Privacy Policy

A. 4. How We Use Information

We will never monetize the PI of any User of the Services by providing it to a third party in exchange for money, except as described in this policy in the context of a sale of the Company.

We and our third-party service providers may use the information collected from Users as follows:

User Information Information collected from Users may be used:

• To permit you to register and use the Services, including, for example, to send you communications your usage or your Account, or to allow you to provide Feedback.

• To respond to your inquiries and fulfill your requests, retrieve your password, or provide technical support. While it is never our intention to send any marketing messages to children, if you believe a Child User has received such a marketing communication, please contact us as described in Section 13 (Contact Us) below. You can always choose to stop receiving these marketing messages by simply following the instructions contained in the message or, if the communication is by phone, informing the caller of your desire not to receive further phone communications. For all Accounts, you may not opt out of receiving administrative messages from us regarding your Account, such as password reset emails, and customer support messages.

• To deliver our advertising to you based on your visits to the non-child-directed portions of the Services (such as Little Classical Musician), for example when you visit third-party websites and applications or via postal mail. We do not currently respond to web browser “do not track” signals due to lack of standardization regarding how that signal should be interpreted; however, you may opt out of receiving online interest-based advertising from our interest-based advertising providers by visiting www.aboutads.info/choices. For more information about web browser “do not track” signals, visit www.allaboutdnt.org. California residents have additional rights under the CCPA. For more information please see Section 8 below.

• To measure the effectiveness of our advertising to adults.

User Information Information collected from Users may be used:

• To allow us to assess and improve the Services, its educational content, and other services we provide, for example, to improve our content and user experience; to research, evaluate, and improve the Services’ educational efficacy; and to inform our understanding of the Services’ user base.

• To customize, adapt, and personalize Users’ viewing and content-consumption experience, for example, by measuring a User’s performance in activities and adapting the User’s learning path to their learning needs.

• To maintain and analyse the functioning of the Services.

• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to detect violations of and enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates, including the security of the Services; (f) to protect our rights, privacy, safety, or property, or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain (collectively, (a)-(g) are Other Uses and Disclosures).
  

B. 5. When We Disclose Information to Third Parties

Information collected from Users will not be disclosed except as follows:

• To third parties who perform certain services for us, such as process credit cards or conduct or evaluate research (such as on the educational impact of the Services), provided that the service providers agree to keep the information confidential and to use it only for purposes that are permitted by this Privacy Policy. By continuing to use the Services, you are intentionally directing us to transmit the information submitted to us by Users to our affiliates and business partners for business purposes, such as executing transactions and preventing fraud.

• As we believe to be necessary or appropriate as set forth above in Other Uses and Disclosures and in other instances substantially similar to those listed in this Section.

• Where we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. If required or permitted to do so under the law, and if deemed necessary or warranted, we may provide notice to Users prior to the disclosure.

• Subject to confidentiality agreements, the terms of this Privacy Policy, and applicable law, information may be disclosed to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, transfer, or license all or a portion of our assets in bankruptcy or otherwise. This means that if some or all our assets are acquired or otherwise transferred or licensed, including in bankruptcy, that such acquirer shall be subject to the same commitments stated under this Privacy Policy.

In addition, with respect to Consumer and Other Accounts, we may use third-party advertising networks and other affiliates in association with cookies, pixel tags, or IFrames, for Users’ visits to the non-child-directed portions of the Services and to (1) deliver interest-based advertising to those Users, including our advertising, when those Users visit third-party websites; and (2) provide us with statistics about the effectiveness of our advertising on third-party websites. These third-party advertising networks may use this cookie information in accordance with their own privacy policies.

We do not disclose the PI of any User to third parties for any marketing or promotional purposes. This also means that we do not share the PI of children under the age of 16 for valuable consideration.

We also may disclose de-identified and/or aggregated User information for any other purpose as permissible by applicable law—for example, the distribution of de-identified user records to outside researchers or the distribution of reports containing aggregate user demographic and traffic patterns—provided that no individual User or User or any specific end-user device can be readily identified.

