PRIVACY POLICY OF PROGKIDS INC.
This Privacy Policy (the "Policy"), an integral part of the ProgKids General Terms and Conditions, explains how ProgKids Inc. a legal entity established and organized under the laws of the USA, located at 541 Jefferson Ave, Ste 100, Redwood City, CA 94063, (hereinafter - 'ProgKids'); hereinafter: "ProgKids", "Company", "we", or "us") collects, stores, uses, and discloses personal information from its users and their students ("you", "user") in connection with our online learning service ("Online Classes") and website located at www.ProgKids.com and it's subdomains (the "Website"), as well as in ProgKids's mobile application ("Application") operated by the Company including registering an account for your child on the Website ("Registration") and virtual chatting with ProgKids ("Chatting"). This Policy also contains information about the collecting of the personal data regarding the natural persons who apply as teachers to ProgKids ("Applying as a Teacher").

The processing and collecting of personal data by ProgKids shall be in harmony with the directly applicable data protection laws in effect:

(i) In case of personal data processing, the Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter: "GDPR"), furthermore the recommendations of the Article 29 Data Protection Working Party (hereinafter: "WP29") and of the European Data Protection Board (hereinafter: "EDPB") shall apply.
(ii) Furthermore, in respect of Californian individuals ProgKids complies with the Senate Bill No. 1121 California Consumer Privacy Act of 2018 (hereinafter: "CCPA").
(iii) Furthermore, We comply with the requirements of the Nevada Privacy law (https://legiscan.com/NV/text/SB260/id/2404614/Nevada-2021-SB260-Enrolled.pdf), which provides residents with choices regarding how we share information.
(iv) For the collection and processing of personal data of individuals residing in other countries, where the personal data regulations are in place and apply to the foreign entities, ProgKids is in compliance with those regulations as well.

The Company is the data controller of any data which constitutes personal data, and which is uploaded when using our services.

The Company bound in honor to protect personal data, especially children's personal data; therefore, the Company will keep confidential the personal data received and take all necessary steps to secure data processing.

Before your child starts using ProgKids, we want to make sure you understand how ProgKids collects and uses your personal information and what rights are available for you and your child in relation your personal data.

Please make sure that you read and put attention on ProgKids Children's Privacy Notice describes how we collect, use, and process personal information from children under 13., for your child before he or she starts the online classes.

Please read and make sure you understand this Policy. If you do not agree with this Policy or our practices, you may not use our Website or our services.
1. DEFINITIONS
The following definitions are determined according to the GDPR:

'personal data': shall mean any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
'consent': shall mean any freely given, specific, informed and unambiguous indication of the will of the Data Subject by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
'data controller': shall mean the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
'data processing': shall mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
'data processor': shall mean a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
'third party': shall mean a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;
'personal data breach': shall mean a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;
'recipient': shall mean a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with European Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;
'supervisory authority': shall mean one or more independent public authorities provided by each Member State which is responsible for monitoring the application of the GDPR in order to protect the fundamental rights and freedoms of natural persons in relation to processing and to facilitate the free flow of personal data within the European Union;
'supervisory authority concerned': shall mean a supervisory authority which is concerned by the processing of personal data because: (a) the controller or processor is established on the territory of the Member State of that supervisory authority; (b) data subjects residing in the Member State of that supervisory authority are substantially affected or likely to be substantially affected by the processing; or (c) a complaint has been lodged with that supervisory authority.
2. WHAT INFORMATION DOES PROGKIDS COLLECT?
The information we gather from users enables ProgKids to personalize and improve the services, to allow the users to set up accounts on the Website or get information about our services. We collect the following types of information from our Teachers and Users:

2.1 Information you provide to us:

2.1.1 At Registration:

We collect the following personal data uploaded during the registration on the Website:

● Full name,
● E-mail address,
● Phone number.

Please note that the e-mail address provided does not require the inclusion of personal data, such as your name. You are free to choose an e-mail address that contains information about your identity.

After the Registration you must add the following personal data to your ProgKids Account in order to use our services:

● Your children's data (name, age, gender).

