Last modified: 01.15.2021
1. Children under the Age of 13
The Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”) require us to inform parents and legal guardians (as used in this section, “parents”) about our practices for collecting, using, and disclosing personal information from children under the age of 13 (“children”). It also requires us to obtain verifiable consent from a child’s parent for certain collection, use, and disclosure of the child’s personal information.
This section notifies parents of:
● The types of information we may collect from children.
● How we use the information we collect.
● Our practices for disclosing that information.
● Our practices for notifying and obtaining parents’ consent when we collect personal information from children, including how a parent may revoke consent.
● All operators that collect or maintain information from children through this Service.
This section only applies to children under the age of 13 and supplements the other provisions of this Policy. Only the other provisions of this Policy apply to teens and adults.
1.1. Information We Collect from Children.
Children can access some parts of the Service without providing us with personal information. However, some content and features are available only to registered users. In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they visit or use the Service.
We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary.
PLEASE NOTE THAT THE PERSONAL INFORMATION WE COLLECT INCLUDES PERSONAL INFORMATION HELD IN RECORDINGS OF TEACHING SESSIONS, AS DESCRIBED IN GREATER DETAIL IN SECTION 4.
1.1.1. Information We Collect Directly
A child must provide us with the following information to register with the Service: the child’s name, birth date, grade level, and a parent’s email address. We also require the child to create a member name and password. We may request additional information from your child, but this information is optional. We specify whether information is required or optional when we request it.
1.1.2. Automatic Information Collection and Tracking
We use technology to automatically collect information from our users, including children, when they access and navigate through the Service and use certain of its features. The information we collect through these technologies may include:
● One or more persistent identifiers that can be used to recognize a user over time and across different websites and online services;
● Personal information held in recordings of teaching sessions (see Section 4, Audio/Visual Recordings)
● Information that identifies a device’s location (geolocation information).
We also may combine non-personal information we collect through these technologies with personal information about you or your child that we collect online.
For more information about our automatic information collection practices, including how you can opt out of certain information collection, see Section 3.2, Information We Collect Through Automatic Data Collection Technologies; and Section 7, Choices About How We Use and Disclose Your Information.
1.2. How We Use Your Child’s Information
We use the personal information we collect from your child to:
● register him or her with the Service;
● communicate with him or her about activities or features of the Service that may be of interest;
● improve the Service;
● track his or her performance in the Service, including live sessions and games or other activities.
We use the information we collect automatically through technology (see Section 3.2, Information We Collect Through Automatic Data Collection Technologies) and other non-personal information we collect to improve our Service and to deliver a better and more personalized experience by enabling us to:
● Estimate our audience size and usage patterns.
● Store information about the child’s preferences, allowing us to customize the content according to individual needs and interests.
● Store information about the child’s progress, allowing us to adjust to meet the child’s individual learning needs.
● Speed up your searches.
We use geolocation information we collect to optimize technology across regions.
1.3. Our Practices for Disclosing Children’s Information
We do not share, sell, rent, or transfer children’s personal information other than as described in this Section 1.
We may disclose aggregated information about many of our users, and information that does not identify any individual. In addition, we may disclose children’s personal information:
● To third parties we use to support the internal operations of our Service and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.
● If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.
● If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Savvy, our customers or others, including to:
o protect the safety of a child;
o protect the safety and security of the Service; or
o enable us to take precautions against liability.
● To law enforcement agencies or for an investigation related to public safety.
In addition, if Savvy is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Savvy’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the personal information we have collected or maintain to the buyer or other successor.
1.4. Accessing and Correcting Your Child’s Personal Information
At any time, you may review the child’s personal information maintained by us, require us to correct or delete the personal information (subject to the limitations in Section 9), and/or refuse to permit us from further collecting or using the child’s information.
You can review, change, or delete your child’s personal information by:
● Logging into your child’s account and visiting his or her account profile page.
● Sending us an email at email@example.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.
1.5. Operators That Collect or Maintain Information from Children
A list of all operators that may collect or maintain personal information from children through the Service is available at the end of this document. Please direct your inquiries about any operator’s privacy practices and use of children’s information to the operator at its contact information provided.
