Trust

Parental Consent

How we obtain and verify consent for processing photos of children under 13.

Last updated: January 1, 2026

SmilePlease is designed to help parents create beautiful school-style portraits of their children. Because we process photos that may include children under 13, we comply with the Children's Online Privacy Protection Act (COPPA) and require verifiable parental consent.

When consent is required

Verifiable parental consent is required when:

  • You are a parent or legal guardian at least 18 years old.
  • You upload a photo of a child under 13 years of age.
  • The child's image will be processed by our AI system (Google Gemini) to generate portraits.
  • The child's image will be shared with our print fulfillment partner (Finerworks) for printing.

What we collect

For children under 13, we collect only:

  • Uploaded photo: The image you upload of your child.
  • Generated portraits: AI-generated variations based on the uploaded photo.

We do not collect names, email addresses, or other personal information directly from children. All account and payment information is collected from the parent or guardian.

How to provide consent

We offer the following methods to verify parental consent:

Option 1: Credit Card Verification

During checkout, your payment card is verified as belonging to an adult. By completing a purchase for prints containing your child's portrait, you are providing verifiable consent for processing and fulfillment.

Option 2: Email Consent Form

Email privacy@smileplease.app with subject "Parental Consent Request" to receive a consent form. We will verify your identity by matching the email to your account and may ask security questions.

Option 3: Government ID Verification

For additional verification, you may submit a copy of government-issued ID. Email privacy@smileplease.app with subject "ID Verification for Parental Consent" for instructions.

Option 4: Signed Consent (Organizations)

For schools, daycares, or organizations, we offer a signed consent form option. Email privacy@smileplease.app for details.

Biometric consent (Illinois residents)

When you upload a photo, our AI system may analyze facial features to generate portrait variations. This processing may constitute collection of biometric data under the Illinois Biometric Information Privacy Act (BIPA).

Illinois residents: By uploading a photo and initiating AI generation, you provide written consent under BIPA to the processing of facial features. We do not create or store facial templates, face prints, or biometric identifiers beyond what is necessary to generate your portraits. Uploaded photos are deleted within 10 days of generation. Generated portraits are deleted within 30 days (or 12 months if you purchase and opt in).

Separate consent for sharing

Per COPPA requirements, we obtain separate consent before sharing your child's photo with third parties:

  • AI Processing (Google Gemini): By uploading a photo and initiating generation, you consent to the photo being processed by Google's Gemini AI.
  • Print Fulfillment (Finerworks): By completing a print order, you consent to the generated portrait being shared with our print partner for production and shipping.

You may use our service for AI generation only (without ordering prints) if you prefer not to share with our print partner.

Your rights as a parent

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

  • Review: Request a copy of any photos or data we have collected about your child.
  • Delete: Request immediate deletion of your child's photos and data at any time.
  • Refuse: Decline further collection or use of your child's data.
  • Withdraw consent: Revoke your consent at any time, and we will stop processing and delete the data.

To exercise any of these rights, email privacy@smileplease.app with the subject "Parental Rights Request." We will respond within 48 hours.

Data retention and deletion

  • All photos of children are automatically deleted within 30 days of upload.
  • You may request immediate deletion at any time before the 30-day period.
  • If you have downloaded digital copies, those remain in your possession after deletion from our servers.
  • Order records (without images) are retained for legal and tax purposes as described in our Privacy Policy.

Our commitment

  • We never use children's photos for advertising or marketing.
  • We never sell children's data to third parties.
  • We never use children's photos to train AI models.
  • We collect only the minimum data necessary to provide the service.
  • We use industry-standard security measures to protect all data.

Consent timeline

  • Email consent requests: Processed within 24 hours.
  • Parental rights requests: Responded to within 48 hours.
  • Deletion requests: Completed within 24 hours.

Questions?

If you have questions about parental consent or COPPA compliance, contact us at privacy@smileplease.app.

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