Children’s Privacy Policy

1. Operator Information

MySummitKeep LLC
Email: support@mysummitkeep.com
Website: www.mysummitkeep.com

2. How Children’s Information Is Collected

The Service is designed for use by Scouting America (Boy Scouts of America) units and their adult leaders, parents, and guardians. We do not collect personal information directly from children under thirteen (13). Children’s personal information is entered into the Service by:

• Troop Administrators: Adult leaders (Scoutmasters, Committee Chairs, and other authorized adult volunteers) who manage scout records as part of troop administration.
• Parents and Guardians: Parents or legal guardians who create family accounts and enter information about their children, including health forms and emergency contact details.

We operate as a service provider to these adults, who serve as the direct operators responsible for obtaining parental consent before entering children’s information.

3. Parental Consent

We require that troop administrators and parents/guardians obtain verifiable parental consent before entering personal information of children under thirteen (13) into the Service. Our consent mechanisms include:

• Consent through the Platform: When a troop administrator creates a scout profile for a child under thirteen, the Service requires that an invitation be sent to the child’s parent or guardian. The parent or guardian must create an account and affirmatively consent to the collection and use of their child’s information before the profile is activated.
• Consent Form Method: Troop administrators may collect parental consent using electronic consent forms provided through the Service, which specify the types of information collected and how it will be used.

Consent is obtained for the specific purposes described in this policy. We do not condition a child’s participation in any activity on the disclosure of more personal information than is reasonably necessary.

4. Information We Collect About Children

Through the actions of troop administrators and parents/guardians, the following categories of information about children under thirteen may be entered into the Service:

• Identity Information: First and last name, date of birth, BSA member ID number.
• Contact Information: Home address (associated with parent/guardian account), parent/guardian phone number and email address.
• Scouting Records: Rank advancement, merit badge progress, camping nights, service hours, leadership positions, and activity attendance.
• Health Information: Medical form data (BSA Annual Health and Medical Record), allergies, medications, dietary restrictions, and emergency contact information. This data is encrypted using zero-knowledge encryption; we cannot access it in unencrypted form.
• Event Participation: Permission slip responses, event attendance records, and transportation arrangements.

5. How We Use Children’s Information

We use children’s personal information solely for the following purposes:

• To provide the troop management features of the Service, including advancement tracking, event management, and record keeping.
• To enable authorized adult leaders and parents/guardians to manage and monitor their children’s scouting activities.
• To store health and emergency contact information for use during scouting events and activities, accessible only to authorized adult leaders.
• To generate advancement reports and records for the troop and the child’s family.
• To support the safety and security of the Service.

6. Disclosure of Children’s Information

We do not sell, rent, or trade children’s personal information. We share children’s information only as follows:

• Within the Troop: Children’s information is accessible to authorized adult leaders within the troop or unit, and to the child’s parent or guardian, consistent with role-based access controls. Scout-to-scout visibility is limited to name, patrol assignment, and advancement rank, unless configured otherwise by the troop administrator.
• Service Providers: We use third-party service providers (hosting, infrastructure) bound by contractual obligations to protect children’s data.
• Legal Requirements: We may disclose information as required by law, to protect children’s safety, or to protect the security of the Service.

7. Data Security for Children’s Information

We apply enhanced security measures to children’s personal information, including:

• Zero-knowledge encryption for health data, ensuring that even we cannot access the unencrypted information.
• Strict role-based access controls limiting who can view children’s records.
• Encryption of all data in transit (TLS 1.2+) and at rest (AES-256).
• Audit logging of all access to children’s records.
• No direct access by minors to the platform without parent/guardian oversight.

8. Parental Rights

Parents and legal guardians have the following rights regarding their child’s personal information:

• Right to Review: Parents may review the personal information we have collected about their child by logging into their parent/guardian account or by contacting us.
• Right to Correction: Parents may request correction of any inaccurate personal information about their child.
• Right to Deletion: Parents may request deletion of their child’s personal information by contacting us or by submitting a request through the Service. Upon receiving a verified deletion request, we will delete the child’s information within 30 days, except where retention is required by law.
• Right to Refuse Further Collection: Parents may refuse to permit further collection of their child’s personal information. This may limit the child’s ability to participate in certain features of the Service.
• Right to Revoke Consent: Parents may revoke their consent at any time by contacting us. Upon revocation, we will cease processing the child’s data and delete it as described above.

9. Data Retention

We retain children’s personal information only for as long as is necessary to fulfill the purposes described in this policy. When a scout record is deactivated or when parental consent is revoked, we will delete the child’s personal information within 30 days, subject to any legal retention obligations.

10. Changes to This Policy

If we make material changes to this Children’s Privacy Policy, we will notify parents and guardians by email and/or through the Service, and will obtain new parental consent where required by COPPA before any materially different collection, use, or disclosure of children’s information.

11. Contact Information

If you have questions or concerns about this Children’s Privacy Policy or our practices regarding children’s information, please contact us at:

MySummitKeep LLC
Email: support@mysummitkeep.com
Website: www.mysummitkeep.com

You may also contact the Federal Trade Commission at:

Federal Trade Commission
Children’s Privacy, Bureau of Consumer Protection
600 Pennsylvania Avenue, NW
Washington, DC 20580
ftc.gov — Children’s Privacy