NAMA’s Little Money Lab Family and Children’s Privacy Notice

Effective date: July 31, 2026

Last updated: July 31, 2026

NAMA’s Little Money Lab provides financial-literacy stories, videos, activities, worksheets, coloring materials, family discussion prompts and educational resources for children and the adults who guide them.

This Family and Children’s Privacy Notice explains how Debora T DiBiasie, doing business through the applicable AVBrand, handles information associated with NAMA’s Little Money Lab websites, landing pages, downloads, videos, emails, purchases, and related services.

This Notice supplements the AltaVidaSites Privacy Policy, Terms of Use, and Cookie Policy. If this Notice conflicts with the general AltaVidaSites Privacy Policy concerning NAMA’s Little Money Lab, this Notice controls for NAMA-related information.

For purposes of this Notice:

  • “NAMA” refers to NAMA’s Little Money Lab.
  • “We,” “us,” and “our” refer to Debora T DiBiasie, doing business through the applicable AVBrand.
  • “Adult User” means a parent, legal guardian, educator, caregiver, or other adult who accesses or administers NAMA materials.
  • “Child” means an individual under 13 for purposes of this Notice.
  • “Services” means NAMA’s websites, landing pages, stories, videos, activities, downloads, educational materials, emails, purchases, and related features.

“Personal Information” means information that identifies or can reasonably be linked to an individual, including information treated as personal information under applicable children’s-privacy laws.

  1. Adult-directed access and administration

NAMA’s Little Money Lab is designed to be accessed and administered by adults.

NAMA includes educational Content intended to be viewed or used by children under adult supervision. Describing access and administration as adult-directed does not change any children’s-privacy obligations that may apply to particular Content, pages, technologies or data practices.

Adults should:

  • access the website;
  • register for resources;
  • provide email addresses;
  • make purchases;
  • download materials;
  • supervise videos and activities;
  • submit questions;
  • communicate with NAMA; and
  • decide how materials are used with a child.

Children should not independently:

  • create accounts;
  • subscribe to email;
  • submit forms;
  • make purchases;
  • upload files;
  • send photographs;
  • submit voice recordings;
  • provide names or contact information;
  • provide school information;
  • provide precise location information;
  • provide financial information; or
  • communicate privately with NAMA.

NAMA does not require or knowingly request that a child provide Personal Information to access ordinary stories, videos, printable activities or family discussion materials.

  1. Information collected from adults

Depending on how an Adult User interacts with NAMA, we may collect:

  • adult name;
  • adult email address;
  • adult telephone number;
  • mailing or billing address;
  • account or order information;
  • educator or organization name;
  • relationship to the child;
  • requested resource;
  • purchase and payment status;
  • communication preferences;
  • support requests;
  • survey or feedback responses;
  • testimonials submitted by adults;
  • information entered in contact forms; and
  • technical information collected when the Services are accessed or used.

Complete payment-card information is intended to be processed by an independent payment processor rather than stored directly by us.

  1. Information concerning children

NAMA does not require or knowingly request that Adult Users provide a child’s full name, email address, telephone number, home address, school, photograph, voice recording or precise location.

An Adult User may voluntarily provide limited information to help select educational materials, such as:

  • a child’s general age range;
  • grade range;
  • general learning interests;
  • preferred activity type;
  • general accessibility needs; or
  • whether the materials will be used at home, in a classroom or in another adult-supervised setting.

Adult Users should use age ranges, grade ranges, initials, nicknames or general descriptions rather than unnecessary identifying information.

Adult Users should not submit a child’s:

  • full legal name;
  • personal email address;
  • personal telephone number;
  • home address;
  • school name;
  • student identification number;
  • precise location;
  • photograph;
  • video;
  • voice recording;
  • Social Security number;
  • government identification;
  • financial-account information;
  • medical record;
  • biometric information; or
  • other sensitive Personal Information.

We do not currently offer a feature requiring this information. Before introducing any feature that requests or permits its collection, we will evaluate the applicable legal requirements and implement any required direct parental notice, verifiable parental consent, data minimization, security and parental controls before collection begins.

  1. Information collected automatically

When the Services are accessed, we and our service providers may automatically collect certain technical information through server logs, cookies and similar technologies active on the applicable page or service.

This may include:

  • IP address;
  • browser type;
  • device type;
  • operating system;
  • approximate region;
  • referring page;
  • pages viewed;
  • links selected;
  • date and time of access;
  • error information;
  • security events;
  • cookie preferences; and
  • interactions with requested emails.

