Dearist Finder: Privacy Policy

Effective Date: September 1, 2026 

Chapter Group LLC ("Company," "we," "us," or "our") operates Dearist Finder (the "Program"), a pen-pal program that allows children to exchange physical correspondence through participating brick-and-mortar retailers and related Program services. We are committed to protecting the privacy and safety of children, Parents/Guardians, and participating retailers.

This Privacy Policy explains what information we collect, how we use it, how we protect it, when we share it, how long we keep it, and the choices available to individuals. It applies to information collected through the Program, our website or registration tools, participating retailers, customer support, and other services that link to this Privacy Policy.

1. Our Privacy Commitments

The Program is designed to minimize the information collected. We collect only information reasonably necessary to operate and protect the Program.

• We do not require children to provide home addresses, telephone numbers, personal email addresses, school names, teacher names, or social-media information.
• We do not require a child's exact date of birth for ordinary Program participation.
• We do not sell children's personal information.
• We do not use children's personal information for targeted advertising.
• We design the Program so children can participate without directly exchanging home addresses or other direct-contact information.
• We give Parents/Guardians meaningful ways to access, correct, delete, or withdraw consent concerning their child's information, subject to applicable law.

2. Information We Collect

The information we collect depends on how a person interacts with the Program.

A. Parent/Guardian Information

• full name;
• email address and other contact information;
• information used to establish or document parental or guardian consent;
• account, registration, or participation information; and
• payment information, if the Program ever accepts payment directly from a Parent/Guardian.

B. Child Information

• first name or an approved nickname;
• current school grade;
• Program participation or matching information; and
• limited information associated with Program correspondence when needed for routing or administration.

We intentionally do not require a child's exact age or date of birth for ordinary Program participation. A child should not include unnecessary personal information in correspondence.

C. Retailer Information

• business name and location;
• business contact information;
• employee or representative contact information needed to administer the Program;
• Program training, compliance, and participation records; and
• information contained in safety, privacy, or operational reports.

D. Website and Technical Information

If you visit our website or use an online registration or support tool, we may automatically receive limited technical information such as IP address, browser type, device type, operating system, approximate location derived from IP address, pages viewed, referring website, and dates and times of access.

We use this information for security, troubleshooting, fraud prevention, analytics, and operation of the website. We will not use technical information to build a behavioral advertising profile for a child.

3. Information We Do Not Intentionally Collect From Children

The Program does not require children to provide:

• home or residential addresses;
• personal telephone numbers;
• personal email addresses;
• school names or school addresses;
• classroom, teacher, or schedule information;
• social-media usernames or account information;
• government-issued identification numbers;
• financial account or payment information; or
• precise location information.

We ask Parents/Guardians to discuss with their children what information they feel is appropriate to provide voluntarily, including sensitive information through letters, forms, messages, or other Program communications.

4. How We Use Information

We use personal information only for purposes reasonably necessary to operate, administer, secure, and improve the Program, including to:

• register families and administer participation;
• verify or document Parent/Guardian consent;
• facilitate school grade-appropriate matching procedures;
• route and manage physical correspondence;
• communicate with Parents/Guardians and participating retailers;
• provide customer and safety support;
• train and monitor participating retailers;
• prevent fraud, abuse, harassment, and misuse;
• investigate safety concerns and enforce Program rules;
• maintain security and respond to suspected incidents;
• comply with legal obligations and valid legal requests;
• resolve disputes and enforce our agreements; and
• maintain, evaluate, and improve the Program.

5. Children's Privacy and Parental Consent

The Program may be available to children under 13. Where applicable law, including the federal Children's Online Privacy Protection Act and its implementing rule (COPPA), requires verifiable parental consent before collecting, using, or disclosing a child's personal information, we will obtain the required consent before engaging in the covered collection, use, or disclosure.

Parent/Guardian Consent Is Separate From Privacy Policy Acknowledgment

The Program distinguishes between:

• agreement to the Terms of Service or other contractual terms;
• acknowledgment that the Parent/Guardian has reviewed this Privacy Policy; and
• parental consent or authorization when consent is required by applicable law.

Checking a box acknowledging this Privacy Policy does not, by itself, constitute or replace any separate form of verifiable parental consent that may be required by applicable law.

Our consent process may include verification of Parent/Guardian status, electronic consent, email confirmation, or another method designed to satisfy applicable law. A child will not be required to provide more personal information than is reasonably necessary to participate.

