Privacy Policy for Children

StarlyKID’S PRIVACY POLICY FOR CHILDREN

Welcome to StarlyKID (“StarlyKID”, “we/us”, “us” or “our”)! Your child’s online privacy and security is extremely important to us. This Children’s Privacy Policy describes our practices involving the online collection, use and disclosure of personal information from children regarding the StarlyKID online education service (“StarlyKID Site”), accessible through our website at StarlyKID.com.

StarlyKID will use personal information collected from children as stated in this Children’s Privacy Policy. On the other hand, some parts of the StarlyKID site

The separate StarlyKID website and mobile app cater to a general audience, with registration pages, direct notification to parents, and credit card payment pages.

Note that it is intended for parents and other adults. Any personal information we collect from other users through these StarlyKID services and pages that are not intended for children It will be processed in accordance with the Privacy Policy:

StarlyKID is committed to complying with the Children’s Online Privacy Protection Act (“COPPA”) and other child privacy laws. As set forth below, we obtain consent from parents or legal guardians, where required by applicable law, before collecting, using and/or disclosing personal information from children through the use of the StarlyKID Site. We take children’s privacy seriously and encourage parents to take an active role in protecting their children’s privacy and online experiences at all times. You can reach StarlyKID at the following addresses:

Name: StarlyKID LLC

Address: 112 Capitol Trail Suite A111 Newark, DE 19711

Email: info@StarlyKID.com

What Information Do We Collect From Children?

We collect personal information from children when they use the StarlyKID Site.

In order for a child to access and use the StarlyKID Site, a parent or legal guardian must log into a sub-account created and protected for the child through their own account. Parent or legal guardian for a child before accessing the StarlyKID Site

Must state the child’s name, age and English proficiency level. After the sub-account is created, the parent or legal guardian must also approve the collection of the child’s personal information.

Personal information is collected directly and automatically from the child by us (and in some cases by our service providers) after the parent logs into the relevant sub-account for the child. To put it more clearly:

• Training activity data including:
• Progress and performance data generated based on the child’s interaction with the StarlyKID Site.
• Video recordings of the child’s lessons with the instructors and messages between the child and the instructor. The purpose of StarlyKID recording these is so that StarlyKID administrators can examine the child’s English learning level and communicate with the child about this issue.

• StarlyKID user identification number, which is an internal number we use to track information associated with the account and the child’s activity.
• We also use data related to cookies, IP addresses, MAC addresses and web beacons to provide and improve StarlyKID, to collect error logging, analytics and information about the child’s usage and browser, software and operating system, as well as information related to device type and similar details. including persistent identifiers. Like many websites, the StarlyKID Site does not currently respond to “Do Not Track” browser banners. However, you can take steps to limit cookie tracking by deleting cookies from the child’s computer or other device and setting the child’s browser to block all cookies or by warning the child before a cookie is stored. However, if you choose to block or delete cookies, some features of the StarlyKID Site may not function properly.

We will not ask children for more personal information than is reasonably necessary to participate in the StarlyKID Site. Additionally, although children interact directly with instructors, we do not allow children to have the option or opportunity to make their personal information more publicly available through the StarlyKID Site.

How Do We Use the Information We Collect from Children?

We use the information we collect from children for the following purposes:

• · For the purposes for which the child provides information, including, for example, monitoring the child’s educational progress, providing parents and legal guardians with information and reports on the child’s performance, and creating and maintaining the child’s sub-account. We also use collected information to provide features and functionality of the StarlyKID Site to children.
• To personalize the content that children see based on their personal characteristics or preferences.
• To obtain and analyze insights based on children’s use of the StarlyKID Site. We use this information for a number of internal purposes, such as logging bugs, ensuring security, helping to improve the StarlyKID Site, and developing new products and services.
• We may combine children’s personal information collected through the StarlyKID Site with other information about children collected by us or third parties in other contexts. Other contexts include our communications with parents or legal guardians via email or telephone, or customer service records associated with the child’s user account.

How and With Whom Do We Share Information Received from Children?

StarlyKID does not sell children’s personal information. We do not share or disclose children’s personal information for marketing purposes. This includes third parties for direct marketing purposes. Furthermore, as stated above, children do not have the option or opportunity to make their personal information publicly available through the StarlyKID Site.

