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PRIVACY POLICY

Effective: May 7th, 2024

Introduction
StudyPad, Inc. ("Company," “SplashLearn,” “we,” “us,” “our,”) knows that you
care about how your and your child's Personal Data is used and shared. Please
read this Privacy Policy to learn how we treat your and your child’s Personal
Data.
By visiting the SplashLearn website or any other linked pages, features,
content, or applications offered from time to time by Company in connection
therewith (collectively, the "Services"), or using any of our Services, you
acknowledge that you accept the practices and policies outlined below and you
hereby consent that we will collect, use and share your data as described in
this Privacy Policy.
Remember that your use of SplashLearn's Services is at all times subject to our
Terms of Use, which incorporates this Privacy Policy. Any terms we use in this
Policy without defining them have the definitions given to them in the Terms of
Use.
Table of Contents
What Does This Privacy Policy Cover?
How is Children's Personal Data treated?
What Personal Data and Children's Personal Data Does Company Collect?
What Sources does the Company Collect Data from
How does the Company Use the Data it Collects
Will Company Share any of the Data it Receives?
Is Personal Data About me Secure?
Data Deletion & Retention
Communication Choices
California Resident Rights
Virginia Resident Rights
Colorado Resident Rights
Connecticut Resident Rights
Utah Resident Rights
Exercising Your Rights Under State Privacy Laws
Other State Law Privacy Rights
European Union Data Subject Rights
Changes to this Privacy Policy
Questions or Concerns
What Does This Privacy Policy Cover?
This Privacy Policy covers how we treat Personal Data. “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.
In this document "Personal Data" shall apply to Personal Data of individual
Service users who are not child registrants. References to "Children's Personal
Data" shall only apply to Personal Data of Child under the Age of Consent
(defined below) users of the Services. General references to "data" or
"information" shall apply to all users.
Company gathers Personal Data and Children’s Personal Data when you or your
Child under the Age of Consent accesses or uses the Services. 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
Children's Personal Data is handled, please email us at
compliance@splashlearn.com
How is children's Personal Data treated?
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. 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 collect or solicit Personal Data from a child under the age
of 13 (if such child is 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 under the Age of Consent”) without obtaining verifiable
consent from that child’s parent or guardian (such consent, “Parental Consent”
and such individual, “Parent ”), except for the limited amount of Personal Data
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. Parental Consent is further
described below in the “Data about Children” section.
If you are a Child under the Age of Consent, you may not register for the
Services or otherwise disclose any Children's Personal Data to us before we
obtain Parental Consent, except that you may share Required Information solely
for the purpose of the Company obtaining Parental Consent. You may only interact
with the Services under an account created by your Parent who has provided
Parental Consent.
If you believe that a Child under the Age of Consent has provided us with
Children’s Personal Data (beyond the Required Information) without our obtaining
Parental Consent, please contact us at compliance@splashlearn.com. We do not
condition participation in our Services on disclosure of more Children’s
Personal Data from a Child under the Age of Consent than is reasonably necessary
for that Child under the Age of Consent participation in the Services, and we do
not retain Children’s Personal Data from Children under the Age of Consent any
longer than is reasonably necessary in order to fulfill the purpose for which it
was disclosed.
If you are a Parent of a user of our Services who is a Child under the Age of
Consent , you may contact us at any time (compliance@splashlearn.com) to ask
that (a) we stop collecting Children’s Personal Data from such user, (b) we
delete any Children’s Personal Data already collected from such user (although
note that we may further retain and use Anonymized Data as set forth the “Data
that is Not Personal Data” section below), or (c) we stop disclosing Children’s
Personal Data collected from such user to third parties, but continue to allow
for collection and use of Children’s Personal Data collected from such user in
connection with the Services.
If you are a child and your parent has signed up for the Service, you understand
that your parent may be able to view all data within or associated with the
account, including without limitation progress reports and usage data that
tracks your performance on games, assessments and other tests available through
the Services.
