What Does This Privacy Policy Cover?
        
        This General Privacy Policy covers how we treat Personal Data that we gather when non-Child Users access or use
        our Services. "Personal Data" means any information that identifies or relates to a particular individual and
        also includes information referred to as "personally identifiable information" or "personal information" under
        applicable data privacy laws, rules or regulations. This policy does not apply to the practices of companies
        that Company does not own or control, or to individuals that Company does not employ or manage.
        
          If you have any questions about this privacy policy or how your Personal Data or Child User Personal Data is
          handled, please email us at 
compliance@splashlearn.com
         
      
        
          How is Child User Personal Data Treated?
        
        For a detailed overview of how we process Child User Personal Data, please see the 
Child User Privacy Policy.
      
 
      
        
          What Personal Data Does the Company Collect?
        
        The Personal Data you provide is used for such purposes as providing you the Services, answering questions,
        sending product updates, and communicating with you about Company's products and services, including specials
        and new features. The Child User's Personal Data you provide shall only be used for creating individual accounts
        (which will allow you to receive progress reports that include tracking your child's performance and progress).
        You can choose not to provide us with certain data, but then you may not be able to take advantage of many of
        our special features.
        
          You may review, modify, stop collection of or remove your Personal Data or, if you are a Parent, your Child
          User's Personal Data identified below at any time by logging into your account and accessing features to edit
          your profile and/or account information.
        
        
          If you are a teacher or a School, by sharing information about students ("Student Data") or other data to
          SplashLearn, you expressly grant, and you represent and warrant that you have all rights necessary to grant,
          to
          SplashLearn a non-exclusive, royalty-free, worldwide license during the term of the Agreement to use,
          transmit,
          distribute, modify, reproduce, display, and store the Student Data solely for the purposes of (i) providing
          the
          Services as contemplated by the Agreement, and as otherwise described herein, (ii) maintaining, supporting,
          evaluating, improving and developing our products, applications, and Service, and (iii) enforcing our rights
          under the Agreement.
        
        
          We collect the following types of data from our non-Child Users:
        
        
          Contact and Payment Information
          We collect your email address, account password, zip code, phone number, credit card and/or other payment
          information and any other information necessary for us to provide the Services. If you are a teacher or a
          school
          administrator we also collect your school name from you in order to provide you school level features and
          prevent misuse of the Services meant for teachers and Schools.
        
 
        
          We also offer Parents and teachers the ability to sign up for the Services using their existing Facebook or
          Google account. If you choose to sign up for the Services using one of these accounts, we may receive your
          full
          name and other information from the service provider managing that account.
        
        
          Additionally, you may also provide us with additional Personal Data when you contact us for product or
          technical
          support like an alternate communication method which we will use to answer your queries and process your
          requests. If you are using the service as an Educational Institution, Student Data may be visible during
          Customer Support and/or Troubleshooting. Personal Data such as name, email address, login dates and times may
          be
          viewed on our Service by product support staff.
        
        
          Push Notifications
          If opted-in, we may send practice and live class reminders, alerts about offers, in-app activity, new events,
          content and features designed for Parents and teachers in the form of notifications through our mobile
          applications. You can turn-off these notifications or modify the frequency of these notifications at any time
          through the app or device settings.
        
 
        
          Activity Data
          We receive and store certain types of information whenever you interact with our Services or use our Services.
          Company automatically receives and records information on our server logs from your browser including your IP
          address, Cookie information, and the page you requested.
        
 
        
          Cookies
          The Services also use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and
          JavaScript (collectively, "Cookies"). Cookies are small pieces of data– usually text files – placed on your
          computer, tablet, phone or similar device when you use that device to access our Services. We may also
          supplement the information we collect from you with information received from third parties, including third
          parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies,
          the Services do not support "Do Not Track" requests sent from a browser at this time.
        
 
        
          We use information collected through Cookies and usage of the Services for purposes such as to learn more
          about
          our user base; analyze trends; authenticate and secure the Services; enhance and personalize your experience;
          and in general to improve and operate our Services.
        
        
          Such technology is also used to receive confirmation when you open an email from us. We use this confirmation
          to
          help us make emails more interesting and helpful. When you receive emails from us, you can opt out of
          receiving
          further emails by following the included instructions to unsubscribe.
        
        
          Advertising
          We may run advertising campaigns to market our Services and use technology such as cookies to analyze the
          performance of advertising and improve them. We do not display third party advertisements on our Services or
          use
          third party Cookies to track Child Users for advertising purposes. We also do not engage in targeted
          advertising
          based on Student Data or Child User Personal Data.
          
          For more information about our use of Cookies, please see our 
Cookie Policy.
         
        
          To view summary of the categories of Personal Data that we collect and have collected over the past 12 months,
          
click here.
        
