Effective Date: June 18, 2020

Previous Privacy Policy: March 16, 2020

This Privacy Policy describes the ways in which Tijiko, Inc., and its subsidiaries (collectively, we, our, us, or the Company) collect, use, and disclose information about you and the children who use your account (Account), and any other websites, applications, and online services (Apps) that link to this policy (collectively, the Services).

Please read this Privacy Policy closely. By using the Services, you agree to the handling of your information in accordance with this Privacy Policy.

1. Account Users

Users of the Services include ChildUsers (any child under age 18 who uses the learning portion of the Services) and Adult Users (including parents and legal guardians of Child Users), collectively referred to as Users.

2. Information Collection

There are two general categories of information that we collect.

A.Information Users Provide to Us

As more fully set forth below, we and our third-party service providers collect information that Users provide when using the Services, including when Adult Users create an Account, sign up for Services, participate in customer surveys, enter into raffles or contests or or contact us with a question, comment, or request. We store information you provide through forms, surveys, raffles or online applications; however, we will only use or disclose this information in accordance with this policy and applicable law.

Adult Users must register for an account on behalf of the Child User. Adult Users are asked to provide certain Personal Information about themselves when registering for any Account, including first and last name and email address. Payment information is also collected from Adult Users who purchase an account. For your security, we do not store your complete credit card number in our databases but retain only the first six digits and last four digits so that we can identify your account and respond to your requests and questions.

If you submit any information relating to other people in connection with the Services, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.

B.Information We Collect from Users

We and our third-party service providers collect Personal Information directly from Users of the Services in the form of the actions they take and activities (or quests) they complete when using the Services. For example, from Adult Users, we may collect information about patterns of usage and order history; from Child Users, we may collect information about patterns of usage.

We and our third-party service providers also use a variety of technologies, such as cookies (small text files that the Services save on your computer or mobile device), to automatically collect certain technical information from your computer or mobile device over time and across different websites, including when you use the Services, such as your browser type, operating system, device type, the page served, your IP address, the approximate geographic region your computer or mobile device is located in, and the websites you visited prior to visiting the Services.

We and our third-party service providers may use the information collected through these technical methods for a number of purposes, including delivering content and tracking and enhancing our Users’ experience on the Services. For example, when you return to the Services after logging in, cookies help the Services recognize who you are without having to log back in. We do not allow third-party advertising networks to collect information about Users who are logged in to their Accounts.

What Are Cookies?

Cookies are small text files placed on your device to collect standard internet log information and visitor behavior information. The cookies may transmit information via your browser with a purpose of authenticating or identifying the computer (via, e.g., the IP address) or the User. Cookies may contain information such as registration data and User preferences.

We use Cookies to:

1. automatically collect certain technical information from your computer or mobile device over time and across different websites, including when you use the Services, such as your browser type, operating system, device type, the page served, your IP address and your geolocation; and;
2. collect and store information about your location to provide you with educational experiences or email updates that are tailored for your region. The location information we have access to may include (1) your postal code, if you provide one to us; and (2) the approximate geographic region your computer or mobile device is located in, as determined from your IP address. However, we do not collect your street name and the name of your city/town. You may be able to change the settings on your computer or mobile device to prevent it from providing us with such IP information.

When a server receives a request from a device which stores a cookie from a website, the server is able to use the information stored in the cookie in combination with the information stored on the server to allow the website to respond to you as an individual and to tailor their operations to your needs, likes, and dislikes by gathering and remembering information about your preferences. A cookie cannot collect information from your computer and cannot carry any viral or other damaging files.

Types of Cookies

We use the following cookies:

Essential Cookies

These cookies are essential to provide you with services available through Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Services and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies

These cookies allow us to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details, and remembering the changes you make to other parts of Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Services.

Analytics and Performance Cookies

These cookies are used to collect information about traffic to our Services and how users use the Services. The information gathered does not identify any individual visitor. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information, and to monitor the level of activity on our Services.

Social Media Cookies

These cookies are used when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter, or Google+. The social network will record that you have done this.

Except as otherwise provided in this policy, such as when a California resident has opted-out of our sharing Personal Information for valuable consideration, by continuing to use our Services, you are accepting our use of these cookies that make communications more relevant to you and your interests and further help us to improve our Services.

Pixel Tags and IFrames

We also use pixel tags (which are also known as web beacons and clear GIFs) on our Services to track the actions of Users on our Services. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on web pages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Services, so that we can manage our content more effectively.

We and our third-party service providers may use the information collected through these technical methods for a number of purposes, including delivering content and tracking and enhancing our Users’ experience on the Services. For example, when you return to the Services after logging in, cookies help the Services recognize who you are without having to log back in. The information collected through these technical methods on the child-directed portions of the Services are used only to support the internal operations of the Services. We do not allow third-party advertising networks to collect information about Child Users who are logged into their Accounts.