What Personal Data Does 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 Children's Personal Data you provide shall only be used for creating
individual account (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 under the Age of Consent'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 customers:
Children’s Personal Data
Profile Information: We collect certain information about Child under the Age of
Consent such as screen name, age and gender directly from Parents when such
Parents set up an account. For additional information about the data that we
collect from Child under the Age of Consent, please see the table further below.
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 avail 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 information. The process only reads the information contained
in the QR code, which does not include any personal information.
Activity Data: We also record data around Child under the Age of Consent’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 under the Age of Consent (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 you 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 Recording may also
be shared with student participants and their Parents.
Parental Consent: SplashLearn obtains verifiable parental consent before
collecting Personal Data from Children under the Age of Consent. If the Parent
does not provide consent, we will not collect, use or disclose any Personal Data
about the Child under the Age of Consent.
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 will receive your full name 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 information may
be visible during Customer Support and/or Troubleshooting. Personal Data such as
Student Name, Teacher Email Address, login dates and times may be viewed on our
service by Product Support Staff.
Push Notifications
We may also send parents and teachers practice reminders through our mobile
apps. These notifications are intended for grown-ups only and can only be
requested through the parent/grown-up sections of our mobile apps. You can
opt-out from 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
currently display third party advertisements on our Services or use third party
cookies to track Children Under the Age of Consent for advertising purposes. We
also do not engage in targeted advertising based on Student Data or Children’s
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.
What Sources does the company collect information 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 Information 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 Company Share any of the Information it Receives?
Your Personal Data and Children's Personal Data is an integral part of our
business. We neither rent nor sell your Personal Data or Children's Personal
Data to anyone. We share your Personal Data and Children's only as described
below. We never share that Children'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 Children'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
Children'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 Children'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 partner Stripe, Inc. (“Stripe”) collects your
     voluntarily-provided payment card information necessary to process your
     payment.
   * Please see Stripe’s terms of service and privacy policy for information on
     its 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
Over time, SplashLearn may grow and reorganize. We may share your information,
including Personal Data and Children’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 Children’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.
User Profiles
Children under the Age of Consent are not allowed to enter or upload User
Submissions, as defined in our Terms of Use. No Children's Personal Data will
ever be displayed to any third party through a user profile. Email addresses are
used to add new User Submissions to user profiles and to communicate through
User Submissions. Users' email addresses will not be directly revealed to other
users by Company, except, when the user is "connected" to another user via a
shared group membership, or an invitation, or if the user has chosen to include
their email address in their user profile.
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 Children’s 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 Children’s 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 Children’s 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.
With Your Consent
Except as set forth above, you will be notified when your Personal Data or
Children’s Personal Data may be shared with third parties, and you will be able
to prevent the sharing of this information.
Is Personal Data and Children’s Personal Data Secure?
The security of your Personal Data and Children’s 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
Children’s 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 Children’s
   Personal Data is encrypted at rest, which converts all Personal Data or
   Children’s 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 Children’s 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 Children's 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 Children's
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. As and when required by the
applicable 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 details as
mandated by applicable laws, such as: 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 Children’s Personal Data for as long as it is
necessary to provide products and Services, including those described above.
Personal Data or Children’s 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.
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.
Student Data Protection Policy: We will not retain a student's 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's Personal Data. Additionally, we only keep a student's Personal Data for
as long as his or her student 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.
Please see the following section on information about data deletion due to
account inactivity:
Home Accounts: For accounts created by parents, if neither the student, nor the
student's parent(s) or any of the other student accounts associated with the
parents' accounts have logged into their account in 2 years, SplashLearn will
automatically delete or de-identify the Personal Data tied to the student
account that is not necessary for educational purposes or legal obligations,
including device tokens, device identifiers and IP addresses. In effect, the
student account will be anonymized and de-linked from the parent account and the
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 Personal Data about the student. Parents can always request
deletion of their accounts as outlined in the "Deleting your account" section.