Some technical information—including an IP address, cookie identifier or other persistent identifier—may constitute Personal Information under children’s-privacy laws when collected through a child-directed website or online service.

  1. Cookies, analytics and advertising

NAMA may use strictly necessary technologies to:

  • operate the website;
  • maintain security;
  • deliver requested resources;
  • process an adult’s purchase;
  • remember privacy choices;
  • prevent fraud;
  • maintain a secure session; and
  • support essential website functions.

We do not use child-facing pages for:

  • cross-context behavioral advertising;
  • remarketing directed toward children;
  • unnecessary third-party tracking;
  • creation of child advertising profiles;
  • audience matching based on child activity; or
  • persistent identification of children across unrelated websites or services.

We will not activate optional analytics on child-facing pages unless we have determined that the configuration is legally permitted and implemented any required notice, verifiable parental consent and privacy controls.

Before activating embedded video, social-media, advertising or analytics tools on child-facing pages, we will evaluate what information the provider collects, how the information is used and disclosed, whether persistent identifiers are created and whether notice or verifiable parental consent is required. Where appropriate, the feature will use a privacy-enhanced, consent-controlled or click-to-load configuration.

Additional information is provided in the AltaVidaSites Cookie Policy.

  1. How adult information is used

We may use information provided by Adult Users to:

  • provide requested educational resources;
  • deliver downloads;
  • send requested access links;
  • process purchases;
  • provide order confirmations;
  • respond to inquiries;
  • provide customer support;
  • administer adult accounts;
  • maintain security;
  • prevent fraud and misuse;
  • maintain consent records;
  • improve NAMA materials;
  • correct errors;
  • understand general resource usage;
  • manage email preferences;
  • send educational updates when permitted;
  • document permissions for testimonials or submitted materials;
  • comply with legal obligations;
  • enforce applicable terms; and
  • carry out other purposes disclosed when information is collected.

NAMA will not use or disclose a child’s Personal Information for a materially different purpose without providing any required direct notice and obtaining any required verifiable parental consent.

  1. No sale, targeted advertising or profiling involving children’s Personal Information

We do not sell children’s Personal Information.
We do not disclose children’s Personal Information for targeted or cross-context behavioral advertising.
We do not use children’s Personal Information to create advertising profiles or deliver targeted advertising.

Before materially changing our advertising, analytics or technology practices, we will evaluate the proposed collection, use and disclosure of children’s Personal Information and implement any legally required policy updates, direct parental notice, separate verifiable parental consent and privacy controls before activating the changed practice.

  1. Email and communications

Email subscriptions, purchase confirmations, resource delivery and marketing communications are intended for Adult Users.

NAMA does not request a child’s email address or send marketing communications directly to children under 13.

Transactional communications may include:

  • download links;
  • order confirmations;
  • requested materials;
  • account notices;
  • support responses;
  • security notices;
  • policy notices; and
  • other communications necessary to provide a requested service.

Marketing communications may include:

  • financial-literacy articles;
  • new activities;
  • printable resources;
  • parent guides;
  • educator resources;
  • product announcements;
  • event information; and
  • related updates.

Adults may unsubscribe from marketing communications through the unsubscribe link provided in the message or by contacting us.

Unsubscribing from marketing may not stop transactional, security, purchase or legally required communications.

  1. Purchases and downloads

Purchases and paid transactions must be initiated and completed by an Adult User.

Information associated with a purchase may include:

  • adult purchaser name;
  • adult contact information;
  • billing address;
  • product purchased;
  • transaction date;
  • payment status;
  • transaction identifier;
  • shipping or delivery address, where applicable;
  • refund or dispute information; and
  • limited information received from the payment processor.

Purchased or requested materials and related transactional communications are delivered or made available to the Adult User.

The Adult User is responsible for supervising a child’s use of the materials and determining whether they are appropriate for the child.

 

  1. Adult-submitted photographs, stories, reviews and testimonials

We may invite Adult Users to provide feedback, reviews, stories, artwork, photographs or other submitted Content through an adult-directed submission process.

Adult Users must not submit Content concerning or identifying a child unless they:

  • are the child’s parent or legal guardian or otherwise have lawful authority;
  • have reviewed what is being submitted;
  • understand the intended use;
  • provide any requested permission;
  • avoid disclosing unnecessary identifying information; and
  • do not expose the child’s school, address, precise location or other sensitive information.

We will not publicly display or use a child’s name, image, voice, artwork, story or other identifiable Content without confirming the submitting adult’s authority and completing a separate, clear permission and release process appropriate to the intended use.

