-readable format.
  • The right to withdraw consent at any time where we relied on consent to process your information.

To exercise any of these rights, please contact us at privacy@smilesandfrowns.com. You also have the right to complain to a Data Protection Authority in the EEA or the UK Information Commissioner’s Office (ICO).

NOTICE:  Data Protection Contact: For all questions regarding the processing of Personal Data under GDPR, data subject access requests, or concerns about our data practices, please contact: Laws of Attraction, LLC — privacy@smilesandfrowns.com — Subject Line: GDPR Inquiry. Note: Laws of Attraction, LLC will formally designate a Data Protection Officer (DPO) if and when required by the volume or nature of its EEA/UK data processing activities under GDPR Articles 37–39. The status of DPO designation will be updated in this section.

Children’s Privacy

Our Service is designed for use by parents, educators, and caregivers in connection with managing children’s behavior. While children may be the subjects of behavior data tracked in the App, direct accounts are intended for adults (parents, educators, and caregivers aged 18 and above). We do not knowingly collect personally identifiable information directly from children under 13 without verifiable parental consent, consistent with COPPA requirements. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us at privacy@smilesandfrowns.com and we will take steps to remove that information.

KIDS VIEW EDITION  The Kids View Edition allows children to interact with the Service on their own devices, but only through a parent-initiated code-pairing process. For EEA/UK users, processing of children’s data through Kids View is based on parental consent obtained through the code-pairing mechanism. Parents may withdraw consent and deactivate Kids View access at any time through their Home Edition account settings. Deactivation does not clear data already stored on the child’s device; such locally stored data is removed only if the Kids View app is deleted from the device and the user selects “Yes” to the “Remove all Data” prompt presented by the iOS operating system.

Service Providers / Analytics     

We may employ third-party Service Providers to facilitate, perform, or analyze our Service. These providers have access to Personal Data only to perform tasks on our behalf and are obligated not to disclose or use it for any other purpose. Current providers vary by edition as follows:

Home Edition: Amplitude Analytics, Google Analytics, and Firebase are active in the Home Edition. Analytics events in the Home Edition may be associated with the internal database key field (an integer)      to support usage analysis and app improvement. This key is not associated with directly identifying information such as a name or email address outside the Smiles & Frowns database, and cannot by itself be used to identify an individual.     

Classroom Edition: Amplitude Analytics, Google Analytics, and Firebase are active in the Classroom Edition. Facebook (Meta) is used only to support Facebook Login for user authentication, implemented via Facebook Limited Login, and is not used for analytics or behavioral tracking. Analytics events in the Classroom Edition may be associated with the internal database key field (an integer) to support usage analysis and app improvement; this key is not associated with directly identifying information such as a name or email address outside the Smiles & Frowns database, and cannot by itself be used to identify an individual. Student Data and student behavioral data are not transmitted to third-party analytics platforms. For a full description of data collected and third-party services used, see Part IV, Section 6.     

Kids View Edition: No third party software is used within Kids View. Kids View transmits data only to the Smiles & Frowns servers, and that data is not shared with any third party except where disclosure is required by law.           

Payments

We use third-party payment processors for paid products and services. We do not store or collect payment card details. Payment processors adhere to PCI-DSS standards. Current processors include Apple Store In-App Payments.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and, where material, by sending notice to your registered email address prior to the change becoming effective.

Contact Us

For questions about this Privacy Policy: privacy@smilesandfrowns.com

PART IV — CLASSROOM EDITION ADDENDUM

NEW — Effective Date: April 10, 2026  •  Applies to Classroom Edition accounts only

This Classroom Edition Addendum (“Addendum”) supplements and, where applicable, supersedes the Terms of Use and Privacy Policy set forth in Parts I through III with respect to the use of Smiles & Frowns™ Classroom Edition features by teachers, school administrators, and other educators (collectively, “Classroom Users”). By activating or using Classroom Edition features, Classroom Users agree to the terms of this Addendum.