Classroom Account: If neither the teacher, nor any of the students associated
with the teacher account have logged into their account in 2 years or performed
any activity, SplashLearn automatically deletes or de-identifies any Personal
Data tied to the student accounts that is not necessary for educational purposes
or legal obligations, including device tokens, device identifiers and IP
addresses.
Please note that some content will not be deleted given various compliance and
record-keeping obligations schools have. Please contact your (or the student's )
school if you would like this content deleted. If the school determines that the
request should be implemented, they may submit a request to us.
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 Children’s
Personal Data associated with it.
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.
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.
California Resident Rights
If you are a California resident, you have the rights set forth in this section.
Please see the “Exercising Your Rights under the State Privacy Laws” section
below for instructions regarding how to exercise these rights. Please note that
we may process Personal Data of our customers’ end users or employees in
connection with our provision of certain services to our customers. If we are
processing your Personal Data as a service provider, you should contact the
entity that collected your Personal Data 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 and you are a California resident, the 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 rights
apply to you, please contact us at compliance@splashlearn.com.
Access
You have the right to request certain information about our collection and use
of your Personal Data over the past 12 months. In response, we will provide you
with the following information:
 * The categories of Personal Data that we have collected about you.
 * The categories of sources from which that Personal Data was collected.
 * The business or commercial purpose for collecting or selling your Personal
   Data.
 * The categories of third parties with whom we have shared your Personal Data.
 * The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business
purpose over the past 12 months, we will identify the categories of Personal
Data shared with each category of third party recipient. If we have sold your
Personal Data over the past 12 months, we will identify the categories of
Personal Data sold to each category of third party recipient.
Deletion
You have the right to request that we delete the Personal Data that we have
collected about you. Under the CCPA, this right is subject to certain
exceptions: for example, we may need to retain your Personal Data to provide you
with the Services or complete a transaction or other action you have requested.
If your deletion request is subject to one of these exceptions, we may deny your
deletion request.
Correction
You have the right to request that we correct any inaccurate Personal Data we
have collected about you. Under the CCPA, this right is subject to certain
exceptions: for example, if we decide, based on the totality of circumstances
related to your Personal Data, that such data is correct. If your correction
request is subject to one of these exceptions, we may deny your request.
Personal Data Sales Opt-Out and Opt-In
We will not sell your Personal Data, and have not done so over the last 12
months. To our knowledge, we do not sell the Personal Data of children under 16
years of age.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA.
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 the CCPA.
Colorado Resident Rights
If you are a Colorado resident, you have the rights set forth under the Colorado
Privacy Act (“CPA”). Please see the “Exercising Your Rights under the State
Privacy Laws” section below for instructions regarding how to exercise these
rights. Please note that these rights are subject to certain conditions and
exceptions under applicable law, which may permit or require us to deny your
request.
If there are any conflicts between this section and any other provision of this
Privacy Policy and you are a Colorado resident, the 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 rights
apply to you, please contact us at compliance@splashlearn.com.
Access
You have the right to request confirmation of whether or not we are processing
your Personal Data and to access and request a copy of your Personal Data in a
machine-readable format, to the extent technically feasible, twice within a
calendar year.
Correction
You have the right to correct inaccuracies in your Personal Data, to the extent
such correction is appropriate in consideration of the nature of such data and
our purposes of processing your Personal Data.
Deletion
You have the right to delete Personal Data concerning you.
Personal Data Sales and Targeted Advertising Opt-Out
We do not currently sell or process for the purposes of targeted advertising
your Personal Data as defined under the CPA.
We do not sell or process for the purposes of targeted advertising the Personal
Data of minors under 13 years of age.
