Child User Privacy Policy
Effective date: July 9, 2025
At SplashLearn, we take your privacy seriously. Please read this Child User Privacy Policy to learn how we treat
your personal data if you are a student user, a child under the age of 13 or deemed a child or minor by your state's
law (if located in the United States), or a child under the age of 16 (if such child is located in the European
Economic Area or United Kingdom) (in each case, a "Child User").
Please see the General Privacy Policy for a discussion
of how we protect Personal Data, the rights you may have under applicable law, and general information about the
Company's practices related to the processing of Personal Data.
If you are a Child User, you may only use SplashLearn Services and disclose information to us with your Parent's
consent. Please refer to SplashLearn's Terms of
Use, which incorporate this Child User Privacy Policy, regarding how SplashLearn and/or a relevant School
(defined therein) collect verified parental consent before a Child User can use SplashLearn Services. Only a Child
User's parent or guardian, or teacher or school administrator, can sign up such Child User to SplashLearn
Services.
By agreeing to sign up a Child User to SplashLearn Services, you, as either such Child User's Parent or teacher or
school administrator, (i) acknowledge that you accept the practices and policies outlined below on behalf of such
Child User; (ii) hereby consent that we will collect, use and share the Personal Data of such Child User as
described in this Child User Privacy Policy; and (iii) represent and warrant that you're such Child User's Parent,
or teacher or school administrator, have the legal authority to accept these terms on behalf of such Child User,
and grant such consent in compliance with applicable laws and regulations.
Table of Contents
What this Child User Privacy Policy Covers
This Child User Privacy Policy covers how we treat Personal Data that we gather when 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 Privacy Policy does not cover the practices of
companies we don't own or control or people we don't manage.
As noted above, if you're not a Child User, please see the General Privacy Policy to learn how we treat your
Personal Data.
No Behavioral Advertising
We do not use or disclose Personal Data of a Child User or any other information about a Child User collected
through such Child User's School (whether Personal Data or otherwise) for behavioral targeting of advertisements
or for creating a profile of such Child User.
Personal Data of Child Users
The Children's Online Privacy Protection Act ("COPPA") requires that online service providers obtain parental
consent before they knowingly collect personally identifiable information online from children who are under 13
years of age. Certain U.S. state privacy laws specifically regulate the processing of Personal Data related to
individuals deemed children or minors. Moreover, the EU General Data Protection Regulation (the "GDPR") requires
that data controllers obtain consent from the holders of parental responsibility over children who are under 16
years of age before such controllers knowingly collect and process Personal Data from such children.
We do not knowingly or intentionally collect or solicit personally identifiable information from a Child User
without obtaining verifiable consent from that child's parent or guardian ("Parental Consent" and such
individual, "Parent"), except for the limited amount of personally identifiable information we need to collect
in order to obtain Parental Consent ("Required Information"). Until we have received Parental Consent, we will
only use Required Information for the purpose of obtaining Parental Consent.
If you are a Child User, please do not attempt to send any Personal Data about yourself to us before we obtain
Parental Consent, except for the Required Information in the context of the Parental Consent process. If you
believe that a Child User has provided us with Personal Data (beyond the Required Information) without our
obtaining Parental Consent, please contact us at help@splashlearn.com.
We do not condition participation in our Services on disclosure of more Personal Data from Child Users than is
reasonably necessary for that participation, and we do not retain Personal Data from Child Users longer than is
reasonably necessary in order to fulfill the purpose for which it was disclosed.
If you are a Parent of a Child User of our Services, you may contact us at any time to ask that (a) we stop
collecting Personal Data from such Child User, (b) we delete any Personal Data already collected from such Child
User (although note that we may further retain information in an anonymous or aggregated form where that
information would not identify such Child User personally), or (c) we stop disclosing Personal Data collected
from such Child User to third parties, but continue to allow for collection and use of Personal Data collected
from such Child User in connection with the Services.
If you are a Child User, you represent and warrant that you've received your parent's or guardian's permission
to use the Services and gotten your parent or guardian to agree to our Terms of Use on your behalf and also to agree on
their own behalf.