2.1.2 While Chatting:

We collect the following personal data uploaded during the Chatting on the Website:

● E-mail address,
● Any other personal information provided by you during Chatting.

2.1.3 When participating in Online Classes:

We collect the following personal data uploaded during Online Classes:
● Video (including audio) of the participants of Online Classes,
● Parental, sibling and extended family details,
● Homework or any educational progress submitted via the Website,
● Attendance,
● Level of proficiency in programming
● Any other personal data shared directly or indirectly during Online Classes

However we do not collect any personal information about racial or ethnic origin, religion or beliefs).

2.1.4 When Applying as a Teacher:
We collect the following personal data uploaded during Applying as a Teacher:
● Full name
● Teaching experience
● Photo and video about the data subject,
● Birthday (age),
● Languages spoken,
● Gender,
● E-mail address,
● Nationality,
● Skype ID,
● Phone number
● Previous work experience,
● Educational information,
● Residency information,
● Information on other teaching certificates.

2.2 Information Collected Automatically:
We receive and store certain types of information whenever you interact with our Website, services or Application.

2.3 When using the Website
ProgKids automatically receives and records information on our server logs from your browser including your IP address, unique device identifier, browser characteristics, domain and other system settings, search queries, device characteristics, operating system type, language preferences, referring URLs, actions taken on our Website, page requested, content consumed (e.g., viewed, uploaded, and shared), dates and times of Website visits, gender, age range, approximate location and other information associated with other files stored on your device.

3. WHAT ABOUT COOKIES?
The Company processes anonymous data in order to improve the Website, to bring it to perfection. During this procedure ProgKids can incorporate "cookies", which collect the visitor's first level domain name, the date and the exact time of access and other informations. The "cookie" alone can't be used to reveal the identity of the visitor. The "cookie" is a small text file, which is sent to the browser of the visitor and stored on the hard drive of visitor. Cookies don't damage the computer of the visitor. The browser can be set to indicate when a cookie is received, so the visitor can decide to accept the so-called cookie or not. The Company does not use cookies to collect or manage any information that would allow the identification of the user. For further information, please read our Cookie Policy.
4. HOW DOES PROGKIDS USE THE COLLECTED INFORMATION?
We may use the information we collected, including your and your children's personal information - based on diverse purposes as well as the legal basis of the processing - as follows:

4.1. We process the following personal data for the purpose and on the legal basis of the performance of the contract, product and service fulfillment:

● Full name,
● Children's name,
● Children's age,
● Children's gender,
● E-mail address,
● Phone number.

The above obligatory or optional personal data you provide is used for purposes such as fulfilling the obligations defined in the General Terms and Conditions and providing the service, responding to your questions, requests relating to the service, customizing the visualized content, communicating with you about sales offers relating to special services and new features, and responding to problems relating to our services.

4.2. We process the following personal information based on the legitimate interest of the Company (as the legal basis of this processing) for marketing purposes and to deliver e-mails:

● Full name,
● Email address.
● Phone number,
● Any other personal data provided to the data processors of ProgKids.

Whenever ProgKids processes data for its legitimate interest, ProgKids always keeps your personal data rights in high regard and will take them in account. The users always have the right to object to this processing. However, objecting against such data processing might affect ProgKids's ability to carry out tasks above for the benefit of the user.

4.3. We process personal data for the purpose and on the legal basis of compliance with legal obligations to prevent fraudulent transactions, monitor against theft and otherwise protect our customers and our business. We also process personal data for the purpose and on the legal basis of legal compliance and to assist law enforcement and respond to subpoenas.

This means that in some cases the data processing is stipulated by the applicable laws and we have an obligation to process and keep this data for the required time. This includes employment data, billing data, data which is necessary to assist law enforcement etc.