If you do not want the Services to collect information through the use of cookies, you can set your web browser to reject cookies from the Services. Each browser is different, so you should check your browser’s Help menu to learn how to change your cookie preferences. However, please note that if you reject or block cookies from the Services, the Services may not function as intended. For example, you will not be able to remain logged into your Account, and therefore you would have to log in during each page transition.

3. How We Use Information

We will never monetize the Personal Information of any User of the Services by providing it to a third party in exchange for money, except as described in this policy in the context of a sale of the Company.

We and our third-party service providers may use the information collected from Users as follows:

Adult User Information Information collected from Adult Users may be used:

• To permit you to register for and use the Services, including, for example, to send you communications about Child User progress or your Account, or to allow you to provide Feedback.
• To complete and fulfill your purchase, such as to process your payments, communicate with you regarding your purchase, and provide you with related customer service.
• To respond to your inquiries and fulfill your requests, retrieve your password, or provide technical support.
• To send you marketing communications that we believe may be of interest to you. While it is never our intention to send any marketing messages to children, if you believe a Child User has received such a marketing communication, please contact us as described in Section 12 (Contact Us) below. You can always choose to stop receiving these marketing messages by simply following the instructions contained in the message or, if the communication is by phone, informing the caller of your desire not to receive further phone communications. For all Accounts, you may not opt out of receiving administrative messages from us regarding your Account, such as password reset emails and customer support messages.

• To allow us to assess and improve the Services, its educational content, and other services we provide, for example, to improve our content and user experience; to research, evaluate, and improve the Services’ educational efficacy; and to inform our understanding of the Services’ user base.
• To customize, adapt, and personalize Users’ viewing and content-consumption experience.
• To maintain and analyze the functioning of the Services.
• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to detect violations of and enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates, including the security of the Services; (f) to protect our rights, privacy, safety, or property, or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain (collectively, (a)-(g) are Other Uses and Disclosures).

4. When We Disclose Information to Third Parties

Information collected from Users will not be disclosed except for the following purposes, which include our operations purposes:

• To third parties who perform certain services for us, such as process credit cards, or conduct or evaluate research (such as on the educational impact of the Services), provided that the service providers agree to keep the information confidential and to use it only for purposes that are permitted by this Privacy Policy.
• As we believe to be necessary or appropriate as set forth above in Other Uses and Disclosures and in other instances substantially similar to those listed in this Section.
• Where legally required and in certain other cases, we may make such disclosures without first providing notice to Users.
• Subject to confidentiality agreements, the terms of this Privacy Policy, and applicable law, information may be disclosed to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, transfer, or license all or a portion of our assets in bankruptcy or otherwise. This means that if some or all of our assets are acquired or otherwise transferred or licensed, including in bankruptcy, that such acquirer shall be subject to the same commitments stated under this Privacy Policy.

We do not disclose the Personal Information of any Child User to third parties for any marketing or promotional purposes. This also means that we do not share the Personal Information of children under the age of 16 for valuable consideration.

We also may disclose de-identified and/or aggregated User information for any other purpose as permissible by applicable law—for example, the distribution of de-identified User records to outside researchers or the distribution of reports containing aggregate User demographic and traffic patterns—provided that no individual Adult User or Child User or any specific end-user device can be readily identified.

5. How to Access, Change, or Delete Account Information

Adult Users may contact us at any time as described in Section 12 (Contact Us) below to request that we provide for their review, or delete from our records, any PI they have provided about Child Users associated with their Accounts, or to cease collecting PI from those Child Users, as applicable. Please keep in mind that a request to delete PI may lead to cancellation of your Account or the inability to use the Services or certain portions of the Services.

When we change or delete any PI at your request, we will make good faith efforts to make the changes in our then-active databases as soon as reasonably practicable, generally within 24–48 hours. Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules. Please note that information may remain in backup or archive records, and we may retain certain data relevant to preventing fraud or future abuse or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable or de-identified data, Account recovery, or if required by law. All retained data will continue to be subject to the Privacy Policy in effect at the time.

6. Account Cancellation and Reactivation; Data Deletion

At any time, Adult Users may cancel their Account(s. For Accounts that have been canceled, if the account remains inactive for 24 months, we will delete all PI in our active databases associated with the account (Account Information), unless otherwise stated in this Privacy Policy. The 24 months is provided so that you have the ability, following cancellation of an Account or inactivity, to reactivate your Account and potentially recover previous information and resume where the Child User left off. However, we provide no guarantee, and shall have no liability or obligation to ensure that all Account Information and Services-related progress will be available or accessible or all learning, or personalization features will be able to be recovered or resumed. If a User requests that PI be deleted prior to the end of the 24-month period of inactivity, we will take commercially reasonable steps to satisfy that request; provided, however, that if the User is a California resident the provisions of Section 8 below shall be followed.

