ABCmouse Privacy Policy: Australia – New Zealand - Singapore
Effective Date: October 29, 2024
1. Introduction
Welcome to ABCmouse.com® Early Learning Academy (ABCmouse), which is owned and operated by Age of Learning, Inc. We are committed to providing children with a learning environment where every activity is just as fun as it is educational and where you can feel confident that your children’s privacy is protected.
This Privacy Policy describes the ways in which Age of Learning, Inc., and its subsidiaries (collectively, we, our, us, or the Company) collect, process, and disclose information about our Users (as defined below) within Australia, New Zealand and Singapore, and the children who use the accounts of our Australian, New Zealand and Singaporean Users through ABCmouse, and any other websites, applications, and online services (Apps) that link to this Privacy Policy (collectively, the Services). Our Services are directed toward nursery school through second-grade aged children.
This Privacy Policy applies across the following jurisdictions: Australia (where the Australian Privacy Act 1988 (Cth) (AU Privacy Act) applies), New Zealand (where the New Zealand Privacy Act 2020 (NZ Privacy Act) applies), and Singapore (where the Singapore Personal Data Protection Act 2012 (SG Protection Act) applies) (collectively the Privacy Acts).
2. Personal Information
For the purposes of this Privacy Policy, the term “Personal Information” encompasses both the definition of “personal data” under the SG Protection Act and the respective definitions of “personal information” under the AU Privacy Act and NZ Privacy Act.
Please read this Privacy Policy carefully to understand our views and practices regarding your Personal Information and how we will treat it. By using the Services, you acknowledge reading this Privacy Policy and that we will use your Personal Information in accordance with the terms of this Privacy Policy. We may provide additional privacy notices to individuals at the time we collect their Personal Information. This type of an “in-time” notice will govern how we may process the Personal Information you provide at that time. If you do not agree to our use of your Personal Information in line with this Privacy Policy, please do not use the Services.
3. Types of Accounts, Services, and Users
How we collect, process, and disclose Personal Information depends on the type of account held and the type of User (as defined below). We currently offer consumers Family Accounts, which are detailed in our Terms & Conditions.
Users of the Services include Child Users (any child under 16 who uses the learning portion of the Services) and Adult Users (including parents, legal guardians and anyone with parental responsibility for Child Users, purchasers of an Account as a gift (Gift Account)), whom are collectively referred to as Users.
4. Personal Information We Collect and How We Collect it
a. Personal Information Users Provide
In addition to collections permitted or required by relevant law, we collect Personal Information directly from Users that such Users provide when using the Services, including when Adult Users create an Account, sign up for Services, or contact us with a question, comment, request, or complaint. However, we will only use or disclose this information in accordance with this Privacy Policy and applicable data protection and privacy law. Please see section 7 (When We Disclose Information to Third Parties) for more information about how we limit disclosure of Child User information.
If you created a profile/registered with us, you will have been asked to tick to agree to provide this information to access our Services, purchase our products, and/or view our content.
i. Adult Users
Adult Users are asked to provide certain Personal Information about themselves when registering for any Account, including:
1. first name; 2. last name; 3. email address; and 4. telephone number (optional).
Any other information provided at registration depends on the type of Account or Adult User. For example:
Payment information is collected from Adult Users who purchase a Family Account, including those who purchase a Gift Account for others. For your security, we do not store your complete credit card number in our databases but retain only the first six digits and last four digits so that we can identify your Account and respond to your requests, questions, or complaints.
In addition, Adult Users can provide us with information through separate password-protected sections (i.e., the Parent section) of the Services. These sections, accessible via the Menu or Settings link on the Services, allow Adult Users to administer their accounts, including when they add Child Users, provide testimonials, seek customer support, or submit comments or questions.
ii. Child Users
Adult Users who register for a Family Account are asked to provide certain Personal Information about the relevant Child Users of such Accounts during ABCmouse® registration, including:
1. the first name (or nickname); 2. birth month and year; and 3. gender of Child Users who will be accessing the Services through their Accounts.