Parents/Guardians may withdraw consent and request that their child stop participating at any time by contacting the Privacy Contact listed below. Withdrawal may end the child's participation in the Program.

6. Registration and Checkbox Acknowledgment

When a Parent/Guardian registers a child for the Program, the registration process may require the Parent/Guardian to affirmatively acknowledge this Privacy Policy.

The Privacy Policy acknowledgment should be presented separately from acceptance of the Program's Terms of Service or other contractual agreements.

Where the registration process uses an electronic checkbox, the checkbox should be presented as an affirmative acknowledgment and should not be pre-selected.

The Parent/Guardian may be asked to affirmatively check a box substantially similar to:

☐ I acknowledge that I have reviewed the Dearist Finder Privacy Policy and understand how the Program collects, uses, shares, protects, and retains personal information as described in the Privacy Policy.

The words "Privacy Policy" should provide access to the complete current Privacy Policy before the Parent/Guardian completes registration.

A Privacy Policy acknowledgment is intended to document that the Parent/Guardian was provided an opportunity to review the Privacy Policy. It does not, standing alone, create a contractual agreement to the Privacy Policy or replace any legally required consent.

Where separate agreement to the Terms of Service is required, the registration process should use a separate affirmative checkbox substantially similar to:

☐ I have read and agree to the Dearist Finder Terms of Service.

Where separate parental consent or authorization is required, the Program may use a separate consent statement and verification process appropriate to the applicable law.

The Company may maintain records of the Privacy Policy version, Terms of Service version, date and time of acknowledgment or acceptance, and other reasonable transaction information necessary to document the registration and consent process.

7. How We Share Information

We limit sharing to circumstances reasonably necessary for the purposes described in this Policy.

A. Participating Retailers

Retailers may receive or access limited information necessary to perform their Program responsibilities. Depending on their role, this may include Parent/Guardian contact information, a child's first name or approved nickname, grade, matching or routing information, and limited safety or operational information.

Retailers may not use Program information for unrelated marketing, profiling, advertising to children, locating children, contacting children outside the Program, selling information, or other unrelated commercial purposes.

B. Service Providers

We may use carefully selected service providers for hosting, secure storage, email delivery, payment processing, customer support, security, administrative services, or other functions necessary to operate the Program.

We expect service providers handling personal information to use it only as necessary to provide services to us and to maintain appropriate confidentiality and security protections.

C. Legal, Safety, and Business Disclosures

We may disclose information when reasonably necessary to comply with law; respond to valid legal process; protect a child or another person; investigate suspected abuse, fraud, threats, or unlawful activity; protect our rights or property; enforce our agreements; or support a lawful business transaction such as a merger, acquisition, financing, or sale of assets, subject to applicable law and appropriate protections.

8. No Exchange of Home Addresses

Program-Designated Correspondence Address

The Dearist Finder program is designed so that participating pen pals correspond with one another using the designated mailing address of a Participating Retailer. The Participating Retailer’s address serves as the Program-designated correspondence address for receiving and distributing Pen Pal correspondence.

Correspondence between participants that is sent to, from, or through an address other than a Participating Retailer’s designated Program address is outside the scope of the Dearist Finder program. The Company does not represent that correspondence exchanged outside the Program’s designated correspondence process is subject to the Program’s privacy, safety, security, or information-handling procedures.

The Program does not authorize or facilitate the exchange of participants’ residential addresses, personal telephone numbers, personal email addresses, school addresses, social-media contact information, or other direct-contact information for purposes of communicating outside the Program’s designated retailer-based correspondence process.

The use of a Participating Retailer’s address is intended to help limit the need for participating children to disclose their residential or other direct-contact information to one another.

A core privacy and safety feature of the Program is that children do not need to exchange home addresses. Program procedures are designed to route correspondence without requiring participating children to know one another's residential addresses.

Children should not include their home address in letters and should not request another participant's home address, telephone number, personal email address, school address, social-media information, or other direct-contact information.

9. Children's Content

A child may voluntarily include personal information in a letter. We do not ask children to provide unnecessary sensitive information.

If a child voluntarily provides information that creates a safety or privacy concern, we may take reasonable steps to protect the child and other participants, including contacting the Parent/Guardian or appropriate authorities when legally permitted or required.