StarlyKID may share or disclose personal information we collect from children as described below.

• With Parents or Legal Guardians. The child’s account will be associated with the parent or legal guardian’s account, meaning the parent or legal guardian can view and monitor the child’s progress. A parent or legal guardian can also access video recordings of their child’s lessons with instructors.
• Instructors. As part of the StarlyKID Site, children can schedule and receive lessons from instructors via video chat sessions. Once a child initiates a video call session with an instructor, the instructor will receive the child’s name and any other personal information the child shared. The instructor will be able to review the child’s learning progress and provide feedback through his/her own instructor account. Children can also communicate with instructors on the StarlyKID Site through direct messaging, other than video chat sessions.
• Service Providers. We may use third-party service providers, contractors or agents to assist us in making the StarlyKID Site available or improving the StarlyKID Site. For example, we use a service provider to provide video connectivity for children’s lessons, as well as database hosting and

We also use data storage providers. Such service providers may themselves collect information or have access to personal information we collect from children to assist us with the purposes set forth in the “How We Use Information We Collect from Children” section above.

• Aggregated and De-Identified Information. We may disclose aggregated and anonymised data regarding activities on the StarlyKID Site to third parties or the public. By way of example only, this may include providing reports on children’s interaction with the StarlyKID Site and/or their English language learning progress for purposes such as conducting educational research, evaluating the educational benefits of using the StarlyKID Site, improving the StarlyKID Site, or demonstrating the effectiveness and usage of the StarlyKID Site when marketing the StarlyKID Site. Such aggregated and anonymous data does not include children’s personal information, including persistent identifiers.
• Business Transfers. Children in the event of a merger, equity or asset sale, reorganization, equity investment, consolidation or similar transaction (or due diligence indicating that such an attempt has occurred) involving StarlyKID. The information we hold, including personal information collected, is transferred to the new organization as a corporate asset. We will notify parents or legal guardians of changes in ownership or use of children’s personal information and the options a parent or legal guardian has regarding the child’s personal information by email and/or by placing a prominent notice on the StarlyKID Site.
• Legal. Within the framework of good faith, by law or legal action We use and disclose children’s personal information when we believe it is necessary to do so under due process (such as a court order, search warrant, or subpoena) or to protect the rights, property, or personal safety of StarlyKID, our users, and/or third parties. >

We may share aggregated and de-identified data regarding activities on the StarlyKID Site with third parties or the public. By way of example only, this may include providing reports on children’s interaction with the StarlyKID Site and/or their English language learning progress for purposes such as conducting educational research, evaluating the educational benefits of using the StarlyKID Site, improving the StarlyKID Site, or demonstrating the effectiveness and usage of the StarlyKID Site when marketing the StarlyKID Site. Such aggregated and de-identified data does not include personal information collected from children.

Parents’ Rights to Review, Delete and Control Their Children’s Personal Information

When a child’s account is first opened, we ask the parent or legal guardian for permission to collect, use and disclose children’s personal information as described in this Children’s Privacy Policy. We also recommend that parents or legal guardians log into their child’s account to view their child’s activities and progress. Parents or legal guardians may review the type of information collected from children or change their consent for the collection, use and sharing of the child’s personal information. They can also contact StarlyKID. Parents or legal guardians may also request that personal information from their children be stopped at any time and that all information collected to date be deleted. However, such requests may terminate the child’s access to and use of the StarlyKID Site.

To contact us about these parenting rights, with questions or comments, please contact us at:

Name: StarlyKID LLC

Address: 112 Capitol Trail Suite A111 Newark, DE 19711

Email: info@StarlyKID.com

The parent or legal guardian’s email address and the child’s name must be included in any correspondence. To protect children’s privacy and safety, we take reasonable steps to verify the identity of a parent or legal guardian before granting access to children’s personal information.

Data Storage

Unless there is a request to delete the data, we retain personal information collected online from children for as long as the child’s subscription continues and for a period of two years after the child’s account is deactivated. The reason we retain this information after the subscription ends is that users often want to pick up where they left off if they reactivate their expired subscription, rather than losing their progress and starting over. On the other hand, all personal information collected from children is automatically deleted from our active servers after two years of account inactivity.