4.4. We process the following personal data for the purpose and on the legal basis of the legitimate interests of the Company, to improve the effectiveness of the Website, our services, and marketing efforts, to conduct research and analysis, including focus groups and surveys and to perform other business activities as needed, or as described elsewhere in this Policy:

● IP address,
● Browser information,
● Contact information,
● Content consumed on the Website,
● Unique device identifier,
● Browser characteristics,
● Domain and other system settings,
● Search queries,
● Device characteristics,
● Operating system type,
● Language preferences,
● Referring URLs,
● Actions taken on our Website,
● Page requested,
● Content consumed (e.g., viewed, uploaded, and shared),
● Dates and times of Website visits,
● The link that you have been redirected to our Website from,
● Gender,
● Age range,
● Approximate Location,
● The type of web browser used,
● Actions taken in the Application,
● Dates and times of using the Application,
● Time spent in the Application and the regularity of your visits,
● Other software and hardware information
● Other information associated with other files stored on your device

Where it is feasible, we anonymize personal data or use non-identifiable statistical data. We do not collect personal data in advance and store it for potential future purposes unless required or permitted by the applicable laws.

For collecting anonymously, the above-mentioned data and making statistics and analysis we may use the following software and programs:
4.5. Data integrity and purpose limitation: ProgKids will only collect and retain personal data which is relevant to the purposes for which the data is collected, and we will not use it in a way that is incompatible with such purposes unless such use has been subsequently authorized by you. We will take reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete and current. We may occasionally contact you to determine that your data is still accurate and current. To secure your personal information processed we save your personal information to backup archives in every ___ hours. The data stored in our backup archives will be deleted in ____ years.
5. HOW LONG WE RETAIN YOUR PERSONAL DATA?
We will retain your personal data for so long as it is needed to fulfill the purposes outlined in this Policy or until you withdraw your consent, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements, further for the establishment, exercise or defense of legal claims). When we have no longer or no legal basis to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
6. WILL PROGKIDS SHARE ANY OF THE INFORMATION IT RECEIVES?
Information about our users is an integral part of our business, and we may share such information with our affiliated entities. Except as expressly described below, we neither rent nor sell your information to other people or nonaffiliated companies unless we have your permission.

6.1. ProgKids shall not ensure access for a third party to personal data provided by you without your preliminary consent, except the cases, when data transfer is necessary for the performance of the contract or for enforcing of ProgKids's legitimate interest or prescribed by law.

6.2. Every teacher working for ProgKids is considered as a data processor according to the regulations of the GDPR. The teachers have access only to the personal data of the children they are teaching in order to minimize the processing of personal data.

6.3. ProgKids may share certain personal information with third party vendors in the EU or in third countries, who supply software applications, web hosting and other technologies or services for the Website and our services (hereinafter: "Data Processor"). The Company will only provide these third parties with access to information that is reasonably necessary to perform their work or comply with the law. Those third parties will never use such information for any other purpose except to provide services in connection with the Website and our services. During the service of data process, the Data Processor shall abide under the present Policy, relevant legislations in force, furthermore the provisions of the existing contracts between him and ProgKids.

You can see the list of Data Processors we use the data process service at the Annex 1.
7. IS INFORMATION ABOUT ME SECURE?
We take commercially reasonable measures to protect all collected information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Please understand that you can help keep your information secure by choosing and protecting your password appropriately, not sharing your password and preventing others from using your computer. Please understand that no security system is perfect and, as such, we cannot guarantee the security of the Website, or that your information won't be intercepted while being transmitted to us. If we learn of a security systems breach, then we may either post a notice, or attempt to notify you by email and will take reasonable steps to remedy the breach.
8. CHILDREN'S PRIVACY

8.1 Children's Privacy Notice
This privacy notice supplements our Privacy Policy and provides additional information about how we collect, use and share personal information from children under the age of 13 (a "Child" or "Children").


8.2 ProgKids is committed to Children's privacy.
Protecting the privacy of Children is especially important to ProgKids. For that reason, we created certain features designed to help protect personal information relating to Children ("Child Users"). When a Child creates an account, we seek the consent of a parent or statutory representative ("Parent") for that account.


8.3 How Children can use and register for our Service
Users may view our content and do exercises without creating an account. Functionality is limited if users do not create an account.

ProgKids does not knowingly permit Child Users to create an account without the consent of a P. If ProgKids learns that personal information of a Child User has been collected on our Service without statutory representative or consent, ProgKids will take appropriate steps to delete this information. If you are a statutory representative and discover that your child under the age of 13 has a registered account with our Service without consent, please Contact ProgKids (support@ProgKids.com) and request that we delete that child's personal information from our systems.