When an Adult User submits any Personal Information relating to a Child User in connection with the Services, the Adult User represents that they have the authority to do so and agree to us using Personal Information in accordance with this Privacy Policy. To the extent legally required, we request Adult Users to consent to the processing of the Personal Information of their Child User. We may also ask Adult Users submitting Personal Information relating to a Child User that they have the capacity and authorization to do so (i.e., holder of the parental responsibility over the child).
Children can create free-form artwork. We encourage you to use the Services with your Child Users and to view and monitor any content created or uploaded (if applicable) by them. If you would like to review all content saved by your Child Users, you can access this content by clicking on the My Files menu item in each Child User’s About Me section of the Services.
Other than in the places and for the purposes explicitly disclosed in this Privacy Policy, we do not knowingly collect any Personal Information directly from Child Users under the age of 16.
b. Information Automatically Collected from Users
Our third-party service providers also use a variety of technologies, such as pixel tags and cookies (small text files that the Services save on your computer or mobile device), to automatically collect certain technical information from your computer or mobile device—see the Cookie Policy at the end of this Privacy Policy for further details about how pixel tags and cookies are used. The information we collect using pixel tags is not actively linked to our Users’ Personal Information (i.e., account data).
5. Advertising and Marketing
a. Advertising
We use third parties such as network advertisers and others to assist us in advertising, including displaying our advertisements on other websites and through social media platforms; we also may use third parties that display advertisements based on your visits to our Services, as well as other websites, and other third parties to assist us in identifying relevant advertising on our Services. These third parties may collect and use click stream information, browser type, device make, model, and operating system, device properties related to screen size, orientation, audio, battery status, device memory usage, settings, and boot time; device settings related to accessibility features (font size, theme and name of mobile carrier), language preferences, time and date, and subject of advertisements clicked or scrolled over during your visits to the Services and other websites to provide advertisements about goods and services likely to be of interest to you. Third-party ad network providers, advertisers, sponsors, and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs, and other technologies to measure the effectiveness of their ads and to personalise advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one.
Advertising to you is based on your visits to the non-child-directed portions of the Services (such as abcmouse.com.au, abcmouse.co.nz or abcmouse.com.sg) when you visit third-party websites and applications. We will never use information collected in the child-directed portions of the Services for targeted advertising purposes.
b. Marketing
We would like to send you information about our products and Services and those of our associated companies which may be of interest to you. If you have opted in to receive marketing information, you may opt out at any time. If you no longer wish to be contacted for marketing purposes please contact us via the contact details in section 15 (Complaints, Reporting Violations, and Contacting Us) or click on the Unsubscribe button at the bottom of any email received from us.
You may not opt out of receiving administrative messages from us regarding your Account, such as password reset emails, customer support messages, and emails about changes to our Privacy Policy in accordance with section 14 (Changes to Our Privacy Policy).
While we never intend to send marketing messages to children, if you believe a Child User has received a marketing communication, please contact us as described in section 15 (Complaints, Reporting Violations, and Contacting Us).
Push Notifications and SMS. Additionally, if you downloaded the App on your mobile device to access the Services, as part of your use of the Services we may ask if you would like to receive push notifications, which may include alerts and notifications, badges, banners, and sounds on your mobile device. You may choose to stop receiving push notifications at any time by changing the settings on your mobile device. We may also ask if you would like to receive SMS text messages. Please note that your network provider may charge you for the text messages you receive. To permanently stop receiving SMS text messages from us text STOP, CANCEL, or UNSUBSCRIBE in reply to any SMS text message sent by us.
6. How We Use Your Personal Information
We and our third-party service providers may use the information collected from Users for the following purposes in addition to uses permitted or required by relevant law:
a. Adult User Personal Information.