For Child Users, no matter whether you're under the age of 13 or above, your Parent, teacher, or school
administrator can view all information within or associated with your SplashLearn account, including, without
limitation, messages between you and your teacher, your work assignments and results, comments, comments you
received on your assignments, your projects saved in your account.
For clarity, we do not collect, maintain, use or share Child User Personal Data beyond what is needed for
authorized educational/school purposes, or as authorized by the Child User or his/her Parent, or teacher or
school administrator under this Child User Privacy Policy. We never sell Child User Personal Data collected and
we do not share Child User Personal Data with third parties for their own marketing, advertising purposes, or
creating advertising profiles.
Categories of Personal Data We Collect
Within the past 12 months we have collected the following categories of Personal Data from Child Users:
Profile Information:
We collect certain information about Child Users such as screen name, age
and gender directly from Parents when such Parents set up an account.
If you are a teacher or a school administrator, you may also provide a full name for each applicable student to
be able to track progress and distinguish students. Therefore, you may choose to provide a different identifier
instead of a student's name for this purpose. You may also provide us with a username and a password for each of
the student accounts.
As a teacher you may also make available a QR-code-based login feature for their students. This method requires
students to scan a QR code using their device's camera. The process of scanning the QR code does not capture any
image, video, or other Personal Data. The process only reads the information contained in the QR code, which
does not include any Personal Data.
Activity Data:
We also record data around Child User's usage of the Services such as their
activities, their performance on games and activities, in order to send you reports and recommend the most
appropriate games and activities.
Voice Recordings:
A Child User (or Parent) can record their voice while reading a digital book
and play it back to help them learn to read. This recording stays on your device and is not sent to our servers.
The recording is automatically deleted as soon as they move to the next page of the book. The record voice
feature is optional, and microphone access can be denied without affecting access to the books.
Live Classes and Class Recordings:
SplashLearn's live classes offering ("Live Classes") have
live tutoring sessions ("Class Sessions") conducted over video conferencing by expert tutors. There may be more
than one student participant in a Class Session. Student participants cannot turn on their video or audio and
they cannot see or interact with other student participants during the Class Session. They may answer questions
through a quizzing platform or using the chat feature available on the video conferencing platform. Their
answers are only visible to the tutors and class coordinators and not to other student participants.
SplashLearn may make recordings of the class during a live class session ("Class Recordings"). As described
above, since student participants cannot turn on their audio or video, Class Recordings only capture the audio
and video of the tutor conducting the Class Session.
The Class Recordings may be used for improving the quality of instruction and to improve the class experience.
To enable student participants to review a Class Session or in the case they were not able to attend it, Class
Recordings may also be shared with student participants and their Parents.
Push Notifications:
Users of SplashLearn mobile applications may receive push notifications, if
they opt-in for them. Some notifications may be locally served from the device while others may be remotely
served. Remotely served notifications require collection of push notification tokens and SplashLearn will serve
them only after obtaining verifiable parental consent. Push notifications are used to alert users about in-app
activity along with new games, events, offers and features. Push notifications may be disabled at any time by
changing the device's notification settings for the SplashLearn app. If these notifications are not disabled, we
may continue to send them.
Parental Consent:
SplashLearn obtains verifiable parental consent before collecting Personal
Data from Child Users. If the Parent does not provide consent, we will not collect, use or disclose any Personal
Data about the Child User.
Categories of Sources of Personal Data
We collect Personal Data about Child Users from the following categories of sources:
You
- When you provide such information directly to us.
- When your Parent or teacher or school administrator creates an account or you use our interactive tools and Services.
- When you voluntarily provide information in free-form text boxes through the Services. We do not have control over what personally identifiable information you may include in free-form text boxes, so please use caution not to include any personally identifiable information.
- When you send us an email or otherwise contact us.
- The Services provide the functionality that allow Child Users to create voice recordings in connection with their projects. We do not require Child Users to submit any voice recordings, but Child Users can voluntarily opt to use such functionality to create voice recordings.
- When you use the Services and such information is collected automatically.
