Privacy Policy

1. Who we are and what this covers

Rivo Care (“Rivo”, “we”, “us”) is operated by Rivo Care, Inc. (registered address to be confirmed). Rivo is a platform that helps families understand the whole child by bringing together what parents and guardians, educators, specialists, and children themselves share, identifying each child’s unique pattern of strengths, challenges, interests, and developmental patterns (“Ripples”), and helping families understand what support may fit.

This policy covers the Rivo website, the Rivo platform, Rivo Reflect (the part of Rivo made for children), and any related communications (together, the “Services”). It applies to parents and guardians, to educators and specialists who are invited to a child’s team, to children who take part with a parent or guardian’s consent, and to visitors of our website.

Rivo does not diagnose. Rivo helps you understand your child and get the right help sooner. It is not a substitute for a professional evaluation or medical advice. Rivo is not a healthcare provider and is not a “covered entity” under HIPAA; the health-related information you choose to share with us is protected under this policy and the laws described below. Counsel to confirm HIPAA position, including any business-associate relationships with providers.

2. Information we collect

Information a parent or guardian provides

• Account information: your name, email address, password, relationship to the child, and contact preferences.
• About your child: the child’s first name or nickname, age or date of birth, and what you share in the screening and afterwards, such as strengths, interests, challenges, developmental milestones, relevant health history, previous evaluations and services, family context, and everyday experiences.
• Documents you upload: evaluations, reports, work samples, and similar material you choose to add.
• Team invitations: the names and email addresses of teachers and specialists you invite to your child’s team.

Information educators and specialists provide

• Professional account information, including name, role, organization, and email address, and, where applicable, professional credentials credential verification process to be confirmed.
• Observations, notes, session information, and progress updates about a child whose family has invited them.

Information a child provides in Rivo Reflect

• With a parent or guardian’s consent, a child may create an avatar and take part in age-appropriate check-ins, reflections, and activities. We collect what the child shares in those check-ins and how they respond to activities.
• We do not ask a child for more information than is reasonably necessary to take part. Exactly what Reflect records (for example, response patterns) must be confirmed and reviewed by counsel before publication, including whether any audio, video, or biometric information is ever collected. The prototype assumes none is.

Information collected automatically

• Technical information such as device type, browser, operating system, IP address, approximate location derived from IP address, pages visited, and actions taken within the Services.
• Cookies and similar technologies, described in section 13. We do not use advertising cookies or trackers.

Information from other people

• Information a school or organization shares with us at the family’s direction or under an agreement with the school (see section 9).
• Information from service providers who help us run the Services, such as email delivery status.

Much of the information above is sensitive under privacy laws, including information about a child’s health, development, and education. We treat all information about a child as sensitive, whatever its legal classification.

3. Children’s privacy (COPPA)

The Children’s Online Privacy Protection Act (“COPPA”) governs how online services collect personal information from children under 13 in the United States. Rivo is designed so that a child only ever takes part through a profile created and controlled by a parent or guardian.

• Consent before collection. We do not knowingly collect personal information from a child under 13 unless a parent or guardian has provided verifiable consent. Our method of obtaining verifiable parental consent is to be confirmed (for example, consent within a parent-verified account, a signed consent form, or a payment-card verification).
• Direct notice. Before a child takes part in Rivo Reflect, the parent or guardian receives a direct notice describing what will be collected, how it will be used, and how to withdraw consent.
• Parents’ rights. A parent or guardian can review the personal information collected from their child, ask us to delete it, and refuse to allow any further collection or use, at any time, by using the controls in their account or by contacting us (section 15). Refusing further collection may mean the child can no longer take part in Rivo Reflect, but the family can continue to use the rest of Rivo.
• No conditioning. We do not condition a child’s participation on disclosing more personal information than is reasonably necessary for the activity.
• No advertising to children. We do not serve behavioral or targeted advertising to children, and we do not sell children’s personal information or share it for cross-context behavioral advertising.
• Limited disclosure. Information collected from a child is used to provide the Services to that child’s family and team, and is shared only as described in section 5.
• Children 13 and older. Where a child is 13 or older, we still require a parent or guardian to create and control the profile and to consent to the child’s participation. Age range served by Rivo to be confirmed.

If you believe we have collected information from a child without appropriate consent, please contact us (section 15) and we will delete it promptly.

4. How we use information

We use information for the following purposes, and only these purposes:

• To provide the Services: to run the screening, bring together what the family, educators, specialists, and the child share, identify the child’s Ripples, prepare the Rivo Ripple Report, and show progress over time.
• To support the child’s team: to make the information a family has chosen to share available to the people the family has invited.
• To communicate with you: to send service messages, respond to your requests, and, with your consent where required, send updates about Rivo. You can opt out of non-essential messages at any time.
• To keep Rivo safe and working: to protect accounts, prevent misuse, fix problems, and meet our legal obligations.
• To improve Rivo: to understand how the Services are used and make them better. Where we use information about children for this purpose, we use it in de-identified or aggregated form that cannot reasonably be linked to a child or family, and we do not attempt to re-identify it. Whether any product research uses identifiable information, and the consent required for it, to be confirmed.

