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
- 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.
Our list of third-party operators that collect personal information from Children on our Services is set forth below:
Parental Choices and Controls
- Google Analytics (analytics)
- Daily.co (video conferencing)
- Lucky Orange (behavioral tracking and analytics)
- Klaviyo (email generation)
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:
- Responsible Parents may send Kira an email at email@example.com.
- 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 firstname.lastname@example.org 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.