Last Updated October 14, 2025
Kibeam Learning, Inc. (“Kibeam,” “we,” or “us”) provides a screen-free,
connected educational toy called the Kibeam Wand (the “Wand”), along with a
mobile application (the “Companion App”), books, promotional websites, and
other online or offline offerings (collectively, the “Services”).


Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we
collect, use, and share you and your child’s personal information, and to assist in
exercising the privacy rights available to you.


We may revise this Privacy Policy from time to time at our sole discretion. If
there are any material changes to this Privacy Policy, we will notify you as
required by applicable law. You understand and agree that you will be deemed
to have accepted the updated Privacy Policy if you continue to use the Services
after the new Privacy Policy takes effect.


WHAT YOU NEED TO KNOW
We want you to understand our Services and how they work. Here are a few of
the key takeaways you should know:

Parents are in control. Parents control all registration and setup of the
Wand via the Companion App. By using the App, parents can download
their content onto the Wand for the child to access. The Wand itself
cannot be used to make purchases.

By default, the Wand only processes information locally on the
device. The Wand contains a camera that is used to identify images and
words on the pages of Kibeam books. The Wand does all the work of
identifying the images by itself: we never see what the Wand camera sees
except on a limited basis when an adult gives us explicit, opt-in consent
(such as part of a specific voluntary testing program or in the context of a
limited customer support interaction). This means two things:
o First, it means you and your child can use the Wand even when you
don’t have an active internet connection, so long as you’ve
previously downloaded the book content onto the Wand using the
Companion App.
o It also means that you don’t have to worry about the Wand
uploading any personally identifiable information from you or your
child during regular use.

Neither the Wand nor the App contains any third-party advertising
technologies. While we may utilize some third-party technologies
described below in our Companion App to help us analyze and improve
the App experience, we do not share this information with third-party
advertisers.

Our promotional and store websites are designed for adults, and we
use standard web tracking technology on these sites to support our
advertising and analytics efforts. We may partner with third parties, who
use industry standard technologies such as cookies to track visitors to our
websites for adults and encourage adults to purchase our products and
services. As an adult, you can control this tracking by managing your
cookie settings (for instance by using the cookie banner that appears on
our promotional website) or otherwise by contacting us, as described in
more detail in Section V Our use of behavioral advertising is solely to
target adults, not children.
We welcome your thoughts and feedback about our practices and this policy. If
you have any questions, you can contact us at privacy@Kibeam.com.

Contents

I........... PERSONAL INFORMATION WE COLLECT.
II.......... HOW WE USE YOUR INFORMATION.
III........ DISCLOSING YOUR INFORMATION TO THIRD PARTIES.
IV........ INTERNATIONAL DATA TRANSFERS.
V......... YOUR CHOICES.
VI........ DATA RETENTION.
VII....... SECURITY OF YOUR INFORMATION.
VIII..... ADDITIONAL INFORMATION FOR RESIDENTS OF CALIFORNIA,
VIRGINIA, CONNECTICUT, UTAH, COLORADO, AND NEVADA
IX........ CHILDREN’S INFORMATION.
X......... OTHER PROVISIONS.
XI........ CONTACT US.

I. PERSONAL INFORMATION WE COLLECT.
When you use our Services, we may collect personal information from you. The
specific categories of personal information we collect depend on whether you
are an adult or child, and the requirements of applicable law. Please note that
the following sections describe our current practices as well as our practices
over the preceding 12 months.

Information You Provide to Us Directly.

Your Purchases on Our Website. If you make a purchase on our website, our
service providers will collect your billing, payment, and shipping information to
complete your purchase. If your purchase is a gift, we will also collect shipping
information about the recipient (who may be an adult or a child), along with any
gift message you choose to send.

Account Creation: To create a user account, we collect the following
information:

Adult:
  • full name
  • zip code
  • phone
  • email address
  • Wifi Access
  • Smartphone access (Y/N)
  • Smartphone operating system
Child
  • Unique enrollment ID
  • Grade level

Crash Reports. If you provide crash reports, we may collect personal
information related to such crash reports, including detailed diagnostic
information about your device and the activities that led to the crash.