          
            
              
                | Category of Personal Data | Examples of Personal Data We Collect | Categories of Third Parties With Whom We Share this Personal Data | 
            
            
              
                | Profile or Contact Data | 
                    First and last nameEmail addressPhone numberUnique identifiers such as passwordsYear of birth for purpose of age screeningSchool name and address (with respect to teachers only) | 
                    Service ProvidersAnalytics Partners | 
              
                | Payment Data | 
                    Payment Information (credit card etc) provided by you | 
                    Service Providers (specifically our payment processing partners, currently Stripe, Inc. and PayPal, Inc. and wallet providers Apple and Google) | 
              
                | Commercial Data | 
                    Purchase history on SplashLearn | 
                    Service ProvidersAnalytics Partners | 
              
                | Device/IP Data | 
                    IP addressDevice IDDomain serverType of device/operating system/browser used to access the ServicesAd_ID for Android | 
                    Service ProvidersAnalytics PartnersAdvertising Partners | 
              
                | Web Analytics | 
                    Web page interactionsReferring webpage/source through which you accessed the ServicesNon-identifiable request IDsStatistics associated with the interaction between device or browser and the Services | 
                    Service ProvidersAnalytics PartnersAdvertising Partners | 
              
                | Social Network Data |  | 
                    Service ProvidersAnalytics Partners | 
              
                | Consumer Demographic Data | 
                    Year of birth (for age screening)Zip codeGenderAge | 
                    Service ProvidersAnalytics Partners | 
              
                | Professional or Employment-Related Data | 
                    Job title (e.g., teacher) | 
                    Service ProviderParties You Authorize, Access or Authenticate | 
              
                | Geolocation Data | 
                    IP-address-based location information | 
                    Service ProvidersAnalytics Partners | 
              
                | Inferences Drawn From Other Personal Data Collected | 
                    Profiles reflecting user attributes, behavior, preferences or abilities/aptitudes (for example,
                      profiles reflecting mathematics abilities) |  | 
              
                | Other Identifying Information that You Voluntarily Choose to Provide | 
                    Identifying information in emails or letters you send usPhone or other contact information you may provide to us when you ask us to contact you, such as
                      for support | 
                    Service ProvidersAnalytics Partners | 
            
          
         
       
      
        What Sources Does the Company Collect Personal Data from?
        Categories of Sources of Personal Data
        We collect Personal Data about you from the following categories of sources:
        
          You
          
            - 
              When you provide such information directly to us
              
                - When you create an account or use our interactive tools and Services.
- When you voluntarily provide information in free-form text boxes through the Services or through
                  responses to surveys or questionnaires.
- When you send us an email or otherwise contact us.
 
- 
              When you use the Services and such information is collected automatically
              
                - Through Cookies (defined in the "Cookies" section).
- If you download our mobile application or use a location-enabled browser, we may receive information
                  about your location and mobile device, as applicable
- If you download and install certain applications and software we make available, we may receive and
                  collect information transmitted from your computing device for the purpose of providing you the
                  relevant
                  Services, such as information regarding when you are logged on and available to receive updates or
                  alert
                  notices.
 
 
        
          Public Records
          
            - From the government or other sources.
 
        
          Third Parties
          
            - 
              Teacher or School Administrator
              
                - 
                  As noted above, teachers or school administrators may provide a student's name or other identifier for
                  purposes of tracking progress and distinguishing students. Teachers or school administrators may also
                  provide us with a username and a password for each of the student accounts.
                
 
- 
              Vendors
              
                - 
                  We may use analytics providers to analyze how you interact and engage with the Services, or third
                  parties may help us provide you with customer support.
                
- 
                  We may use vendors to obtain information to generate leads and create user profiles.
                
 
- 
              Advertising Partners
              
                - 
                  We receive information about you from some of our vendors who assist us with marketing or promotional
                  services related to how you interact with our websites, applications, products, Services,
                  advertisements
                  or communications.
                
 
- 
              Social Networks
              
                - 
                  If you provide your social network account credentials to us or otherwise sign in to the Services
                  through a third-party site or service, some content and/or information in those accounts may be
                  transmitted into your account with us.
                
 
 
       
      
        How does the Company Use the Personal Data it Collects?
        Our Commercial or Business Purposes for Collecting Personal Data
        
        
          - 
            Providing, Customizing and Improving the Services
            
              - 
                Creating and managing your account or other user profiles.
              
- 
                Processing orders or other transactions; billing.
              
- 
                Providing you with the products, services or information you request.
              
- 
                Meeting or fulfilling the reason you provided the information to us.
              
- 
                Providing support and assistance for the Services.
              
- 
                Improving the Services, including testing, research, internal analytics and product development.
              
- 
                Personalizing the Services, website content and communications based on your preferences.
              
- 
                Doing fraud protection, security and debugging.
              
- 
                Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth
                in applicable data privacy laws, such as the California Consumer Privacy Act (the "CCPA").
              
 
- 
            Marketing the Services
            
              - 
                Marketing and selling the Services.
              
