← Back to Orca
Legal

Children's Privacy Addendum

Last updated .

On this page
  1. Age policy
  2. Under 13
  3. Verifiable parental consent
  4. What we collect from minors
  5. What we never collect from minors
  6. Parent and guardian rights
  7. How to contact us
  8. 2025 COPPA amendments
  9. Schools and educators
This addendum supplements the Orca Privacy Policy and applies whenever the user is a minor. "Orca" is operated by Simplifine Corp, a Delaware C Corporation.

Age policy

Orca's minimum age is 16. Users between 13 and 15 may use Orca only if a parent or legal guardian has provided verifiable parental consent ("VPC") through the process described below. We do not permit account creation by users under 13.

Under 13

Account creation by users under 13 is prohibited. If we learn that we have collected personal information from a child under 13 without VPC, we will delete that information promptly. If you believe a child under 13 has provided personal information to Orca, contact privacy@orcaclient.com and we will act within 10 business days.

Verifiable parental consent

For users between 13 and 15, Orca requires VPC before creating the account. We accept the following methods, drawn from those listed in the FTC's Children's Online Privacy Protection Rule, 16 C.F.R. § 312.5(b):

  • Parent email plus card token.The parent provides their email address and authorizes a $0 card-authorization charge through Stripe. We use the card token as a proxy for verifying the parent's identity. We do not retain the card number; we retain only the Stripe customer ID and the last four digits.
  • Government-issued ID verification (optional). If you prefer not to use a card, a parent may submit a government-issued ID for one-time review through our verification partner. The image is deleted after verification.

The consenting adult must confirm they are the parent or legal guardian and that they agree on the minor's behalf to our Terms of Service and Privacy Policy.

What we collect from minors

For an under-16 account with VPC on file, we collect only what we need to run Minecraft servers:

  • The minor's display name and email or Discord OAuth ID.
  • Server configuration: server names, mod/plugin lists, world data, and uploaded files.
  • Server logs: player join/leave, command usage, and crash reports.
  • AI assistant conversation history scoped to the minor's account.
  • Basic device information: browser, operating system, region from IP.
  • The parent's email address and the Stripe customer token from VPC.

What we never collect from minors

  • Precise geolocation (street-level or finer).
  • Biometric identifiers (face prints, fingerprints, voiceprints).
  • Government-issued ID numbers (driver's license, passport, SSN).
  • Real name beyond an optional first name.
  • Phone number.
  • Photographs or video of the minor.
  • Inferences used to build behavioral profiles for advertising.

Parent and guardian rights

The parent or guardian who provided VPC may, at any time:

  1. Review the personal information Orca has collected from the minor.
  2. Direct us to deletethe minor's personal information and close the account.
  3. Refuse further collection by withdrawing consent. We will stop collecting new information from the minor; this will terminate the account, since we cannot run the service without the data described above.
  4. Update the email address or contact method we have for the parent.

To exercise any of these rights, send an email from the address used during VPC to privacy@orcaclient.com with the subject line "Parental Request". We respond within 10 business days.

How to contact us

For any question about a minor's account or data, email privacy@orcaclient.com. Include the minor's account email or Discord username so we can locate the record.

2025 COPPA amendments

Orca's practices reflect the FTC's 2025 amendments to the COPPA Rule, including:

  • Separate, explicit parental consent before personal information is disclosed to third parties for purposes outside what is needed to run the service.
  • Explicit data-retention limits and a published data-retention policy (see "What we collect" in the Privacy Policy).
  • Restrictions on using minor data for targeted advertising; Orca does not run targeted advertising on or about minors.
  • A documented internal program to review and respond to parental requests within 10 business days.

Schools and educators

If you are a teacher or school administrator who would like to use Orca for an educational program with users under 16, email privacy@orcaclient.com before signing students up. Under FTC guidance, a school may, in limited circumstances, act in loco parentis to consent on behalf of students for school-authorized educational uses. We will work with you to put a written agreement in place.