Your Communications with Us. We collect personal information from you such
as email address, phone number, or mailing address when you request
information about our Services, register for our newsletter or loyalty program,
request customer or technical support, or otherwise communicate with us.

Data Collected from Voluntary Testing Programs. We have voluntary user-
testing programs to test our product including the usability of our App, new
game concepts, and other aspects of user experience. If you sign up to be a
Tester, we will access your Wand’s camera when the Wand is turned on, for the
duration of the testing program. We use this data internally solely to address
technical issues and otherwise to improve our Services.

Surveys. We may contact you to participate in surveys, or to have your child
participate in a survey with your consent. If you or your child participates, you
may be asked to provide certain information, which may include personal
information, such as your demographic information.
Social Media Content. We may offer forums, blogs, or social media pages on
other sites such as Facebook or Twitter. Any content you provide on these third-
party channels will be considered “public” and is not subject to privacy
protections.

Sweepstakes or Contests. We may collect personal information you provide for
any sweepstakes or contests that we offer. In some jurisdictions, we are
required to publicly share information of sweepstakes and contest winners.

SMS Communications. If you provide your mobile number, we may use it to
send you:
• Transactional messages such as one-time passcodes (OTP), order
updates, or service alerts.
• Promotional messages, only if you’ve explicitly “opted in” to marketing
communications.

Standard message and data rates may apply, as charged by your mobile carrier.
You may opt out at any time by replying STOP to any SMS message. For help,
contact us at support@kibeam.com. We do not share your mobile number with
third parties for marketing purposes without your explicit consent.

Conferences, Trade Shows, and Other Events. We may collect personal
information from adults when we attend or host conferences, trade shows, and
other events.

Information Collected Automatically or From Others

Information from the Kibeam Wand. The Kibeam Wand is a physical device
that can be used to interact with the Services. When you connect a Wand, the
device will send a unique device certificate via Bluetooth to your mobile device.
Once the Bluetooth connection is established, the device and App will share
information over a shared Wi-Fi connection. Once connected, we will
automatically collect information about how you have configured the Wand.

The Wand itself contains a camera, microphone, accelerometers, and buttons,
all of which are designed to let your child interact with our Services. The Wand
is designed to process all of this information locally on the device, meaning that
it is not seen or collected by us, other than in cases where an adult gives
specific opt-in consent (such as in the context of a Voluntary Testing Program,
or in the context of a customer support interaction). When you connect the
Wand to the Companion App via Bluetooth however, we will collect limited
information about your child’s use of the Wand, such as what books they read,
what activities they engage in and complete, and similar usage information.

Automatic Data Collection. We may collect certain information automatically
when you use the Companion App and our websites. This information may
include your Internet protocol (IP) address, user settings, MAC address, cookie
identifiers, mobile carrier, mobile advertising and other unique identifiers,
details about your browser, operating system or device, general location
information (e.g., to determine time zone), Internet service provider, pages that
you visit before, during and after using the Services, information about the links
you click, and other information about how you use the Services. Information we
collect may be associated with accounts and other devices.

In addition, we may automatically collect data regarding your use of our
Services, such as the types of content you interact with and the frequency and
duration of your activities. We may combine your information with information
that other people provide when they use our Services.

Our App and physical products do not contain third-party advertising
technologies. However, on our websites for parents, we, as well as third parties
that provide content, advertising, or other functionality on the Services, may use
cookies, pixel tags, and other technologies (“Technologies”) to automatically
collect information from Website Visitors. Technologies are essentially small
data files placed on your computer, tablet, mobile phone, or other devices that
allow us and our partners to record certain pieces of information whenever you
visit or interact with our websites.

