Ask ABC Mouse Privacy Policy and Notice at Collection
Effective Date: July 26, 2023
Welcome to the Ask ABC Mouse mobile application, which is owned and operated by Age of Learning, Inc.
This Privacy Policy describes the ways in which Age of Learning, Inc., and its subsidiaries (collectively, we, our, us, or the Company) collect, use, and disclose information about you and the children who use Ask ABC Mouse (Ask ABC Mouse or the Services). The Services are primarily directed toward children between the ages of 4 and 10.
Please read this Privacy Policy closely. By using the Services, you agree to the handling of your and your child’s information in accordance with this Privacy Policy. If you provide us with your information (directly or indirectly through our service providers), we treat your information according to this Privacy Policy. We will use your Personal Information only in accordance with this Privacy Policy. If we need to use your Personal Information for any other purpose, other than as disclosed herein, we will update this Privacy Policy, as explained under Section 9 (Changes to Our Privacy Policy) below.
Summary of Key Points
You should read this entire Privacy Policy and our Terms & Conditions, but here are some key points:
- Ask ABC Mouse is a free interactive educational chat app primarily for Child Users (defined below) powered by generative artificial intelligence (AI) technology, such as OpenAI’s ChatGPT. Users may ask questions or make comments (collectively prompts) to have a conversation with animated characters within the app about age-appropriate, educational topics (for example, animals and habitats). Chat responses are generated by a generative AI model that we have instructed to provide Child Users with age-appropriate, educational, and engaging responses to their prompts.
- Personal Information (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 seriously and, as much as possible, minimize the amount of PI we collect. We do not and will not ask for you to submit PI. However, our systems may automatically collect certain data considered to be PI in several states, including IP addresses and a device ID. To the extent we cannot avoid collecting such PI, we will never monetize it.
Link to Ts&Cs page
1. Users
Users of the Services include Child Users (any child under age 18 who uses the learning portion of the Services) and Adult Users (including parents and legal guardians of Child Users), collectively referred to as Users.
2. Information Collection
There are two general categories of information that we collect.
A. Information Users Provide to Us Through Ask ABC Mouse
While we expect Child Users will be the primary users of Ask ABC Mouse, Adult Users can also use it. This Section applies equally to all Users.
Ask ABC Mouse integrates speech-to-text capabilities, which requires enabling microphone access on the device being used for the Services. Once the microphone is enabled, User(s) can use their voice to interact with Ask ABC Mouse. We capture an audio file of the User’s prompts solely as a replacement for written words. Once an audio file is converted to text, it is immediately deleted.
We will not ask Users to share any PI with us; to the contrary, we ask that all Users not share any PI in their interactions with the Services. To the extent Users share PI in their interactions with the Services, we take commercially reasonable steps to filter PI out and prevent our systems from storing and processing it. Prompts from Users are (i) filtered to try to remove all profanity, all PI, and any other inappropriate language before a prompt is submitted to the AI model; (ii) after filtering, retained by us as we retain other User data as described in this Privacy Policy; (iii) after filtering, used to support the Child User’s ongoing experience and further developing and improving the Services; and (iv) after filtering, retained by our generative AI service provider(s) for a maximum of 30 days for the internal purpose of monitoring for abuse and misuse of their services.
Filtering technology may not block collection or retention of all profanity, PI, or other inappropriate language that Users choose to include in their prompts while using Ask ABC Mouse. If we determine that PI has been collected and retained by Ask ABC Mouse, we will delete such PI upon discovery or request that it be deleted as soon as possible by a service provider, which may take up to 30 days.
B.
Information We May Automatically Collect from All Users
We and our third-party service providers may use the information collected from both Child and Adult Users as follows:
- 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 educational efficacy of the Services; and to inform our understanding of the Services’ User base.
- To maintain and analyze the functioning of the Services.
- As we believe necessary or appropriate: (a) under applicable 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 affiliates, including the security of the Services; (f) to protect our rights, privacy, safety, or property, or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain (collectively, items (a)–(g) are Other Uses and Disclosures).
3. How We Use Information
We and our third-party service providers may use the information collected from both Child and Adult Users as follows:
- 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 educational efficacy of the Services; and to inform our understanding of the Services’ User base.
- To maintain and analyze the functioning of the Services.
- As we believe necessary or appropriate: (a) under applicable 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 affiliates, including the security of the Services; (f) to protect our rights, privacy, safety, or property, or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain (collectively, items (a)–(g) are Other Uses and Disclosures).
4. When We Disclose Information to Third Parties
PI collected from both Adult and Child Users will not be disclosed except for the following purposes, which include our operations purposes:
- To third parties who perform certain services for us, such as conducting research on the educational impact of the Services, or filtering User prompts sent to Ask ABC Mouse, provided that the service providers agree to keep the information confidential and to use it only for purposes that are permitted by this Privacy Policy. To the extent PI is not removed by our filtering process, such PI may also be shared with our generative AI service provider(s).