2. Children Under the Age of 16
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Section 9, Your California Privacy Rights for more information.
3. Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Site, including the following:
● Personal information;
● Information that is about you but individually does not identify you, such as age, gender, grade level, reading level, and attendance patterns; and/or
● Information about your internet connection, the equipment you use to access our Site, and usage details.
We collect this information:
● Directly from you when you provide it to us.
● Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.
3.1. Information You Provide to Us
The information we collect on or through our Site may include:
● Information that you provide by filling in forms on our Service. This includes information provided at the time of registering to use our Service, subscribing to our Service, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Service.
● Records and copies of your correspondence (including email addresses), if you contact us.
● Your responses to surveys that we might ask you to complete for research purposes.
● Details of transactions you carry out through our Service and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Service.
● Personal data held in recordings of teaching sessions (see Section 3.3, Audio/Visual Recordings)
● Your search queries on the Service.
3.2. Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
● Details of your visits to our Service, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.
● Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Service and to deliver a better and more personalized service, including by enabling us to:
● Estimate our audience size and usage patterns.
● Store information about your preferences, allowing us to customize our Service according to your individual interests.
● Speed up your searches.
● Recognize you when you return to our Site or Service.
The technologies we use for this automatic data collection may include:
Web Beacons. Pages of our Service and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Savvy, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
4. Audio/Video Information
In order to improve our Service and the overall user experience, we may record teaching sessions delivered through the Service. Such recordings may include both audio and visual information, which may include personal information. We do not share such audio or video recordings or the personal information they contain with third parties. We may use share aggregated or statistical data that does not identify any individual that is derived from such audio or video recordings as permitted elsewhere in this Policy.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Section 7, Choices About How We Use and Disclose Your Information.
6. How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
● To present our Service and its contents to you.
● To provide you with information, products, or services that you request from us.
● To fulfill any other purpose for which you provide it.
● To provide you with notices about your account or subscription, including expiration and renewal notices.
● To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
● To notify you about changes to our Service or any products or services we offer or provide though it.
● To allow you to participate in interactive features of our Service.
● In any other way we may describe when you provide the information.
● For any other purpose with your consent.
We may also use your information to contact you about our own goods and services that may be of interest to you. If you do not want us to use your information in this way, please see Section 7, Choices About How We Use and Disclose Your Information.
7. Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide as described in this Policy:
● To our subsidiaries and affiliates.
● To contractors, service providers, and other third parties we use to support our business.
● To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Savvy’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Savvy about our Site users is among the assets transferred.
● To fulfill the purpose for which you provide it.
● For any other purpose disclosed by us when you provide the information.
● With your consent.
We may also disclose your personal information:
● To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
● If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Savvy, our customers, or others.
8. Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
8.1. Contact Address and Telephone
You may be asked to provide your mailing address or telephone number for Savvy to be able to send materials and information regarding Savvy’s Service. Examples include the “Savvy Silver Reward” items. Providing this information is optional but is required for us to be able to perform the relevant services.
8.2. Technical Support
You may elect to communicate information regarding technical issues which may be used to improve Savvy products and services and to provide training.
8.3. Promotional Offers from Savvy
If you do not wish to have your contact information used by Savvy to promote our own products or services, you can opt-out by sending us an email stating your request to firstname.lastname@example.org. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to Savvy as a result of a Service subscription or other transactions.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
9. Accessing and Correcting Your Information
You can review and change your personal information by logging into the Site and visiting your account profile page.
You may also send us an email at email@example.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. PLEASE NOTE THAT WE CANNOT DELETE PERSONAL INFORMATION HELD IN RECORDINGS OF TEACHING SESSIONS.
10. Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa.
11. Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
It is our policy to post any changes we make to our Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Site home page. The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this Policy to check for any changes.
13. Contact Information
To ask questions or comment about this Policy and our privacy practices, contact us at: firstname.lastname@example.org.
List of Operators
There are no operators that have access to this information at this time.