Permission to submit Content for review does not authorize advertising, social-media publication, commercial reuse, AI-model training or any other materially different use. Each such use requires express authorization through an appropriate release or consent process.

  1. Accidental submissions from children

If we learn that a child under 13 directly submitted Personal Information without legally sufficient parental authorization, we will stop further collection and take reasonable steps to delete the information, unless retention is legally required or legally permitted for security, integrity or another limited purpose.

Where appropriate, we may also:

  • disable or restrict the associated submission or account;
  • notify the parent or legal guardian when legally permitted;
  • preserve only information reasonably necessary to document the request, comply with law, protect security or prevent recurrence; and
  • review the relevant feature or data flow to reduce the risk of future unauthorized collection.

A parent or legal guardian who believes a child directly submitted Personal Information may contact us using the information provided in this Notice.

  1. Parental rights and requests

A verified parent or legal guardian may exercise applicable rights concerning a child’s Personal Information, including requesting:

  • confirmation of whether NAMA collected or maintains Personal Information concerning the child;
  • a description of the categories and specific types of Personal Information collected;
  • access to or review of the child’s Personal Information;
  • correction of inaccurate information;
  • deletion of the child’s Personal Information;
  • withdrawal of previously provided consent;
  • cessation of further collection, use or disclosure;
  • limitation of disclosure where applicable; and
  • information about service providers or other third parties involved in processing or receiving the information, as required by law.

 

We may require reasonable verification that the requester is the child’s parent or legal guardian before releasing, changing, or deleting information.

We will not require a parent or legal guardian to provide more Personal Information than is reasonably necessary to verify identity and authority, protect the child’s information and complete the request.

  1. Schools, educators and group use

Educators, schools, libraries, youth organizations and other institutions may use NAMA materials under appropriate adult supervision and subject to their own applicable privacy, consent and student-record obligations.

Unless a separate written agreement states otherwise:

  • we do not create student accounts;
  • we do not require student email addresses;
  • we do not request student identification numbers;
  • educators should not upload student records;
  • educators should not submit identifiable student work without appropriate authority;
  • educators and institutions remain responsible for obtaining any required school, district or parental authorization before providing information to NAMA; and
  • NAMA is an educational resource, not a student-information system.

NAMA does not currently provide student accounts, student profiles, classroom dashboards or features designed to collect identifiable student submissions. Before introducing any such feature, we will evaluate and implement the additional notices, agreements, consent processes, contractual restrictions and safeguards required by applicable children’s-privacy, student-data and education laws.

  1. Use of Augmented Intelligence, Artificial Intelligence and Machine-Assisted Tools

NAMA uses augmented intelligence and other machine-assisted technologies to support human creativity, research, educational development, communication, and operational workflows. These technologies may include systems commonly referred to as artificial intelligence or AI.

These tools may assist with:

  • drafting or organizing educational content;
  • developing illustrations and activity concepts;
  • translation and formatting;
  • research and information organization;
  • producing adult-facing support materials;
  • identifying errors; and
  • improving internal workflows.

Published NAMA materials remain subject to human direction, review and editing.

AI-assisted materials receive human review, but errors may remain.

We do not submit a child’s Personal Information—including a photograph, voice recording, precise location, school information, government-issued identifier or biometric information—to a general-purpose AI or machine-assisted service unless the processing is necessary for a specifically disclosed feature and we have implemented any required direct parental notice, verifiable parental consent, data-minimization measures, contractual restrictions and security protections before submission.

We do not use or permit children’s Personal Information to be used to train a general-purpose public AI model without clear disclosure and any legally required verifiable parental consent.

  1. Service providers

We may use service providers to perform limited operational functions for NAMA, such as:

  • website hosting;
  • cloud storage;
  • database services;
  • email delivery;
  • digital-download delivery;
  • payment processing;
  • customer support;
  • security;
  • backups;
  • video hosting;
  • document generation;
  • analytics;
  • software development; and
  • professional services.

Service providers may process Personal Information only for defined purposes and subject to applicable contractual, confidentiality, security, retention and deletion requirements.

Before permitting a service provider to collect or process Personal Information through a child-directed feature, we evaluate the provider’s collection, use, disclosure, retention and security practices and determine whether direct parental notice, verifiable parental consent or other safeguards are required.

Where required by applicable law, this Notice or a linked service-provider disclosure will identify the categories of providers that collect or maintain children’s Personal Information through the Services.

