No selling or trading of your personal information
No advertisement You don’t have to worry about inappropriate Google, Youtube ads popping up. We are not going to sell anything to your kids nor allow other companies to do so.
No private messaging, chatting or emails We understand dangers abound online, which is why your children’s accounts exist under yours. There is no peer to peer private messaging or chatting. Many other schools and programs ask for children’s emails, we don’t ask and don’t store that data anywhere. Subscribers to the Multilingual Immersion program have the option of participating in our international pen pal program. You can find out more about this program here, but know that it is a teacher-led pen pal program where your child’s coach facilitate language and cultural exchange between chosen pen pals.
No Storage or tracking of personal identifying Information
- Children can be signed up by their parents, and there’s no need for children to provide their email or identifying personal information.
- Any information requested are only used to create personal evaluation/assessment reports, website login and payment processing.
- We take your privacy very seriously, and we never sell your Personal Information; we use it to enhance your experience with opportunities like individualized learning and offers.
- During Account registration, the only information we may ask you to provide about a child who will be using the Services is the child’s first name (or nickname), birth month and year to begin customizing their learning program.
We do not knowingly collect any PI directly from Child Users under age 13. For more information about where in the Services we may collect PI from children, please see Information We Collect from Users below.
- We do not ask for certain sensitive PI such as social security numbers, driver’s license numbers, or biometric data. However, paying subscribers are asked for payment information when they subscribe. Please see Information Collection for more information about how we safeguard payment information.
- We use commercially reasonable physical, technical, and administrative security measures designed to safeguard all information collected by the Services.
- The Services are backed by our Child Safe guarantee. This means that Accounts will never include any pop-up ads or other advertisements directed to children.
- Personal Information, or PI, is defined in this policy to mirror the text of the California Consumer Privacy Act (CCPA) and means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
- Adult Users (as defined below) may contact us, when applicable, via our website to request that we provide for their review, or delete from our records, any PI they have provided about Child Users associated with their Account, or to cease collecting PI from those Child Users.
- Account Users
Users of the Services include Child Users (any child under age 18 who uses the learning portion of the Services) and Adult Users (including parents and legal guardians of Child Users), collectively referred to as Users.
- Information Collection
There are two general categories of information that we collect.
- Information Users Provide to Us
As more fully set forth below, we and our third-party service providers collect information that Users provide when using the Services, including when Adult Users create an Account, sign up for Services, or contact us with a question, comment, or request. However, we will only use or disclose this information in accordance with this policy and applicable law. Please see When We Disclose Information to Third Parties below for more information and how we limit disclosure of Child User information.
Adult Users must register for an account on behalf of the Child User. Adult Users are asked to provide certain Personal Information about themselves when registering for any Account, including first and last name, email address, and telephone number (which is optional). Payment information is also collected from Adult Users who purchase an account. For your security, we do not store your complete credit card number in our databases but retain only the first six digits and last four digits so that we can identify your account and respond to your requests and questions.
In addition, Adult Users can provide us with information through a separate password-protected section (i.e., the Parent Dashboard) of the Services. This section, accessible via the Menu on the Character Select section of the Services, allows Adult Users to administer their Accounts, including when they add Child Users, provide testimonials, seek customer support, or submit comments or questions.
- Information We Collect from Users
We and our third-party service providers collect Personal Information directly from Users of the Services in the form of the actions they take and activities (or quests) they complete when using the Services. For example, from Adult Users, we may collect information about patterns of usage and order history; from Child Users, 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 Services the child frequents, the number of questions answered correctly or incorrectly, and the child’s choice of Avatar and customization.
We and our third-party service providers also use a variety of technologies, such as cookies (small text files that the Services save on your computer or mobile device), to automatically collect certain technical information from your computer or mobile device over time and across different websites, including when you use the Services, such as your browser type, operating system, device type, the page served, your IP address, the approximate geographic region your computer or mobile device is located in, and the websites you visited prior to visiting the Services. When you download and use one of our Apps, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
What Are Cookies?
Cookies are small text files placed on your device to collect standard internet log information and visitor behavior information. The cookies may transmit information via your browser with a purpose of authenticating or identifying the computer (via, e.g., the IP address) or the User. Cookies may contain information such as registration data and User preferences.
