Review-ready draft. A qualified lawyer must approve it before use; items in [brackets] are decisions or facts for counsel to confirm. This text is not legal advice.

Children's data policy

Origin Pixel Solutions, Chennai, Tamil Nadu, India · Version 2026-11-03 · Last updated 3 November 2026

The Origin Platform is a business tool and is not directed at children. Some clients (schools, coaching centres, clinics, gyms) serve families, so this policy explains what clients must do and what the platform does when the people they talk to may be children.

1. Who counts as a child

  • India (DPDP Act s.2(f)): anyone under 18.
  • United States (COPPA): under 13; several states add protections up to 16 or 18.
  • EU (GDPR Art. 8): under 16, or the lower age a Member State sets (not below 13). UK: under 13 for consent to online services; the Age Appropriate Design Code applies to under-18s.

2. Origin Pixel's own services

Our websites, demo and accounts are for adults acting for a business. We do not knowingly collect children's data as controller. If we learn we have, we delete it. Write to grievance@originpixel.in.

3. What clients must do

  • Obtain verifiable consent of a parent or lawful guardian before processing a child's personal data (DPDP s.9(1) and Rule 10, for example using DigiLocker-based age or identity tokens; COPPA verifiable parental consent; GDPR Art. 8).
  • Do not track, behaviourally monitor or target advertising at children (DPDP s.9(3)); do not use lead scoring, retargeting or abandoned-cart reminders for children.
  • Do not process children's data in a way likely to harm their well-being (DPDP s.9(2)).
  • Address marketing to the parent or guardian, not to the child.
  • Keep the minimum data and the shortest retention that serves the purpose.

4. What the platform provides

  • An industry setting "my audience may include children" that adds an age question to chat and forms, marks contacts as minors, and blocks marketing, scoring and retargeting for them until guardian consent is recorded [contact flags and guardian flow delivered by WP-PRIVACY P1-P5].
  • Consent records per purpose and channel, with proof of who consented and how.
  • Retention settings, erasure and export tools for parent requests.

5. Exemptions

The DPDP Rules exempt some processing (for example by educational institutions and healthcare professionals for their core services and for the child's safety) from parts of s.9. Clients relying on an exemption must document it. [Counsel: confirm the Fourth Schedule classes that apply to the presets.]

6. Contact

Parents can contact the business that collected the data, or our grievance officer.