8.4 A Child User may sign up for a ProgKids Account with Parent consent
When a Child User registers for our Service, we request a username, birthdate, password, and a Parent's email address so that we can email the Child User's Parent in order to seek consent for the Child to use the Service. ProgKids does not ask the Child User for any more information than is necessary to provide the Service to the Child User or to seek Parent consent. The Child User is permitted to use the Service for 7 days through a Restricted Account while we notify the Parent and request consent. If we do not receive consent from the Parent within 7 days, the Child User's Restricted Account is closed, and the Child's personal information is deleted from our systems. ProgKids may rely on a School to provide consent on behalf of a Parent , as described below.


8.5 Methods for providing Parental consent
Parent may provide consent for a Child User to use the Service through a Restricted Account by responding affirmatively to an email sent by ProgKids to the Parent's email address provided by the Child User during registration. If we do not receive consent from the Parent within 7 days, the Child User's account will be closed and the Child's personal information will be deleted from our systems. Restricted Accounts may access and use certain features of the Service in a limited manner.


8.6 Parent accounts
To enable additional functionality for the Child User account and to enable full access and control over the Child User's account activity, the Parent must create a "Parent Account" on the Service and connect to the Child User's account by clicking on the account creation link in the Parental consent notice. Parent Accounts control the settings and functionality of the Child User's account. The Parent can maintain the Child's Restricted Account, and can enable additional account functionality and features, if desired. Parents can revoke a Child User's permissions to use the Service at any time by deleting the account.


8.7 Restricted Accounts for Child Users
ProgKids attempts to restrict a Child User's access to certain features that could result in disclosure of the Child's personal information. A Restricted Account limits sharing and displaying private information about the Child User in various ways.

For example, a Child User with a Restricted Account cannot:

Display personal information other than a username. Restricted Accounts contain the Child's username and do not include other personal information or profile information. Because the username may be displayed on the Service, we strongly recommend selecting a username that does not relate to or identify the real name of the Child. The Child's username can be selected or revised by the Parent by creating a Parent Account.

Add or edit personal information associated with a Restricted Account.

Post to public community forums, or post questions or answers on lessons.

Receive emails from ProgKids (all emails are sent to the Parent email on file).

Communicate with or share personal information with Teachers other than a username and Service usage activity (i.e., lessons completed, badges earned, etc.). Similarly, Teachers cannot communicate with a Child User with a Restricted Account except to assign content for the Child User.


8.8 What information we collect from a Child User, and how we use this information
We collect a username, birthdate, and Parent's email address when a Child User registers for the Service, as well as any other personal information a Parent adds to a Child User's account, as described above. We collect information about the Child User's use of the Service (lessons completed, badges earned). We also collect usage and device information, as described in this Privacy Policy .

We use this information to provide the Service and for the purposes described in this Privacy Policy . We use the Parent's email address to communicate messages about the account.


8.9 How we disclose information relating to a Child User
As described above, Restricted Accounts have limited information sharing capabilities. A username and progress information, along with any personal information the Parent added to the Child's profile, is shared with a Teacher added to the Child User's account, though a Parent Account may restrict the Child User from adding Coaches to the account. Parent may also enable additional information sharing features through a Parent Account, for example, by adding profile information and permitting the profile to be shared with Coaches and other users, or enabling the Child User to post content (e.g., questions and answers) to the Service. Parent that enable content-posting features should be aware that a Child User could post personally identifiable information in free-form content on the Service, and should monitor the Child User's posts and delete personal information if needed. We may also disclose personal information of Child Users for business purposes, as described in this Privacy Policy.


8.10 No Third Party Tracking and No Targeted Advertising
ProgKids does not display any targeted advertising on the Service. We do not disclose personal information of Child Users for direct marketing purposes or for targeted advertising purposes. In addition, we take steps to disable third party ad networks on webpages with child-directed content or when a Child User logs into a Restricted Account on the Service.