NOTICE: Data Access Controls Between Editions: The Classroom Edition and Home Edition operate within a shared data environment, but are governed by strict software-level access controls that prevent cross-edition data access. Student Data entered into the Classroom Edition is not accessible from Home Edition accounts, and vice versa. Creator accounts may be shared between editions, but behavior data related to students, children, or adults is not synchronized or accessible across editions. If a parent and a teacher both use Smiles & Frowns™ for the same child, the behavior data in each edition remains independently managed and access-controlled. These controls are enforced at the application level.

Section 1 — Definitions

  • Classroom Edition: The version of the Smiles & Frowns™ App that includes features designed for classroom behavior tracking, whole-class management, and individual student behavior plans.
  • Student: Any minor enrolled in a class or program whose behavior is tracked through the Classroom Edition by a Teacher or Administrator.
  • Student Data: Any personally identifiable information relating to a Student that is entered into, generated by, or stored in the Classroom Edition, including behavior records, plan settings, reward histories, and any notes or observations entered by a Teacher.
  • Caution Regarding Behavior Notes: The behavior notes field is a single, character-limited free-text field. Educators should not enter health, disability, IEP/504, disciplinary, mental-health, or similar sensitive information in free-text notes unless authorized by school policy and necessary for the educational purpose.
  • Creator: An individual educator, aged 18 or older, who creates and manages a classroom account within the Classroom Edition.
  • Champion: An adult, aged 18 or older, invited by a Creator or Teacher to support a student’s behavior plan – which may include a parent added only with the consent of authorized school or district leadership – whose access is limited to the board(s) to which they are invited.
  • Teacher or Teacher/TA: A teacher or teaching assistant, aged 18 or older, who uses the Classroom Edition within the scope of their professional duties to create or manage behavior plans and track student behavior.
  • Administrator: A school or district administrator, aged 18 or older, who manages Teacher accounts and has access to aggregated or individual classroom data within their institution.
  • Institution: A school, school district, or other educational organization that has authorized use of the Classroom Edition on an institution-wide or distributed basis under a separately negotiated agreement. Note: The Classroom Edition is currently offered directly to individual Teachers and Administrators. Schools or districts deploying on an institution-wide basis must negotiate separate terms with Laws of Attraction, LLC.
  • Education Records: As defined by the Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. § 1232g, records, files, documents, and other materials directly related to a student and maintained by an educational agency or institution.

Section 2 — FERPA Compliance

The Classroom Edition is designed for use by individual Teachers, Administrators, and other educators acting within the scope of their professional duties. Schools or districts wishing to deploy the Classroom Edition on a distributed or institution-wide basis are required to contact Laws of Attraction, LLC to negotiate separate terms and conditions prior to such deployment.

2.1 Data Control in Individual Educator Use

The Classroom Edition is made available directly to Teachers, Administrators, and other authorized educators as individual users and is designed to support authorized educational use. It is not a substitute for any school, district, FERPA, COPPA, or state student privacy requirement that may apply. Before using the Classroom Edition or entering any Student Data     , each Teacher or Administrator represents and warrants that:

  • They are at least 18 years of age and are acting within the scope of their authorized professional duties at their school or educational organization;
  • Their use of the Classroom Edition is consistent with their school or district’s applicable policies regarding educational technology;
  • Their school or district — as the educational agency generally responsible for maintaining student education records — is, where applicable, the party responsible for those records and the Data Controller for any Student Data entered into the Classroom Edition under applicable FERPA requirements and school or district policy; and
  • They have obtained, or will obtain before entering Student Data, any school, district, or parental consent or authorization required by applicable law or by their      school or district policy.     
  • They will not enter Student Data into the Classroom Edition if their school or district requires a Data Processing Agreement, formal school or district approval, or other authorization that has not yet been obtained; and
  • They will use the Classroom Edition only for legitimate educational purposes and not for any unrelated commercial, personal, or non-school purpose.
  • Student Data Privacy Commitment. Before creating a Classroom Edition board or entering any Student Data, each Teacher or Administrator must affirmatively acknowledge the following: “By creating a Classroom Edition behavior tracking board, I confirm that I am an adult educator or authorized school professional, that my use of Smiles & Frowns is consistent with my school or district’s privacy and data policies, and that I have obtained, or will obtain before entering student information, any school, district, or parental approvals required by those policies. I will use Classroom Edition only for educational purposes.”