C. 6. How to Access, Change, or Delete Account Information

A User can review or change the information they provided when they registered for the Services, including by updating their personal information, or by editing their Child User information. In addition, Users may contact us at any time as described in Section 13 (Contact Us) below to request that we provide for their review, or delete from our records, any PI they have provided about Users associated with their Accounts, or to cease collecting PI from those Users, as applicable. Please keep in mind that a request to delete PI may lead to cancellation of your Account or the inability to use certain Services.

When we change or delete any PI at your request, we will make good faith efforts to make the changes in our then-active databases as soon as reasonably practicable, generally within 24–48 hours. Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules. Please note that information may remain in backup or archive records, and we may retain certain data relevant to preventing fraud or future abuse or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable or de-identified data, Account recovery, or if required by law. All retained data will continue to be subject to the Privacy Policy in effect at that time.

D. 7. Account Cancellation and Reactivation; Data Deletion

At any time, Users may cancel their Accounts through the settings function. Alternatively Users may contact Us at Section 13 (Contact Us) to cancel.

Upon Account cancellation, de-identified User information may nonetheless persist internally in our archive files or similar databases, and may still be used, on a de-identified basis, for our internal support, administrative, and record-keeping purposes including, but not limited to, allowing us to improve the Services and other services we provide through research, evaluation, and analytics as permissible by applicable law.

Please note that following a request to delete information or your Account under Sections 6 or 7 of this Privacy Policy, information including PI may remain in backup or archive records, and we may retain certain data if required by law, relevant to preventing fraud or future abuse, or for legitimate business purposes, such as account recovery and customer support, and all subject to our internal records retention periods. All retained data will continue to be subject to the Privacy Policy in effect at that time and applicable law.

E. 8. California Privacy Rights

Effective January 1, 2020, the CCPA provides California residents with specific rights regarding their PI. This section describes your CCPA rights and explains how to exercise those rights. In this section “you” or “your” refers to California residents. Under the new law we are required to disclose the categories of sources from whom we collect PI, and the third parties with whom we share it, which we have explained above. We are also required to communicate information about rights you have under California law, such as:

• Right to access Personal Information. You may be entitled to receive the specific pieces of your PI we hold.

• Right to data portability. You may be entitled to receive a copy of your electronic PI in a readily-usable format.

• Right to disclosure. You may be entitled to receive information regarding the categories of PI we collected, the sources from which we collected PI, the purposes for which we collected and shared PI, the categories of PI that we sold and the categories of third parties to whom the Personal Information was sold, and the categories of PI that we disclosed for a business purpose in the 12 months preceding your request.

• Right to deletion. You may be entitled to request that we delete the PI that we have collected from you. We will use commercially reasonable efforts to honour your request, in compliance with applicable laws. Please note, however, that we may need or be required to keep such information, such as for our legitimate business purposes or to comply with applicable law.

• Right to opt-out of certain sharing with third parties. As stated in the Summary of Key Points above, we will never monetize the PI of any User of the Services by providing it to a third party in exchange for money. The CCPA has a broader definition of the term “sell” which includes disclosing PI to any third party for valuable consideration. When we work with our advertising partners, we are disclosing certain information such as cookies for their services, which are of value to us. You may be entitled to direct us to stop disclosing your PI to third parties for monetary or other valuable consideration. You can exercise such right to opt-out Do Not Sell My Personal Information.

Information we Collect and Share

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

Business and Commercial Purposes for which we use Personal Information: We use and disclose the information we collect from each of the Categories of PI listed below for the business purposes described in this policy, including but not limited to: process payments, conduct research, detect security incidents and prevent fraud, debug and repair errors, maintain your account, provide customer service, enabling and affecting commercial transactions and advancing our commercial and economic interests, such as delivering interest-based advertising to Users and analysing the effectiveness of our advertisements and other activities to improve our services, show advertising, market our services, and understand how users interact with our services.

Categories of Personal Information we collect: In the preceding 12 months, we have also disclosed the following categories of PI for one or more business purposes: identifiers, commercial information, internet or electronic network activity information, geolocation data (see Section 3. B. Information we collect from Users), and inferences we draw or derive about users.