We do not use personal information to advertise to your family, to build profiles of children for anyone else’s purposes, or for any purpose that is incompatible with the purpose for which it was shared with us.

5. Who can see information

The people who can see your child’s information are, first and foremost, the people you invite.

• Your child’s team. Educators and specialists see a child’s information only when the parent or guardian invites them. A parent or guardian can change or remove that access at any time. Team members are bound by our Terms of Service and by their own professional and legal obligations of confidentiality.
• The Rivo team. Rivo staff and contractors who need access to provide the Services, including child-development specialists who review Ripple Reports, if applicable, to be confirmed, may access information under confidentiality obligations and role-based access controls.
• Service providers. Companies that host our systems, deliver email, and provide similar services on our behalf. They may use personal information only to provide their services to us and are contractually required to protect it. List of service-provider categories to be confirmed.
• Schools and organizations. Where a school or organization has an agreement with Rivo and a family uses Rivo through that school, information may be shared with the school as described in section 9 and in the family’s consent.
• Legal and safety. We may disclose information when we reasonably believe it is required by law, by a court order, or by a lawful request from a public authority; to enforce our terms; or to protect the safety of a child, another person, or the public, in each case only to the extent permitted or required by law. Educators and specialists on a child’s team may also have their own legal duties, such as mandated reporting.
• Business transfers. If Rivo is involved in a merger, acquisition, financing, or sale of assets, personal information may be transferred as part of that transaction. We will require the recipient to honor this policy for information collected under it, and we will notify affected families before any material change in how their information is used.

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising. Counsel to confirm.

6. Technology, patterns, and human review

Rivo uses technology, including automated analysis and machine-learning techniques, to connect information that the family and the child’s team share and to notice patterns over time. This is what allows Rivo to bring different perspectives into one shared picture.

• Insights inform people; they do not replace them. Patterns that Rivo notices are provided to the parents, educators, and specialists on a child’s team to support their judgment. Decisions about a child’s support are made by people. Confirm whether any step is fully automated without human review, and describe it here if so.
• No solely automated decisions with legal or similarly significant effects. Rivo does not make decisions about a child that have legal or similarly significant effects based solely on automated processing. Counsel to confirm.
• No emotion recognition or biometric identification. Rivo does not use facial recognition, voiceprints, or other biometric identifiers, and does not attempt to infer a child’s emotional state from images, video, or audio. Product team to confirm; this statement must match what Rivo Reflect actually does before publication.
• Training and improvement. Where we use information to improve the technology behind Rivo, we do so in de-identified or aggregated form, as described in section 4.

7. Your choices and rights

Wherever you live, you can:

• Access the personal information we hold about you and your child, and receive a copy in a portable format.
• Correct information that is inaccurate or incomplete.
• Delete your account, your child’s profile, or specific information. Some information may be retained where the law requires it or where we need it to resolve a dispute; we will tell you if that applies.
• Control your child’s team by adding or removing educators and specialists at any time.
• Withdraw consent for your child’s participation in Rivo Reflect, or for any optional use of information, at any time.
• Opt out of non-essential communications using the link in any message or your account settings.

To exercise any of these rights, use the controls in your account or contact us (section 15). We will need to verify your identity, and that you are the parent or guardian of the child concerned, before acting on a request that involves a child’s information. You may designate an authorized agent to make a request on your behalf, subject to verification. We will not discriminate against you for exercising your rights.

Content a child has posted. A child who is a California resident under 18, or their parent or guardian, can ask us to remove content the child posted in the Services, as provided by California Business and Professions Code section 22581. Parents and guardians can do this at any time from the child’s profile.

8. California privacy rights (CCPA/CPRA)

This section applies to California residents and supplements the rest of this policy. It is provided under the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”). Counsel to confirm whether Rivo meets the CCPA’s applicability thresholds at launch; Rivo intends to honor these rights regardless.

Categories of personal information

In the preceding twelve months we have collected, or expect to collect, the following categories of personal information, for the purposes described in section 4, from the sources described in section 2:

Your rights

• Right to know what personal information we collect, use, disclose, and the categories of sources and recipients.
• Right to delete personal information we collected from you, subject to legal exceptions.
• Right to correct inaccurate personal information.
• Right to opt out of sale or sharing. We do not sell personal information or share it for cross-context behavioral advertising, and we do not sell or share the personal information of anyone under 16. If that ever changes, we will provide a “Do Not Sell or Share My Personal Information” link and obtain opt-in consent for consumers under 16 as the law requires.
• Right to limit use of sensitive personal information. We use sensitive personal information only to provide the Services you have asked for and for the other purposes permitted by the CCPA regulations. If we ever use it for other purposes, we will provide a “Limit the Use of My Sensitive Personal Information” link.
• Right to non-discrimination for exercising any of these rights.