Where applicable and to the extent permitted under the policies and agreements of the relevant school or district, Laws of Attraction, LLC is intended to provide      services to Teachers and Administrators in a capacity consistent with FERPA’s “school official” framework,      with a legitimate educational interest, as contemplated under FERPA 34 C.F.R. § 99.31(a)(1). Whether this designation applies to any specific use depends on the policies, authorizations, and applicable law governing the relevant school or district. Laws of Attraction, LLC does not assume the role of Data Controller for Student Data, and nothing in this Addendum should be read as a representation that an individual educator’s use of the Classroom Edition, by itself, satisfies all applicable FERPA, COPPA, school, district, or state student privacy requirements     .          

2.2 Laws of Attraction’s FERPA Obligations

In its capacity as a service provider supporting individual educators and their schools, Laws of Attraction, LLC agrees to:

  • Use Student Data only to provide, maintain, secure, support, and improve the Classroom Edition for authorized educational and app-operational purposes, and not for advertising, behavioral, profiling, sale, targeted marketing, model training, or any unrelated commercial purpose     ;
  • Not disclose Student Data to any third party without the written consent of the Teacher, Administrator, or their school, or as required by law;
  • Maintain Student Data with the same level of security and confidentiality required of educational agencies under FERPA;
  • Return or permanently destroy Student Data upon account termination or upon written request by the Teacher, Administrator, or — in the case of a distributed deployment — the Institution;
  • Notify the affected Teacher, Administrator, and, where applicable, their school or district promptly in the event of any security breach affecting Student Data.

2.3 Educator Responsibilities Under FERPA

Teachers, Administrators, and other educators using the Classroom Edition are responsible for:

  • Ensuring their use of the App is authorized by and consistent with their school or district’s policies regarding educational technology and student data;
  • Obtaining any parental consents required by FERPA or applicable school policy before entering Student Data into the Classroom Edition;
  • Limiting access to Student Data within the App to individuals with a legitimate educational interest;
  • Being aware that their school or district may have independent obligations under FERPA to notify parents and guardians of the use of third-party educational technology tools, including Smiles & Frowns™ Classroom Edition; and
  • Contacting Laws of Attraction, LLC at privacy@smilesandfrowns.com if they become aware that their school or district requires a formal Data Processing Agreement or institution-level terms prior to use.

Section 3 — Student Data Non-Disclosure Commitment

This section sets forth Laws of Attraction’s unconditional commitments regarding the use and non-disclosure of Student Data. These commitments apply regardless of any other terms in this document.

Laws of Attraction, LLC makes the following binding commitments with respect to Student Data:

  • We will NEVER sell Student Data to any third party for any purpose.
  • We will NEVER use Student Data to build advertising profiles of students or their families.
  • We will NEVER disclose Student Data to advertising networks, data brokers, or any third party whose primary purpose is advertising or marketing.
  • We will NEVER use Student Data to train machine learning or AI models for purposes unrelated to providing the Classroom Edition, and will NEVER use Student Data for any purpose other than providing the Classroom Edition services to the Teacher, Administrator, or other authorized educator or “     Champions” using the App, and improving those services in ways that directly benefit students.
  • We will NEVER retain Student Data after a Teacher or Administrator account is closed, except as required by applicable law or as expressly requested by the account holder or their school or district.
  • We WILL provide Teachers, Administrators, and — where applicable under a separately negotiated institutional agreement — schools and districts with the ability to review, correct, and delete Student Data upon request.
  • We WILL notify affected Teachers, Administrators, and where applicable their school or district of any change in our data practices before that change takes effect.

Section 4 — COPPA Compliance in Classroom Settings

The Children’s Online Privacy Protection Act (COPPA) requires verifiable parental consent before collecting personal information from children under 13. The “school consent exception” under COPPA permits schools to provide consent on behalf of parents for the collection of student information by educational service providers, subject to the following conditions:

  • The data collected is used for an educational purpose and not for commercial purposes.
  • The service provider does not retain data beyond what is necessary to provide the educational service.
  • The school has authority to consent on behalf of parents under applicable law.

