Effective Date: August 29, 2018
Cambly Kids is committed to compliance with COPPA and other children’s privacy laws. As discussed below, we obtain consent from a parent or legal guardian before collecting, using, and/or disclosing to third parties any personal information collected from a child. 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:
340 Lemon Ave #4343
Walnut, California 91789
What Information Do We Collect from Children?
We will not collect, use, and/or disclose any personal information about children without the consent of a parent or legal guardian.
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 Cambly Kids site, the parent or legal guardian is required to provide the child’s first name, gender, year of birth, 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.
· A child may edit his or her name, age range, English proficiency level, and avatar, in which case we will collect that information directly from the child.
· We collect the child’s progress and performance data generated based on the child’s interaction with the Cambly Kids Site.
· We collect video records of the child’s sessions with tutors, as well as messages between the child and the tutor.
· We assign to each child’s account a Cambly Kids user ID, which is an internal number that we use to track information associated with the account and the child’s activity.
· We also collect persistent identifiers, including cookies, IP addresses, MAC addresses, and data associated with web beacons. As discussed below, we use these identifiers for a variety of purposes, including error logging, analytics, and to collect usage information, such as when, how often, and for how long the child uses the Cambly Kids Site, as well as such information as the child’s “clicks” and pages viewed when using the Cambly Kids Site. We also may associate these identifiers or other personal information with information about the child’s hardware and software attributes, such as data about the child’s browser software and operating system, device type, and similar information. Like many websites, the Cambly Kids Site does not currently respond to “do not track” browser headers. However, you can take steps to limit cookie tracking by erasing cookies from the child’s computer or other device and by setting the child’s browser to block all cookies or warn the child before a cookie is stored. However, if you choose to block or delete cookies, certain features of the Cambly Kids Site may not operate correctly.
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 for internal purposes, as follows:
· We may use collected information 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.
· We may use the collected information, including persistent identifier information, to personalize the content that children see based on personal characteristics or preferences.
· We may also use persistent identifiers and other information 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, 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 e-mail 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 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 vendors, 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.”
· 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 involving Cambly Kids, the information we possess, including children’s personal information, 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.
Parental Rights to Review, Delete, and Control Their Child’s Personal Information
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.
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.
Children’s personal information will remain in our backup servers for a period of two weeks 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 his or her child’s personal information 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.
Effective Date and Changes to this Policy
Questions or Comments
For questions or comments regarding this Children’s Policy, please contact us at [email protected] or:
340 Lemon Ave #4343