- 
                Advertising our products and services; measuring and improving the effectiveness of advertisements
              
 
- 
            Corresponding with You
            
              - 
                Responding to correspondence that we receive from you, contacting you when necessary or requested, and
                sending you information about SplashLearn or the Services.
              
- 
                Sending emails and other communications according to your preferences or that display content that we
                think will interest you including reports, new features and promotional offers.
              
 
- 
            Meeting Legal Requirements and Enforcing Legal Terms
            
              - 
                Fulfilling our legal obligations under applicable law, regulation, court order or other legal process,
                such as preventing, detecting and investigating security incidents and potentially illegal or prohibited
                activities.
              
- 
                Protecting the rights, property or safety of you, SplashLearn or another party.
              
- 
                Enforcing any agreements with you.
              
- 
                Responding to claims that any posting or other content violates third-party rights.
              
- 
                Resolving disputes.
              
 
          We will not collect additional categories of Personal Data or use the Personal Data we collected for
          materially
          different, unrelated or incompatible purposes without providing you notice.
        
       
      
        Will the Company Share any of the Personal Data it Collects?
        Your Personal Data and Child User's Personal Data is an integral part of our business. We neither rent nor sell
        your Personal Data or Child User Personal Data to anyone. We share your Personal Data and Child User Personal
        Data only as described below. We never share that Child User's Personal Data with any third party other than
        service providers. Usage data (i.e. performance on tests, games, etc. available on the Services) is shared
        through aggregated, anonymous comparisons, but never in a way that could personally identify a user. In
        addition, we do not offer students chat rooms or community features that allow the sharing or posting of Child
        User's Personal Data in a public forum.
        
          We employ APIs of other companies and people to perform tasks on our behalf and may need to share your
          information with them, including Personal Data or Child User's Personal Data, to provide products or services
          to
          you. Examples include sending billing receipts and weekly progress reports and providing user services. Unless
          we tell you differently, these companies do not have any right to use Personal Data or Child User's Personal
          Data we share with them beyond what is necessary to execute tasks at hand. We will also require that these
          companies agree to protect the security of the information we share with them. For any privacy inquiries
          related
          to how these companies may handle your information on our behalf, please use the contact information of
          SplashLearn at the bottom of this page, and we will respond to all such inquiries.
        
        
          We disclose your information to the categories of service providers and other parties listed in this section.
          For more information, please refer to the state-specific sections below.
        
        
          Service Providers: These parties help us provide the Services or perform business functions
          on
          our behalf. They include:
          
            - Hosting, technology and communication providers.
- Security and fraud prevention consultants.
- Support and customer service vendors.
- Product fulfillment and delivery providers.
- Payment processors.
              
                - 
                  Our payment processing partners, PayPal, Inc. ("PayPal") and Stripe, Inc. ("Stripe"), collect your
                  voluntarily-provided payment card information necessary to process your payment.
                
- 
                  Apple Pay and Google Pay are available as payment methods through our integration with Stripe. When you use these services, both the wallet provider (Apple or Google) and Stripe may process your information according to their respective privacy policies. Your actual card details are not shared with us. The specific processing entities may vary based on your geographic location and jurisdiction.
                
- 
                  Please see terms of service and privacy policies of Stripe, PayPal, Apple and Google for information on their use and
                  storage
                  of your Personal Data.
                
 
 
        
          Analytics Partners: These parties provide analytics on web traffic or usage of the Services.
          They include:
          
            - Companies that track how users found or were referred to the Services.
- Companies that track how users interact with the Services.
 
        
          Advertising Partners: These parties help us market our services and provide you with other
          offers that may be of interest to you. They include:
          
            - Ad networks.
- Marketing providers.
 
        
          Parties You Authorize, Access or Authenticate
          
            - Third parties you access through the services.
- Social media services.
- Other users.
Here
          is the list of partners that we work with.
        
 
        
          Sharing with Affiliated Businesses and Business Transfers
          Over time, SplashLearn may grow and reorganize. We may share your information, including Personal Data and
          Child
          User's Personal Data with affiliates such as a parent company, subsidiaries, joint venture partners or other
          companies that we control or that are under common control with us, in which case we will require those
          companies to agree to use your Personal Data and Child User's Personal Data in a way that is consistent with
          this Privacy Policy.
        
 
        
          In the event that SplashLearn is involved in a merger, reorganization, dissolution, sale of business or assets
          or similar event, information disclosed to or collected by may be transferred to SplashLearn's successor, or
          to
          the purchaser of such assets, as applicable. We will notify you within thirty (30) days following the
          completion
          of such a transaction via email and a prominent notice on our Website of any change in ownership or uses of
          your
          Personal Data, as well as any choices you may have regarding your Personal Data.
        