Because the Classroom Edition is made available directly to individual Teachers and Administrators, the availability and scope of the school consent exception with respect to any specific use of the App depends on the policies, authorizations, and applicable law governing the relevant school or district. Laws of Attraction, LLC does not independently verify whether a given Teacher or Administrator’s school or district has authorized reliance on the school consent exception. By activating Classroom Edition features, each Teacher or Administrator represents and warrants that:

  • Their school or district has authorized, or would authorize, the collection of Student Data through the App in a manner consistent with the school consent exception to COPPA, to the extent that exception is applicable under their school or district’s policies and applicable law;
  • Their use of the App for students under 13 is in furtherance of an educational purpose and not a commercial one; and
  • They will not enter Student Data for children under 13 into the App without the authorization of their school or district.

Laws of Attraction, LLC will rely on this representation for purposes of the school consent exception, where that exception is available under applicable law and the relevant school or district’s policies. This reliance does not relieve Laws of Attraction, LLC of its own obligations as an operator under COPPA, including providing appropriate notice, limiting use of personal information, practicing data minimization, honoring retention and deletion requirements, maintaining reasonable security, and refraining from using children’s personal information for advertising, behavioral profiling, sale, or unrelated commercial purposes. Teachers or Administrators who are uncertain whether their school or district has authorized such use are encouraged to confirm with their school administration before entering Student Data for children under 13. Laws of Attraction, LLC recommends that schools and districts wishing to formally authorize use of the Classroom Edition contact privacy@smilesandfrowns.com to discuss institutional agreements.     

Section 5 — State Student Privacy Laws

In addition to FERPA and COPPA, numerous states have enacted their own student privacy laws that impose additional obligations on edtech providers. This section addresses the most widely applicable of these laws. Teachers, Administrators, and other educators are encouraged to familiarize themselves with applicable laws in their state. 

Where applicable, Laws of Attraction, LLC will comply with state student privacy laws that apply to its operation of the Classroom Edition. Depending on the states in which the Classroom Edition is used, marketed, or deployed, some states may require additional terms, school or district authorization, a Data Processing Agreement, or a state-specific addendum. This Addendum does not attempt to address the requirements of every state.

5.1 California — SOPIPA

The Student Online Personal Information Protection Act (SOPIPA), California Business & Professions Code § 22584, applies to operators of websites, online services, and mobile apps used primarily for K–12 school purposes. To the extent SOPIPA applies to its operation of the Classroom Edition, Laws of Attraction, LLC, agrees to comply with SOPIPA, including the following commitments:

  • We will not use Student Data to engage in targeted advertising to students.
  • We will not use Student Data to amass a profile about a student except in furtherance of the educational purpose for which the data was collected.
  • We will not sell Student Data.
  • We will not disclose Student Data unless required to do so by law or as permitted under SOPIPA.
  • We will maintain a comprehensive security program reasonably designed to protect Student Data from unauthorized access, destruction, use, modification, or disclosure.
  • We will delete Student Data within a reasonable time upon request by the Teacher, Administrator, or — where applicable — the school or district.

5.2 New York — Education Law 2-d

New York Education Law § 2-d and its implementing regulations impose obligations on educational technology vendors operating in New York. With respect to Teachers and Administrators at New York schools, and to the extent Education Law § 2-d applies to its operation of the Classroom Edition, Laws of Attraction, LLC commits to:

  • Executing a Data Privacy Agreement (DPA) upon request by a New York educational agency or, where applicable, an individual educator acting with school authorization, consistent with the requirements of Education Law § 2-d.
  • Not selling Student Data or using it for any purposes other than those authorized by the Teacher, Administrator, or their school.
  • Maintaining Student Data using reasonable administrative, technical, and physical safeguards.
  • Notifying the affected Teacher, Administrator, and where applicable their school or district of any breach of Student Data in accordance with applicable law.

