//Last Updated: July 17, 2022
Kira Learning Privacy Notice
This Privacy Notice is designed to help you understand how Kira Learning, Inc. (“Kira Learning,” “we,” “us,” and “our”) collects, uses, and shares your personal information and to help you understand and exercise your privacy rights.
1//SCOPE
2//CHANGES TO OUR PRIVACY NOTICE
3//PERSONAL INFORMATION WE COLLECT
4//HOW WE USE YOUR INFORMATION
5//HOW WE DISCLOSE YOUR INFORMATION
6//YOUR PRIVACY CHOICES AND RIGHTS
7//SECURITY OF YOUR INFORMATION
8//INTERNATIONAL DATA TRANSFERS
9//RETENTION OF PERSONAL INFORMATION
10//SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
11//SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
12//CHILDREN’S INFORMATION
13//THIRD-PARTY WEBSITES/APPLICATIONS
14//SUPERVISORY AUTHORITY
15//CONTACT US
EXHIBIT A – SUPPLEMENTAL PRIVACY NOTICE FOR CHILDREN UNDER THE AGE OF SIXTEEN
1//SCOPE
This Privacy Notice applies to personal information processed by us, including on our websites, mobile application, and other online or offline offerings. To make this Privacy Notice easier to read, our websites, mobile application, and other offerings are collectively called the “Services.”
2//CHANGES TO OUR PRIVACY NOTICE
We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.
3//PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on how you interact with us, our Services and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.
A {Information You Provide to Us Directly}
We may collect the following personal information that you provide to us. Please see Exhibit A “Supplemental Privacy Notice for Children Under Sixteen” for more information about our collection of information about children under sixteen.
  • Account Information. We may collect personal information in connection with the creation and administration of your account such as your name, email address, phone number, non-public information including educational records or details, and details about your employer.
  • Child Registration. Children may provide personal information about their Responsible Parent for the purpose of helping the Responsible Parent provide their consent for the Child’s use of the Services. This may include, but is not limited to, the Responsible Parent’s name and email address.
  • Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about Kira Learning or the Services, or otherwise communicate with us.
  • Interactive Features. We may collect personal information that you submit or make available through our interactive features (e.g., video conferencing feature, contact functionalities, social media pages, etc.). Please note that to use our video conferencing feature, you will need to provide Kira with access to your device’s microphone and/or camera and consent to our making a video and audio recording of you. Any recordings of video conferencing meetings we collect will not be made generally available to the “public” unless we have provided you with notice of this practice and obtained your consent. Any personal information you provide on any public sections of these features will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.
  • Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
  • Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend conferences, trade shows, and other events.
  • Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
  • Job Applications. We may post job openings and opportunities on our Services. You may reply to one of these postings by submitting your application, CV, cover letter, and/or other information to us.
B {Information Collected Automatically}
We may collect personal information automatically when you use our Services:
  • Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as analytics about your use of the Services, personal information contained in any content you generate using our Services, details about your software coding efforts and capabilities, your coursework progress, pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
  • Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
    • Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
    • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
    • Our uses of these Technologies fall into the following general categories:
    • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
    • Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
    • Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
    • Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.
    • See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
  • Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include Google Analytics. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information on our website, please click here.
We may obtain information about you from other sources, including through third-party services and organizations. For example, schools and/or school districts may provide us with personal information about their students that use the Services on their behalf.
C {Information Collected from Other Sources}
We may obtain information about you from other sources, including through third-party services and organizations.
4//HOW WE USE YOUR INFORMATION
We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below. Please see Exhibit A “Supplemental Privacy Notice for Children Under Sixteen” for more information about our use of information about children under sixteen.
A {Provide Our Services}
We use your information to fulfill our contract with you and provide you with our Services, such as:
  • Managing your account and information;
  • Answering requests or inquiries;
  • Communicating with you, including about activities on our Services and policy changes;
  • Processing applications if you apply for a job we post on our Services; and
  • Allowing you to register for events.
  • If a child under the age of sixteen wishes to register for our Services and provides us with their parent’s or guardian’s first name, last name and email address, we will only use the the name and email address to obtain consent for the child unless the parent or guardian opts-in to other uses of the name and email address by Kira.
B {Administrative Purposess}
We use your information for various administrative purposes, such as:
  • Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
  • Measuring interest and engagement in our Services;
  • Improving, upgrading or enhancing our Services;
  • Developing new products and services;
  • Ensuring internal quality control and safety;
  • Authenticating and verifying individual identities;
  • Debugging to identify and repair errors with our Services;
  • Auditing relating to interactions, transactions and other compliance activities;
  • Sharing information with third parties as needed to provide the Services;
  • Enforcing our agreements and policies; and
  • Other uses as required to comply with our legal obligations.
C {Marketing and Advertising our Products and Services}
We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we may market to you include email campaigns, text messages, phone calls, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.
D {Other Purposes}
We also use your information for other purposes as requested by you or as permitted by applicable law.
  • Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
  • De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.
5//HOW WE DISCLOSE YOUR INFORMATION
We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below. Please see Exhibit A “Supplemental Privacy Notice for Children Under Sixteen” for more information about our disclosure of information about children under sixteen.
A {Disclosures to Provide our Services}
The categories of third parties with whom we may share your information are described below.
  • Service Providers. We may share your personal information with 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.
  • Other Users You Share or Interact With. The Services may allow you to share personal information or interact with other users.
  • Your Teacher, School, or School District. If you use our Services as a student on behalf of a school or school district, your teacher, school, and/or school district may access personal information related to your use of the Services.
  • Affiliates. We may share your personal information with members of our corporate family.
  • Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.
  • Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”
B {Disclosures to Protect Us or Others}
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C {Disclosure in the Event of Merger, Sale, or Other Asset Transfers}
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, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
6//YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
  • Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Notice).
  • Text Messages. You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.
  • “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
  • Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.