        
          Promotional Offers
          We may send offers to you on behalf of other businesses. However, when we do so, we do not give the other
          business your name and address and such communications will not be sent to Child Users. If you do not wish to
          receive these offers, please unsubscribe using the instructions provided in the email, the account management
          tools on the website, or by sending an email with your request to 
help@splashlearn.com
         
        
          Legal Obligations
          We may share any Personal Data or Child User Personal Data that we collect with third parties in conjunction
          with any of the activities set forth under "Meeting Legal Requirements and Enforcing Legal Terms" in the "Our
          Commercial or Business Purposes for Collecting Personal Data" section above.
        
 
        
          Protection of Company and Others
          We may release Personal Data or Child User Personal Data to protect the rights, property, or safety of the
          Company, our employees, our users, or others. This includes, in the case of Personal Data, exchanging
          information with other companies and organizations for fraud protection and credit risk reduction.
        
 
        
          Data that is Not Personal Data
          We may create aggregated, de-identified or anonymized data from the Personal Data and Child User Personal Data
          we collect, including by removing information that makes the data personally identifiable to a particular user
          ("Anonymized Data"). We may use such Anonymized Data and share it with third parties for our lawful business
          purposes, including to analyze, build and improve the Services and promote our business, provided that we will
          not share such data in a manner that could identify the user.
        
 
       
      
        Is Personal Data and Child User Personal Data Secure?
        The security of your Personal Data and Child User Personal Data is important to us. To prevent unauthorized
        access, disclosure, or improper use of your information, and to maintain data accuracy, we've established
        physical, technical, and administrative safeguards to protect the Personal Data and Child User Personal Data we
        collect. In particular:
        
          -  We periodically review our information collection, storage and processing practices, including physical
            security measures, to guard against unauthorized access to systems.
-  We perform application security testing; penetration testing; conduct risk assessments; and monitor
            compliance with security policies.
-  When you enter any information anywhere on the Service, we encrypt the transmission of that information
            using secure socket layer technology (SSL) by default.
-  SplashLearn's database where we store your Personal Data and Child User Personal Data is encrypted at
            rest, which converts all Personal Data or Child User Personal Data stored in the database to an
            unintelligible form.
-  We ensure passwords are stored and transferred securely using encryption and salted hashing.
-  SplashLearn's Website and the Service is hosted by third-party
              service providers at separate facilities, with whom we have a contract providing for enhanced security
            measures.
-  We restrict access to Personal Data and Child User Personal Data to authorized SplashLearn employees,
            agents or independent contractors who need to know that information in order to process it for us, and who
            are subject to strict confidentiality obligations and may be disciplined or terminated if they fail to meet
            these obligations.
          Company endeavors to protect user information to ensure that user account information is kept private,
          however,
          Company cannot guarantee the security of user account information. Your Personal Data or Child User Personal
          Data is protected by a password for your privacy and security. You need to ensure that there is no
          unauthorized
          access to your account and Personal Data or Child User Personal Data 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.
        
        
          Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of
          user
          information at any time. The website contains links to other sites. Company is not responsible for the privacy
          policies and/or practices on other sites. When linking to another site you should read the privacy policy
          stated
          on that site. This Privacy Policy only governs information collected on the Services. Please be aware that
          whenever you voluntarily post information to public areas on the Services or any other public forums, such
          information can be accessed by the public.
        
        
          If SplashLearn becomes aware of a systems security breach by an unauthorized party or that any user data was
          used for an unauthorized purpose, we will comply with relevant state and other data breach laws. We will
          notify
          users of any breach resulting in unauthorized release of data electronically, at minimum, and without
          unreasonable delay so that you can take appropriate steps. The notification will include: date of the breach,
          the types of information that were subject to the breach, general description of what occurred and steps
          SplashLearn is taking to address the breach.
        
       
      
        Data Deletion & Retention
        We store your Personal Data or Child User Personal Data for as long as it is necessary to provide products and
        Services, including those described above. When establishing a retention period for specific categories of data,
        we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data,
        and the sensitivity of the Personal Data. Personal Data or Child User Personal Data associated with your account
        will be kept until your account is deleted unless we no longer need the data to provide products and Services.
        
          Please note that we may have to retain some information after your account is deleted, to comply with legal
          obligations, to protect the safety and security of our community or our Service, or to prevent abuse of our
          Terms. We may further retain information in an anonymous or aggregated form where that information would not
          identify an individual personally.
        
        
          Deleting Your Account
          You have the right to ask us to delete your account at any time. You can do so by contacting us at 
help@splashlearn.com. In case a Parent wants to get a student's
          classroom account deleted, please contact the student's school.
        
 
        
          What happens when an account is deleted: SplashLearn de-identifies or deletes any Personal
          Data
          tied to the accounts, including emails, usernames, device token, device identifiers, IP addresses. Some
          information may persist in backups that we maintain, for a reasonable amount of time. SplashLearn retains
          de-identified usage information about the accounts unless we contractually obligated to delete such
          information.
        
        
          When a teacher or school administrator deletes an account from within their SplashLearn dashboard, the deleted
          accounts are kept in a recoverable state for 14 days before the deletion actually takes place. This is done so
          that any erroneous deletions on the user's part can be recovered and accounts may be restored.
        