5.3 Other State Laws

Many states have enacted student privacy laws including, but not limited to, Colorado (C.R.S. Title 22, Article 16 — the Student Data Transparency and Security Act), Connecticut (Conn. Gen. Stat. §§ 10-234aa to 10-234dd and § 10-234ff), Illinois (105 ILCS 85/1 et seq. — the Student Online Personal Protection Act), and Texas (Texas Education Code Chapter 32, Subchapter D). General consumer privacy laws, such as the Colorado Privacy Act (C.R.S. Title 6, Article 1, Part 13), may also apply to certain data depending on the circumstances. As noted above, additional state-specific obligations may apply depending on the states in which the Classroom Edition is used, marketed, or deployed, and this Addendum does not purport to address the requirements of every state. Teachers and Administrators in states not specifically named above are encouraged to contact us at privacy@smilesandfrowns.com to discuss applicable requirements in their jurisdiction.     

Section 6 — Security and Encryption

The Classroom Edition has been designed with enhanced security features specifically to protect Student Data. These protections apply to all Classroom Edition accounts regardless of whether the account is held by an individual Teacher or Administrator or under an institutional agreement.

Laws of Attraction, LLC employs the following security measures for Classroom Edition accounts:

  • Encryption: Classroom Edition requires Student Data to be encrypted before it leaves the user’s device. The user’s device encrypts Student Data using AES-256 before transmission to Laws of Attraction’s servers, and encrypted Student Data remains encrypted in transit and at rest on Laws of Attraction’s servers. Student Data is not necessarily stored in encrypted form on the user’s device and may be readable on an authorized user’s device while the user is entering or viewing it. The board creator creates and controls the decryption code, which is not transmitted to or stored by Laws of Attraction; Laws of Attraction cannot read encrypted Student Data without the board creator’s code. Adults invited to a board who do not hold the decryption code may participate, but protected student names are displayed to them as “Protected.” Other data stored on our servers is protected through server-level access controls and secure infrastructure practices.
  • Encryption in Transit: All data transmitted between the App and our servers is protected using TLS 1.2 or higher AND the on device encryption.. TLS 1.3 is used by default where supported by the client device.
  • Access Controls: Teacher and Administrator access to Student Data is controlled through role-based access permissions. Board creators and administrators are responsible for the access they provide to individual boards through invitations for others to participate within these roles, which is transparent within the app itself. Where administrative accounts exist under a separately negotiated institutional agreement, Administrator access is limited to data within their school or district.
  • Data Isolation: Student Data from Classroom Edition accounts is subject to software-level access controls that prevent cross-edition access. While the Classroom Edition and Home Edition share an underlying data environment, application-level controls are enforced to prevent Student Data from being accessible within Home Edition accounts.
  • Incident Response: In the event of a data breach affecting Student Data, Laws of Attraction, LLC will notify the affected Teacher or Administrator and, where applicable, their school or district      without unreasonable delay and in no event later than required by applicable breach notification      law.     

Section 7 — Data Processing Agreements

Laws of Attraction, LLC recognizes that some schools and districts require a Data Processing Agreement (DPA)      with edtech vendors before authorizing teacher use of classroom software. While the Classroom Edition is designed for direct use by individual Teachers and Administrators, we are committed to supporting Institutions that require formal agreements.

Teachers or Administrators whose school or district requires a DPA before use may request our standard DPA by contacting privacy@smilesandfrowns.com with the subject line “DPA Request.” Our standard DPA incorporates the commitments set forth in this Addendum and may be customized to reflect the requirements of specific state laws or district policies upon mutual agreement. Schools or districts seeking to deploy the Classroom Edition on an institution-wide or distributed basis should contact us separately to negotiate appropriate terms.

Certification Status Disclosure

Laws of Attraction, LLC is committed to transparency regarding the status of privacy certifications. References to certifications in this document reflect our intent to pursue and, where applicable, our active engagement with the certification process. We will update this section promptly upon obtaining any certification. Teachers, Administrators, and Institutions may inquire about current certification status at any time by contacting privacy@smilesandfrowns.com.

Section 8 — Parental Rights in Classroom Contexts

Under FERPA, parents and eligible students (students aged 18 and older) have the right to inspect and review education records, request amendment of records believed to be inaccurate, and consent to disclosure of records. Because Student Data entered into the Classroom Edition may constitute education records, these rights apply.

