COPPA Privacy Policy

CARSON DELLOSA EDUCATION SUMMER BRIDGE ACTIVITIES®
COPPA PRIVACY POLICY

Last Updated and Effective as of May 8, 2023.

This COPPA Privacy Policy (“Privacy Policy”) relates and applies to our Summer Bridge Activities mobile application (the “App”). We at Carson-Dellosa Publishing, LLC, which sometimes does business as Carson Dellosa Education (“Carson Dellosa Education,” “we,” “us,” or “our”) created this Privacy Policy because we know that you care about how information provided to us is used and shared. This Privacy Policy relates and applies to the information collection and use practices of Carson Dellosa Education in connection with the App and the services offered through the App (the “Services”) which are made available to children under the age of 13 situated in the United States.

We strive to educate parents and children about how to appropriately safeguard their privacy when using the App or our Services. We are committed to complying with the Children’s Online Privacy Protection Act of 1998 (“COPPA”), which requires us to inform parents and legal guardians about our information collection and use practices. COPPA also requires that we obtain parental consent before we allow children under the age of 13 to access and/or use our App or Services. We urge children to check with their parents/guardians before entering any information through our App and/or Services, and we recommend that parents discuss with their children restrictions regarding the online release of Personal Information (as defined below) to anyone they don’t know.

By visiting our App and/or using our App or Services, or by permitting your child to visit our App use our App or Services, you are agreeing to the terms of this Privacy Policy and the Summer Bridge Activities® Mobile Application End User License Agreement (also referred to as “EULA”). Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our EULA if defined therein.

Definitions

• "Child" (or “Children”) means a user (or users) under the age of 13.
• The “App” means Carson Dellosa Education’s Summer Bridge Activities mobile application.
• “Parent” means a parent or legal guardian of a Child or Children.
• “You” or “your” means and refers to you if you are not a Child, and to both you and your Child if you are a Parent.

Information We Collect.

Personal Information

We do not knowingly collect any Personal Information from you unless you voluntarily provide it to us.

When someone signs up to become a user of the App (a “User”), they will be asked to provide us with certain personal information, such as their first name, last name, and email address. In this Privacy Policy, we refer to this information, as well as other information discussed below, as “Personal Information.” Other than the online contact information required to obtain parental consent, we do not collect any information that is considered Personal Information from Users under the age of 13 unless the User’s Parent has first provided us with consent for that User to use the Services and disclose Personal Information to us. (Likewise, if you are not a Child and sign up to become a User, you will be asked to provide us with certain Personal Information, such as first name, last name, and email address.) If you are a Child, please do not send any Personal Information to us if we have not obtained prior consent from your Parent. If we learn we have collected Personal Information from a Child without Parental consent, or if we learn a Child has provided us Personal Information beyond what we request from him or her, we will endeavor to delete that information as quickly as possible or assist you in deleting that information. If you believe that a Child may have provided us Personal Information in violation of this Privacy Policy, please contact us at sba.app@carsondellosa.com.

We may collect from you the following categories of “Personal information” that you choose to provide us through the App or Services:

• Your email address
• Your first and last name
• Your Username
• Your school grade for the current and/or upcoming school year
• Your mobile device’s Persistent Identifiers (see Usage Information)

Usage Information

When you use our App or Services we record and collect information that identifies your device, to track your use of our services and to collect certain basic information about you. This information includes information about your operating system, your IP addresses, unique device numbers, referring URLS, keywords, date and time, the amount of time you spent on the App or Services, what sections of the App or Services you visit, your user id, username, email, password hash, user sub-account name, grade, device information such as ID, model, OS, and brand, as well as user interactions, performance metrics, and other similar information concerning your use of the App and the Services (the “Usage Information”).

We collect this Usage Information by using cookies and pixel tags (also called web beacons or clear gifs). Cookies are small packets of data that an App stores so that your App will “remember” information about your visit. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of App users. You can reject cookies by following the directions provided in your Internet provider’s “help” file. If you reject cookies, you may still visit the App, but may not be able to use some areas of the App and/or the Services.

We do not collect Personal Information in this way, but if you have provided us with Personal Information, we may associate that information with the information that is collected automatically. Automatic data collection also may be performed on our behalf by our services providers.

How We Use Your Information.

