Children’s Privacy Notice
Effective Date: January 1, 2025
Kids Discover, LLC (“Kids Discover”, “we”, “us”, or “our”) is committed to protecting the privacy of children who use our Services. The U.S. Children’s Online Privacy Protection Act (“COPPA”) requires us to inform parents and legal guardians about our practices for collecting, using, and disclosing personal data from children under the age of 13 (“children” or “child”). This Children’s Privacy Notice supplements our Privacy Policy and is intended to comply with COPPA and provides additional details regarding our data collection practices for Services directed to children under the age of 13.
Capitalized terms not defined in this COPPA Notice are otherwise defined in the Privacy Policy.
1. PROTECTING CHILDREN’S PRIVACY
We take precautions to protect the privacy of children using our Services. If you have a question about whether a particular Service is directed to children, please Contact Us.
When a child creates an account, we collect their information in compliance with applicable laws, including by seeking the consent of a parent or legal guardian for creation of that account. When our Services are used by a school in an educational setting, we rely on the school to provide the requisite consent, on behalf of the Parent, for us to collect information from a child under the age of 13 for educational purposes.
2. COLLECTION OF CHILDREN’S PERSONAL DATA
We only collect the minimal amount of personal data necessary for children to use our Services. Note that a child’s participation or access to our Services cannot be conditioned on the child providing more personal data than is reasonably necessary for that activity. Accordingly, we may collect the following:
Registration and account activity information. As part of certain subscriptions, schools and districts will use the individual accounts system which allows students and their teachers to share a virtual classroom. Student and teacher accounts are organized by classrooms, which are created by the teachers. For these accounts, we ask the students to enter their first and last name, username, password, and class code. We also require the teachers’ email for password recovery. The only personal data collected about students is their first and last name, username, password, and class code. We do NOT collect students’ email or physical addresses. We store the Lexile ® Reading Level data that may be set by a teacher, so that our content may be served up dynamically to a reader. We also store student performance on any Kids Discover Online Assessments that have been completed, in order to provide the educator(s) of those students with data pertaining to student performance. Please note that this data is not shared, tracked, or analyzed by Kids Discover, nor is it rented, sold, or used by any third-party service providers. It is saved in our system to deliver a more optimal reading experience for the students and teachers using the service. It is not used in any other way.
Automatically collected information. We use cookies and other similar technologies, to collect information for internal purposes when children use our Services. We also collect browser and device data and usage information, including IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, and add-ons. We may use these technologies to track the amount of time children spend on learning activities available through the Services, the actions performed by children such as logging in and out, and the pages children visit.
3. USE OF CHILDREN’S PERSONAL DATA
We may use children’s personal data for the following purposes:
- To provide the Services in which the child is participating;
- To operate and improve our Services, including access management, payment processing, Services administration, internal operations, troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To comply with laws, regulations, and other legal requirements;
- To comply with relevant industry standards and our policies;
- To protect and enforce our rights and the rights of other Users against unlawful activity, including identify theft and fraud, and other violations of our Terms and Conditions;
- To protect and enforce our rights;
- To protect the integrity and maintain the security of our Services, including secured areas of the Services;
- To operate, evaluate and improve our business, including conducting surveys and market research, developing new products, services, and promotions (such as, for example, special events, programs, offers, contests); analyzing and enhancing existing products, services, and promotions; managing our communications; performing accounting, auditing, and other internal functions;
- Evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about the users of our Services is among the assets transferred; and
- For any other purpose for which a parent, guardian, or school may provide consent.
We will retain children’s personal data only for as long as is necessary for the purposes set out in this Children’s Privacy Notice. We will retain and use children’s personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain certain children’s personal data for internal analysis purposes. This information is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.
Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with the child; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position, including regard to applicable statutes of limitations, litigation or regulatory investigations.
4. DISCLOSURE OF CHILDREN’S PERSONAL DATA
We do not sell or rent children’s personal data to any third parties for monetary purposes. However, we may disclose personal data to the following categories of third parties:
- Our affiliates. We may share personal data with our business affiliates, in which case, we will require such third parties to comply with the terms of this Children’s Privacy Notice and our general online Privacy Policy.
- Service providers. We share personal data with our service providers to provide services on our behalf, such as payment processing, analytics, hosting, streaming services, customer and technical support, and other services. These third parties are well-known, established service providers, who are bound contractually to practice adequate security measures and only use the information for the sole purpose of providing the Services.
- Schools and similar organizations. We share personal data with the organizations and entities on behalf of which we are providing the Services to the child.
- Account administrators. We may disclose personal data to the designated administrator of the child’s account, if the child has an individual school or other educational subaccount, regarding use of the Services by individual subaccounts.
- Compliance and harm prevention. We reserve the right to disclose children’s personal data if we are required to do so by law or if we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order or legal process.
- Affiliate and business transfers and transactions. We also reserve the right to transfer children’s personal data in case of a corporate restructuring (such as a merger or acquisition), as long as the receiving entity adopts this Children’s Privacy Notice and our Privacy Policy. Any future successors must also pledge their commitment to the K-12 School Service Provider Pledge that we have signed and agreed to cooperate with.
- Other third parties. We may also disclose children’s personal data other third parties with express parental or school consent.
Please note that we may share non-personally identifiable information, including aggregated or anonymized data, with analytics, search engine, or other service providers that help us improve our Services; to report to our affiliates, licensors, and service providers about the use of various aspects of the Services; and with other users or prospective users of the Services. As stated above, aggregated and anonymized data is not considered personal data and is not subject to this Children’s Privacy Notice or our Privacy Policy.
5. PARENTAL CHOICES AND CONTROLS
We provide parents and guardians with the ongoing rights to: (1) access and review your child’s personal data maintained by us; (2) request that we update or delete such personal data; and/or (3) refuse to allow us from further collecting or using your child’s personal data.
Parents or guardians may also consent to the collection and use of their child’s personal information without consenting to the disclosure of that information to third parties. Parents may submit such a request by using the information included in the Contact Us section and including “COPPA Inquiry” in the subject line, if available.
Parents/guardians of children using our Services through a school account should contact their school to exercise their rights and we will work with the parent/guardian and school together to facilitate those requests.
Please note that if you choose to exercise your right to delete information, your child may not be able to participate in our school-related Services. Please also note that we may not be able to delete information in all instances. For example, we may retain certain information as necessary to prevent fraud or future abuse, for recordkeeping or other legitimate business purposes, or if required by law. Retained personal data will remain subject to the terms of this Children’s Privacy Notice and our Privacy Policy.
To protect your and your child’s privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any personal data or make corrections.
CONTACT US
If you have any questions about this Children’s Privacy Notice or our privacy practices, please email us at questions@kidsdiscover.com, or write to us at:
ATTN: Legal Team
Kids Discover, LLC
606 Post Rd East
Suite 3
Westport, CT 06880