- As we believe to be necessary or appropriate as set forth above in Other Uses and Disclosures and in other instances substantially similar to those listed in this Section.
- When we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. If required or permitted to do so under the law, and if deemed necessary or warranted, we may provide notice to Users prior to the disclosure.
- Subject to confidentiality agreements, the terms of this Privacy Policy, and applicable law, information may be disclosed to service providers, advisers, 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 Privacy Policy.
Ask ABC Mouse does not knowingly collect Child User PI. Accordingly, we cannot and do not disclose the PI of any Child User to third parties for any marketing or promotional purposes, nor do we share the PI of children under the age of 16 for valuable consideration.
We also may disclose de-identified and/or aggregated User information for any other purpose as permissible by applicable law.
5. State-Specific Privacy Rights
States with comprehensive consumer data privacy laws may provide residents with additional rights regarding our use of PI. This Section applies to individuals who reside in specific jurisdictions that provide additional privacy rights, including California, Colorado, Connecticut, Utah, and Virginia (collectively, 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 (explained above). 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 twelve (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 or selling that PI.
- The categories of third parties with whom we share that PI.
- The specific pieces PI we collected about you (also called a data portability request).
- If we disclosed PI for a business purpose,the business purpose(s) for which PI was disclosed and the PI categories that each category of recipient obtained
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 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 Services 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. When we work with our advertising partners, we are disclosing certain information for their services, which are of value to us. You may be entitled to direct us to stop disclosing your PI to third parties for monetary or other valuable consideration. You can exercise such right to opt out here: Do Not Sell My Personal Information.
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.
Information We Collect and Share
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, drivers 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. | No |
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 | No |
G. Geolocation data | Physical location or movements | No |
H. Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information | Yes |
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 |
In addition, 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:
- To fulfill or meet the reason you provided the information;
- To provide, support, personalize, and develop our 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 our Services;
- 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; 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:
Business Purpose Disclosures of Adult and Child Personal Information | ||
Personal Information Category | Sharing with Third-Party Recipients | Sales to Third-Party Recipients |
A. Identifiers | Affiliates, partners, parent/subsidiary organizations, service providers, advertising networks, and government entities | None |
B. PI categories | None | None |
C. Protected classification characteristics under applicable state or federal law | None | None |
D. Commercial information | None | None |
E. Biometric information | None | None |
F. Internet or other similar network activity | None | None |
G. Geolocation data | None | None |
H. Sensory data | Service providers | None |
I. Professional or employment-related information | None | None |
J. Nonpublic education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | None | None |
K. Inferences drawn from other PI | None | None |
L. Sensitive PI | None | None |
Our 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:
- 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 Services investigate possible violations of our terms and conditions of use, or protect ourselves.
If we determine your PI is no longer necessary using the factors above, we will generally destroy or anonymize that PI.
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 10 (Contact Us) below.
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. You may also make a verifiable consumer request on behalf of your Child.
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:
- 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 our 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.
Non-Discrimination
We fully support your privacy rights and will not discriminate against you for exercising them.
Notice of Financial Incentives
We may offer special incentives to users who enroll in certain promotions. The availability of these promotions to you at any given time will vary. If we offer such programs, we may ask for your PI (such as your email address) as a prerequisite to your participation in the promotion. You can opt in to, or opt out of, our programs at any time through the same means they are offered, or by contacting us at the contact information provided in Section 10 (Contact Us) below.
Afsheen- This should link to a Do Not Sell My Personal Information page / popup. You can see the ABCmouse version in Sec. 8 of the ABCmouse privacy policy
6. Links to Other Services
Users of the Services include Child Users (any child under age 18 who uses the learning portion of the Services) and Adult Users (including parents and legal guardians of Child Users), collectively referred to as Users.
7. Location of Information Processing
The Services are controlled and operated by us from the United States. Your information may be stored and processed in any country where we have facilities or in which we engage service providers, including the United States, which may 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.
8. Security
We maintain reasonable safeguards designed to protect against loss, misuse, unauthorized access, disclosure, alteration or destruction of the PI we collect, including, but not limited to, encryption. Despite these efforts, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee the absolute security of your PI. If there is a breach of our security, we will notify you where required by law or deemed necessary and appropriate under the circumstances.
9. 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, we will either display an alert next to the Privacy Policy or display an alert upon accessing to the Services.
10. Contact Us
Age of Learning, Inc., is in the United States of America. Age of Learning, Inc. is the operator of all the Services. You may contact us below if you have any questions, complaints, or other issues related to this Privacy Policy and issues related to your or a Child User’s information for which you are responsible:
For all Accounts
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 of our Privacy Officer: privacy@aofl.com