Cookies. Cookies are small text files placed in your computer browsers to
store their preferences. Most browsers allow you to block and delete
cookies. However, if you do that, some aspects of the Services may not
work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a
piece of code embedded in the Services that collects information about
your engagement on that web page. The use of a pixel tag allows us to
record, for example, that you have visited a particular web page or clicked
on a particular advertisement for our Services.

Our uses of these Technologies fall into the following general categories:
Operationally Necessary. This includes Technologies that allow you
access to our Services, applications, and tools that are required to identify
irregular website behavior, prevent fraudulent activity, improve security,
or allow you to make use of our Service functionality;
Performance-Related. We may use Technologies to assess the
performance of our Services, including as part of our analytic practices to
help us understand how individuals use our Services (see Analytics
below);
Functionality-Related. We may use Technologies that allow us to offer
you enhanced functionality when accessing or using our Services. This
may include identifying you when you sign into our Services or keeping
track of your specified preferences, interests, or past items viewed;
Advertising- or Targeting-Related. We may use first party or third-party
Technologies to deliver content, including ads relevant to your interests,
on our Services or on third-party digital properties. 

See “Your Choices” below to understand your choices regarding these
Technologies.

Analytics. We may also use the following service providers to collect
information regarding behavior and demographics on our Services:

Facebook Connect. For more information about Facebook’s use of your
personal information, please visit Facebook’s Data Policy. To learn more
about how to opt-out of Facebook’s use of your information, please
click here while logged in to your Facebook account.

Google Analytics. For more information about how Google uses your
personal information (including for its own purposes, e.g., for profiling or
linking it to other data), please visit Google Analytics’ Privacy Policy. To
learn more about how to opt-out of Google Analytics’ use of your
information, please click here.

Information from Other Sources. We may obtain information about you from
other sources, including through third-party services and organizations to
supplement information provided by you. For example, if you access our
Services through a third-party application, such as an app store, a third-party
login or payment service, or a social networking site, we may collect information
about you from that third-party application that you have made public via your
privacy settings. Information we collect through these services may include your
name, your user identification number, your user name, location, gender, birth
date, email, profile picture, and your contacts stored in that service. This
supplemental information allows us to verify information that you have provided
to us and to enhance our ability to provide you with information about our
business, products, and Services.

Other Social Media Pages. We may offer publicly accessible blogs, forums,
social media pages, and private messaging features hosted on other sites. By
using these third-party sites, you assume the risk that the personal information
provided by you may be viewed and used by third parties for any number of
purposes. In addition, social media buttons such as Facebook, Instagram and
Twitter (that might include widgets such as the “share this” button or other
interactive mini-programs) may be present on our commercial websites and
portions of the Services only accessible to adults. These features may collect
your IP address, which page you are visiting on our site, and may set a cookie to
enable the feature to function properly. These social media features are either
hosted by a third party or hosted directly on our site. Your interactions with
these features apart from your visit to our site are governed by the privacy
policy of the company providing it.

Referrals and Sharing Features. Our Services may offer various tools and
functionalities that allow you to provide personal information about your friends
through our referral service. Our referral services may also allow you to forward
or share certain content with a friend or colleague, such as an email inviting
your friend to use our Services. Please only share with us contact information of
people with whom you have a relationship (e.g., relative, friend, neighbor, or co-
worker).

II. HOW WE USE YOUR INFORMATION.
We use your information for a variety of business purposes, including to:
Fulfill our contract with you and provide you with our Services, such as:
• Managing your information and accounts;
• Providing access to certain areas, functionalities, and features of our
Services;
• Answering requests for customer or technical support;
• Communicating with you about your account, activities on our Services
and policy changes;
• Undertaking activities to verify or maintain the quality or safety of our
Service or devices;
• Processing your financial information and other payment methods for
products or Services purchased;
• Analyzing and advertising our Services to parents;
• Processing applications and transactions; and
• Allowing you to register for events.