  1. Disclosure of information

We may disclose Personal Information only as described below:

  1. To service providers

Personal Information may be disclosed to service providers that perform defined operational functions on our behalf, subject to applicable contractual, confidentiality, security, retention and deletion requirements.

  1. At the Adult User’s direction

Personal Information may be disclosed when an Adult User requests or authorizes a specific delivery, purchase, submission or interaction, subject to any additional parental consent required for a child’s Personal Information.

  1. For legal, security and safety purposes

Personal Information may be disclosed when reasonably necessary and legally permitted to:

  • comply with applicable law;
  • respond to a court order, subpoena or lawful request;
  • protect a child or another person;
  • investigate suspected fraud or misuse;
  • address a security incident;
  • enforce agreements; or
  • establish, exercise or defend legal claims.
  1. In a business transaction

Adult User information may be disclosed in connection with a merger, acquisition, financing, reorganization, sale or other lawful transfer of all or part of the business, subject to applicable legal and contractual safeguards. Children’s Personal Information will not be transferred for a materially different purpose without any legally required direct parental notice and verifiable parental consent.

We do not disclose children’s Personal Information to third parties for targeted or cross-context behavioral advertising.

  1. Data minimization and retention

We collect only Personal Information reasonably necessary for the specific disclosed purpose.

Adult contact, transaction and communication information may be retained for periods reasonably necessary to:

  • deliver resources;
  • maintain accounts;
  • document purchases;
  • provide support;
  • maintain consent records;
  • honor unsubscribe requests;
  • comply with tax, accounting and legal obligations;
  • resolve disputes;
  • maintain security; and
  • protect legal rights.

We retain a child’s Personal Information only for as long as reasonably necessary to fulfill the specific purpose for which it was collected and do not retain it indefinitely.

When Personal Information is no longer reasonably necessary and no legal retention obligation applies, we delete, deidentify, aggregate or securely dispose of it.

Deletion from active systems may not immediately remove information from encrypted backups, suppression records, legal holds or records that must be retained by law. Backup copies expire or are rendered inaccessible according to established backup schedules, subject to legal holds and security requirements.

  1. Security

We use administrative, technical and physical safeguards designed to protect Personal Information according to its nature and sensitivity.

Safeguards may include:

  • secure transmission;
  • encryption where supported;
  • access controls;
  • least-privilege permissions;
  • authentication;
  • vendor review;
  • software updates;
  • backups;
  • confidentiality obligations;
  • data minimization;
  • incident-response procedures; and
  • limited retention.

No online system can guarantee absolute security.

Adult Users should not send a child’s Personal Information through ordinary email, social-media messaging or unsecured forms.

  1. Security incidents

If a security incident affects Personal Information, we may take appropriate steps to investigate, contain, remediate, document and respond to the incident, including:

  • preserving relevant evidence;
  • restricting or terminating unauthorized access;
  • notifying affected service providers;
  • engaging legal, cybersecurity, insurance or forensic professionals;
  • notifying affected Adult Users, parents or legal guardians when legally required or otherwise appropriate;
  • notifying government authorities when legally required; and
  • taking additional protective action appropriate to the nature and scope of the incident.

Any notification will be provided in accordance with applicable law and based on the nature of the information, the persons affected and the risk presented by the incident.

  1. International access

NAMA is operated from the United States. Personal Information may be processed in the United States and in other countries where approved service providers operate, subject to applicable contractual and legal safeguards.

NAMA is not presently designed to offer child-directed accounts, data-collection features or personalized services outside the United States.

The availability of NAMA materials online does not mean that we actively offer regulated child-directed services in every country or jurisdiction.

Before intentionally offering a child-directed service in another country, we will evaluate the applicable privacy, parental-consent, data-transfer and children’s-protection requirements.

  1. Changes to this Notice

NAMA may update this Notice to reflect changes in:

  • educational materials;
  • service features;
  • data practices;
  • service providers;
  • legal requirements;
  • security procedures; or
  • business operations.

The revised Notice will display an updated date. Before making a material change to the collection, use or disclosure of a child’s Personal Information, we will provide any legally required direct parental notice and obtain renewed verifiable parental consent where required.

  1. Contact information

Questions, parental requests and privacy concerns may be directed to:

NAMA’s Little Money Lab
Operated by: Debora T DiBiasie, doing business through the applicable AVBrand
Subject line: NAMA Privacy Request

Email: wealth@altavidacapital.com

 

To protect a child’s Personal Information, we may verify the requesting adult’s identity and parental or legal authority before granting access, correction, deletion or other parental rights.