2. CONTENT YOU SUBMIT

A.    Information Users Provide to Us

We and our third-party service providers collect information that Users provide when using the Products, including when Adult Users create an account, sign up for Products, or contact us with a question, comment, or request. However, we will only use or disclose this information in accordance with this Privacy Policy and applicable law. Please see Section 4 (When We Disclose Information to Third Parties) for more information and how we limit disclosure of Adult User and Child User information.

An Adult User must register for an Account on behalf of each Child User. Each Adult User is asked to provide certain information about himself or herself when registering for an account, including email address. After creating an account, an Adult User can add Users to the Adult User’s Account. The Adult User will be asked to enter just the first name or a nickname for the Child User (which will be used to create a login name for the Child User), a password, the birth month and year, and gender. The login name and password will be used to authenticate individual Child Users. If a Child User forgets his or her login name or password, the Adult User will be able to recover the information by logging into the Adult User’s Account. Payment information will also be collected from Adult Users who purchase any Products through the Site. Each payment is a one-time payment for a course and not a recurring payment. We do not store any credit card information or other information provided to authorize the payment.

If you submit any information relating to other people in connection with the Products, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.

We encourage you to use the Products with your Child Users and to view and monitor the use of the Products by them.

B.     Information We Collect from Users

i.      From the Site:

We and select third parties that we partner with to provide analytics and other operational services automatically collect information when users visit our Site. Information that may be collected when you visit our Site include: (1) IP addresses; (2) domain servers; (3) types of computers accessing the Site; (4) types of web browsers used to access the Site; (5) referring Uniform Resource Locator (URL) that sent you to the Site; (6) URL of the site you navigate to directly after leaving our Site; and (7) other information associated with the interaction of your browser and the Site (collectively, “Traffic Data”).

A variety of technologies are used to obtain Usage Data (as defined below) and Traffic Data, including “cookies”. Cookies are small data files stored on your computer. They contain information such as your username, user preferences, the pages you’ve visited and the activities you’ve performed while using the Site and Products. Cookies enable us to recognize your browser on return visits to our Site and to remember your preferences.  You may disable or block cookies or set your browser to alert you when cookies are being sent to your device; however, by disabling cookies, you may not have access to all of the features of the Site or Products. To learn more about browser cookies, visit allaboutcookies.org.

ii.     From the Products:

We and our third-party service providers collect information directly from Users of the Products in the form of the actions they take and activities they complete when using the Products (“Usage Data”). For example, we may collect information about patterns of usage, which activities a child commences and completes, when a child starts and stops an activity, which areas of the Products the child frequents, the number of questions answered correctly or incorrectly, and the child’s choice of customization. We automatically collect and store interaction and learning performance data on databases locally and in our servers on Amazon Web Services. This information is used to update the progress chart within the apps, adjust the personalized learning experience accordingly for individual children, and populate the information portal available for parents and teachers to monitor their children’s usage.

Push Notifications. Additionally, if you downloaded a Product on your mobile device, as part of your use of the Product we may ask if you would like to receive push notifications, which may include alerts and notifications, badges, banners, and sounds on your mobile device. You may choose to stop receiving push notifications at any time by changing the settings on your mobile device.

We and our third-party service providers may use the information collected through these technical methods for a number of purposes, including delivering content, tracking and enhancing our Users’ experience on the Products. For example, when the User returns to the Products after logging in, cookies help the Products recognize who the User is without having to log back in. For more information, see Section 3 (How We Use Information). The information collected through these technical methods by the Products are used only to support the internal operations of the Products. We do not allow third-party advertising networks to collect information about Users who are logged in to their Accounts.

3. HOW WE USE INFORMATION

We will never sell or rent the PII of any User of the Products to a third party, except as described in this Privacy Policy or in the context of a sale of our company. We and our third-party service providers may use the information collected from Users as described below.

A.     Adult User Information 

Information collected from Adult Users may be used:

• To permit you to register and use the Products, including, for example, to send you communications about Child User progress or your Account.