You can exercise these rights through your account or by contacting us (section 15) toll-free number to be added if required. We will confirm receipt within 10 business days and respond within 45 days, extendable once by a further 45 days where reasonably necessary, and we will tell you if we need more time. We honor the Global Privacy Control signal as a valid opt-out request where it applies.

9. Schools and student privacy (FERPA and state law)

Families can use Rivo on their own, and can invite their child’s teacher to add what they see. Schools and learning-support teams can also work with Rivo under an agreement with the school. When they do, the following applies.

• FERPA. When a school shares personally identifiable information from a student’s education records with Rivo, Rivo acts as a “school official” with a legitimate educational interest, under the school’s direct control, and uses that information only for the purpose the school has authorized. Rivo does not re-disclose education records except as the school directs or the law permits, and supports the school’s obligations to give parents access to and control over their child’s records.
• PPRA. Where a school administers Rivo’s screening or check-ins and questions touch on topics protected by the Protection of Pupil Rights Amendment (for example, mental or psychological problems, or family relationships), the school is responsible for providing the notices and obtaining the consents PPRA requires, and Rivo supports the school in doing so. Families using Rivo directly provide consent themselves.
• State student-privacy laws. Rivo is being built to comply with state laws that govern operators of online services used for K–12 purposes, including California’s Student Online Personal Information Protection Act (SOPIPA) and similar laws in other states. Under these laws, we do not use student information for targeted advertising, do not build profiles of students for any purpose other than the educational purpose agreed with the school or family, do not sell student information, maintain reasonable security, and delete student information at the school’s request.
• Data agreements. Schools may require a written data-privacy agreement with Rivo. Where the agreement’s terms are more protective than this policy, the agreement governs the information covered by it. Template school agreement to be prepared.

10. How we protect information

We use administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, and loss, including encryption of information in transit and at rest, role-based access controls, logging, staff confidentiality obligations and training, and regular review of our practices. Security program details and any independent assessments to be confirmed.

No system can be guaranteed to be completely secure. If we learn of a security incident affecting your personal information, we will notify you and the relevant authorities as required by applicable law, including state breach-notification laws.

11. How long we keep information

• We keep account and child information for as long as the family’s account is active, so that a child’s progress can be seen over time.
• When a parent or guardian deletes a child’s profile or the family account, we delete the associated personal information within retention period to be confirmed, except where we must keep it to comply with a legal obligation, resolve a dispute, or enforce our agreements, or where it exists in secure backups that are overwritten on a fixed schedule.
• Educator and specialist accounts are kept while active; information they added about a child stays with the child’s profile under the family’s control.
• Information a school has shared under an agreement is retained and deleted according to that agreement.
• De-identified and aggregated information that cannot reasonably be linked to a person may be kept and used to improve Rivo.

12. Users outside the United States

Rivo is operated from the United States and personal information is stored and processed there. Whether Rivo will be offered outside the United States at launch to be confirmed. If you use Rivo from another country, you understand that your information will be transferred to and processed in the United States, where privacy laws may differ from those in your country.

Where the EU or UK General Data Protection Regulation, Canada’s PIPEDA, or other similar laws apply, you have additional rights, including the right to object to or restrict certain processing and the right to lodge a complaint with your data protection authority, and we rely on appropriate legal mechanisms for international transfers. Our lawful bases for processing under such laws are consent (for children’s information and optional uses), performance of our contract with you, our legal obligations, and our legitimate interests in running and improving the Services in ways that do not override your rights.

13. Cookies and analytics

• Essential cookies keep you signed in and keep the Services secure. They cannot be switched off.
• Preference cookies remember settings such as an open menu or a dismissed notice.
• Analytics. We use analytics provider and configuration to be confirmed to understand how the Services are used, configured so that it does not build advertising profiles. Where the law requires consent for analytics, we ask for it.
• No advertising cookies. We do not use cookies or trackers for advertising, and we do not allow third parties to collect information about your activity on Rivo for their own purposes.

You can control cookies through your browser settings. Blocking essential cookies may stop parts of the Services from working.

14. Changes to this policy

We will update this policy as Rivo develops and as the law changes. When we make material changes, we will notify parents and guardians by email and within the Services before the change takes effect, and, where a change would materially affect how we use a child’s information, we will ask for a parent or guardian’s consent again before applying it to that child’s information.

15. How to contact us

Questions, requests, and concerns about privacy can be sent to:

• Email: privacy contact address to be confirmed
• Mail: Rivo Care, Inc., mailing address to be confirmed
• Online: through the contact page

If you are not satisfied with our response, you may also contact the Federal Trade Commission, your state attorney general, or, outside the United States, your data protection authority.