- automatically collect certain technical information from your computer or mobile device over time and across different websites, including when you use the Services, such as your browser type, operating system, device type, the page served, your IP address and your geolocation. When you download and use our App(s), we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number;
- collect and store information about your location to provide you with educational experiences or email updates that are tailored for your region. The location information we have access to may include (1) your postal code, if you provide one to us; and (2) the approximate geographic region your computer or mobile device is located in, as determined from your IP address. However, we do not collect your street name and the name of your city/town. You may be able to change the settings on your computer or mobile device to prevent it from providing us with such IP information;
- we may collect information from your mobile device if you have downloaded our App(s). This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your IP address, geographic location, how you use the App(s), and information about the type of device you use. In addition, in the event our App(s) crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our App(s). This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual. In addition, if you choose to turn on your Bluetooth, wi-fi or other geolocation functionality when you use our App(s), we may collect and use your geolocation information; and
When a server receives a request from a device which stores a cookie from a website, the server is able to use the information stored in the cookie in combination with the information stored on the server to allow the website to respond to you as an individual and to tailor their operations to your needs, likes, and dislikes by gathering and remembering information about your preferences. A cookie cannot collect information from your computer and cannot carry any viral or other damaging files.
Types of Cookies
We use the following cookies:
These cookies are essential to provide you with services available through Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Services and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
These cookies allow us to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details, and remembering the changes you make to other parts of Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Services.
Analytics and Performance Cookies
These cookies are used to collect information about traffic to our Services and how users use the Services. The information gathered does not identify any individual visitor. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information, and to monitor the level of activity on our Services.
Social Media Cookies
These cookies are used when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter, or Google+. The social network will record that you have done this.
Except as otherwise provided in this policy, such as when a California resident has opted-out of our sharing Personal Information for valuable consideration, by continuing to use our Services, you are accepting our use of these cookies that make advertising and communications more relevant to you and your interests and further help us to improve our Services.
Pixel Tags and IFrames
We also may use pixel tags (which are also known as web beacons and clear GIFs) on our Services to track the actions of Users on our Services. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on web pages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Services, so that we can manage our content more effectively.
- How We Use Information
We will never monetize the Personal Information of any User of the Services by providing it to a third party in exchange for money, except as described in this policy in the context of a sale of the Company.
We and our third-party service providers may use the information collected from Users as follows:
Adult User Information Information collected from Adult Users may be used:
- To permit you to register for and use the Services, including, for example, to send you communications about Child User’s assessment results and progress or your Account, or to allow you to provide Feedback through the Parent Dashboard. For security purposes, the Parent Dashboard is password protected.
- 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 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 via our website. You can always choose to stop receiving these marketing messages by simply following the instructions contained in the message or, if the communication is by phone, informing the caller of your desire not to receive further phone communications. 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.
- To measure the effectiveness of our advertising to adults.
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.
Both Adult and Child User Information Information collected from both Adult and Child Users may be used:
- To allow us to assess and improve the Services, its educational content, and other services we provide, for example, to improve our content and user experience; to research, evaluate, and improve the Services’ educational efficacy; and to inform our understanding of the Services’ 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 Services.
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to detect violations of and enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates, including the security of the Services; (f) to protect our rights, privacy, safety, or property, or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain (collectively, (a)-(g) are Other Uses and Disclosures).
- When We Disclose Information to Third Parties
Information collected from both Adult and Child Users will not be disclosed except for the following purposes, which include our operations purposes:
- As we believe to be necessary or appropriate as set forth above in Other Uses and Disclosures 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.
In addition, with respect to your Account, we may use third-party advertising networks and other affiliates in association with cookies, pixel tags, or IFrames for Adult Users’ visits to the non-child-directed portions of the Services and to (1) deliver interest-based advertising to those Adult Users, including Company-branded advertising, when those Adult Users visit third-party websites; and (2) provide us with statistics about the effectiveness of our advertising on third-party websites. These third-party advertising networks may use this cookie information in accordance with their own privacy policies.
We do not disclose the Personal Information of any Child User to third parties for any marketing or promotional purposes. This also means that we do not share the Personal Information of children under the age of 16 for valuable consideration.
We also may disclose de-identified and/or aggregated User information for any other purpose as permissible 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.
- How to Access, Change, or Delete Account Information
An Adult User can review or change the information they provided when they registered for the Services, including by adding or removing Child Users to or from the Account, by updating information through the Parent Dashboard of the Services. In addition, Adult Users may contact us at any time as described in our contact page to request that we provide for their review, or delete from our records, any PI they have provided about Child Users associated with their Accounts, or to cease collecting PI from those Child Users, as applicable. Please keep in mind that a request to delete PI may lead to cancellation of your Account or the inability to use the Services or certain portions of the Services.