• To complete and fulfill your purchase, such as to process your payments, communicate with you regarding your purchase, and provide you with related customer service.

• To respond to your inquiries and fulfill your requests, retrieve your password, or provide technical support.

• To send you marketing communications for RoundEd Learning products, relevant research, and newsletters that we believe may be of interest to you. While it is never our intention to send any marketing messages to children, if you believe a Child User has received such a marketing communication, please contact us as described in Section 11 (Contact Us) . You can always choose to stop receiving these marketing messages by simply following the instructions contained in the message. For all Accounts, you may not opt out of receiving administrative messages from us regarding your Account, such as password reset emails and customer support messages.

B.     Child User Information 

Information collected from Child Users may be used:

• To measure a Child User’s performance in activities and to adapt a Child User’s learning experience to the Child User’s learning needs.

• To analyze, provide progress reports on, or provide an assessment of a Child User’s performance to the Adult User on the Account.

C.     Both Adult and Child User Information 

Information collected from both Adult Users and Child Users may be used:

• To allow us to assess and improve the Products, its educational content, and other services we provide, for example, to improve our content and user experience; to research, evaluate, and improve the Products’ educational efficacy; and to inform our understanding of the Products’ user base.

• To customize, adapt, and personalize Users’ viewing and content-consumption experience, for example, by measuring a Child User’s performance in activities and adapting the Child User’s experience to his or her learning needs.

• To maintain and analyze the functioning of the Products.

• To avoid any violations of this Privacy Policy, our Terms of Use, or any applicable law.

• As we believe to be necessary or appropriate under applicable law in order to: (a) comply with legal process; (b) respond to requests from public and government authorities, including public and government authorities outside your country of residence; (c) detect violations of and enforce our Terms of Use; (d) protect our operations or those of any of our affiliates, including the security of the Products; (e) protect our rights, privacy, safety, or property, or that of our affiliates, you, or others; and (f) allow us to pursue available remedies or limit the damages that we may sustain.

4. When We Disclose Information to Third Parties

Information collected from both Adult Users and Child Users will not be disclosed to third parties except as follows:

• To third parties who perform certain services for us, such as process credit cards or conduct or evaluate research (such as on the educational impact of the Products), provided that the service providers agree to keep the information confidential and to use it only for purposes that are permitted by this Privacy Policy.

• As we believe to be necessary or appropriate as set forth above in Section 3 and in other instances substantially similar to those listed in this Section.

• Where legally required and in certain other cases, we may make such disclosures without first providing notice to Users.

• Subject to confidentiality agreements, the terms of this Privacy Policy, and applicable law, information may be disclosed to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, transfer, or license all or a portion of our assets in bankruptcy or otherwise. This means that if some or all of our assets are acquired or otherwise transferred or licensed, including in bankruptcy, that such acquirer shall be subject to the same commitments stated under this Privacy Policy.

We do not disclose the personally identifiable information of any Child User to third parties for any marketing or promotional purposes.

We also may disclose de-identified and/or aggregated User information for any other purpose as permitted by applicable law – for example, the distribution of de-identified User records to outside researchers or the distribution of reports containing aggregate User demographic and traffic patterns – provided that no individual Adult User or Child User or any specific end-user device can be readily identified.

5. How to Access, Change, or Delete Account Information

An Adult User can review or change the information they provided when they registered for the Products, including by adding or removing Child Users to or from the Account, by logging into the Adult User’s Account from the Site and choosing to edit or delete the applicable Account(s). In addition, Adult Users may contact us at any time as described in Section 11 (Contact Us) to request that we provide for their review, or delete from our records, any PII associated with their Accounts. Please keep in mind that a request to delete a User’s PII may lead to the loss of saved game data and an inability by the User to use the Products or certain portions of the Products.