Analyze and improve our Services pursuant to our legitimate interest, such as:

• Detecting security incidents, protecting against malicious, deceptive,
fraudulent or illegal activity, and prosecuting those responsible for that
activity;
• Measuring interest and engagement in our Services, including monitoring
your interactions with the software;
• Undertaking research for technological development and demonstration;
• Researching and developing products, services, marketing or security
procedures to improve their performance, resilience, reliability or
efficiency;
• Improving, upgrading or enhancing our Services or device;
• Developing new products and services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to
exercise your rights under this Privacy Policy;
• Debugging to identify and repair errors that impair existing intended
functionality;
• Enforcing our terms and policies; and
• Complying with our legal obligations, protecting your vital interest, or as
may be required for the public good.

Provide you with additional content and services, such as:

• Furnishing you with customized materials about offers, products, and
Services that may be of interest, including new content or services;
• Auditing relating to interactions, transactions and other compliance
activities; and
• Other purposes you consent to, are notified of, or are disclosed when you
provide personal information.

Automated profiling. We may use technologies considered automated decision
making or profiling to personalize and enhance your experience with our
Services. For example, we may remember that your child likes certain games or
activities to suggest similar games or activities in future sessions, or to
recommend additional products or services within the Companion App. We will
not make automated decisions about you that would significantly affect you or
your child, unless such a decision is necessary as part of a contract we have
with you, we have your consent, or we are permitted by law. You may escalate
any concerns you have by contacting us as set forth below. For institutional
users of the Kibeam Classroom Kit, no personally identifiable data is used to
train AI models or for algorithmic decision-making without the express written
consent of the Institution and parents, per our separate Classroom Kit
Agreement.

Use De-identified and Aggregated Information. We may use personal
information and other data about you to create de-identified and aggregated
information, such as de-identified demographic information, de-identified
location information, information about the computer or device from which you
access our Services, or other analyses we create.

Share Content with Friends. The Wand and Companion App do not allow for
sharing content externally. However, we may offer sharing functionalities in our
websites directed at adults. For example, our website may allow you to provide
information about your friends through our referral services. Our referral
services may allow you to forward or share certain content with a friend, such as
an email inviting your friend to use our Services.

Notice Regarding Third-Party Websites. The Services may contain links to
other websites, and other websites may reference or link to our website or other
Services. These other websites are not controlled by us. We encourage you to
read the privacy policies of each website and application with which you
interact. We do not endorse, screen, or approve and are not responsible for the
privacy practices or content of such other websites or applications. Visiting
these other websites or applications is at your own risk.

III. DISCLOSING YOUR INFORMATION TO THIRD PARTIES.

The categories of third parties with whom we may share your personal
information are described below.
Other Users. We may offer functions as part of the Services, such as on our
social media pages, that allow you to share personal information or interact
with others. Please exercise caution before sharing information that may identify
you or your child in the real world.

Service Providers. We may share any personal information we collect about you
with our third-party service providers and vendors, who may only use your data
to provide services to us. The categories of service providers (processors) to
whom we may entrust personal information include, but are not limited to:
shipping providers, IT and related services to support our technology
infrastructure; payment processors; customer service providers; and vendors to
otherwise support the provision of the Services.

Business Partners. We may share your personal information with business
partners to provide you with a product or service you have requested, or with
whom we jointly offer products or services. In such cases, our business partner’s
name will appear along with ours, and you will have an opportunity to review
the data being transferred before choosing to participate.

Advertising Partners. On our commercial websites for parents, we may share
your personal information with third-party advertising partners. These third-
party advertising partners may set Technologies and other tracking tools on our
Services to collect information regarding your activities and your device (e.g.,
your IP address, cookie identifiers, page(s) visited, location, time of day). These
advertising partners may use this information (and similar information collected
from other services) for purposes of delivering personalized advertisements to
you when you visit digital properties within their networks. This practice is
commonly referred to as “interest-based advertising” or “personalized
advertising. If you prefer not to share your personal information with third-
party advertising partners, you may follow the instructions in “Your Choices”
below to opt out.

APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”)
and software development kits (“SDKs”) as part of the functionality of our
Services. APIs and SDKs may allow third parties including analytics and
advertising partners to collect your personal information for various purposes,
including to provide analytics services and content that is more relevant to you.
For more information about our use of APIs and SDKs, please contact us as set
forth in “Contact Us” below.

In addition, we share information in the following scenarios:

Disclosures to Protect Us or Others. We may access, preserve, and disclose
any information we store about you to external parties if we, in good faith,
believe doing so is required or appropriate to: comply with law enforcement or
national security requests and legal process, such as a court order or subpoena;
protect your, our or others’ rights, property, or safety; enforce our policies or
contracts; collect amounts owed to us; or assist with an investigation or
prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are
involved in an actual or proposed merger, acquisition, financing due diligence,
reorganization, bankruptcy, receivership, purchase or sale of assets, or transition
of service to another provider, then your information may be sold or transferred
as part of such a transaction. We will make this disclosure in accordance with
applicable law and/or contract, and notify you of this change as required by law
and/or contract.

IV. INTERNATIONAL DATA TRANSFERS
All information processed by us may be transferred, processed, and stored
anywhere in the world, including, but not limited to, the United States or other
countries, which may have data protection laws that are different from the laws
where you live. We endeavor to safeguard your information consistent with the
requirements of applicable laws.

If we transfer personal information which originates in the European Economic
Area, Switzerland, and/or the United Kingdom to a country that has not been
found to provide an adequate level of protection under applicable data
protection laws, one of the safeguards we may use to support such transfer is
the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of
your personal information, please contact us as set forth in Contact Us below.

V. YOUR CHOICES.
General.

You have certain choices about your personal information. Where you have
consented to the processing of your personal information, you may withdraw
that consent at any time and prevent further processing by contacting us as
described below. Even if you opt out, we may still collect and use non-personal
information regarding your activities on our Services and for other legal
purposes as described above.

Email and Telephone Communications.

If you receive an unwanted email from us, you can use the unsubscribe link
found at the bottom of the email to opt out of receiving future emails. Note that
you will continue to receive transaction-related emails regarding products or
Services you have requested. We may also send you certain non-promotional
communications regarding us and our Services, and you will not be able to opt
out of those communications (e.g., communications regarding the Services or
updates to our Terms or this Privacy Policy).

Mobile Devices.

We may send you push notifications through our mobile application. You may at
any time opt-out from receiving these types of communications by changing the
settings on your mobile device.

“Do Not Track.”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web
browsers. Additionally, some browsers or plug-ins use a “Global Privacy
Control” (“GPC”), which you can learn more about
at https://globalprivacycontrol.org/. Please note that we do not respond to or
honor DNT signals or similar mechanisms transmitted by web browsers.
However, if our site detects a GPC signal from your device, we will interpret it
as a Do Not Sell request under California law.

Opting out of Cookies, Interest-Based Advertising, and Analytics.

As noted above, our websites directed to parents use various Technologies to
provide advertising, analytics, and other services in connection with our Service.
You may stop or restrict the placement of these Technologies on your device by
selecting “decline” when prompted with our site’s cookie banner, using a GPC
signal as described above, or you may remove cookies altogether by adjusting
your preferences as your browser or device permits. Note that, if you remove or
reject all cookies, our Services may not work properly. Please note that cookie-
based opt-outs are not effective on mobile applications.
You may opt-out of personalized advertisements on some mobile applications
by following the instructions for Android, iOS, and others. The online
advertising industry also provides websites from which you may opt out of
receiving targeted ads from data partners and other advertising partners that
participate in self-regulatory programs. You can access these and learn more
about targeted advertising and consumer choice and privacy by visiting
the Network Advertising Initiative, the Digital Advertising Alliance, the
European Digital Advertising Alliance, and the Digital Advertising Alliance of
Canada. Please note you must separately opt out in each browser and on each
device.
Your Privacy Rights.
In accordance with applicable law, you may have the following rights:

Access to and Portability of Your Personal Information (the “right to
know”/ “right of data portability”), including: (i) confirming whether we
are processing your personal information; (ii) obtaining access to or a copy
of your personal information; and (iii) receiving an electronic copy of
personal information that you have provided to us, or asking us to send
that information to another company in a structured, commonly used, and
machine readable format;
Request Correction of your personal information where it is inaccurate or
incomplete. In some cases, we may provide self-service tools that enable
you to update your personal information;
Request Deletion of your personal information;
Request Restriction of or Object to our processing or sharing of your
personal information where such rights are granted under applicable law;
and
Withdraw your Consent to our processing of your personal information.
Please note that your withdrawal will only take effect for future
processing, and will not affect the lawfulness of processing before the
withdrawal.

If you would like to exercise any of these rights, please contact us as set forth
in Contact Us below. We will process such requests in accordance with
applicable laws. To protect your privacy, we will take steps to verify your
identity before fulfilling your request, such as by requiring you to log in to your
account or answer questions regarding your activities on our Services. Once you
have verified your account ownership, and as permitted under applicable law,
you may also provide written confirmation authorizing an agent to exercise
these rights for you.

You have a right not to receive discriminatory treatment as a result of your
exercise of these rights.

VI. DATA RETENTION.

We store the personal information we receive as described in this Privacy Policy
for as long as you use our Services or as necessary to fulfill the purpose(s) for
which it was collected, provide our Services, resolve disputes, establish legal
defenses, conduct audits, pursue legitimate business purposes, enforce our
agreements, and comply with applicable laws.

VII. SECURITY OF YOUR INFORMATION.

We take steps to ensure that your information is treated securely and in
accordance with this Privacy Policy. Unfortunately, no system is 100% secure,
and we cannot ensure or warrant the security of any information you provide to
us. To the fullest extent permitted by applicable law, we do not accept liability
for unintentional disclosure.

By using the Services or providing personal information to us, you agree that we
may communicate with you electronically regarding security, privacy, and
administrative issues relating to your use of the Services. If we learn of a
security system’s breach, we may attempt to notify you electronically by posting
a notice on the Services, by mail or by sending an e-mail to you.

VIII. ADDITIONAL INFORMATION FOR RESIDENTS OF
CALIFORNIA, VIRGINIA, CONNECTICUT, UTAH, COLORADO,
AND NEVADA.

Depending on how you use our Services, the information we may have collected
within the last twelve (12) months about you, as well as the categories of third
parties with whom we have shared this information, are described in the table
below.
Category of Personal Information Collected by Kibeam Category of Third Parties Personal Information is Disclosed to for a Business Purpose Category of Third Parties to Whom Personal Information is Sold and/or Shared
Identifiers.
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
  • Service providers
  • Other users or third parties you share or interact with
  • Advertising partners (personal identifiers shared in order to provide targeted advertising to adults)
  • Data analytics providers (mobile identifiers only)
  • Service Providers (such as for analytics)
  • Advertising partners (personal identifiers shared in order to provide targeted advertising to adults)
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
A name, address, credit card number, debit card number, or any other financial information.
  • Service providers (e.g., shipping providers)
n/a
Protected classification characteristics under California or federal law
Age (40 years or older).
  • Service providers
  • Ad networks (for compliance purposes only)
  • Ad networks (for compliance purposes only)
Commercial information
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Service providers (e.g., e-commerce and shipping partners, analytics providers)
  • Advertising partners (for targeted advertising to adults only)
  • Service providers
  • Advertising partners (for targeted advertising to adults only)
Internet or other electronic network activity
Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement.
  • Service providers
  • Advertising partners (shared to provide targeted advertising to adults only)
  • Service providers
  • Advertising partners (shared to provide targeted advertising to adults only)
Inferences drawn from other personal information to create a profile about a consumer
Profile reflecting a consumer’s preferences.
  • Service providers
  • Advertising partners (shared to provide targeted advertising to adults only)
  • Service providers
  • Advertising partners (shared to provide targeted advertising to adults only)
Sensory data
Audio, electronic, visual, thermal, olfactory, or similar information.
  • Service providers
n/a


We may use or disclose the Personal Information we collect for the purposes
outlined in Use of Information above. Where required under applicable law, we
will not collect additional categories of Personal Information or use the Personal
Information we have collected for materially different, unrelated, or
incompatible purposes without first providing you notice.