Parents or eligible students wishing to exercise FERPA rights with respect to Student Data in the Classroom Edition should contact the Teacher or Administrator who entered the data, or the relevant school or district, which is generally the entity responsible      for such records under FERPA. Where applicable, Laws of Attraction, LLC will cooperate with Teachers, Administrators, and their schools in facilitating the exercise of parental rights.     

IEP and Section 504 Plan Data Disclaimer

IMPORTANT:  Smiles & Frowns™ Classroom Edition is a general-purpose behavior tracking tool. It is NOT designed or intended to serve as an Individualized Education Program (IEP) management system, a Section 504 Plan management system, or a repository for special education documentation. Teachers and Administrators should not use the Classroom Edition to store or manage IEP documents, 504 Plan documents, psychological evaluations, or other special education records. While behavior data tracked in the Classroom Edition may relate to goals within an IEP or 504 Plan, the App does not replace the school’s official systems of record for such plans. Laws of Attraction, LLC makes no representation regarding the App’s suitability for compliance with the Individuals with Disabilities Education Act (IDEA) or Section 504 of the Rehabilitation Act.

Section 9 — Account Termination and Data Deletion

While a Teacher or Administrator account remains active, Laws of Attraction, LLC retains classroom and student behavior records only for as long as reasonably necessary to provide the Classroom Edition and to support educators’ typical classroom needs – including reviewing student and classroom progress over the course of a school year, identifying longer-term behavior trends, generating reports, and assessing progress. Classroom and student behavior board structures may be retained for continued use by active accounts.

As a default, classroom and student behavior records are automatically deleted on a rolling 365-day basis, so that behavior records older than 365 days are removed in the ordinary course of operating the Classroom Edition.

Classroom and student data and behavior records are also deleted upon account      inactivity or      account deletion, as follows:

  • An account with no login activity for 180 consecutive days may be treated as abandoned. After 150 consecutive days of inactivity, the account owner will receive a notice providing an opportunity to reactivate the account or to have it deleted. If the account owner does not log in before day 180, the classroom and student data and behavior records associated with the account are deleted.
  • If an account owner requests deletion of their account, Laws of Attraction will process the request in accordance with its account deletion procedures. Once the account deletion is completed, the classroom and student data and behavior records associated with that account are deleted from active systems. Deleted data may remain in backups, logs, or archives for a limited period for security, legal compliance, disaster recovery, or ordinary backup rotation before being overwritten or deleted in accordance with our backup practices.     
  • Laws of Attraction, LLC will provide written confirmation of data deletion upon request.
  • Individual Student records may be deleted at any time upon written request by the Teacher or Administrator, without requiring full account termination.
  • Where a school or district has a separately negotiated institutional agreement, data deletion terms in that agreement will govern to the extent they differ from the above.

     In the event that Laws of Attraction, LLC ceases operations, is acquired, or becomes insolvent, we commit to making reasonable efforts to: (a) provide affected Teachers, Administrators, and Institutions with advance written notice where legally and practically possible; (b) make Student Data available for export during any such notice period; and (c) ensure that any successor or acquiring entity is bound by the same Student Data non-disclosure commitments set forth in Section 3 of this Addendum, or that Student Data is permanently deleted if the successor entity cannot or will not accept those commitments.

Where circumstances beyond our control — including but not limited to insolvency proceedings, regulatory action, or other legal constraints — prevent advance notice or the fulfillment of these commitments in full, Laws of Attraction, LLC will use commercially reasonable efforts to protect Student Data and minimize disruption to affected Teachers, Administrators, and Institutions. In any acquisition or succession scenario where advance notice is possible, we commit to a minimum of 30 days’ written notice.     

Section 10 — Changes to This Addendum

Laws of Attraction, LLC reserves the right to modify this Addendum from time to time. We will provide affected Teachers and Administrators with at least 30 days’ advance written notice of any material changes to this Addendum via email to the address registered with their account. Where a school or district has a separately negotiated institutional agreement, notice will also be provided to the designated institutional contact. Continued use of the Classroom Edition following the effective date of any modification constitutes acceptance of the modified Addendum.