We may use your Personal Information and Usage Information in a manner that is consistent with this Privacy Policy and the context of our relationship with you. We will use your Personal Information and Usage Information collected through the App for the following purposes:

1. To identify you when you sign in to your account;
2. To respond to your requests and to provide you with the Services (such as the games and activities available for play);
3. To respond to your inquiries and contact you about changes to the App and/or the Services;
4. To send you notices (for example, in the form of e-mails, mailings, and the like) regarding products or services you are receiving, and for billing and collection purposes;
5. To send you information we think you may find useful or that you have requested from us;
6. To enhance and improve the App or the Services, such as through personalized features and content;
7. To analyze the use of the App and the Services and the people visiting to improve our content and App and the Services;
8. As necessary for business interests (such as when we collect and use a Child's data in support of internal operations, taking into account the impact on the Child's privacy);
9. To comply with the law (such as when we use Personal Information for record-keeping to satisfy legal and compliance obligations), and to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required by law;
10. For any other purposes disclosed at the time the information is collected or to which you consent; and
11. As otherwise specifically described in this Privacy Policy.

Disclosure of Personal Information to Third Parties.

We do not disclose your Personal Information to third parties for their direct marketing purposes.

We, like many businesses, sometimes hire other companies to perform certain business-related functions. Examples include but are not limited to mailing information, maintaining databases, hosting services, and processing payments. When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function(s), which may include Personal Information.

If we or all or substantially all of our assets are acquired, we expect that the information that we have collected, including Personal Information, would be transferred along with our other business assets.

We may disclose your Personal Information and Usage Information to government authorities and to other third parties when compelled to do so by government authorities, at our discretion, or otherwise as required by law, including but not limited to in response to court orders and subpoenas. We may also disclose your Personal Information and Usage Information when we have reason to believe that someone is or may be causing injury to or interference with our rights or property, other users of the App, or anyone else that could be harmed by such activities.

How We Protect Your Information.

We endeavor to take commercially reasonable steps to protect the Personal Information and Usage Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mails sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Accessing and Modifying Account Information; Deleting Your Account.

You may update the information that is stored in your user account by e-mailing us at sba.app@carsondellosa.com.

You may also delete your account within the App by following these steps:

1. Go to the Roadmap.
2. Click the avatar in the top right corner.
3. Click "Parent Access."
4. Enter your” Password."
5. Select " Delete Account."
6. Click "CONFIRM."

We strive to help parents ensure that their children have a safe experience using the App or our Services. Parents can review any Personal Information collected about their Child and have this information deleted. We take steps to verify the identity of anyone requesting information about a Child and to ensure that that person is in fact the Child’s parent or legal guardian.

Your Choices.

If you wish to stop receiving promotional e-mails, you may do so by e-mailing sba.app@carsondellosa.com. You may also choose to unsubscribe from our emails by following the instructions in the bottom of the email.

Links.

The App may contain content, services, and other materials that link to websites operated by third parties. We have no control over those other sites, and this Privacy Policy does not apply to them. Please refer to the privacy policies of those sites for more information on how the operators of those sites collect and use your Personal Information.

Specific Disclosures for California Residents.

Under California Civil Code Section 1798.83, California residents who have an established business relationship with us may choose to opt out of our sharing their contact information with third parties for direct marketing purposes. If you are a California resident and you wish to opt out, please send an e-mail to sba.app@carsondellosa.com.

We do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have the right to know what Personal Information has been collected from them in the last 12 months and to ask for it to be deleted. Also under the CCPA, parent or guardian permission is required to sell Personal Information. We do not sell Personal Information. We also do not give Personal Information to third parties for their direct marketing purposes.

Data Processing in the United States.

Information provided to or collected by us on the App or through the Services is transmitted to us and processed in the United States and other countries, either by us or our service providers on our behalf, and will be protected subject to this Privacy Policy and applicable laws, which may not be as protective as the laws in other countries.

Important Notice to Users Outside the U.S.

The App and the Services are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By providing us with any information through the App or the Services, you consent to this transfer.

Changes to This Privacy Policy.

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time and will post any changes on the App as soon as they go into effect. By accessing the App or using the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us.

If you have questions about this Privacy Policy, please e-mail us at sba.app@carsondellosa.com, “PRIVACY POLICY” in the subject line, or mail us at the following address: Carson Dellosa Education, PO Box 35665, Greensboro, NC, 27425.