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Youth Data Protection Addendum

Effective Date: March 2026


Applies To: Cyber 429 Programs Involving Minors


This Youth Data Protection Addendum (“Addendum”) supplements the Cyber 429 Privacy Policy
and applies to programs, events, internships, educational offerings, and other services involving
individuals under the age of eighteen (18) (“Minors”).


In the event of a conflict between this Addendum and the Privacy Policy, this Addendum
controls with respect to Minor data.

1. Scope

This Addendum applies when Cyber 429 collects, processes, or stores personal information
relating to Minors in connection with:

  • Educational programs (including CIPHER or similar initiatives)

  • Internships or mentorship programs

  • Youth workshops or cybersecurity camps

  • Events marketed to high school students

  • Any activity reasonably expected to involve individuals under 18

2. Parental / Guardian Consent

Where required by law, Cyber 429 will obtain verifiable parental or legal guardian consent prior
to collecting personal information from a Minor.


Consent may be obtained through:

  • Signed registration forms

  • Electronic consent forms

  • Written authorization

  • Contractual agreements with educational institutions

  • Other legally acceptable verification mechanisms

​

Cyber 429 reserves the right to deny participation if proper consent is not obtained.

3. Categories of Youth Data Collected

We may collect limited information necessary to administer participation, including:

  • Participant name

  • Date of birth or age confirmation

  • School affiliation

  • Parent/guardian name and contact information

  • Emergency contact information

  • Email address (if age-appropriate)

  • Program-related performance or participation data

  • Media releases (if separately authorized)

​

We do not knowingly collect:

  • Sensitive health information (except emergency disclosures)

  • Social Security numbers (unless legally required and separately disclosed)

  • Financial account information from Minors directly

​

Payment processing is handled through authorized guardians or institutions.

4. Purpose Limitation

Youth data is collected solely for:

  • Program administration

  • Safety and emergency contact

  • Educational instruction

  • Internship or mentorship placement

  • Compliance with legal obligations

  • Program improvement (aggregated or de-identified where possible)

​

Youth data will not be used for behavioral advertising or profiling.
We do not sell youth data.

5. Data Sharing

Youth data may be shared only with:

  • Program instructors or administrators

  • Authorized Cyber 429 personnel

  • Educational institution partners (if applicable)

  • Service providers necessary for program delivery (e.g., learning platforms)

  • Emergency services when required

  • Legal authorities as required by law

​

All vendors receiving youth data are required to maintain appropriate safeguards.

6. Data Retention

Youth personal information will be retained only as long as necessary to:

  • Complete the program

  • Maintain academic or program records

  • Comply with legal requirements

  • Resolve disputes

​

After retention periods expire, data will be securely deleted or de-identified.

7. Security Safeguards

Cyber 429 implements reasonable administrative, technical, and physical safeguards designed
to protect youth data from unauthorized access, disclosure, alteration, or destruction.
Access to youth data is limited to personnel with a legitimate operational need.

8. Rights of Parents and Guardians

Parents or legal guardians may:

  • Request access to their child’s personal information

  • Request correction of inaccurate data

  • Request deletion (subject to legal or contractual obligations)

  • Withdraw consent for future data collection

​

Requests may be submitted to:
privacy@cyber429.com


Identity verification may be required before processing requests.

9. FERPA Considerations

When Cyber 429 operates in partnership with educational institutions, data handling may be
governed by the Family Educational Rights and Privacy Act (FERPA) or other applicable student
privacy laws.


In such cases, Cyber 429 acts as a “school official” with legitimate educational interest where
designated by contract.

10. Limitation of Liability

Cyber 429 implements reasonable safeguards; however, no system is immune from risk.
Participation in programs acknowledges inherent risks associated with digital platforms and
online communications.

11. Changes to This Addendum

Cyber 429 may update this Addendum periodically. Continued participation after updates
constitutes acceptance.

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