Section 11 — Contact for Classroom Edition Privacy Matters

For all questions, concerns, DPA requests, or data deletion requests related to the Classroom Edition:

Email: privacy@smilesandfrowns.com

Subject Line: Classroom Edition — [describe your request]

Response Time: We will acknowledge all Classroom Edition privacy inquiries within 2 business days.

Teachers or Administrators whose school or district requires institution-level terms, a formal DPA, or distributed deployment support should use the subject line: “Classroom Edition — Institutional Inquiry.”

PART V — KIDS VIEW EDITION ADDENDUM

NEW — Effective Date: April 10, 2026  •  Applies to Kids View Edition use only

This Kids View Edition Addendum (“Addendum”) supplements and, where applicable, supersedes the Terms of Use and Privacy Policy set forth in Parts I through III with respect to the use of the Smiles & Frowns™ Kids View companion app by children on their own devices, as initiated and authorized by a parent or guardian through the Smiles & Frowns™ Home Edition.

Section 1 — What Is Kids View?

Kids View is a companion app that allows children to view and interact with behavior boards created by their parents or guardians in the Smiles & Frowns™ Home Edition. Kids View is not a standalone app. It cannot be used independently and has no independent registration process.

Key characteristics of Kids View:

  • Kids View can only be activated by a parent or guardian who holds an active Home Edition account.
  • Activation requires the parent to generate a unique pairing code within their Home Edition account and physically enter that code on the child’s device.
  • Kids View displays only the behavior board(s) that the parent has specifically chosen to share with the child.
  • Kids View does not connect to, share data with, or access data from the Classroom Edition.
  • Kids View does not include any social features, messaging, public profiles, or communication with other users.
  • Kids View does not include any in-app purchase functionality or any mechanism by which a child could initiate a financial transaction.

Section 2 — Parental Consent Mechanism

The Kids View pairing process serves as the verifiable parental consent mechanism under COPPA for data collection associated with the child’s use of Kids View.

How It Works

  • The parent logs into their authenticated Home Edition account.
  • The parent navigates to the Manage Kids View setup and selects a behavior board to share.
  • At the time of code generation, the parent is presented with a clear COPPA consent disclosure that explains:      that Kids View lets the child view selected behavior boards on their own device; what data will be collected from the child’s device, which is limited to technical data needed so the app works reliably; that the app does not collect the child’s name, contact information, photos, voice recordings, or location; how that data will be used; that the data will not be used for advertising or marketing, sold, or shared with advertisers or data brokers; the parent’s right to revoke Kids View access      at any time through the Manage Kids View tab in the Home Edition settings and to request deletion of associated data;      how to contact Laws of Attraction with questions; and that generating the pairing code constitutes the parent’s consent to that collection and use.
  • The parent affirmatively acknowledges the disclosure and generates the pairing code.
  • The parent enters the code on the child’s device to activate Kids View.
  • The consent event — including timestamp, parent account identifier, and code generation — is logged and retained as an auditable consent record.

This mechanism satisfies COPPA’s verifiable parental consent requirements because: the parent must hold an authenticated account with a verified email address; the parent must affirmatively act to generate the code; the parent must have physical access to the child’s device; the parent is presented with and must acknowledge a clear consent disclosure before activation; and the process cannot be initiated by a child.     

Section 3 — Data Collected in Kids View

Kids View is designed to minimize data collection from the child’s device.

Data displayed to the child (sourced from the parent’s Home Edition account):

  • Behavior board name and categories
  • Smiles and frowns earned
  • Reward names and progress toward rewards

Data collected from the child’s device:

  • Device type and operating system version (for compatibility and troubleshooting)
  • App version
  • Session timestamps (when the child opens and closes the app)
  • Crash and performance logs (anonymized)

Data NOT collected from the child’s device:

  • No name, email address, or other contact information
  • No photos, videos, or voice recordings
  • No precise geolocation data
  • No persistent advertising identifiers
  • No free-text input from the child (Kids View is view-only and interaction-limited)
  • No data from other apps on the child’s device

Section 4 — Analytics and Advertising Restrictions

  • No third party software is active in Kids View.      
  • No advertising of any kind is displayed in Kids View.
  • No advertising identifiers are collected in Kids View.
  • Kids View transmits data only to the Smiles & Frowns servers. Kids View data is not shared with any third party, except where disclosure is required by law.     