        
          Please note that after an account is deleted from our systems, it is not possible for us to restore the
          account
          or any Personal Data or Child User Personal Data associated with it.
        
        
          For details on our retention policy around Child User Personal Data and associated adult users' Personal Data
          please refer to the "Data Deletion and Retention" section in the 
Child User Privacy Policy
         
      
        Communication Choices
        During the time that you use the Services, you will receive emails from us, which includes emails around new
        features and updates, practice reports and reminders, promotional offers and account related emails. Such
        communications will not be sent to Child Users.
        
          You may opt-out from receiving emails from within your SplashLearn account, or by using unsubscribe links
          included in the emails themselves. Opting out from certain types of emails may prevent us from providing you
          key
          portions of the services, such as providing progress reports that explain your child's performance and
          progress
          using the Services.
        
        
          Please note even if you subscribe, we will still need to send certain essential emails while you have an
          account
          with us. These may include payment related emails, important legal or security related updates.
        
       
      
        State Law Privacy Rights
        If you reside in certain U.S. states such as California, Colorado, Connecticut, Delaware, Iowa, Montana,
        Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia you may have certain rights afforded to
        you (as described below) depending on your state of residence. Please see the 'Exercising Your Rights under U.S.
        State Privacy Laws' section below for instructions regarding how to exercise these rights. Please note that your
        rights may be subject to certain conditions or exceptions in accordance with applicable U.S. State Privacy Laws.
        
          If you have any questions about this section or whether any of the following rights apply to you, please
          contact
          us at 
help@splashlearn.com.
        
          Access: You may have the right to request confirmation of or access to the Personal Data that
          we process about you. You can also request access to a portable copy of your Personal Data. If you are an
          Oregon
          resident, you also have the right to request a list of specific third parties, other than natural persons, to
          which we have disclosed your Personal Data.
        
        
          Deletion: You may have the right to request that we delete the Personal Data that we have
          collected about you.
        
        
          Correction: You may have the right to request that we correct any inaccurate Personal Data we
          have collected about you.
        
        
          Portability: You may have the right to request a copy of your Personal Data in a
          machine-readable format, to the extent technically feasible.
        
        
          "Selling," "Sharing," or "Targeted Advertising"
          As described in the "Cookies" section above, certain Cookies placed by third parties into our Services may
          allow
          those third parties to collect your Personal Data for measuring effectiveness of advertising campaigns and/or
          targeted advertising purposes. Under certain U.S. State Privacy Laws, this may constitute a "sale" and/or
          "share" of your Personal Data.
        
 
        
          You have the right to opt-out of the sale or share of your Personal Data by following the instructions in the
          "Exercising Your Rights under U.S. State Privacy Laws" section. Once you have submitted an opt-out request, we
          will not ask you to reauthorize the sale of your Personal Data for at least 12 months.
        
        
          We sell or share your Personal Data to the following categories of third parties:
          
          Over the past 12 months, we have sold or shared the following categories of Personal Data to categories of
          third
          parties listed above:
          
            - Device/IP Data
- Web Analytics
          For clarity, we do not sell or share Child User Personal Data. For more detail regarding our processing of
          such
          data, please see our 
Child User Privacy
            Policy.
        
          Processing of Sensitive Personal Data
          The Personal Data of Child Users may be deemed "sensitive" under certain U.S. State Privacy Laws ("Sensitive
          Personal Data"). For more detail regarding our processing of such data, please see our 
Child User Privacy Policy.
        
 
        
          Anti-Discrimination
          We will not discriminate against you for exercising your rights under applicable privacy laws. We will not
          deny
          you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and
          services if you exercise your rights under applicable privacy laws. However, we may offer different tiers of
          our
          Services as allowed by applicable data privacy laws with varying prices, rates or levels of quality of the
          goods
          or services you receive related to the value of Personal Data that we receive from you.
        
 
        
          Other State-Specific Privacy Rights
          Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to
          prevent
          disclosure of Personal Data to third parties for such third parties' direct marketing purposes; We do not
          disclose Personal Data to third parties for their direct marketing purposes as defined under California Civil
          Code Sections 1798.83-1798.84. If you would like to learn more, please contact us at 
help@splashlearn.com.
        
 
        
          If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third
          parties. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised
          Statutes Chapter 603A.
        
        
          Exercising Your Rights under U.S. State Privacy Laws
          To exercise the rights described in this Privacy Policy, you or your Authorized Agent (if applicable and as
          defined below), must send us a request that (1) provides sufficient information to allow us to verify that you
          are the person about whom we have collected Personal Data (such as your Contact or Profile Data), and (2)
          describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each
          request
          that meets both of these criteria will be considered a "Valid Request." We may not respond to requests that do
          not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity
          and
          complete your request. You do not need an account to submit a Valid Request.
        
