Cambly Kids Children’s Privacy Policy

Effective Date: November 16, 2020

Welcome to Cambly Kids (“Cambly Kids,” “we,” “us,” or “our”)!  Your child’s online privacy and safety are very important to us.  This Children’s Privacy describes our practices involving the online collection, use, and disclosure of personal information from children in connection with the Cambly Kids online educational service (the “Cambly Kids Site”) accessed through our website at https://www.cambly.com/kids/student.  

Cambly Kids will handle personal information collected from children as described in this Children’s Privacy Policy.  Please note, however, that some portions of the Cambly Kids site—such as the sign-up pages, direct notice to parents, and credit card payment pages—as well as the separate general-audience Cambly website and mobile application, are directed to parents of children and other adults.  Any personal information we collect from other users through these non-child-directed Cambly services and pages will be treated in accordance with the general-audience Cambly Privacy Policy, which can be accessed here: https://www.cambly.com/static/legal/pp.html.

Cambly Kids is committed to compliance with the Children’s Online Privacy Protection Act (“COPPA”) and other children’s privacy laws.  As discussed below, we obtain consent from a parent or legal guardian where required by applicable law before collecting, using, and/or disclosing personal information from a child through the use of the Cambly Kids Site.  We take children’s privacy seriously, and we encourage parents to take an active role in protecting their children’s privacy and online experience at all times.  Cambly Kids can be contacted at:

Cambly Inc.

340 Lemon Ave #4343

Walnut, California 91789

kids@cambly.com

What Information Do We Collect from Children?

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

For a child to access and use the Cambly Kids Site, a parent or legal guardian must log the child into a sub-account created and maintained through the account of the parent or legal guardian.  Prior to logging a child into the CamblyKids site, the parent or legal guardian is required to provide the child’s first name, age, and English language proficiency level.  Upon creation of the sub-account, the parent or legal guardian also must consent to the collection of personal information from the child.

After a parent logs a child into the child’s sub-account, we (and in some cases our service providers) collect personal information from the child both directly and automatically.  More specifically: 

We will not ask for more personal information from children than is reasonably necessary for children to participate in the Cambly Kids Site.  Further, although children interact directly with tutors, we do not allow children to have the option or ability to make personal information more publicly available through the Cambly Kids Site.

How Do We Use the Information We Collect from Children? 

We use the information we collect from children, as follows:

·      For the purposes for which the child provided the information, including, for example, to monitor the child’s educational progress, to provide parents and legal guardians with information and reports about the child’s performance, and to create and maintain the sub-account for the child.  We also use the collected information as necessary to provide the features and functionality of the Cambly Kids Site to children.

·      To personalize the content that children see based on personal characteristics or preferences.

·      To analyze and draw insights based on your child’s use of the Cambly Kids Site.  We use this information for a range of internal purposes, such as error logging, security, helping us improve the Cambly Kids Site, and developing new products and services. 

·      We may combine children’s personal information collected through the Cambly Kids Site with other information that we or third parties collect about children in other contexts—such as our communications with parents or legal guardians via email or phone, or customer service records related to a child’s user account.

How and with Whom Do We Share Information from Children?

Cambly Kids does not sell children’s personal information, and we do not share or disclose children’s personal information for marketing purposes, including to third parties for their own direct marketing purposes.  Moreover, as noted above, children do not have the option or ability to make personal information publicly available through the Cambly Kids Site. 

Cambly Kids may share or otherwise disclose the personal information that we collect from children as described below. 

·       With Parents or Legal Guardians.  A child’s account will be associated with the parent or legal guardian’s account, such that the parent or legal guardian can view and monitor his or her child’s progress.  A parent or legal guardian can also access video recordings of his or her child’s lesson with tutors.   

·      Tutors.  As part of the Cambly Kids Site, children can schedule and take lessons with tutors through video chat sessions.  When a child engages in a video chat session with a tutor, the tutor will receive the child’s first name and any other personal information your child shares. The tutor, through his or her own tutor account, will be able to review the child’s learning progress and offer feedback.  Children also can communicate directly with tutors outside a video chat session on the Cambly Kids Site, such as through direct messages.

·      Service Providers. We may use third-party service providers, contractors or agents to assist us in making the Cambly Kids Site available or to help us improve the Cambly Kids Site.  For example, we use a service provider to provide the video connection for the children’s tutoring sessions, and we use database hosting and data storage providers.  Such service providers may collect data themselves or obtain access to the personal information we collect from children to assist us in achieving the purposes discussed above in the section entitled “How Do We Use the Information We Collect from Children.”  A list of our service providers is available here.

·       Aggregated and De-Identified Information.  We may report aggregated, anonymous data relating to activity on the Cambly Kids Site to third parties or the general public. By way of example only, this may include the provision of reports regarding child engagement with the Cambly Kids Site and/or English-learning progress for such purposes as educational research, to evaluate the educational benefit of using the Cambly Kids Site, to improve the Cambly Kids Site, or to show the efficacy and usage when marketing the Cambly Kids Site.  Such aggregated, anonymous data will not contain any children’s personal information, including persistent identifiers. 

·       Business Transfers.  In the event of a merger, sale of capital stock or assets, reorganization, capital investment, consolidation, or similar transaction (or the due diligence in contemplation thereof) involving Cambly Kids, the information we possess, including personal information collected from children, shall be transferred as a corporate asset to the acquiring entity.  We will notify parents or legal guardians via email and/or post a prominent notice on the Cambly Kids Site of any change in ownership or uses of children’s personal information, as well as any choices available to the parent or legal guardian regarding the children’s personal information.

