Age of Learning, Inc. Privacy Policy

 

Age of Learning, Inc. (AofL) respects your privacy. To protect your privacy and provide transparency about what we do, we have adopted the following Privacy Policy (Policy) which describes the ways in which Age of Learning, Inc. and its 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 (Website(s)). 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.

Please read this Privacy Policy closely. By using the Website, you agree to the handling of your information in accordance with this Policy. If you provide us with your information (directly or indirectly through our service providers), we treat your information according to this Policy. We will use your Personal Information only in accordance with this Policy.

Summary of Key Points

• Personal information, or PI, is defined in this Policy to mirror the text of the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights 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 seriously, and we never monetize your PI.
• 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 or through the Website.

 

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. Collection and Use of Information. The PI we and our third-party service providers collect from you is limited to the information you provide to us via this Website, which may include, but is not limited to, first and last name, email, school/district, and job title. We also collect limited information about you using a variety of technologies, such as cookies. We use cookies to automatically collect certain technical information from your computer or mobile device over time, without identifying you, including, your device type, the page served, your IP address, the approximate geolocation of your computer or mobile device, and the websites you visited prior to visiting the 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. We do not knowingly collect any PI directly from users under the age of 13.Additional details about collection, retention, and use of PI are provided in Section 6 below.

 

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, for example, 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 information technology staff.

 

4. Security Procedures to Protect Information. We maintain security standards and procedures to help prevent unauthorized access to your PI. 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% 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.

 

5. 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 or other legal proceeding. In such instances, we may share your personal information without your consent, as required to do so by a law enforcement or government agency, court order or similar document compelling us to do so 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 PI.

 

6. State-Specific Privacy Rights. States with comprehensive consumer data privacy laws may provide residents with additional rights regarding our use of PI. The following applies to individuals who reside in specific jurisdictions that provide additional privacy rights, including California, Colorado, Connecticut, Utah, and Virginia (“Relevant States”).
   Under the Relevant States’ laws, we are required to disclose the categories of sources from whom we collect PI (explained below) and the third parties with whom we share it. We are also required to communicate information about rights you have under Relevant States’ laws, such as:Right to Access Specific Information and Data Portability Right: You have the right to request that we disclose certain information to you about our collection and use of PI over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
   • The categories of PI we collected about you
   • The categories of sources for the PI we collected about you
   • Our business or commercial purpose for collecting that PI
   • The categories of third parties with whom we share that PI
   • The specific pieces of PI we collected about you (also called a data portability request)
   • The business purpose for which PI was disclosed, and the PI categories that each category of recipient obtained if we disclosed PI for a business purpose

    

   Right to Correct Information: You have the right to request we update PI about you that is incorrect in our systems.

    

   Right to Delete: You have the right to request that we delete the PI that we have collected from you, subject to certain exceptions. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) the PI from our records, unless an exception applies. Please note, however, that we may need or be required to keep such information for our legitimate business purposes or to comply with applicable law.

    

   Right to Opt Out of the Sale or Sharing of Personal Information for Cross-Contextual Behavioral Advertising: We will never monetize the PI of any user of the Website by providing it to a third party in exchange for money. Some Relevant States’ laws apply a broader definition of the term “sell” that includes disclosing PI to any third party for valuable consideration.

    

   Right to Limit Sensitive Personal Information Use: You have the right to limit the use of sensitive PI regarding you.

    

   Non-Discrimination: We will not discriminate against you for exercising any of your rights.

   For details on exercising these rights, please see “Exercising Access, Disclosure, Data Portability, and Deletion Rights” below.

 

A. Information We Collect

1. We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. We have collected the following categories of PI from or about consumers within the last 12 months:

 

Category	Examples	Collected
A. Identifiers	A real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, Account name, or other similar identifiers	Yes
B. PI categories	A name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some PI included in this category may overlap with other categories.	Yes
C. Protected classification characteristics under applicable state or federal law	Sex (including gender)	No
D. Commercial information	Records of personal property; products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies	No
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information—such as fingerprints, face prints, voiceprints, iris or retina scans, keystroke, gait, or other physical patterns and sleep, health, or exercise data	No
F. Internet or other similar network activity	Browsing history; search history; or information on a consumer’s interaction with a website, application, or advertisement	Yes
G. Geolocation data	Physical location or movements	No
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	No
I. Professional or employment-related information	Current or past job history or performance evaluations	No
J. Nonpublic education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student, such as grades, class lists, student schedules, and student identification codes, maintained by an educational institution or party acting on its behalf	No
K. Inferences drawn from other PI	Profile information reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No
L. Sensitive PI	Social security number, driver’s license, state identification card, or passport number; account login, financial account, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; a precise geolocation; racial or ethnic origin; religious or philosophical beliefs; mail, email, and text message contents; and genetic data.	No

 

B. Information We Share

1. . Additionally, we are required to provide you certain information about the business and commercial purposes for which we collect and share PI.