  • The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

    Please note you must separately opt out in each browser and on each device.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
  • Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; or (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the “right of data portability”);
  • Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
  • Request Deletion of your personal information;
  • Request Restriction of or Object to our processing of your personal information; and
  • Withdraw Your Consent to our processing of your personal information.
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws
7//SECURITY OF YOUR INFORMATION
We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.
8//INTERNATIONAL DATA TRANSFERS
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
9//RETENTION OF PERSONAL INFORMATION
We store the personal information we collect as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
10//SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Kira Learning has collected about them and whether Kira Learning disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:
Category of Personal Information Collected by Kira Learning
Identifiers
Personal information categories listed in Cal. Civ. Code § 1798.80(e)
Internet or other electronic network activity
Professional or employment-related information
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g, 34 C.F.R. Part 99))
Inferences drawn from other personal information to create a profile about a consumer
Categories of Third Parties Personal Information is Disclosed to for a Business Purpose
  • Service providers
  • Other Users You Share or Interact With
  • Your Teacher, School, or School District
  • Advertising Partners
  • Service providers
  • Other Users You Share or Interact With
  • Your Teacher, School, or School District
  • Service providers
  • Advertising Partners
  • Service providers
  • Service providers
  • Your Teacher, School, or School District
  • Service providers
  • Advertising Partners
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.
Additional Privacy Rights for California Residents
“Sales” of Personal Information under the CCPA. For purposes of the CCPA, Kira Learning does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth in “Contact Us” below.
Verification. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to verify your email address we have on file.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
11//SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.
12//CHILDREN’S INFORMATION
Protecting children’s privacy online is very important to us. Although our Services are designed for a general audience, we take additional steps to obtain verifiable parental consent before collecting any personal information from a child under the age of sixteen in the limited instances our Services are available to such children. For more details regarding our processing of personal information that we collect from children, please see our Supplemental Privacy Notice for Children Under the Age of Sixteen attached hereto as Exhibit A.
13//THIRD-PARTY WEBSITES/APPLICATIONS
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
14//SUPERVISORY AUTHORITY
If you are located in the European Economic Area, Switzerland, or the United Kingdom you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
15//CONTACT US
Kira Learning is the controller of your personal information. If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at:

Kira Learning, Inc.
195 Page Mill Rd
Palo Alto, CA 94306
info@kira-learning.com
Exhibit A

Supplemental Privacy Notice for Children Under the Age of Sixteen
This Supplemental Privacy Notice for Children Under the Age of Sixteen (“Supplemental Privacy Notice for Children”) governs Kira’s collection, use and disclosure of personal information from children under the age of sixteen (each a “Child” and collectively “Children”). This Supplemental Privacy Notice for Children supplements Kira’s Privacy Notice to notify parents, guardians, schools, and/or school districts (each a “Responsible Parent”) of:

  • The types of personal information Kira may collect from Children;
  • How Kira uses the personal information it collects from Children;
  • Kira’s practices for disclosing that Child’s personal information; and
  • How Responsible Parent may request access, modification, and deletion of the Children’s personal information Kira has collected.