- Account Cancellation and Reactivation; Data Deletion
Upon Account cancellation, de-identified Adult 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 Services and other services we provide through research, evaluation, and analytics as permissible by applicable law.
- California Privacy Rights
Effective January 1, 2020, the CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. In this section “you” or “your” refers to California residents. Under the new law we are required to disclose the categories of sources from whom we collect personal information, and the third parties with whom we share it, which we have explained above. We are also required to communicate information about rights you have under California law, such as:
- Right to access Personal Information. You may be entitled to receive the specific pieces of your Personal Information we hold.
- Right to data portability. You may be entitled to receive a copy of your electronic Personal Information in a readily-usable format.
- Right to disclosure. You may be entitled to receive information regarding the categories of Personal Information we collected, the sources from which we collected Personal Information, the purposes for which we collected and shared Personal Information, the categories of Personal Information that we sold and the categories of third parties to whom the Personal Information was sold, and the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding your request.
- Right to deletion. You may be entitled to request that we delete the Personal Information that we have collected from you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws. Please note, however, that we may need or be required to keep such information, such as for our legitimate business purposes or to comply with applicable law.
Information we Collect and Share
In addition, we are required to provide you certain information about the business and commercial purposes for which we collect and share your personal information.
Business and Commercial Purposes for which we use Personal Information: We use and disclose the information we collect from each of the Categories of Personal Information listed below for the business purposes described in this policy, including but not limited to: process payments, conduct research, detect security incidents and prevent fraud, debug and repair errors, maintain your account, provide customer service, enabling and affecting commercial transactions and advancing our commercial and economic interests, such as delivering interest-based advertising to Adult Users and analyzing the effectiveness of our advertisements and other activities to improve our service, market our services, and understand how users interact with our services.
Categories of Personal Information we collect: In the preceding 12 months, we have also disclosed the following categories of personal information for one or more business purposes: identifiers, commercial information, internet or electronic network activity information, geolocation data, and inferences we draw or derive about users.
Categories of Sources from which we collect Personal Information: We collect Personal Information from each of the aforementioned Categories of Personal Information from You, your child and, if applicable, your child’s teacher or school.
Categories of Third Parties with whom we share Personal Information: We share Personal Information from each of the aforementioned Categories of Personal Information with the following categories of Third Parties, including as part of a sale or for commercial or business purposes:
Categories of Personal Information we share with Third Parties: We share, and have shared during the past 12 months, the following categories of Personal Information with Third Parties, including as part of a sale or for commercial or business purposes: personal identifiers such as name and credit card number; commercial information, such as services subscribed to, obtained or considered; and information regarding your interaction with or use of our products and services, including the Services. We do not sell the Personal Information of children under 16 years of age.
Exercising Access, Disclosure, Data Portability, and Deletion Rights
To exercise the access, disclosure, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either contacting us via our website.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your Child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We fully support your privacy rights and will not discriminate against you for exercising any of your CCPA rights.
- Links to Other Services
In certain sections of the Services, we may include links to external websites or applications (for example, Facebook and Twitter). However, in order to protect children from accessing these external websites, an Adult User will be required to enter a valid password. 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.
- Location of Information Processing
The Services are controlled and operated by us from the United States, Japan and Singapore. Your information may be stored and processed in any country where we have facilities or in which we engage service providers, including the countries listed above, which may have data protection laws that are different from those of your country. In addition, your information may be subject to access requests from governments, courts, or law enforcement officials in countries where it may be processed, under the laws of those countries.
The security of your personal information is important to us, and we employ physical, technical, and administrative security measures designed to safeguard the information collected by the Services. We use industry standard SSL (secure socket layer technology) encryption to transfer PI. Other security safeguards include, but are not limited to, data encryption, firewalls, and physical access controls to buildings and files.
Account holders create a password in the registration process. You can help protect against unauthorized access to your Account and PI by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account. At registration, we assign a username to each Account and use those usernames to authenticate logins, allow access to the subscription content, and monitor compliance. The username is also used to authenticate Users when requesting technical support. Access to PI is limited (through user/password credentials and two-factor authentication) to those employees who require it to perform their job functions.
Please be aware, however, that no information system can be guaranteed to be 100 percent 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 Services 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 via our website.
- Contact Us