 
        
          We will work to respond to your Valid Request within the time period required by applicable privacy laws. We
          will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or
          manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee
          and
          explain that decision before completing your request.
        
        
          Request to Opt-Out of Sale, Share, and/or Targeted Advertising
          As applicable, you may opt-out from any "sales," "shares," or targeted advertising through Cookies, by using
          the
          following methods:
          
            - By accessing your Cookie consent mechanism by accessing your "Cookie Settings" at the bottom left of our
              website.
- By implementing the Global Privacy Control or similar universal privacy control that is legally
              recognized
              by a government agency or industry standard and that complies with applicable State Privacy Laws. The
              signal
              issued by the control must be initiated by your browser and applies to the specific device and browser you
              use at the time you cast the signal. Please note this does not include Do Not Track signals.
 
        
          Request to Access, Delete, Correct
          As applicable, you may submit a Valid Request for your right to access, delete, correct, or obtain a copy of
          your Personal Data described in this Privacy Policy by using the following methods:
          
         
        
          If you are a California, Colorado, Connecticut, Delaware, Montana, Nebraska, New Hampshire, New Jersey,
          Oregon,
          or Texas resident, you may also authorize an agent (an "Authorized Agent") to exercise your rights on your
          behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on
          your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a
          request on your behalf.
        
        
          Appealing a Denial
          If you are a Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon,
          Texas,
          or Virginia resident and we refuse to take action on your request within a reasonable period of time after
          receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must
          (1) provide sufficient information to allow us to verify that you are the person about whom the original
          request
          pertains and to identify the original request, and (2) provide a description of the basis of your appeal.
          Please
          note that your appeal will be subject to your rights and obligations afforded to you under the State Privacy
          Laws (as applicable). We will respond to your appeal within the time period required under the applicable law.
          You can submit a Verified Request to appeal by the following methods:
          
         
        
          If we deny your appeal, you have the right to contact the Attorney General of your State.
        
       
      
        European Union Data Subject Rights
        EU Residents
        If you are a resident of the European Union ("EU"), United Kingdom, Lichtenstein, Norway or Iceland, you may
        have additional rights under the EU General Data Protection Regulation (the "GDPR") with respect to your
        Personal Data, as outlined below.
        
          For this section, we use the terms "Personal Data" and "processing" as they are defined in the GDPR, but
          "Personal Data" generally means information that can be used to individually identify a person, and
          "processing"
          generally covers actions that can be performed in connection with data such as collection, use, storage and
          disclosure, and includes Child User Personal Data.
        
        
          SplashLearn will be the controller of your Personal Data processed in connection with the Services. Note that
          we
          may also process Personal Data of our customers' end users or employees in connection with our provision of
          certain services to customers (e.g. educational institutions) , in which case we are the processor of Personal
          Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller
          party in the first instance to address your rights with respect to such data.
        
        
          If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or
          portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any
          questions about this section or whether any of the following applies to you, please contact us at 
help@splashlearn.com.
        
          Personal Data We Collect
          The "What Personal Data Does Company Collect" section above details the Personal Data that we collect from
          you.
        
 
        
          Personal Data Use and Processing Grounds
          The "How does the Company Use the Information it Collects" section above explains how we use your Personal
          Data.
        
 
        
          Sharing Personal Data
          The "Will Company Share any of the Information it Receives" section above details how we share your Personal
          Data with third parties.
        
 
        
          EU Data Subject Rights
          You have certain rights with respect to your Personal Data, including those set forth below. For more
          information about these rights, or to submit a request, please email us at 
help@splashlearn.com.
        
 
        
          If any request made under this section is clearly unfounded or excessive, we may reject the request or require
          a
          reasonable fee to honor the request. Additionally, we may not be able fully comply with your request if it
          jeopardizes the rights of others, or if it is not required by law, If we decide to reject your request, we
          will
          inform you of the reasons for not taking action and provide information on other possible remedies. If we
          decide
          that a reasonable fee is necessary, we will promptly inform you and will comply with the request upon receipt
          of
          this fee.
        
        
          In some cases, we may also need you to provide us with additional information, which may include Personal
          Data,
          if necessary to verify your identity and the nature of your request.
        
        
          We will respond to all requests within a reasonable timeframe. If our full response will ever take more than a
          month due to complexity or scope, we will notify you of this and keep you updated.
        
        
          Review and update your data: You have the right to access and update any personal data that
          we
          have collected. Some personal data, such as the account holder's name and email address can be found and
          updated
          using the account management tools on our website at . For any
          personal
          data beyond this, please submit a request using the contact information at the end of this section.
        
        
          Delete your data: You also have the right to get your personal data deleted. This is
          sometimes
          known as the 'right to be forgotten'. To request that we delete all personal data about you, please submit a
          request using the contact information at the end of this section.
        