Upon Account cancellation, de-identified User information may nonetheless persist internally in our archive files or similar databases, and may still be used, on a de-identified basis, for our internal support, administrative, and record-keeping purposes including, but not limited to, allowing us to improve the Services and other services we provide through research, evaluation, and analytics as permissible by applicable law.

Please note that following a request to delete information or your Account under Sections 5 or 6 of this Privacy Policy, information including PI may remain in backup or archive records, and we may retain certain data if required by law, relevant to preventing fraud or future abuse, or for legitimate business purposes, such as account recovery and customer support, and all subject to our internal records retention periods. All retained data will continue to be subject to the Privacy Policy in effect at that time and applicable law.

7. California Privacy Rights

Effective January 1, 2020, the CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. In this section “you” or “your” refers to California residents. Under the new law we are required to disclose the categories of sources from whom we collect personal information, and the third parties with whom we share it, which we have explained above. We are also required to communicate information about rights you have under California law, such as:

• Right to access Personal Information. You may be entitled to receive the specific pieces of your Personal Information we hold.
• Right to data portability. You may be entitled to receive a copy of your electronic Personal Information in a readily-usable format.
• Right to disclosure. You may be entitled to receive information regarding the categories of Personal Information we collected, the sources from which we collected Personal Information, the purposes for which we collected and shared Personal Information, the categories of Personal Information that we sold and the categories of third parties to whom the Personal Information was sold, and the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding your request.
• Right to deletion. You may be entitled to request that we delete the Personal Information that we have collected from you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws. Please note, however, that we may need or be required to keep such information, such as for our legitimate business purposes or to comply with applicable law.

We will never monetize the Personal Information of any User of the Services by providing it to a third party in exchange for money. The CCPA has a broader definition of the term “sell” which includes disclosing Personal Information to any third party for valuable consideration.

In addition, we are required to provide you certain information about the business and commercial purposes for which we collect and share your personal information.

We use and disclose the information we collect for the business purposes described in this policy, including but not limited to: process payments, conduct research, detect security incidents and prevent fraud, debug and repair errors, maintain your account, provide customer service, and other activities to improve our service, market our services, and understand how users interact with our services.

We use and disclose the information we collect for the following business purposes: enabling and affecting commercial transactions and advancing our commercial and economic interests.

Exercising Access, Disclosure, Data Portability, and Deletion Rights

To exercise the access, disclosure, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either contacting us as set forth in Section 12 (Contact Us) below, or by visiting:

• Privacy Portal

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your Child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Non-Discrimination

We fully support your privacy rights and will not discriminate against you for exercising any of your CCPA rights.

8. Links to Other Services

In certain sections of the Services, we may include links to external websites or applications (for example, Facebook and Twitter). These websites and applications are governed by their own privacy policies or information collection practices, which may be substantially different from ours. We encourage you to review the privacy policies and information collection practices of any external websites and apps, as those parties’ practices would not be subject to this policy.

9. Location of Information Processing

The Services are controlled and operated by us from the United States. Your information may be stored and processed in any country where we have facilities or in which we engage service providers, including the United States, which may have data protection laws that are different from those of your country. In addition, your information may be subject to access requests from governments, courts, or law enforcement officials in countries where it may be processed, under the laws of those countries.

10.Security

The security of your personal information is important to us, and we employ physical, technical, and administrative security measures designed to safeguard the information collected by the Services. We use industry standard SSL (secure socket layer technology) encryption to transfer PI. Other security safeguards include, but are not limited to, data encryption, firewalls, and physical access controls to buildings and files.

Account holders create a password in the registration process. You can help protect against unauthorized access to your Account and PI 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. At registration, we assign a Member ID to each Account and use those Member IDs to authenticate logins, allow access to the subscription content, and monitor compliance. The Member ID is also used to authenticate Users when requesting technical support.

Please be aware, however, that no information system can be guaranteed to be 100 percent secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Services over networks that we do not control, including the internet and wireless networks. If you have reason to believe that your interaction with us is not secure, please contact us as described in Section 12 (Contact Us) below.

11.Changes to Our Privacy Policy

We constantly try to provide the best services, and accordingly our Privacy Policy will change from time to time. If we update this Privacy Policy, we will notify you by posting the revised Privacy Policy on the Services, and for certain revisions that materially expand the ways in which we use or share the information previously collected from you through the Services, either display an alert next to the Privacy Policy, display an alert upon login to the Services, or directly communicate with you (e.g., via the email address associated with your Account).

12.Contact Us

Tijiko, Inc. is located in the United States of America and is the operator of the Services. Questions regarding this Privacy Policy and issues related to your or a Child User’s information for which you are responsible should be directed to us via any of the following methods:

Mailing address:
Tijiko, Inc.
Attention: CEO
P.O. Box 6891

San Jose, CA 95150

Email:

hello@tijiko.com

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