10. Cookies and Similar Technologies

Our website may use cookies, pixels, local storage, or similar technologies that are reasonably necessary for website operation, security, authentication, preferences, and aggregate analytics.

We will not knowingly use behavioral advertising technologies to target advertisements to children using their personal information.

Where required by law, we will provide additional choices or notices concerning cookies and similar technologies.

11. Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction.

Depending on the information and circumstances, safeguards may include access controls, role-based permissions, confidentiality obligations, secure systems, encryption, physical security, employee training, secure handling of paper records, and incident-response procedures.

No method of storage or transmission is completely secure. If we determine that a security incident requires notice under applicable law, we will provide notice as required.

12. Data Retention and Deletion

We retain personal information only for as long as reasonably necessary to fulfill the purpose for which it was collected, operate the Program, protect participants, comply with legal obligations, resolve disputes, prevent fraud or abuse, and enforce agreements.

We maintain reasonable retention and deletion procedures for children's information and do not retain children's personal information indefinitely.

When information is no longer reasonably necessary, we will delete, destroy, or de-identify it, subject to legal, safety, dispute-resolution, and operational requirements.

If a Parent/Guardian requests deletion of a child's information, we will evaluate and respond to the request in accordance with applicable law. Information that must be retained for a permitted purpose will be limited to that purpose.

13. Parent/Guardian Privacy Rights

Subject to applicable law and reasonable verification of identity and authority, a Parent/Guardian may contact us to request:

• access to personal information we maintain about their child;
• correction of inaccurate information;
• deletion of their child's information;
• withdrawal of consent;
• termination of their child's participation; and
• information about our privacy practices and the handling of their child's information.

We may ask for reasonable information to verify the requester's identity and authority to act for the child. We will respond within the time and manner required by applicable law.

14. State Privacy Rights

Privacy rights vary by state. Depending on where a Parent/Guardian or child resides and whether a particular law applies to us, additional rights may include access, correction, deletion, portability, restriction or objection to certain processing, appeal of a denied request, and information about categories of personal information collected, used, or disclosed.

California residents may have additional rights under the California Consumer Privacy Act, as amended, including rights to know/access, delete, correct, and opt out of certain sales or sharing.

We do not sell children's personal information and do not use children's personal information for targeted advertising.

We will process valid privacy requests in accordance with the law applicable to the request.

15. Non-Discrimination

We will not discriminate against a person for exercising privacy rights provided by applicable law.

We may, however, be unable to provide or continue certain Program services when information is necessary to administer the service or when participation has been terminated at the request of a Parent/Guardian.

16. International Data Transfers

The Program is intended for use in the United States.

If personal information is processed or stored outside the United States by us or a service provider, we will use appropriate safeguards as required by applicable law.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The Last Updated date identifies the most recent revision.

If we make a material change to practices affecting children's personal information or to practices for which parental consent was previously obtained, we will provide notice and obtain additional consent when required by applicable law.

We will not make a material change that would materially weaken protections for children's personal information without providing any legally required notice or consent.

18. Contact Us

Privacy questions, requests, or complaints may be directed to:

Chapter Group LLC
6650 Sugarloaf Parkway, Suite 900, Duluth, GA, 30097, USA
info@hellodearist.com
770-476-1004
www.hellodearist.com

Privacy Contact: info@hellodearist.com

Child Safety Contact: info@hellodearist.com

Parents/Guardians may also contact the participating retailer where registration occurred to request access, correction, deletion, withdrawal of consent, or termination of a child's participation.

19. Parent/Guardian Privacy Policy Acknowledgment

By completing the Privacy Policy acknowledgment during registration, the Parent/Guardian confirms that:

• they were provided an opportunity to review this Privacy Policy;
• they understand that the Program is designed to minimize the personal information collected from children;
• they understand that children do not need to exchange home addresses;
• they understand that children's information is not sold or used for targeted advertising;
• they understand that limited information may be shared with participating retailers and service providers when reasonably necessary to operate the Program; and
• they understand that they may exercise applicable privacy rights by contacting the Company.

This acknowledgment does not, by itself, constitute a contractual agreement to this Privacy Policy and does not replace any separate Terms of Service acceptance, parental authorization, or legally required verifiable parental consent.

Recommended Registration Implementation

The registration interface will present the Privacy Policy acknowledgment separately from acceptance of the Terms of Service and from any legally required parental-consent procedure.