        
          For more information on our data deletion and retention practice from the section on "Data Deletion and
          Retention"
        
        
          Restrict Processing: You have the right to restrict how we process your personal data in
          certain circumstances. This is an alternative to requesting the deletion of your data. Rather than requesting
          we
          delete all of your personal data, you may request that we limit our uses of your personal data to specific
          purposes. You may wish to request we restrict our processing if you contest the accuracy of your personal data
          and we are working to verify this information, or if you want us to retain your personal data in connection to
          a
          legal claim but cease processing it.
        
        
          Withdrawal of Consent: If we are processing your personal data based on your consent (as
          indicated at the time of collection of such data), you have the right to withdraw your consent at any time.
          Please note, however, that if you exercise this right, you may have to then provide express consent on a
          case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is
          necessary to enable you to utilize some or all of our Services.
        
        
          Data Portability: You have the right to obtain copies of your information in a structured,
          commonly used format so that you can move your data between our service and the services of others. We may
          request more information to confirm your identity before providing any personal data.
        
        
          Right to Object: You have the right to object to the processing of your personal data for
          direct marketing purposes or when our processing of your data is based on legitimate interests. You may
          request
          that we stop processing your personal data for direct marketing purposes. This is an absolute right and we
          cannot refuse this request. Beyond direct marketing, if you wish to exercise this right, you must give
          specific
          reasons as to why you object to our processing of your data, based on your particular situation. Even after
          receiving such a request, we may continue processing if it is necessary for the exercise/defense of a legal
          claim or if we can demonstrate a compelling legitimate ground for the processing.
        
        
          Right to File Complaint: You have the right to lodge a complaint about SplashLearn's
          practices
          with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list
          of
          Supervisory Authorities is available here:
          
          
https://edpb.europa.eu/about-edpb/board/members_en
         
        
          Lawful Bases for Processing Personal Data:
          If you are an individual in the European Union (EU) or an EU citizen, we collect and process data about you
          only
          where we have legal bases for doing so under applicable EU laws. This means we collect and process your data
          only when:
          
            - It is necessary for a legitimate interest (which is not overridden by your individual privacy
              interests),
              such as preventing fraud, improving the Services, and increasing the security of the Services and network
              infrastructure;
- You have consented to this collection and processing for a specific purpose;
- It is necessary to fulfil our contractual obligations; or
- It is necessary to comply with a legal obligation.
 
        
          Some examples of our legitimate interests and the data being processed include:
          
            - Network and information security (password, IP address, Device ID)
- Customer Support, and fraud prevention (name, email address)
- Improving our products and services (device hardware information, activity logs)
          Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent
          at any time. If you wish to withdraw your consent, please contact us using the information in the Contact for
          Individual Rights Requests section.
        
        
          Where we rely on our legitimate interests to process your personal data, you have the right to object. More
          information on exercising this right can be found in the EU Data Subject Rights section.
        
        
          If you have any questions about or need further information concerning the legal basis on which we collect and
          use your personal data, please contact us at 
help@splashlearn.com
        
          Contact for Individual Rights Requests
          Please use the below information when submitting a request to exercise any of the above rights. Please do not
          submit requests across multiple communication channels. We will make all efforts to respond to your request
          within a reasonable timeframe.
          
          Email: 
compliance@splashlearn.com
          
          Physical Mail:
          
          StudyPad, Inc.
          
          Attn: Joy Deep Nath
          
          548 Market, St #64304
          
          San Francisco CA – 94104
          
        
 
        
          Representative for data subjects in the EU and UK
          
          ​​We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its
          local partners as our privacy representative and your point of contact for the European Union (EU) and United
          Kingdom (UK).
          
          Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase
          personal data). If you want to contact us via our representative, Prighter or make use of your data subject
          rights, please visit the following website: 
            https://prighter.com/q/17025404
         
        
          International / Cross Border Data Transfers
          The Services are hosted and operated in the United States ("U.S.") through SplashLearn and its service
          providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside.
          By
          using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or
          obtained from a third party, is being provided to SplashLearn in the U.S. and will be hosted on U.S. servers,
          and you authorize SplashLearn to transfer, store and process your information to and in the U.S., and possibly
          other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data
          processing agreement incorporating standard data protection clauses or in reliance on the EU-U.S. Data Privacy
          Framework ("EU-U.S. DPF") the UK Extension to the EU-U.S. DPF ("UK-U.S. DPF"), and the Swiss-U.S. Data Privacy
          Framework ("Swiss-U.S. DPF").
        
 
        
          EU-U.S. DPF Swiss – U.S. DPF and UK-U.S. DPF
          
          SplashLearn complies with the EU-U.S. DPF, the UK-U.S. DPF, and Swiss-U.S. Data DPF (collectively, the "DPF")
          as
          set forth by the U.S. Department of Commerce. SplashLearn has certified to the U.S. Department of Commerce
          that
          it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the
          processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the
          United
          Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. SplashLearn has certified to the
          U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S.
          DPF
          Principles) with regard to the processing of personal data received from Switzerland in reliance on the
          Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF
          Principles
          and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy
          Framework (DPF) program, and to view our certification, please visit 
https://www.dataprivacyframework.gov/.
        