Profiling Opt-Out
We do not process your Personal Data for ‘Profiling’ to make ‘Decisions’ under
the CPA. ‘Profiling’ means any form of automated processing performed on
personal data to evaluate, analyze or predict personal aspects related to an
identified or identifiable individual's economic situation, health, personal
preferences, interests, reliability, behavior, location or movements. ‘Decision’
means any ‘Decisions that Produce Legal or Similarly Significant Effects
Concerning a Consumer,’ as defined in the CPA that concern you.
Consent or “Opt-in” Required and How to Withdraw
As discussed above, we will seek Parent consent to collect or process certain
Children’s Personal Data. If you would like to withdraw your consent, please
follow the instructions under the “Exercising Your Rights under State Privacy
Laws” section.
We Will Not Discriminate Against You
We will not process your Personal Data in violation of state and federal laws
that prohibit unlawful discrimination against consumers.
Connecticut Resident Rights
If you are a Connecticut resident, you have the rights set forth under the
Connecticut Data Privacy Act (“CTDPA”). Please see the “Exercising Your Rights”
section below for instructions regarding how to exercise these rights. Please
note that these rights are subject to certain conditions and exceptions under
applicable law, which may permit or require us to deny your request.
If there are any conflicts between this section and any other provision of this
Privacy Policy and you are a Connecticut resident, the 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 rights
apply to you, please contact us at compliance@splashlearn.com.
Access
You have the right to request confirmation of whether or not we are processing
your Personal Data and to access your Personal Data.
Correction
You have the right to correct inaccuracies in your Personal Data, to the extent
such correction is appropriate in consideration of the nature of such data and
our purposes of processing your Personal Data.
Deletion
You have the right to delete Personal Data you have provided to us or we have
obtained about you.
Portability
You have the right to request a copy of your Personal Data that is processed
automatically in a machine-readable format, to the extent technically feasible.
Personal Data Sales and Targeted Advertising Opt-Out
We do not currently sell or process for the purposes of targeted advertising
your Personal Data as defined under the CTDPA.
Profiling Opt-Out
We do not process your Personal Data for ‘Profiling’ as defined under the CTDPA.
‘Profiling’ means any form of automated processing performed on personal data to
evaluate, analyze or predict personal aspects related to an identified or
identifiable individual's economic situation, health, personal preferences,
interests, reliability, behavior, location or movements.
Consent or “Opt-in” Required and How to Withdraw
As discussed above, we will seek Parent consent to collect or process certain
Children’s Personal Data. If you would like to withdraw your consent, please
follow the instructions under the “Exercising Your Rights under State Privacy
Laws” section.
We Will Not Discriminate Against You for Exercising Your Rights Under the CTDPA
We will not discriminate against you for exercising your rights under the CTDPA.
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 the CTDPA.
Utah Resident Rights
If you are a Utah resident, you have the rights set forth under the Utah
Consumer Privacy Act (“UCPA”). Please see the “Exercising Your Rights under the
State Privacy Laws” section below for instructions regarding how to exercise
these rights. Please note that these rights are subject to certain conditions
and exceptions under applicable law, which may permit or require us to deny your
request.
If there are any conflicts between this section and any other provision of this
Privacy Policy and you are a Utah resident, the 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 rights apply to
you, please contact us at compliance@splashlearn.com.
Access
You have the right to request confirmation of whether or not we are processing
your Personal Data and to access your Personal Data.
Portability
You have the right to request a copy of your Personal Data in a machine-readable
format, to the extent technically feasible.
Deletion
You have the right to delete Personal Data that you have provided to us.
Opt-Out of Certain Processing Activities
 * Targeted Advertising:
   We do not process your Personal Data for targeted advertising purposes.
 * Sale of Personal Data:
   We do not currently sell your Personal Data as defined under the UCPA.
 * Processing of Sensitive Personal Data:
   As discussed above, we will seek Parent consent to collect or process certain
   Children’s Personal Data. If you would like to withdraw your consent, please
   follow the instructions under the “Exercising Your Rights under State Privacy
   Laws” section.