When we change or delete any PII at your request, we will make good faith efforts to make the changes in our then-active databases as soon as reasonably practicable, generally within 24-48 hours. Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules. Please note that information may remain in backup or archive records, and we may retain certain data relevant to preventing fraud or future abuse or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable or de-identified data, Account recovery, or if required by law. All retained data will continue to be subject to the Privacy Policy in effect at that time.

6. Account Cancellation and Reactivation; Data Deletion

At any time, Adult Users may cancel their Accounts by choosing to delete such Accounts from their profile page on the Site. For Accounts that have been cancelled, if the account remains inactive for 24 months, we will delete all PII in our active databases associated with the account (“Account Information”). The 24-month period is provided so that you have the ability, following cancellation of an Account or inactivity, to reactivate your Account and potentially recover previous information and resume where the Child User left off. However, we provide no guarantee, and shall have no liability or obligation to ensure that all Account Information and Product-related progress will be available or accessible or all learning or personalization features will be able to be recovered or resumed. If a User requests that PII be deleted prior to the end of the 24-month period of inactivity, we will take commercially reasonable steps to satisfy that request.

Upon Account cancellation, de-identified Adult User and Child User information may nonetheless persist internally in our archive files or similar databases and may still be used, on a de-identified basis, for our internal support, administrative, and record-keeping purposes including, but not limited to, allowing us to improve the Products and other services we provide through research, evaluation, and analytics as permitted by applicable law.

Please note that following a request to delete information or your Account under Sections 5 or 6 of this Privacy Policy, information including PII may remain in backup or archive records, and we may retain certain data if required by law, relevant to preventing fraud or future abuse or for legitimate business purposes, such as Account recovery and customer support, and all subject to our internal records retention periods. All retained data will continue to be subject to the Privacy Policy in effect at that time and applicable law.

7. Links to Other Products

The Site may include links to external websites or applications (for example, Facebook and Twitter) in areas intended for Adult Users. These websites and applications are governed by their own privacy policies or information collection practices, which may be substantially different from ours. We encourage you to review the privacy policies and information collection practices of any external websites and apps, as those parties’ practices would not be subject to this policy.

8. Location of Information Processing

The Products are controlled and operated by us from the United States, and we provide the Products for use only by persons located in the United States. We make no claims that the Products are accessible or appropriate outside of the United States. Access to the Products may not be legal by certain persons or in certain countries. If you access the Products from outside the United States, you do so on your own initiative and are responsible for compliance with local laws.

9. Security

The security of your personal information is important to us, and we employ commercially reasonable physical, technical, and administrative security measures designed to safeguard the information collected by the Products.

Adult Users who hold Accounts create passwords for Accounts for Adult Users and Child Users during the registration process. You can help protect against unauthorized access to such Accounts and PII by selecting and protecting the passwords appropriately, limiting access to your computers and browsers, and signing out of the Accounts at the end of each use. The Account holder’s email address and password are used to authenticate logins. A one-time password is emailed to the email address when registering for the first time or in the event of a forgotten password. Access to PII is limited (through username/password credentials and two-factor authentication) to those employees of RoundEd Learning or our third-party service providers who require it to perform their job functions.

Please be aware, however, that no information system can be guaranteed to be 100% secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Products over networks that we do not control, including the internet and wireless networks. If you have reason to believe that your interaction with us is not secure, please contact us as described in Section 11 (Contact Us).

10. Changes to Our Privacy Policy

If we update this Privacy Policy, we will notify you by posting the revised Privacy Policy on the Site or in the Products, and for certain revisions that materially expand the ways in which we use or share the information previously collected from you through the Products, either display an alert next to the Privacy Policy, display an alert upon login to the Products, or directly communicate with you (e.g., via the email address associated with your Account).

11. Contact Us

RoundEd Learning is located in the United States of America and is the operator of the Products. Questions regarding this Privacy Policy and issues related to your or a Child User’s information for which you are responsible should be directed to us via any of the following methods:

RoundEd Learning Inc.

Pleasanton, CA 94566

Attn: Vidya Raman, CEO

info@roundedlearning.com