 
        
          The Federal Trade Commission has jurisdiction over SplashLearn's compliance with the DPF. This Privacy Policy
          describes the types of Personal Data we collect, the purposes for which we collect and use your Personal Data,
          and the purposes for which we disclose your Personal Data to certain types of third parties in the sections
          above. Pursuant to the DPF, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether
          we maintain Personal Data relating to you in the U.S. Upon request, we will provide you with access to the
          Personal Data that we hold about you. You may also correct, amend, or delete the Personal Data we hold about
          you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to
          the U.S. under DPF, should direct their query to 
compliance@splashlearn.com. If requested to remove data, we
          will
          respond within a reasonable timeframe. For more information about rights afforded to you, please see the
          European Union Data Subject Rights Section of the Privacy Policy.
        
          In addition, we will provide you with the choice to opt-out from the sharing of your Personal Data with any
          third parties (other than our agents or those that act on our behalf or under our instruction), or before we
          use
          it for a purpose that is materially different from the purpose for which it was originally collected or
          subsequently authorized.
        
        
          We will provide you with the choice to opt-in to sharing your sensitive Personal Data with any third parties
          or
          if we plan to process your Personal Data for a purpose other than those for which it was originally collected
          or
          subsequently authorized. To request to limit the use and disclosure of your Personal Data, please submit a
          written request to 
compliance@splashlearn.com.
        
          In addition to any other disclosures described in our Privacy Policy, in certain situations, SplashLearn may
          be
          required to disclose personal data in response to lawful requests by public authorities, including to meet
          national security or law enforcement requirements.
        
        
          SplashLearn is responsible for the processing of personal data it receives, under the DPF Programs , and
          subsequently transfers to third-parties acting as an agent on its behalf SplashLearn complies with the DPF
          Principles for all onward transfers of personal information from the EU, UK and Switzerland, including the
          onward transfer liability provisions. In particular, SplashLearn remains liable under the DPF Principles if
          our
          agents process Personal Data in a manner inconsistent with the DPF Principles, unless SplashLearn proves that
          we
          are not responsible for the event giving rise to the damage.
        
        
          With respect to personal data received or transferred pursuant to the DPF Programs, SplashLearn is subject to
          the jurisdiction and regulatory enforcement powers of the U.S. Federal Trade Commission and other authorized
          statutory bodies. In certain situations, SplashLearn commits to resolve DPF Principles-related complaints
          about
          the collection and use of your personal data. EU, UK and Swiss individuals with inquiries or complaints
          regarding our handling of personal data received in reliance on the DPF Programs should contact us at 
compliance@splashlearn.com. In compliance with the EU-U.S. DPF,
          the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, SplashLearn commits to refer unresolved complaints
          concerning our handling of personal data received in reliance on the DPF Programs to BBB National Programs, an
          alternative dispute resolution provider based in the United States. If you do not receive timely
          acknowledgment
          of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related
          complaint to your satisfaction, please visit 
            www.bbbprograms.org/dpf-complaints  for more information or to file a complaint. The services of BBB
          National Programs are provided at no cost to you.
        
          Cross-Border Transfers other than to the United States
          Personal data may be accessed by our personnel in India for the purpose of providing services. In such
          instances, we use Standard Contract Clauses approved by the European Commission to protect personal data. If
          you
          have queries, please contact us using the contact information mentioned at the end of the document.
        
 
       
      
        Changes to this Privacy Policy
        Company may revise this Privacy Policy from time to time. Use of information we collect is subject to the
        Privacy Policy in effect at the time such information is used.
        
          If we make material changes in the way we use Personal Data or Child User Personal Data, we will notify you by
          posting an announcement on our Services, or by email and, if necessary, obtain prior verifiable parental
          consent.
        
        
          Schools signed up for a membership will be notified in advance of any material changes to privacy policies,
          including practices around new or additional data collection, or new ways of using the data that may lessen
          your
          privacy and rights.
        
        
          We encourage you to review this Privacy Policy from time to time, to stay informed about our collection, use,
          and disclosure of Personal Data through the Service. If you don't agree with any changes to the Privacy
          Policy,
          you may terminate your account. By continuing to use the Service after the revised Privacy Policy has become
          effective, you acknowledge that you accept and agree to the current version of the Privacy Policy.
        
       
      
        
          Questions or Concerns
        
        If you have any questions or concerns regarding privacy on our Services, please send us a detailed email at
          compliance@splashlearn.com. We will make every effort to
          resolve your concerns.
        
        
          STUDYPAD, INC.
          201 Spear Street, Suite 1100
          San Francisco, California 94105
          Phone: +1 855 979 8948
        
       
      
        For data subjects in the EU, Prighter Group with its local partners has been appointed as our representative. If
        you want to make use of your data privacy rights, please visit:
 https://prighter.com/q/17025404
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