Section 5 — Parental Controls

Parents retain full control over Kids View at all times through their Home Edition account:

  • Activate: Parents can generate a pairing code to activate Kids View on a child’s device.
  • Deactivate: Parents can revoke Kids View access at any time from their Home Edition account. Deactivation does not clear data already stored on the child’s device; such data is removed only if the Kids View app is deleted and the user selects “Yes” to the “Remove all Data” prompt presented by the iOS operating system.
  • Modify: Parents can change which behavior boards are visible in Kids View.
  • Delete: Parents can request deletion of all data associated with their child’s Kids View usage by contacting privacy@smilesandfrowns.com or through account settings.

Section 6 — Data Sharing and Isolation

  • Kids View data is linked only to the parent’s Home Edition account.
  • Kids View data is never shared with, accessible by, or connected to the Classroom Edition.
  • Kids View data is never shared with third-party advertisers, data brokers, or marketing platforms.
  • Kids View data is never sold to any third party for any purpose.

Section 7 — Data Retention

               Laws of Attraction, LLC retains Kids View operational data only for as long as necessary to provide the Kids View service and support the associated Home Edition account. The following retention practices apply:

  • Active Use: Operational data collected from the child’s device — including session timestamps and anonymized crash and performance logs — is retained for as long as the associated Home Edition account remains active and Kids View is enabled.
  • Deactivation: Upon a parent deactivating Kids View through their Home Edition account,      data already stored on the child’s device is not automatically cleared; it is removed only if the Kids View app is deleted and the user selects “Yes” to the “Remove all Data” prompt presented by the iOS operating system. Operational analytics data associated with the Kids View session will be deleted      in accordance with our data retention and backup practices.
  • Account Closure: Upon closure of the associated Home Edition account,      the associated Kids View data      is deleted. Deleted data may remain in backups, logs, or archives for a limited period for security, legal compliance, disaster recovery, or ordinary backup rotation before being overwritten or deleted in accordance with our backup practices, except as required by applicable law. This      is consistent with the Home Edition account closure process.
  • Parent-Requested Deletion: Parents may request deletion of their child’s Kids View data at any time by contacting privacy@smilesandfrowns.com with the subject line: “Kids View — Data Deletion Request.” We will confirm deletion in writing upon completion.

Laws of Attraction, LLC does not sell, transfer, or retain Kids View data beyond these purposes. A more detailed automated data retention and deletion mechanism is under active development and will be described in an updated version of this Addendum upon implementation.

Section 8 — COPPA Parental Rights

Under COPPA, parents have the right to:

  • Review the personal information collected from their child through Kids View;
  • Request deletion of their child’s personal information;
  • Refuse to permit further collection or use of their child’s information (by deactivating Kids View);
  • Consent to the collection and use of their child’s information without consenting to disclosure to third parties (which Laws of Attraction does not do in Kids View regardless).

To exercise any of these rights, parents may use the parental controls in their Home Edition account, or contact privacy@smilesandfrowns.com with the subject line: “Kids View — Parental Rights Request.”

Section 9 — Security

Kids View benefits from the same security infrastructure as the Home Edition, including:

  • Encryption of data in transit using TLS 1.2 or higher (TLS 1.3 by default where supported)
  • Encryption of data at rest using AES-256
  • Secure pairing code generation and transmission
  • No persistent storage of behavior board content on the child’s device (data is synced from the parent’s account and cached temporarily for display purposes)

Section 10 — Changes to This Addendum

Laws of Attraction, LLC reserves the right to modify this Addendum from time to time. Parents will be notified of material changes via email to the address associated with their Home Edition account at least 30 days before the changes take effect. Continued use of Kids View after the effective date of changes constitutes acceptance.

Section 11 — Contact

For all questions, concerns, or requests related to Kids View:

Email: privacy@smilesandfrowns.com

Subject Line: Kids View — [describe your request]

Response Time: We will acknowledge all Kids View privacy inquiries within 2 business days.