Age of Learning, Inc. Privacy Policy

Age of Learning, Inc. (“AofL”) knows your personal privacy is very important to you. Because of our interest in protecting your privacy, we have adopted the following Privacy Policy (“Policy”) which describes the ways in which Age of Learning, Inc and its subsidiaries and affiliates (collectively, we, our, us, or the “Company”) collect, use, and disclose information about you collected on www.ageoflearning.com or and any other websites, applications, and online services that link to this Policy (the “Website”). Please note that AofL may, from time to time, update or change this Policy. Please check back periodically to determine if the Policy has been modified.

Summary of Key Points

• • Personal Information, or PI, is defined in this policy to mirror the text of the California Consumer Privacy Act (CCPA) and means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

• • We take your privacy very seriously, and we never monetize your Personal Information; we use it to enhance your experience on our platform and with our team and Company.

• • Because the security of your personal information is important to us, we only ask for PI where it serves a business purpose and try to limit the collection of PI to only what is reasonably necessary to accomplish those purposes. We also use commercially reasonable physical, technical, and administrative security measures designed to safeguard all information collected by the Website.

Assistance For Disabled Applicants

Alternative formats of this Policy are available to individuals with a disability. Please contact dl-humanresources@aofl.com for assistance.

1. Acknowledgement of Your Right to Privacy. At AofL, we believe the confidentiality and protection of personal information is one of our fundamental responsibilities. While information is critical to providing quality products and services, we recognize that one of our most important assets is your trust. Thus, the safekeeping of personal information is a priority.

2. Our Collection, Retention, and Use of Information about You. Information obtained about you (and subject to this Policy) is limited to the information that is voluntarily provided by you via this Website and through the use of “cookies.” AofL employs “cookie” technology to gather limited information about site visitors. We may use cookies to automatically collect certain technical information from your computer or mobile device over time, including when you use the Website, such as your browser type, operating system, device type, the page served, your IP address and your geolocation (if you choose to turn on your Bluetooth, wi-fi or other geolocation functionality when you use our Website).

When a server receives a request from a device which stores a cookie from a website, the server is able to use the information stored in the cookie in combination with the information stored on the server to allow the website to respond to you as an individual and to tailor their operations to your needs. A cookie cannot collect information from your computer and cannot carry any viral or other damaging files.

We also use a limited number of 3rd party analytics and performance cookies to collect information about traffic to our Website and how users use the Website. The cookie information gathered does not identify any individual visitor. It may include the number of visitors to our Website, the pages they visited on our Website, what time of day they visited our Website, whether they have visited our Website before, and other similar information. We use this information to help operate our Website more efficiently, to gather broad demographic information, and to monitor the level of activity on our Website.

We limit the use of your personal information to that which is necessary to administer our business and provide information that is of interest to you. We will use this information only in accordance with the principles set out in this Policy.

3. Limiting Employee Access to Information. Employee access to personally identifiable information is limited to those with a business reason to know such information. Employees with a business reason to access your data include those employees responding to “Contact Us” inquiries made by you, employees on our Human Resources team responding to an employment inquiry from you, members of our PlayCrew user testing team responding to your request to be a part of product testing, and our technical/information technology staff.

4. Notice At Collection For California Residents. If you are applying for a job or user testing opportunity through this Website this Section 4 describes how we handle identifiers and personal or employment related information that we receive.

4.1 Personal Information Collected: The Company collects personal identifiers and professional or employment-related information, including the following:

Identifiers: legal name, nickname or alias, postal address, telephone number, e-mail address, signature, state identification card number, and/or passport number.

Professional or Employment-Related Information: resume, CV’s, membership in professional organizations, professional certifications, work samples, and employment history.

4.2 Purposes of Use:

Recruiting:

• • • • To evaluate applicants’ qualifications for employment with the Company

• • • • To communicate with job and user testing applicants

• • • • To arrange and manage Company-sponsored recruiting or testing events

• • • • To create a talent pool for future job openings

• • • • For recordkeeping purposes

• • • • To demonstrate applicants’ agreement to, or acceptance of, documents presented to them, e.g. acknowledgement of your application or an offer letter

• • • • To evaluate and improve the recruiting process

Monitoring, Security, And Compliance:

• • • • To monitor access to Company information systems and other electronic resources

• • • • To conduct internal audits or investigations

• • • • To protect the safety and security of the Company’s facilities

• • • • To report suspected criminal conduct to law enforcement and to cooperate in investigations

4.3 Personal Information Categories from Cal. Civ. Code §1798.80(e)

• • 1. Personal Information Collected: The Company may collect categories of Personal Information listed in Cal. Civ. Code §1798.80(e) (other than those already listed in “Identifiers,” above) for security, internal identification, and candidate evaluation purposes.

• • 1. Purposes of Use: for security, internal identification, and evaluation purposes.