Personal information collected from children is deleted after being stored on our backup servers for a reasonable period of time from the date of any deletion request and cannot be retrieved. As stated above, parents can request the deletion of personal information collected from their children at any time during the subscription period or after the subscription ends.

If we become aware that we have collected information from a child in a way that does not comply with legal requirements, we will either delete that information or seek parental or legal guardian consent to that collection.

Additional Privacy Notice to California Residents

This Additional Privacy Notice supplements the information contained in our Children’s Privacy Policy above and applies only to California residents, unless stated herein. This notice applies to personal information we collect on or through the Services and through other means (such as information collected offline and by phone).

As noted above, the following categories of personal information may have been collected from children by us or our service providers for business or commercial purposes in the preceding twelve months:

• Identifiers: such as name and other account information.
• Demographic information: such as nationality and language proficiency level.
• Internet or Other Network or Device Activity: Network or device information such as IP address, unique device identifiers, advertising and application identifiers, browsing history or other usage data.

• Location Information: general location information (such as from IP address or time zone).
• Sensory Information: Sensory information such as video and audio recordings of lessons.
• Other Information That Identifies You or Can Be Reasonably Relevant to You: We may also collect other information that identifies or can reasonably be associated with the child, such as troubleshooting questions.

We collect the categories of personal information described above from the child, the child’s parent, or through the child’s use of the Services.

We collect the categories of personal information described above for the following business and commercial purposes:

• Service Provision (e.g. account services and maintenance, order processing and fulfillment, customer service, advertising and marketing, analytics and communications about the Services),
• Operational purposes (e.g. providing the Services and troubleshooting problems with the Services),

• Detecting, protecting against, and investigating security incidents and fraudulent or illegal activities,
• Activities aimed at software error detection, error reporting and protecting the quality or security of the Services,

• Improving existing Services and developing new services (e.g. by conducting research to develop new products or features),
• Other uses we notify you of.

We indicate how we share personal information with others, including our service providers and instructors.

Rights

California residents may have certain rights. California law may allow a parent of a child to request that we:

• Providing the categories of personal information about the child that we have collected or disclosed in the past twelve months, the categories of sources of such information, the business or commercial purpose for collecting such information, and the categories of third parties with whom we shared such information.

• Providing access to and/or a copy of certain information we hold about the child.
• We delete certain information we hold about the child.

Parents may have the right to receive information about financial incentives, if any, we offer you. Parents also have the right not to be discriminated against for exercising certain rights (as set out in applicable law). Certain information may be exempt from such requests under applicable law. We require certain types of information in order to provide the services.

If you ask us to delete this information, our Services may become inaccessible or unusable by you or your child.

If you would like to exercise any of these rights on behalf of your child, please send your request to info@StarlyKID.com. We will need to verify your identity before fulfilling your request. If you have an online account with us, you will help verify your identity and request by logging into your account, but we may request additional information if we believe your account has been compromised. If you do not have an account with us or we have reason to suspect that your account security has been compromised, we will request additional information from you to match it with our existing records to verify your identity based on the nature of your request and the sensitivity of the information requested.

You can also appoint an authorized attorney to make a request on your child’s behalf. To do this, you must provide us with a written authorization document or a power of attorney signed by you, requiring the attorney to act on behalf of the child. However, your identity will still need to be verified directly by us.

Do Not Sell My Information. California residents may opt out of the “sale” of their personal information.

StarlyKID does not sell personal information collected from children.

Effective Date and Changes to This Policy

This Children’s Privacy Policy is effective as of the Effective Date set forth above. We may occasionally update this Children’s Privacy Policy to reflect changes to the StarlyKID Site or our information handling practices. If our practices in this Children’s Privacy Policy change

The Effective Date also varies. If we make material changes to this Children’s Privacy Policy, we will use reasonable efforts, taking into account available technology, to ensure that parents receive direct notification of changes to our practices.

Questions or Comments

For questions or comments regarding this Children’s Policy, please contact us at:

Name: Turkish4Kids LLC

Address: 112 Capitol Trail Suite A111 Newark, DE 19711

Email: info@starlykid.com

Last Update: April 28, 2023