 

Business and Commercial Purposes for Which We Use Personal Information: We may use or disclose the PI we collect from each of the Categories of PI listed above for one or more of the following purposes:

1. 1. 1. 1. • To fulfill or meet the reason you provided the information;
            • To provide, support, personalize, and develop our Website, products, or services;
            • To process your requests;
            • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and to monitor and improve our responses;
            • To provide customer service;
            • To understand how users interact with the Website;
            • To conduct research, testing, analysis, and development;
            • To detect security incidents and prevent fraud;
            • To debug and repair errors;
            • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
            • As described to you when collecting your PI or as otherwise set forth in Relevant States’ laws;
            • To advance our commercial and economic interests, such as delivering interest-based advertising of our products and services and analyzing the effectiveness of our advertising; and/or
            • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which PI held by us about our Users/consumers is among the assets transferred.

 

Categories of Personal Information We Share: We may share your PI by disclosing it to a third party for a business purpose described below. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the PI confidential, and prohibit using the disclosed information for any purpose except performing the contract.

In the preceding 12 months, we have also disclosed the following categories of PI for one or more business purposes:

 

Personal Information Category	Category of Third-Party Recipients
	Business Purpose Disclosures of Personal Information	Sales/Sharing (cross-context behavioral advertising)
A. Identifiers	Affiliates, partners, parent/subsidiary organizations, service providers, advertising networks, and government entities	Sales: none Sharing: None
B. Customer records PI categories	Affiliates, partners, parent/subsidiary organizations, service providers, and government entities	Sales: None Sharing: None
C. Protected classification characteristics under applicable state or federal law	None	Sales: None Sharing: None
D. Commercial information	None	Sales: None Sharing: None
E. Biometric information	None	Sales: None Sharing: None
F. Internet or other similar network activity	Affiliates, partners, parent/subsidiary organizations, service providers, advertising networks	Sales: None Sharing: None
G. Geolocation data	None	Sales: None Sharing: None
H. Sensory data	None	Sales: None Sharing: None
I.  Professional or employment-related information	None	Sales: None Sharing: None
J.  Nonpublic education information	None	Sales: None Sharing: None
K. Inferences drawn from other PI	None	Sales: None Sharing: None
L. Sensitive PI	None	Sales: None Sharing: None

 

C. Retention of Personal Information. We retain PI for as long as necessary to provide the services and fulfill the transactions you have requested, or for other business purposes, such as complying with our legal obligations, resolving disputes, and enforcing our agreements. We decide how long we need PI on a case-by-case basis. We may consider the following factors when making retention decisions:

1. 1. 1. 1. • Whether we are required by law to keep some types of PI for certain periods of time to comply with our legal obligations; and
            • Whether we need some of your PI for other business purposes, such as to prevent harm and ensure safety and security of our Website or protect ourselves.

 

If we determine your PI is no longer necessary using the factors above, we will generally destroy or anonymize that PI.

 

D. Exercising Access, Disclosure, Data Portability, and Deletion Rights. To exercise the access, disclosure, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either contacting us as set forth in Section 9 (Contact Us) below, or by visiting here: Privacy Portal.

 

Only you or a person registered with the applicable Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your PI.

 

For all requests, please clearly state that the request is related to “Your Privacy Rights,” indicate which type of request you are making, and provide your name, street address, city, state, zip code, and an email address or phone number where we may contact you. We are not responsible for notices that are not labeled or sent properly or that do not include complete information.

 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

1. 1. 1. 1. • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected PI or an authorized representative. We will verify your request by asking you to provide information related to your interactions with us. We will not otherwise ask for PI from you that we would not otherwise maintain as part of providing the Website or operating related services.
            • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 

We cannot respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use PI provided in a verifiable consumer request to verify the requester’s identity or authority to make the request.

 

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide the PI that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

To appeal a decision regarding a consumer rights request, please submit your appeal using our portal, email, telephone, or postal mail. Your appeal should include an explanation of the reason you disagree with our decision. Within 60 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

 

7. 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 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.

 

8. Changes to Our Privacy Policy. Our Policy will change from time to time. If we update this Policy, we will notify you by posting the revised Policy on the Website; and for certain revisions that materially expand the ways in which we use or share the information previously collected from you through the Website, we will display an alert upon Website access and/or next to the Privacy Policy.

 

9. Contact Us. Age of Learning, Inc. is located in the United States of America, and is the operator of the Website. You may contact us below if you have any questions, complaints, or other issues related to this Privacy Policy.

 

Mailing address:

Age of Learning, Inc.

Attention: Legal Department

P.O. Box 230

Glendale, CA 91209

USA

 

Telephone Number: +1.800.633.3331

Email address: privacy@aofl.com

 

Data Privacy Officer

DPO@aofl.com

101 N. Brand Blvd., 8th Floor

Glendale, California 91203