Kira takes steps to obtain verifiable parental consent directly from parents and/or guardians where such parent or guardian creates an account or sub-account for the Child. To the extent a school or school district has contracted with Kira to provide the Services to students at its school, Kira is relying on the school and/or school district to consent on behalf of each Child’s parent or guardian to Kira’s collection, use, and disclosure of Children’s personal information as set forth in this Supplemental Privacy Notice for Children. If any provisions in this Supplemental Privacy Notice for Children conflict with the Privacy Notice or the Kira Terms of Service, this Supplemental Privacy Notice for Children controls. Capitalized terms not defined in the Privacy Notice have the meaning set forth in this Supplemental Privacy Notice for Children.

Personal Information Kira Collects from Children

Kira only collects personal information from a Child in connection with the creation or administration of the Child’s account or when the Child uses the Services in connection with their account.

Personal information that Kira collects in connection with the creation or administration of a Child’s account may include the Child’s first and last name, email address, details about the Child such as year born and gender, and educational records or details (including those provided by a school and/or school district). In addition, if a Child communicates with Kira for support or other purposes, Kira may collect personal information from the Child.

Kira may collect certain personal information from Children automatically when they use our Services, such as Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. Kira may also automatically collect personal information regarding a Child’s use of our Services, such as analytics about a Child’s use of the Services, personal information contained in any content a Child generates using our Services, details about the Child’s software coding efforts and capabilities, a Child’s coursework progress, pages that a Child visits before, during and after using our Services, information about the links a Child clicks, the types of content a Child interacts with, the frequency and duration of a Child’s activities, and other information about how a Child uses our Services.

Kira may also collect personal information that Children submit or make available through Kira’s interactive features (e.g., video conferencing feature, contact functionalities, etc.). Please note that to use our video conferencing feature, Kira will need to access the Child’s device microphone and/or camera.

How Kira Uses Children’s Personal Information

Kira only uses personal information collected from Children to provide the Services.

Kira’s Practices for Disclosing Children’s Personal Information

Kira may disclose a Child’s personal information:

  • To other users of the Services that a Child shares or interacts with.
  • To the teacher, school, and/or school district on whose behalf the Child uses the Services.
  • To service providers Kira uses to provide the Services.
  • If Kira is 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 Kira believes the disclosure is necessary or appropriate to protect the rights, property, or safety of Kira, its customers or others, including to:
    • protect the safety of a Child;
    • protect the safety and security of the Services; or
    • enable Kira to take precautions against liability.
  • To law enforcement agencies or for an investigation related to public safety.


In addition, if Kira is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Kira’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, Kira may transfer the Children’s personal information it has collected or maintain to the buyer or other successor.

Third-Party Operators

Our list of third-party operators that collect personal information from Children on our Services is set forth below:
  • Google Analytics (analytics)
  • Daily.co (video conferencing)
  • Lucky Orange (behavioral tracking and analytics)
  • Klaviyo (email generation)


Parental Choices and Controls

At any time, Responsible Parent may use the Services to review a Child's personal information, require Kira to correct or delete a Child’s personal information, and/or refuse to permit Kira from further collecting or using a Child’s personal information. Please keep in mind that a request to delete records may lead to a termination of an account and/or the Services.

Responsible Parents can request assistance from Kira to access, change or delete Children’s personal information that we have collected from their children in two ways:

  1. Responsible Parents may send Kira an email at info@kira-learning.com.
  2. Responsible Parents can request access to and delete their Child’s personal information by logging in to the Child’s account. Responsible Parents will need their Child’s user-name and password. A Responsible Parent can email info@kira-learning.com for details on how to recover a password if the Child cannot recall it.


Kira may require that Responsible Parent take certain steps or provide additional information to verify its identity before Kira provides any information or makes corrections.

A valid request to delete personal information will be accommodated within a reasonable time.