8.11 How to access, modify and delete your Children Accounts
As a Parent, you have the ability to access and control information about your Child User in the "Your Children" section of your Parent Account. To refuse future collection or use of your child's personal information, you can delete your Child User's Account by following the instructions in our Website. Please note, you must delete your Child User's account before you delete the Parent Account.

If you do not have a Parent Account associated with your Child User's Restricted Account, you may contact us at support@ProgKids.com to access or delete the Child User's account. Please note you will need the Child User's username, and we may take steps to authenticate your identity before we can provide access to the Restricted Account.
9. YOU AND YOUR CHILD'S PRIVACY RIGHTS

9.1. Access and Retention:
If you have an account registered on the Website, you can log in to view and update your account information. You have the right to obtain confirmation of whether or not we are processing personal data relating to you or your child, have communicated to you such data

so that you could verify its accuracy and the lawfulness of the processing and have the data corrected, amended or deleted where it is inaccurate or processed in violation of the GDPR.

We encourage you to contact us at support@ProgKids.com with your questions or concerns, or to request edits to your and your child's personal information, or to have it removed from our database. Requests to access, change or remove to any personal data you provided to us will be handled within 30 days.

9.2. Additional Rights for EU Territory:
If you are from the territory of the EU, you may have the right to exercise additional rights available to you under applicable laws, including:

(a) Right of Erasure: In certain circumstances, you may have a broader right to erasure of personal information that we hold about you – for example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.

(b) Right to Object to Processing: You may have the right to request ProgKids to stop processing your personal information and/or to stop sending you marketing communications.

(c) Right to Restrict Processing: You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information, we hold about you is inaccurate or unlawfully held).

(d) Right to Data Portability: In certain circumstances, you may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that we transfer the personal information to another data controller without hindrance.

9.3. Data protection officer

If you would like to exercise the rights included in this section 9 of this Policy, please contact our data protection officer (hereinafter "DPO") at dpo@ProgKids.com or at ____________________________. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.

For any complaints that we can't resolve directly, please contact our European Representative _____________________ (address: ________________________; e-mail address: support@ProgKids.com).

If you don't agree with our decision, you have the right to an effective judicial remedy or to lodge a complaint to any European Data Protection Authority. You also have the right to complain to the EU Data Protection Authority about our collection and use of your personal data. For more information, please contact your local EU Data Protection Authority. The list of European National Data Protection Authorities can be found https://edpb.europa.eu/about-edpb/about-edpb/members_en
10. MODIFICATIONS TO THIS POLICY
We will modify this Policy if our privacy practices change. We will post a modified version at ProgKids.com and notify you of such changes in a system message or in an e-mail sent to the e-mail address provided in the User Account.
11. FOR CALIFORNIA RESIDENTS
If you are a user in California, the Company's Privacy Notice for California Residents (Annex 2) applies to you. We will not share any personal data with third parties for their direct marketing purposes to the extent prohibited by California Consumer Privacy Act of 2018 (CCPA). If our practices change, we will do so in accordance with applicable laws and will notify you in advance.
12. FOR NEVADA RESIDENTS
We do not sell personal information as defined by Nevada law. However, Nevada law requires us to provide Nevada residents with an opportunity to opt out of the sale of their personal information. Nevada residents may email a request to opt out of the sale of their personal information to us at support@ProgKids.com.

Questions
If you have any questions concerning this Policy or the services, please contact us at support@ProgKids.com. You can also contact us at our contact office at 541 Jefferson Ave, Ste 100, Redwood City, CA 94063 USA.
ANNEX 1
LIST OF DATA PROCESSORS
ANNEX 2
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
PROGKIDS INC
Effective Date: _________, 2022

This Privacy Notice for California Residents (this "Notice") supplements the information contained in the Privacy Policy of ProgKids Inc. (the "Company" or "ProgKids") and applies solely to all visitors, users, and others who reside in the State of California ("User" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B personal information") from some its requirements.


1. INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:

● Publicly available information from government records.
● Deidentified or aggregated consumer information.
● Information excluded from the CCPA's scope, like:

a) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
b) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We have collected the following categories of information from users and save it at least (12) months:

Category Examples Collected A. Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, or passport number, or other similar identifiers. YES B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, , bank account number, credit card number, debit card number, or any other financial information,. Some personal information included in this category may overlap with other categories. YES C. Protected classification characteristics under California or federal law. Race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO C (1). Protected classification characteristics under California or federal law. Age (40 years or older), YES D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES (related to our Service) E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO F. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. YES G. Geolocation data. Physical location or movements. NO H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO I. Professional or employment-related information. Current or past job history or performance evaluations. NO J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

We obtain the categories of personal information listed above from the following categories of sources:

● Directly from you. For example, when you create an account to access or utilize our Services.
● Indirectly from you. For example, behavior data collected when you use or utilize our Services.
● Directly and indirectly from activity on our Website. For example, from submissions through our website portal or website usage details collected automatically.
● From third-parties that interact with us in connection with the Services we perform.

2. USE OF PERSONAL INFORMATION
We may use or disclose the personal information we collect for one or more of the following purposes:

● To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
● To provide, support, personalize, and develop our Services.
● To create, maintain, customize, and secure your Account with us.
● To process your requests, purchases, transactions, and payments and prevent transactional fraud.
● To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
● To personalize our service experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Services, third-party sites, and via email or text message (with your consent, where required by law).
● To help maintain the safety, security, and integrity of our Services, the related databases and other technology assets, and business.
● For testing, research, analysis, and product development, including to develop and improve our Services.
● To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
● As described to you when collecting your personal information or as otherwise set forth in the CCPA.
● To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.


2. SHARING PERSONAL INFORMATION
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We share your personal information with the following categories of third parties:

● Service providers, including without limitation Google Analytics (for usage analytics), Yandex and any third-party payment processors and fulfilment service providers.

3. DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE
We expect to disclose your personal information for a business purpose to the following categories of third parties:

● Service providers, including without limitation Google Analytics (for usage analytics), Yandex, Facebook and any third-party payment processors. [KS1]


4. SALES OF PERSONAL INFORMATION
The Company will not be able to sold any personal information.


5. YOUR RIGHTS
The CCPA provides California residents with specific rights to request information about the Company's collection, use and disclosure of your personal information over the prior twelve (12) (or less than twelve (12) months if our data were collected less than twelve (12) months), and ask that we provide you with the following information:

6.1 Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request, we will disclose to you:

● The categories of personal information we collected about you.
● The categories of sources from which we collect personal information.
● Purpose for collecting, using or selling personal information.
● The categories of third parties with whom we share that personal information.
● The specific pieces of personal information we collected about you (known as "data portability request").

If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold.

We do not provide these access and data portability rights for B2B personal information.

6.2 Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

● Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product

recall conducted in accordance with federal law, or otherwise perform our contract with you.

● Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

● Debug products to identify and repair errors that impair existing intended functionality.

● Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

● Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

● Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

● Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

● Comply with a legal obligation.

● Make other internal and lawful uses of that information that are compatible with the context in which you provided it.



We do not provide these deletion rights for B2B personal information.



6.3 Exercising Access, Data Portability, and Deletion Rights



To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at: support@ProgKids.com .



Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.



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



● Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:

- First Name, Last Name, Email used to register with the Company, and Phone Number

● Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.



We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.



Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.



Response timing and format



We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt ((or less than twelve (12) months if our data were collected less than twelve (12) months). The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.



We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.



Non-discrimination



We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

● Deny you goods or services.

● Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

● Provide you a different level or quality of goods or services.

● Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.



6. PERSONAL INFORMATION SALES OPT-OUT AND OPT-IN RIGHTS
We do not sell the personal information of Users, including of those we actually know are less than 16 years of age. Since we do not sell your personal information, you do not have to go through steps to opt-out or opt into the sale of your information.

7. CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update the notice's effective date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.

8. CONTACT INFORMATION
If you have any questions regarding this Notice or information we hold about you, you may contact us at support@ProgKids.com. You can also contact us at our contact office at 541 Jefferson Ave, Ste 100, Redwood City, CA 94063 USA. In order for us to take the appropriate action, please describe in reasonable detail the nature of your request or inquiry.
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