We Will Not Discriminate Against You for Exercising Your Rights Under the UCPA
We will not discriminate against you for exercising your rights under the UCPA.
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 the UCPA.
Virginia Resident Rights
If you are a Virginia resident, you have the rights set forth under the Virginia
Consumer Data Protection Act (“VCDPA”). Please see the “Exercising Your Rights”
section below for instructions regarding how to exercise these rights. Please
note that these rights are subject to certain conditions and exceptions under
applicable law, which may permit or require us to deny your request.
If there are any conflicts between this section and any other provision of this
Privacy Policy and you are a Virginia resident, the 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 rights
apply to you, please contact us at compliance@splashlearn.com.
Access
You have the right to request confirmation of whether or not we are processing
your Personal Data and to access your Personal Data.
Correction
You have the right to correct inaccuracies in your Personal Data, to the extent
such correction is appropriate in consideration of the nature of such data and
our purposes of processing your Personal Data.
Portability
You have the right to request a copy of your Personal Data in a machine-readable
format, to the extent technically feasible.
Deletion
You have the right to delete Personal Data you have provided to us or we have
obtained about you.
Consent or “Opt-in” Required and How to Withdraw
As discussed above, we will seek Parent consent to collect or process certain
Children’s Personal Data. If you would like to withdraw your consent, please
follow the instructions under the “Exercising Your Rights under State Privacy
Laws” section.
Opt-Out of Certain Processing Activities
 * We do not process your Personal Data for targeted advertising purposes.
 * We do not currently sell your Personal Data as defined under the VDCPA.
 * We do not currently process your Personal Data for the purposes of profiling.

To exercise any of your rights for these certain processing activities, please
follow the instructions under the “Exercising Your Rights under State Privacy
Laws” section.
We Will Not Discriminate Against You for Exercising Your Rights Under the VCDPA
We will not discriminate against you for exercising your rights under the VCDPA.
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 the VCDPA.
Exercising Your Rights Under the State Privacy Laws
To exercise the rights described above, you or, if you are a California,
Colorado, or Connecticut resident, your Authorized Agent (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, 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 law. 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.
You may submit a Valid Request using the following methods:
 * Email us at: compliance@splashlearn.com.
 * You can also access certain of your Personal Data by logging on to your
   account.

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, 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 CPA, CTDPA, or VCDPA (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 method:
 * Email us at: compliance@splashlearn.com (title must include “[STATE OF
   RESIDENCE] Appeal”)

If we deny your appeal, you have the right to contact the Attorney General of
your State, including by the following links:
https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint (VA),
www.coag.gov/resources/colorado-privacy-act/ (CO), and
www.portal.ct.gov/AG/Sections/Privacy/The-Privacy-and-Data-Security-Department
(CT).
Other State Law Privacy Rights
California Resident 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; in order to submit such a
request, please contact us at compliance@splashlearn.com.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of
certain Personal Data to third parties who intend to license or sell that
Personal Data. You can exercise this right by contacting us at
compliance@splashlearn.com with the subject line “Nevada Do Not Sell Request”
and providing us with your name and the email address associated with your
account. Please note that we do not currently sell your Personal Data as sales
are defined in Nevada Revised Statutes Chapter 603A.
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 Children’s 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 compliance@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 compliance@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 https://www.splashlearn.com/profile. 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:
 1. 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;
 2. You have consented to this collection and processing for a specific purpose;
 3. It is necessary to fulfil our contractual obligations; or
 4. 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
compliance@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
201 Spear Street, Suite 1100
San Francisco, California 94105

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 following regions:
European Union (EU)
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.
If your DPF complaint cannot be resolved through the above channels, under
certain conditions, you may invoke binding arbitration for some residual claims
not resolved by other redress mechanisms. See Annex 1 of the DPF Principles,
located at
https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.
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 Children's
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 information
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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