- Through Cookies (defined in the "Cookies" section below).
- 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.
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.
Our Commercial or Business Purposes for Collecting Personal Data
- Creating and managing your account or other user profiles as required for the purpose of providing you the Services.
- 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").
- Responding to correspondence that we may receive from you, contacting you when necessary or requested, such as for troubleshooting.
- Carrying out educational purposes as directed by Schools, such as sharing with the parent or guardian of a Child User of project progress, work results, and teacher comments through courses assigned with the Child User's School.
- Supporting educational/school purposes as authorized by the Schools and/or the Parent a Child User.
- 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.
Providing, Customizing and Improving the Services
Corresponding with You
Educational Purposes
Meeting Legal Requirements and Enforcing Legal Terms
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.
Data Deletion & Retention
Deleting your Account
Your Parent or teacher has the right to ask us to delete their account and/or the associated student accounts at
any time. They can do so by contacting us at help@splashlearn.com.
Please note that we may have to retain some information after an 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 you personally.
Data Retention
We will not retain Child User Personal Data for any longer than is necessary for educational purposes, legal or
contractual obligations, or to provide the Service for which we receive or collect the Child User Personal Data.
Additionally, we only keep Child User Personal Data for as long as a Child User's account is active, unless we
are required by law or the child's school to retain it, need it to ensure the security of our community or our
Service or to enforce our Terms.
Home Accounts:
For accounts created by Parents, if neither the Child User, nor Parent(s) or any
of the other Child User accounts associated with the Parents' accounts have logged into their account in 2
years, the Parent and associated student account(s) will be anonymized. SplashLearn will automatically delete or
de-identify the Child User Personal Data tied to the student account(s) that is not necessary for educational
purposes or legal obligations, including device tokens, device identifiers and IP addresses and such data will
be non-recoverable We will make reasonable attempts to inform Parents about the account modification a few days
in advance. We may retain some Personal Data about the Parents for reasons outlined earlier, but these will not
be tied to any Child User Personal Data. Parents can always request deletion of their accounts as outlined in
the "Deleting your account" section in the General
Privacy Policy.
Classroom Accounts:
If neither the teacher, nor any of the Child Users associated with the
teacher account have logged into their account in 2 years or performed any activity, the teacher and the
associated Child User accounts will be anonymized. SplashLearn will automatically delete or de-identify any
Child User Personal Data tied to the student account(s) that is not necessary for educational purposes or legal
obligations, including device tokens, device identifiers and IP addresses and such data will be non-recoverable
We will make reasonable attempts to inform teachers about the account modification a few days in advance
We may retain some Personal Data about the teachers for reasons outlined earlier, but these will not be tied to
any Child User Personal Data. Teachers can always request deletion of their accounts as outlined in the
"Deleting your account" section in the General Privacy
Policy. Please note that some content will not be deleted given various compliance and record-keeping
obligations schools have. They may contact the School if they would like this content deleted. If the School
determines that the request should be implemented, they may submit a request to us.
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.
The Services do not use third-party cookies on pages accessed by Child Users or pages on our website or
application that are targeted towards Child Users for displaying personalized advertising or to track Child
Users and display personalized advertisements on other third-party websites or services. We do not use or
disclose Child User Personal Data or any other information of Child Users collected through such Child User's
School (whether personal information or otherwise) for behavioral targeting of advertisements.
Changes to this Privacy Policy
We're constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time,
but we will alert you to any such changes by placing a notice on the SplashLearn website, by sending you an
email and/or by some other means. Please note that if you've opted not to receive legal notice emails from us
(or you haven't provided us with your email address), those legal notices will still govern your use of the
Services, and you are still responsible for reading and understanding them. If you use the Services after any
changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information
we collect is subject to the Privacy Policy in effect at the time such information is collected.
Contact Information:
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use Student
User's Personal Data or your choices and rights regarding such collection and use, please do not hesitate to
contact us at:
STUDYPAD, INC.
201 Spear Street, Suite 1100
San Francisco, California 94105
201 Spear Street, Suite 1100
San Francisco, California 94105
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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