·       Legal.  We will use and disclose children’s personal information where we, in good faith, believe that the law or legal process (such as a court order, search warrant, or subpoena) requires us to do so or in other circumstances where we believe it is necessary to protect the rights, property, or personal safety of Cambly Kids, our users, and/or third parties.

We may share aggregated, de-identified data relating to activity on the Cambly Kids Site with third parties or the general public. By way of example only, this may include the provision of reports regarding child engagement with the Cambly Kids Site and/or English learning progress for such purposes as educational research, to evaluate the educational benefit of using the Cambly Kids Site, to improve the Cambly Kids Site, or to show the efficacy and usage when marketing the Cambly Kids Site. Such aggregated, de-identified data will not contain personal information collected from children.

Parental Rights to Review, Delete, and Control Their Child’s Personal Information

When a child’s account is first opened, we obtain consent from a parent or legal guardian to the collection, use, and disclosure of personal information from children as described in this Children’s Privacy Policy.  We also encourage parents or legal guardians to log in to their child’s account to view the child’s activities and progress.  Parents or legal guardians may also contact Cambly Kids to review the type of information collected from children or to change their consent to the collection, use, and sharing of their child’s personal information.  Parents or legal guardians may also ask us at any time to stop collecting personal information from their child and request that we delete any information we have already collected.  However, such requests may result in termination of the child’s access to and use of the Cambly Kids Site.

To contact us about these parental rights, please send us an email at kids@cambly.com or contact us at:

Cambly Inc.

340 Lemon Ave #4343

Walnut, California 91789

In any correspondence, please include the parent or legal guardian’s email address and the child’s name.  To protect children’s privacy and security, we will take reasonable steps to verify a parent or legal guardian’s identity before granting access to any children’s personal information.

Data Retention

Absent a request to delete data, we will retain personal information collected online from a child for as long as there is a subscription maintained for the child, and for a period of two years after the child’s account becomes inactive.  We retain this information after a subscription ends because when users reinstate their lapsed subscriptions, they generally want to resume lessons rather than losing their progress and starting over.  Nonetheless, after two years of inactivity, all personal information collected from a child will be automatically deleted from our active servers. 

Personal information collected from children may remain in our backup servers for a reasonable period from the date of any deletion request, after which it will be deleted and cannot be restored.  As discussed above, a parent may request to delete personal information collected from his or her child at any time during the period of the subscription or after the subscription ends. 

In the event we discover that we have collected information from a child in a manner inconsistent with legal requirements, we will either delete the information or seek parent or guardian consent for that collection.

Supplemental Privacy Notice for California Residents

This Supplemental Privacy Notice supplements the information in our Children’s Privacy Policy above, and except as provided herein, applies solely to California residents. It applies to personal information we collect on or through the Services and through other means (such as information collected offline and over the telephone).

As described above, in the preceding twelve months, we or our service providers may have collected the below categories of personal information from children for business or commercial purposes:

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

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

We describe how we share personal information above, including with our services providers and with tutors. 

Rights

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

Parents may have the right to receive information about the financial incentives that we offer to you, if any. Parents also have the right to not be discriminated against (as provided for in applicable law) for exercising certain rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services. If you ask us to delete it, you or your child may no longer be able to access or use the Services.

If you would like to exercise any of these rights on behalf of your child, please submit a request through this form or at help@cambly.com. You will be required to verify your identity before we fulfill your request. If you have an online account with us, logging into your account will serve to verify your identity and request, although we may request additional information if we believe your account has been compromised. If you do not have an account with us, or if we have reason to suspect that the security of your account is compromised, we will request additional information from you to match with our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought.

You can also designate an authorized agent to make a request on your child’s behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your child’s behalf. You will still need to verify your identity directly with us.

Do Not Sell My Info. California residents may opt out of the “sale” of their personal information. Cambly Kids does not sell personal information collected from children.

California Do-Not Track Disclosure

Cambly is committed to providing you with meaningful choices about the information collected on our Services for third party purposes. That is why we have provided links (above) to the NAI "Consumer Opt-Out" link, the DAA opt-out link, and a Google opt-out link. However, Cambly does not currently recognize or respond to browser-initiated Do-Not-Track signals, as the Internet industry is currently still working on Do-Not-Track standards, implementations and solutions.

California Shine the Light Disclosure:

California Civil Code Section 1798.83 permits customers of Cambly who are California residents to request certain information, once per year, regarding our disclosure of their personal information (as defined by California law) to third parties for their own direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such sharing. We do not currently share personal information with third parties for their own direct marketing purposes.

Effective Date and Changes to this Policy

This Children’s Privacy Policy is current as of the Effective Date set forth above. We may update this Children’s Privacy Policy from time to time to reflect changes in the Cambly Kids Site or our information processing practices.  When we make any changes to our practices under this Children’s Privacy Policy, we will change the Effective Date.  If we make a material change to this Children’s Privacy Policy, we will make reasonable efforts, taking into account available technology, to ensure that a parent receives direct notice of the changes to our practices.

Questions or Comments 

For questions or comments regarding this Children’s Policy, please contact us at kids@cambly.com or:

Cambly Inc.

340 Lemon Ave #4343

Walnut, California 91789

+1(415)830-5109