Effective October 5, 2023

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 buy and register books, and 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:
• 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 participate, 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.

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.

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)

● Service providers

● 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 siteor 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 bycontacting usas 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 atprivacy@kibeam.comwith 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, pleasecontact 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

1432 Broadway Ste 199

Oakland, CA 94612

(855) 755-1299

Privacy@Kibeam.com