4.4 Characteristics of Protected Classifications Under California Or Federal Law

• • 1. Personal Information Collected: The Company collects information about race, national origin, disability, sex, and veteran status as necessary to comply with legal obligations, including the reporting requirements of the federal Equal Employment Opportunity Act, the federal Office of Contracting Compliance Programs (applicable to government contractors), and California’s Fair Employment and Housing Act.During the interview process the Company may also observe or collect the following characteristics (in addition to those listed above): (i) religion (includes dress and grooming practices and encompasses all aspects of religious belief, observance and practice); (ii) sex (includes gender, pregnancy, childbirth, breastfeeding, or related medical conditions; also, sexual orientation); (iii) disability; (iv) gender identity; (v) gender expression; (vi) marital status; (vii) age, and (viii) familial status.

       The Company collects these categories of Personal Information on a purely voluntary basis and uses the information only in compliance with applicable laws and regulations.

    2. Purposes of Use: disability, familial status, marital status, and pregnancy, childbirth, breastfeeding, and related medical conditions as necessary to comply with the Family Medical Leave Act and California law; military and veteran status as necessary to comply with leave requirements under applicable law; age incidentally to the use of birth date for birthday celebrations and identity verification; religion and pregnancy, childbirth, breastfeeding, and related medical conditions as necessary for accommodations under applicable law; national origin as necessary to comply with immigration or work visa laws; and marital status and familial status as necessary to provide benefits and for tax purposes.

4.5 Travel & Expense Information

• • 1. Personal Information Collected from Job Applicants: The Company may collect transaction information, including the following: reimbursable products or services purchased, obtained, or considered during the interview or relocation process.
    2. Purposes of Use: reimbursement of travel and lodging related expenses.

4.6 Internet

• • 1. Personal Information Collected: The Company IT systems may passively collect information about job applicants’ use of Company systems and networks in its ordinary course of business (e.g., use of guest wifi while onsite at the Company).
    2. Purposes of Use: IT security and continuity in the ordinary course of business.

4.7 Sensory or Surveillance Data

• • 1. Personal Information Collected: The Company may collect sensory or security data, including the following: audio/visual recordings of web-based interviews or user testing sessions (e.g. through an online Zoom session or similar program) and footage from on-site video security cameras.
    2. Purposes of Use: to protect the safety and security of the Company’s facilities and personnel through video security cameras, to evaluate the job applicant’s suitability for employment, and to evaluate user testing sessions.

4.8 Job Applicants Education Information

• • 1. Personal Information Collected: The Company may collect education information, including some or all of the following: academic transcripts, educational discipline records, and academic counseling records.
    2. Purposes of Use: to evaluate applicants’ qualifications for employment with the Company, eligibility for employment, and to conduct a pre-employment background check.

4.9 Profile Data

• • 1. Personal Information Collected: The Company collects profile data, including task-based evaluations or quizzes regarding applicants’ use of Company product(s) or publicly available social media information (e.g. LinkedIn).
    2. Purposes of Use: to evaluate applicants’ qualifications for employment with the Company using lawful factors.

4.10 Purposes Potentially Applicable to Any of the Categories of Personal Information Listed Above

Most commonly, the Company can accomplish its business needs simply by using aggregated, anonymous information. But occasionally the Company may also include some of an applicants’ Personal Information that has been collected in the course of specific routine administrative functions or for legal reasons. These include, but are not limited to the following:

• • • to manage and operate information technology and communications systems (like our Company wi-fi and security systems) or to facilitate risk management, insurance functions, budgeting, or strategic planning by offering an accurate profile of our employee or applicant pool; and
    • to manage or inform litigation or other legal matters involving the Company and to meet legal and regulatory requirements.

CCPA Metrics: https://www.ageoflearning.com/ccpa

5. Security Procedures to Protect Information. We maintain security standards and procedures to help prevent unauthorized access to confidential information about you. We update and test our technology to improve the protection of our information about you and to assure the integrity of our information. Please be aware, however, that no information system can be guaranteed to be 100 percent secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit over networks that we do not control, including the internet and wireless networks.

6. Restrictions on Disclosing Information to Other Parties. We do not sell, rent, or otherwise reveal specific information about your personally identifiable data. Therefore, your personal information will not be used for the purpose of independent telemarketing or direct mail marketing of any products or services by third parties.

In certain instances, we may be ordered by a governmental entity or court (or similar tribunal) to share your information with that entity or in connection with a court proceeding. In such instances, we will share your personal information without your consent, as required by a law enforcement or government agency, court order or similar document compelling us to do so in order to comply with applicable law, or to protect our legal rights or the legal rights of others. When practicable and permitted by law we will notify you first before sharing any of your information.

7. Disclosing Our Privacy Commitment to You. We want you to understand how we use the information you provide and our commitment to ensuring your personal privacy. If you have any questions about how AofL protects your confidential information, please send an email to legal@aofls.com.

8. Assignment of Information. Subject to confidentiality agreements, the terms of this Privacy Policy, and applicable law, information may be disclosed to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, transfer, or license all or a portion of our assets in bankruptcy or otherwise. This means that if some or all of our assets are acquired or otherwise transferred or licensed, including in bankruptcy, that such acquirer shall be subject to the same commitments stated under this Policy.