We do not sell your personal information, nor have we sold your personal
information in the preceding 12 months, as the term “sale” is commonly
understood. Likewise, we do not have actual knowledge of any sale of personal
information of minors under 16 years of age, and we do not disclose "sensitive
personal information” as the term is defined under California law. That said, we
may share the personal identifiers of adults with third-party advertising
partners for the purpose of promoting our Services as described above. You may
limit such sharing by following the instructions found in in “Your Rights and
Choices” below.

Your Rights and Choices.

Subject to applicable law, if you are a resident of California, Virginia,
Connecticut, Utah, or Colorado, you may have the following rights:

To Know and Access: to obtain a copy of the specific pieces of Personal
Information we have collected about you. (Note that this right only
applies to Personal Information relating to you, and not to any other user.)

Deletion: to request that we delete your Personal Information. This right
may be limited to the extent that we are permitted or required by
applicable law to retain certain information. (Note that if you request
deletion of your Personal Information, you may no longer be able to use
or access the Services. If you decide to use or access the Services again,
we may consider this a new account, and may collect Personal
Information associated with that account in accordance with this Privacy
Policy.)

Opt-Out of “Sale” and Certain Sharing Practices: you have the right to
opt-out of certain information sharing practices with third parties who do
not act as our service providers. In some states, like California, this
information sharing may qualify as a “share” or a “sale,” while in other
states, like Virginia, this information sharing may qualify as “targeted
advertising” (collectively, “personalized advertising”). If you wish to opt-
out of personalized advertising, you can opt out of said sharing by using
the cookie banner available on our site or by contacting us as set forth
below.

Correction: to request the correction of inaccurate Personal Information
that we may have on file about you.

Obtain additional details regarding our information practices: You may
have the right to request disclosures regarding our information practices.
(Note that this information is generally available in this Privacy Policy).
We will not discriminate against you, in terms of price or services that we offer,
if you exercise any of the rights listed above.

Verification and Appeal Process: We are required by law to take reasonable
steps to verify your identity prior to responding to your request. Please note
that your exercise of these rights is subject to certain exemptions to safeguard
the public interest (e.g., the prevention or detection of crime) and our interests
(e.g., the maintenance of legal privilege). If we are unable to process your
request via you authenticating yourself on the Services, we may verify your
request by asking for information sufficient to confirm your identity, based on
the information we have on file. Requests to exercise these rights may be
granted in whole, in part, or not at all, depending on the scope and nature of the
request and as permitted by applicable law. Where required by applicable law,
we will notify you if we reject your request, and notify you of the reasons we are
unable to honor your request.

If you are a resident of Colorado, Virginia, or Connecticut, you have the right to
appeal a request we deny when we have verified your identity and still decline
to honor your request. The process for that appeal will be sent to you separately
if your request is denied.

Authorized Agent: Depending on where you live, you may have the right to use
an authorized agent on their behalf to exercise a privacy right discussed above.
If you are an authorized agent acting on behalf of a user to communicate with us
or to exercise a privacy right discussed above, you must be able to demonstrate
that you have the requisite authorization to act on behalf of the user, and have
sufficient access to that user’s laptop, desktop, or mobile device to exercise that
user’s right digitally. If you are an authorized agent trying to exercise rights on
behalf of one of our users, then you can make a request on the user’s behalf
by contacting us as set forth below: Such requests must include the following
information: (1) a written authorization from the consumer that includes the
consumer’s full name, address, telephone number and valid email address used
by the consumer to interact with us, that is signed by the consumer and clearly
bestows upon the agent the proper authority; and (2) a certificate of good
standing with your state of organization. Alternatively, an acting agent can
provide a valid power of attorney signed by the consumer on the agent’s behalf
and a valid email address used by the consumer to interact with us. The email
address of the consumer will be used to separately verify the agent’s authority
with the consumer.

Refer-a-Friend, Promotions, and Similar Incentive Programs: We may offer
referral programs, promotions such as sweepstakes, or other incentivized
information collection programs. We may offer incentives to you such as
discounts or promotional items or credit in connection with these programs,
wherein you provide Personal Information regarding your friends or colleagues
(such as their email address) and receive rewards when they sign up to use our
Services. (The referred party may also receive rewards for signing up via your
referral.) Alternatively, we may ask you to provide your Personal Information in
exchange for a reward or participation in a promotion. These programs are
entirely voluntary and allow us to grow our business and provide additional
benefits to you. The value of your information to us depends on how you
ultimately use our Services, whereas the value of the referred party’s
information to us depends on whether the referred party ultimately uses our
Services. Said value will be reflected in the incentive offered in connection with
each program. You may withdraw from the incentives at any time. In order to
withdraw from the financial incentive, please contact us as described below.

Shine the Light Disclosure: California residents are entitled to ask us for a notice
that identifies the categories of Personal Information that we share with our
affiliates and/or third parties for marketing purposes, and provides contact
information for such affiliates and/or third parties. If you are a California
resident and would like this information, please submit a written request to us
using the contact information below.

De-Identified Information. If we create or receive de-identified information, we
will not attempt to reidentify such information, except to comply with applicable
law.

Supplemental Notice for Nevada Residents.

If you are a resident of Nevada, you have the right to opt-out of the sale of
certain personal information to third parties who intend to license or sell that
personal information. You can exercise this right by contacting us
at privacy@kibeam.com with the subject line “Nevada Do Not Sell Request” and
providing us with your name and the email address associated with your
account. Please not that we do not currently sell your personal information as
sales are defined in Nevada Revised Statutes Chapter 603A. If you have any
questions, please contact us as set forth in Contact Us below.

IX. CHILDREN’S INFORMATION.

Protecting children’s privacy online is very important to us. We require a
parent’s consent before collecting any information from a child, and limit
personally identifiable information collection and sharing from children to only
what is necessary to support the internal operations of our Services, and/or to
provide parents with tailored content recommendations.

If you are a parent or guardian and wish to review information collected from
your child, or have that information modified or deleted, you may contact us as
described below. If we become aware that a child has provided us with personal
information without the parent’s consent, we will delete any personal
information we have collected, unless we have a legal obligation to keep it, and
if applicable, terminate the child’s account.

X. OTHER PROVISIONS.

Notice Regarding Third-Party Websites. The Services may contain links to
other websites, and other websites may reference or link to our website or other
Services. These other websites are not controlled by us. We encourage you to
read the privacy policies of each website and application with which you
interact. We do not endorse, screen or approve and are not responsible for the
privacy practices or content of such other websites or applications. Visiting
these other websites or applications is at your own risk.

Supervisory Authority. If your personal information is subject to the applicable
data protection laws of Australia, Brazil, the European Economic Area,
Switzerland, or the United Kingdom, you have the right to lodge a complaint
with a supervisory authority if you believe our processing of your personal
information violates applicable law.

• Office of the Australian Information Commissioner
• Autoridade Nacionalde Proteçãode Dados (ANPD)
• EEA Data Protection Authorities (DPAs)
• Swiss Federal Data Protection and Information Commissioner (FDPIC)
• UK Information Commissioner’s Office (ICO)
• Spanish Data Protection Agency (AEPD)

XI. CONTACT US.

If you have any questions about our privacy practices or this Privacy Policy, or if
you wish to submit a request to exercise your rights as detailed in this Privacy
Policy, please contact us at:

Kibeam Learning, Inc.

Attn: DPO

1440 Broadway Ste 200-199

Oakland, CA 94612

(855) 755-1299

Privacy@Kibeam.com