COPPA Privacy Notice

Last Modified: October 10, 2023

The Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”) require us to inform parents and legal guardians (as used in this notice, “parents”) about our practices for collecting, using, and disclosing personal information from children under the age of 13 (collectively, “children” or individually, each a “child”). It also requires us to obtain verifiable consent from a child’s parent for certain collection, use, and disclosure of the child’s personal information.

This notice notifies parents of:

- The types of information we may collect from children.

- How we use the information we collect.

- Our practices for disclosing that information.

- Our practices for notifying and obtaining parents’ consent when we collect personal information from children, including how a parent may revoke consent.

- All operators that collect or maintain information from children through our software development course.

This notice (the “COPPA Privacy Notice”) only applies to data we collect of or about children under the age of 13, and supplements our general Privacy Notice (the “Privacy Notice”), which applies to all other audiences. Terms that are defined in the general Privacy Notice have the same meanings as used in this COPPA Privacy Notice.

1. Information we collect from children

Children can access certain parts of the Services and their content, and use some of their features without providing us with personal information. However, most of the Services’ content and features require us to collect certain information, including personal information, from children. In addition, we use certain technologies, such as cookies and analytics services, to automatically collect information from our users (including children) when they visit or use the Services. We only collect as much information about a child as is reasonably necessary for the child to participate in an activity and for us to understand how our Services function and can be improved for other students, and we do not condition a child’s participation on the disclosure of more personal information than is reasonably necessary for these purposes. We do not use any child’s data for marketing purposes.

2. Information we collect directly, and how we collect it

A child must provide us with the following information to register with this website: the child's first and last name, their email address and their age or school year, the name of the school the child attends, and their software development skill level. As we provide our Services, we may also collect audio files and videos of the child, the first and last name of the child’s parent, the email address and phone number of the child’s parent, the name of the child’s school, and the name and email address of their teachers. We use this information to create a user profile page for children, to create their account to use the Services, and to offer our Services to them. We collect this information in the following ways:

- From the child’s school.

- From the child, when initially signing up for our Services or if they make changes to their account thereafter.

- From parents, when providing consent to our collection of their children’s information.

- From teachers, as needed for us to make our Services available to the child.

We also use automatic collection means. See below for further details of this method of data collection.

3. Automatic information collection and tracking

We use technologies, including those provided by Google LLC (“Google”), to automatically collect information from our users, including children, when they access and navigate through the Services and use certain of its features. The information we collect through these technologies includes:

- Information about your child’s interactions with our Services, including: the languages they choose; pages they visit; when they approach the bottom of each page; when our webpages are in focus on their device; what webpages they come from and head to; their screen resolution; when they access files; the first time they interact with a form; when they submit a form; their search results; and the start time, end time, and progress of any videos they may watch.

- Information about your child as a user of our Services, including: the city, country, continent, subcontinent, region, browser, and IP address from which user activity originated, and the operating system and platform that they use to visit our Services.

We also may combine non-personal information we collect through these technologies with personal information about children that we collect through the use of our Services. For information about our service providers’ automatic information collection practices, including how you can opt out of certain information collection, please visit:

- Google: https://policies.google.com/privacy?hl=en and https://tools.google.com/dlpage/gaoptout/

- Amazon.com, Inc. (“Amazon”): https://aws.amazon.com/privacy/ and by visiting the “Cookie Preferences” link available at the bottom of: https://aws.amazon.com/free/?trk=d77f71c9-93a1-4e15-a87b-91101c810a80&sc_channel=ps&s_kwcid=AL!4422!10!72018238443204!72018780813939&ef_id=57c73725876e1ae0db805239fda46b92:G:s&all-free-tier.sort-by=item.additionalFields.SortRank&all-free-tier.sort-order=asc&awsf.Free%20Tier%20Types=*all&awsf.Free%20Tier%20Categories=*all

4. How we use children’s information

We use the personal information we collect from children to:

- Register children with the Services.

- Provide children with information and features available on or through the Services.

- To provide children with applicable lessons, training, support, and feedback on or through the Services.

- Communicate with children about activities or features of the Services.

- Track children’s performance on the Services.

- Inform teachers and parents about children’s activities and performance on or through the Services.

We use the information we collect automatically through technology and other non-personal information we collect to improve our Services and to deliver a better experience by enabling us to:

- Provide children with access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow children to make use of our functionality.

- To assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (e.g., if a child hovers over a particular button to choose an answer for too long, this may indicate that the child is unsure of the answer, and that may help us tailor our teaching content or support prior to a quiz in the future).

- To offer children enhanced functionality when accessing or using our Services. This may include identifying children when they sign into our Services or keeping track of their specified preferences, or past items viewed on the Services.

5. Our practices for disclosing children's information

We do not share, sell, rent, or transfer children's personal information other than as described in this COPPA Privacy Notice and our FERPA Statement. We may disclose aggregated information about any of our users, and information that does not identify any individual, without restriction. In addition, we may disclose children's personal information:

- To our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, and other related services.

- When children share personal information or interact with other users on or through the Services.

- If children use our Services as a student on behalf of a school or school district, their teacher, school, and/or school district may access personal information related to the children's use of the Services.

- To our affiliates involved in making the Services available.

- To our business partners to provide children with a product or service they have requested, including products/services that we offer jointly with such business partners.

- If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.

- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers or others.

- If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider.

6. Social features

The Services may offer social features, including video conferencing feature, contact functionalities, social media pages, that enable children to communicate with others through the Services. We do not control the types of information children can transmit. We encourage parents to educate their children about safety online and to carefully monitor their children’s use of social features to ensure they do not disclose their personal information through them. Please note that to use our video conferencing feature, children will need to provide their devices with access to their device’s microphone and/or camera and consent to our making a video and audio recording of them. These recordings will not be made public, but may be viewed by other children in the child’s class.

7. Accessing and correcting children’s personal information

At any time, a parent may review the child’s personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child’s information. Parents can review, change, or delete their child’s personal information by:

- Logging into the child’s account and visiting the account profile page, if parents know the child’s login credentials.

- Sending us an email at COPPA@kira-learning.com.

To protect the child’s privacy and security, we may require the parent to take certain steps or provide additional information to verify their and their child’s identity before we provide any information or make corrections.