Personal Information about Adult Users may be used:
i. to generate a transaction identification number and member identification number, which is used by us to identify certain transactions and Users;
ii. to permit you to register for and use the Services, including, for example, to send you communications about Child User progress or your Account, or to allow you to provide Feedback through the Parent section. For security purposes, the Parent section is password protected;
iii. for paid Accounts, to complete and fulfill your purchase, such as to process your payments, communicate with you regarding your purchase, and provide you with related customer service;
iv. to respond to your enquiries or complaints and fulfill your requests, retrieve your password, or provide technical support;
v. to deliver our advertising to you based on your visits to the non-child-directed portions of the Services (such as www.abcmouse.com), for example, when you visit third-party websites and applications or via postal mail;
vi. to measure the effectiveness of our advertising to adults (see section 5 (Advertising and Marketing) for more information); and
vii. to send you marketing communications that we believe may be of interest to you (see section 5 (Advertising and Marketing) for more information).
b. Child User Personal Information. Personal Information about Child Users may be used:
i. to measure a Child User’s performance in activities and to adapt a Child User’s learning experience to the Child User’s learning needs; and
ii. to analyse, provide progress reports on, or provide an assessment of a Child User’s performance to the Adult User on the Account.
c. Both Adult and Child User Personal Information. Personal Information about both Adult and Child Users may be used:
i. to allow us to assess and improve the Services, its educational content, and other services we provide, for example, to improve our content and user experience; to research, evaluate, and improve the Services’ educational efficacy; and to inform our understanding of the Services’ user base;
ii. to customise, adapt, and personalise Users’ viewing and content-consumption experience, for example, by measuring a Child User’s performance in activities and adapting the Child User’s learning path to their learning needs;
iii. to maintain and analyse the functioning of the Services; and
iv. as we believe to be necessary or appropriate: (a) under applicable data protection and privacy law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to detect violations of and enforce our Terms and Conditions; (e) to protect our operations or those of any of our associates, including the security of the Services; (f) to protect our rights, privacy, safety, or property, or that of our associates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain (collectively, (a)-(g) are Other Uses and Disclosures).
We will never sell or rent the Personal Information of any User of the Services to a third party, except as described in this Privacy Policy in the context of a sale of the Company.
Where we intend to process your Personal Information for a purpose other than that for which it was originally collected, we will provide you with information on that other purpose and any relevant further information prior to such processing.
7. When We Disclose Information to Third Parties
Personal Information about both Adult and Child Users will not be disclosed except as follows or as permitted or required by relevant law:
a. to third parties who perform certain services for us, such as to process debit and credit cards; to conduct or evaluate research (such as on the educational impact of the Services); to provide us with our technical infrastructure (i.e., our host provider), and to provide us with statistics about the effectiveness of our advertising on third-party websites, provided that the service providers agree to keep the information confidential and to use it only for purposes that are set out in this Privacy Policy.
b. as we believe to be necessary or appropriate as set forth in Other Uses and Disclosures and in other instances substantially similar to those listed in this section;
c. where legally required and in certain other cases, we may make such disclosures without first providing notice to Users; and
d. subject to confidentiality agreements, the terms of this Privacy Policy, and applicable data protection and privacy 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 our assets are acquired or otherwise transferred or licensed, including in bankruptcy, that such acquirer shall be subject to the same commitments stated in this Privacy Policy.
Any third parties to whom we disclose Personal Information are governed by terms of their own privacy policy and this Privacy Policy does not apply to them.
We do not disclose the Personal Information of any Child User to third parties for any marketing or promotional purposes.
As used in this Privacy Policy, Anonymous Data means data that does not relate to an identified or identifiable natural person or Personal Information rendered anonymous in such a manner that the Data Subject is not, or is no longer, identifiable.
We may disclose Anonymous Data and/or aggregated User information for any other purpose as permissible by applicable data protection and privacy law—for example, the distribution of de-identified User records to outside researchers or the distribution of reports containing aggregate user demographic and traffic patterns—provided that no individual Adult User or Child User or any specific end-user device can be readily identified.
