Privacy Policy

1. Who We Are

The YMCA of Middletown ("YMCA," "we," "us") operates the ClubGuardian digital attendance system for the Club Kid Before & After School Program. ClubGuardian is developed and maintained by SASGuard Computing, LLC ("Technology Provider") on behalf of the YMCA.

2. Information We Collect About Children

ClubGuardian collects the following information about children enrolled in the Club Kid Before & After School Program. This information is entered by authorized YMCA staff on behalf of the program — children do not use the system directly.

Information We Do NOT Collect

• Social Security numbers
• Financial or payment information
• Medical or health information
• Photographs or video of children
• Location/GPS data
• Device fingerprints or persistent identifiers
• Behavioral or browsing data

3. How Information Is Collected

All information is collected by authorized YMCA staff using tablets provided at each school site. Children and parents do not create accounts or interact directly with ClubGuardian.

• Roster data (names, DOB, schedules) is imported from the YMCA's Daxko membership management system and/or entered by YMCA Directors.
• Daily attendance is recorded by site supervisors when children arrive and depart.
• Electronic signatures are captured on the tablet touchscreen when a parent/guardian picks up or drops off their child.
• Offline data: If internet is unavailable, attendance records are stored temporarily on the tablet and synced when connectivity is restored.

4. How We Use This Information

We use the information collected solely for the following purposes:

• Attendance tracking — Recording which children are present at each site for safety and accountability
• Program administration — Managing rosters, schedules, and enrollment across 24 school sites
• Parent verification — Confirming authorized pick-up/drop-off via electronic signature
• Compliance reporting — Generating attendance reports required by state childcare licensing
• Safety — Real-time headcount to account for every child in the program

We do not use children's information for marketing, advertising, profiling, or any purpose unrelated to the Club Kid program.

5. Third-Party Services

ClubGuardian uses the following third-party services to operate. These services process data as necessary to provide the system but do not use children's information for their own purposes.

We do not sell, rent, or share children's personal information with any third party for marketing or commercial purposes.

6. How We Protect This Information

• Encryption in transit: All data is transmitted over HTTPS/TLS 1.3
• Encryption at rest: Database records are encrypted with AES-256 (Google-managed)
• Access control: Only authorized YMCA staff can access ClubGuardian via Google Sign-In with domain-restricted accounts
• Role-based permissions: Directors have full access; Supervisors can only view and record attendance for their assigned school
• Session timeout: Automatic logout after 30 minutes of inactivity on shared tablets
• Web Application Firewall: Cloudflare WAF protects against common web attacks
• Offline data cleanup: Locally cached data is cleared on logout

7. Data Retention

We retain children's information only for as long as necessary to fulfill the purposes described in this policy and to comply with applicable legal and regulatory requirements.

• Attendance records: Retained as required by applicable state childcare licensing regulations and YMCA policy
• Roster data: Maintained for the duration of a child's enrollment in the Club Kid program
• Electronic signatures: Retained with the associated attendance record

When data is no longer needed, it is securely deleted from all systems.

8. Your Rights as a Parent or Guardian

Under the Children's Online Privacy Protection Act (COPPA) and applicable state laws, parents and legal guardians have the following rights:

• Review: You may request to review the personal information we have collected about your child.
• Deletion: You may request that we delete your child's personal information from our records.
• Refuse further collection: You may refuse to allow any further collection or use of your child's information. Note that this may require withdrawing your child from the Club Kid program, as attendance tracking is a program requirement.
• Consent withdrawal: You may withdraw your consent for data collection at any time.

To exercise any of these rights, please contact:

9. Parental Consent

In accordance with COPPA, we obtain verifiable parental consent before collecting personal information about children under 13. Consent is obtained through a signed consent form provided during program enrollment.

Attendance records cannot be submitted for a child until parental consent has been received and recorded by a YMCA Director.

10. Changes to This Policy

We may update this privacy policy from time to time. If we make material changes to how we collect, use, or share children's personal information, we will notify parents through the Club Kid program and obtain new consent as required.

The "Last Updated" date at the top of this page indicates when this policy was most recently revised.

11. Contact Us

If you have questions or concerns about this privacy policy or ClubGuardian's data practices, please contact: