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Squirrel Ai Learning, Inc. (“Squirrel Ai,” “we,” “us,” “our”) offers an artificial intelligence (“AI”)-enabled education device and related software (the “Services”) for K-12 learners (“Learners”) and their parents and guardians. Our Services are made available to through company-operated or franchised Squirrel Ai learning centers (“Learning Centers”).

Parental Consent Needed

We are required by the Children’s Online Privacy Protection Act (“COPPA”) to obtain verified parental consent before we collect, use, or disclose personal information collected from Learners under 13 years of age. This notice provides the information that parents and guardians need to give informed consent to our collection, use, and disclosure of the personal information of Learners under 13 years of age who access our Services at Learning Centers.

We act as a controller for personal information collected from Learners through the Services. Our processing of Learners’ personal information is governed by our Privacy Policy. The Learning Centers may have their own privacy policies that govern the personal information collected by them in connection with the use of our Services.

I confirm that:

• I am the parent or legal guardian of the Learner associated with the account for which this consent is provided;
• I am legally authorized to provide consent on behalf of this Learner;
• The information I am providing is accurate; and
• I have reviewed this COPPA Direct Notice to Parents and Squirrel Ai’s Privacy Policy, and I consent to Squirrel Ai’s collection, use, and disclosure of my child’s personal information for the purpose of providing the Services.

By signing this form electronically, I consent to the use of electronic records and electronic signatures and understand that my electronic signature is the legal equivalent of my handwritten signature.

You may revoke your consent at any time in whole or in part. If you wish to revoke your consent, access or delete your child’s personal information, or otherwise have questions about this Direct Notice or our Privacy Policy, you may contact us at info@squirrelai.com.

What Learner Data Do We Collect?

In this notice, “Learner Data” means information considered “personal information” under COPPA that is collected from Learners through the Services. We collect only personal information from Learners that is reasonably necessary for the operation of the Services.

Our AI-driven Services analyze Learner Data to develop personalized lessons that adjust in real time to Learners’ strengths and challenges. We also use Learner Data to measure progress and provide feedback. We may collect Learners’ and their parents’ and guardians’ names, email addresses, and telephone numbers when they register for an account to use the Services and combine that information with data reflecting how they interact with the Services, perform on lessons, as well as data that Learners upload to the Services.

We and our service providers may automatically collect certain usage information whenever a Learner accesses and uses the Services. For example, we may collect information regarding:

• How often a Learner accesses certain features;
• How Learners interact with our website (including pages visited, time on site, and referral source);
• Information about the device from which they access our website or app (including IP address, device ID, browser type, operating system, and screen resolution);
• Device location information; and
• Diagnostic information.

We may collect images of your facial features through the device camera and use that data to create face prints so that we can verify your identity when you log in and assess how you are responding to the lessons provided. (We do not collect biometric information from Learners in Illinois, Texas, or Washington.)

We also collect your device location information, which we use to detect cross-region use of the device and enable you to find and recover lost devices.

We also may collect information via cookies. These technologies allow us to operate, enhance the performance and functionality of, and perform analytics on our website and app. We do not use cookies or other tracking technologies to target advertisements to Learners.

How Does Squirrel Ai Use the Learner Data?

We use Learners’ personal information for the following purposes:

• To provide our Services: We use Learners’ personal information to create accounts; facilitate the operation of the Services; enable account log-in; evaluate usage patterns, assess Learners’ responses to the materials, and map Learners’ performance and progress; and communicate regarding use of the Services.
• To improve or demonstrate the effectiveness of the Services: We use Learners’ personal information to maintain, support, enhance, evaluate, analyze, diagnose, improve, and demonstrate the effectiveness of the Services as permitted by law, including to respond to customer service and technical support requests.
• To create de-identified data: We create de-identified data from Learners’ personal information and we may use and share such de-identified data for lawful business purposes, including but not limited to, aggregate reporting, analytics, general research, developing new educational technologies and programs, and improving educational services.
• For compliance, fraud prevention, and safety: We may use Learners’ personal information as we believe is necessary or appropriate to enforce our terms and conditions; protect our rights, privacy, safety, or property, as well as the same of Learners and others; enable you to find and recover a lost device; and protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.
• To comply with law: We may use personal information as we believe is necessary and appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

Information Regarding Learner Data Retention and Deletion

You may request deletion or removal of Learner Data from the Services by submitting a request (through phone or email, or an online portal). Such requests will be handled by authorized personnel, who will delete the data from production databases and related systems as appropriate. Learner data are essential to the system since it help evaluate Learner background, levels of understanding, learning progress, etc. Squirrel Ai will automatically delete Learner Data when the Learner Data is no longer needed for the purpose for which it was obtained, typically one year after account closure or inactivity.

How Does Squirrel Ai Share Learner Data?

We will not disclose Learner Data except as follows:

• To Learning Centers: We may share personal information such as the profile, learning history, learning outcome of a Learner with the Learning Center, subject to the agreement between Squirrel Ai and the Learning Center. We do not control and are not responsible for the Learning Centers’ handling of such personal information.
• To Service Providers: We may share personal information with service providers that help us deliver the Services by offering hosting, information technology, customer support, data security, and research services. We also work with service providers to provide us with analytics and other information regarding the use of our Services, including the features used. All these purposes must be integral to providing the service.
• For Administrative, Legal, and Academic Integrity Reasons: We may disclose Learners’ personal information in response to a subpoena, court order, or when otherwise required by law; in response to bankruptcy proceedings; to defend our rights; in response to a request from law enforcement; to protect and/or defend our terms of service agreement or other policies applicable to the Services; or to protect the personal safety, rights, property, or security of any organization or individual.
• For Business Transition and Operational Purposes: In the event that Squirrel Ai is acquired by or merged with another company, or if all or a portion of its assets are transferred to another company, as part of the transfer of the business, Squirrel Ai may transfer Learners’ personal information in connection with such acquisition, merger, or transfer.

 

What Rights Does Squirrel Ai Provide for Learner Personal Information

Parents and guardians have the right to access, correct, and delete their child’s Learner Data and to ask Squirrel Ai to stop disclosing it to third parties. If we change the way we collect, use, or disclose a Learner’s personal information, we will provide you with another Direct Notice and opportunity to give consent.

Squirrel Ai’s Contact Information

Questions, comments, and requests regarding this notice should be addressed to:

info@squirrelai.com
213-316-6586
Squirrel Ai Learning, Inc., 800 Bellevue Way NE, Suite 500, Bellevue, WA 98004