Our third-party service providers automatically collect certain information (including your Personal Information) directly from users of the Services in the form of the actions they take and activities they complete when using the Services. For example, from Adult Users, they may collect information about patterns of usage and order history; from Child Users, they may collect information about patterns of usage, which activities a child commences and completes, when a child starts and stops an activity, which areas of the Services the child frequents, the number of questions answered correctly or incorrectly, how many Tickets the child earns, what virtual items the child selects to exchange for Tickets, and the child’s choice of Avatar and customisation. Please refer to their privacy policies for what personal information they collect, how they use it and to who they disclose it.
8. Overseas Disclosure/Location of Personal Information Processing
The Services are controlled and operated by us from the United States of America. Your information may be transferred to, stored, and processed by us, our associates, and our third-party service providers in the United States of America and Mexico, which have data protection laws that are different from those of your country.
In addition, your information may be subject to access requests from governments, courts, or law enforcement officials in countries where it may be processed, under the laws of those countries.
By using the Services, you agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy.
9. How to Access or Correct Personal Information
An Adult User can review or change the information they provided when they registered for the Services, including by adding or removing Child Users to or from the Account, by updating information through the Parent section of the Services.
As regards Personal Information which cannot be accessed or changed through the Parent section of the Services, a User may make a request to access a copy of the Personal Information held about themselves, or a Child User associated with their Account. A User may also request to have any of their Personal Information, or the Personal Information of a Child User associated with their Account, corrected or updated. An access or correction request should be submitted as described in section 15 (Complaints, Reporting Violations and Contacting Us). We may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request and we may need to take reasonable steps to verify your identity before responding to your request. We will notify you of the outcome of your request within 20 business days.
We may refuse your request in certain circumstances permitted by law. If we are unable to fulfill your request, we will (i) inform you of the reasons why we are unable to do so; (ii) take reasonable steps to include a note with your personal information illustrating that you made a request for access or correction; and (iii) inform you of the mechanisms available to complain about the refusal.
A fee may be charged to cover our reasonable costs of locating the information in responding to your access request. If this is required we will inform you of the fee before processing the access request.
Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules. Please note that information, including Personal Information, may remain in backup or archive records, and we may retain certain data relevant to preventing fraud or future abuse or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable or Anonymous Data, account recovery, or if required by law. All retained data will continue to be subject to the Privacy Policy in effect at that time.
10. Withdrawal of Consent
For Users or Child Users located in Singapore, your consent to the collection, use and disclosure of Personal Information provided at the time of registering for Services will remain valid until such time as you withdraw by giving us reasonable notice in writing to the contact provided in section 15 (Complaints, Reporting Violations, and Contacting Us).
11. Account Cancellation and Reactivation
At any time, Adult Users may cancel their Accounts through the Parent section of the Services.
For Accounts that have been cancelled, if the Account remains inactive for 24 months, we will, subject to legal requirements to the contrary, delete all Personal Information in our active databases associated with the Account (Account Information). The 24 months is provided so that you have the ability, following cancellation of the Account or inactivity, to reactivate your Account and potentially recover previous information and resume where the Child User left off. However, we provide no guarantee and shall have no liability or obligation to ensure that all Account Information and Services-related progress will be available or accessible or all learning or personalisation features will be able to be recovered or resumed.
12. Links to Other Services
In certain sections of the Services, we may include links to external websites or applications (for example, Facebook and X (formerly known as Twitter)). However, to protect children from accessing these external websites, an Adult User will be required to enter a valid password. These websites and applications are governed by their own privacy policies or information collection practices, which may be substantially different from ours. We encourage you to review the privacy policies and information collection practices of any external websites and applications, as those parties’ practices would not be subject to this Privacy Policy.
13. Security
The security of your Personal Information is important to us, and we employ reasonable physical, technical, and administrative security measures designed to safeguard the Personal Information collected by the Services and to guard against unauthorised or unlawful processing of Personal Information and against damage to, accidental loss, or destruction of your Personal Information.
Account holders create a password in the registration process. You can help protect against unauthorised access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your account. At registration, we assign a Member ID to each Account and use those Member IDs to authenticate logins, allow access to the subscription content, and monitor compliance. The Member ID is also used to authenticate users when requesting technical support. Access to information is limited (through user/password credentials and two-factor authentication) to those employees who require it to perform their job functions.
14. Changes to Our Privacy Policy
We constantly try to provide the best services, and accordingly our Privacy Policy will change from time to time. If we update this Privacy Policy, we will notify you by posting the revised Privacy Policy on the Services, and for certain revisions that materially expand the ways in which we use or share the information previously collected from you through the Services, display an alert upon your login to the Services, or directly communicate with you (e.g., via the email address associated with your Account).
15. Complaints, Reporting Violations, and Contacting Us
We are committed to resolving any complaints about our collection or use of your Personal Information. If you want to make a complaint or inquiry regarding this Privacy Policy or our practices in relation to your Personal Information, please contact us as described below with the information regarding your complaint. We will reply as soon as we can and, in any event, within 20 business days.
We hope to resolve any complaint brought to our attention; however, if you feel that your complaint has not been adequately resolved, you reserve the right to contact the competent supervisory authority. In Australia, this is the Office of the Australian Information Commissioner(https://www.oaic.gov.au/). In New Zealand, this is the Office of the Privacy Commissioner (www.privacy.org.nz). In Singapore, this is the Personal Data Protection Commission (https://www.pdpc.gov.sg/).
Age of Learning, Inc. is located in the United States of America. Age of Learning, Inc. is the operator of all the Services. Any questions, concerns, or complaints regarding this Privacy Policy, our data collection or processing practices, or issues related to your or a Child User’s information for which you are responsible should be directed to us via any of the following methods.
Postal Address:
Age of Learning, Inc.
Attention: Legal Department
P.O. Box 230
Glendale, CA 91209
USA
Telephone Number: 800.633.3331
Email Address: privacy@aofl.com
Cookie Policy
1. What Are Cookies?
Our websites and Apps use cookies, which can be found here. Cookies are small text files placed on your device to collect standard internet log information and visitor behaviour information. The cookies may transmit information via your browser with a purpose of authenticating or identifying the computer (via, i.e., the IP address) or the User. Cookies may contain information such as registration data and User preferences.
We use cookies to:
i. automatically collect certain technical information from your computer or mobile device over time and across different websites, including when you use the Services, such as your browser type, operating system, device type, the page served, your IP address and your geolocation as described in ii below. When you download and use our App(s), we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number;
ii. collect and store information about your location to provide you with educational experiences or email updates that are tailored for your region. The location information we have access to may include (1) your postal code, if you provide one to us; and (2) the approximate geographic region your computer or mobile device is in, as determined from your IP address. However, we do not collect your street name and the name of your city/town. You may be able to change the settings on your computer or mobile device to prevent it from providing us with such IP information;
iii. we may collect information from your mobile device if you have downloaded our App(s). This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your IP address, geographic location, how you use the App(s), and information about the type of device you use. In addition, in the event our App(s) crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our App(s). This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual. In addition, if you choose to turn on your Bluetooth, wi-fi or other geolocation functionality when you use our App(s), we may collect and use your geolocation information; and
iv. we may also use third-party advertising networks to collect cookie information about Adult Users’ visits to the non-child-directed portions of the Services and to (1) deliver interest-based advertising to those Adult Users, including ABCmouse-branded advertising, when those Adult Users visit third-party websites; and (2) provide us with statistics about the effectiveness of our advertising on third-party websites. These third-party advertising networks may use this cookie information in accordance with their own privacy policies. Please refer to section 7 of our Privacy Policy (When We Disclose Information to Third Parties) for more information about what Personal Information is transferred to our third-party advertising measurement partner.
When a server receives a request from a device which stores a cookie from a website, the server can 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, likes, and dislikes by gathering and remembering information about your preferences. A cookie cannot collect information from your computer and cannot carry any viral or other damaging files.
2. Managing Your Cookies
Cookies help you to get the most out of our Services, and if you disable cookies some Services or website functionality may not be available. For example, you will not be able to remain logged into your account, and therefore you would have to log in during each page transition. If you do not want the Services to collect information through cookies, you can set your web browser or device to reject cookies from the Services.