Categories of Sources from which we collect Personal Information: We collect PI from each of the aforementioned Categories of PI from Users of Our Services

Categories of Third Parties with whom we share Personal Information: We share PI from each of the aforementioned Categories of PI with the categories of third parties described in Section 5, including as part of a sale or for commercial or business purposes.

Categories of Personal Information we share with Third Parties: We share, and have shared during the past 12 months, the following categories of PI with third parties, including as part of a sale or for commercial or business purposes: personal identifiers such as name and credit card number to payment processors who act as our service provider; commercial information, such as services subscribed to, obtained or considered; and information regarding your interaction with or use of our products and services, including the Services. We do not sell the PI of children under 16 years of age.

Exercising Access, Disclosure, Data Portability, and Deletion Rights

To exercise the access, disclosure, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either contacting us as set forth in Section 13 (Contact Us) below, or by visiting:

• Privacy Portal

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

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

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected PI or an authorized representative. We will verify your request by asking you to provide information related to your interactions with us. We will not otherwise ask for PI from you that we would not otherwise maintain as part of us providing our Services.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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

Non-Discrimination

We fully support your privacy rights and will not discriminate against you for exercising any of your CCPA rights.

Notice of Financial Incentives

We may offer special incentives to users who enroll in certain promotions. The availability of these promotions to you at any given time will vary. If we offer such programs, we may ask for your PI (such as your email address or certain in-game activities associated with your account) as a prerequisite to your participation in the promotion.

The promotions that may be available to you are:

• Email Offers. When you subscribe to receive emails from the Company, we may offer you special savings in the form of digital coupons for free or discounted products and announcements of sweepstakes, contests, and giveaways. To participate in these email offers, you must provide a valid email address.

You may opt-in to the email offers by visiting our website or navigating through your account. You may also withdraw from these promotions at any time by contacting us at the contact information provided in Section 13, below.

The value we place on the PI that we collect in connection with these promotions is calculated by determining the approximate additional spending per promotion participant, compared to individuals for whom we do not have email addresses, in-game activity history and preferences, or other collected information. You can opt-in to, or opt-out of, our programs at any time through the same means they are offered, or by contacting us at the contact information provided in Section 13, below.

CCPA Metrics: www.ageoflearning.com/ccpa

F. 9. Links to Other Services

In certain sections of the Services, we may include links to external websites or applications (for example, Facebook and Twitter). However, to protect children from accessing these external websites, Users will be required to enter a valid password. These websites and applications are governed by their own privacy policies or information collection practices, which may be substantially different from ours. We encourage you to review the privacy policies and information collection practices of any external websites and apps, as those parties’ practices would not be subject to this policy.

G. 10. Location of Information Processing

The Services are controlled and operated by us from Hong Kong. Your information may be stored and processed in any country where we have facilities or in which we engage service providers, including Hong Kong, which may have data protection laws that are different from those of your country. In addition, your information may be subject to access requests from governments, courts, or law enforcement officials in countries where it may be processed, under the laws of those countries.

H. 11.Security

The security of your PI is important to us, and we employ physical, technical, and administrative security measures designed to safeguard the information collected by the Services. We use industry standard SSL (secure socket layer technology) encryption to transfer PI. Other security safeguards include, but are not limited to, data encryption, firewalls, and physical access controls to buildings and files. We also conduct periodic audits of our security (no less than annually) to apply best practices and reasonable industry standards. However, no data transmission over the Internet can be guaranteed to be completely secure. If there is a breach of our security, we will notify you where required by law or deemed necessary and appropriate under the circumstances.

Account holders create a password in the registration process. You can help protect against unauthorized access to your Account and PI by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account. At registration, we assign a Member ID to each Account and use those Member IDs to authenticate logins, allow access to the subscription content, and monitor compliance. The Member ID is also used to authenticate users when requesting technical support. Access to information is limited (through user/password credentials and two-factor authentication) to those employees who require it to perform their job functions.

Please be aware, however, that no information system can be guaranteed to be 100 percent secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Services over networks that we do not control, including the internet and wireless networks. If you have reason to believe that your interaction with us is not secure, please contact us as described in Section 13 (Contact Us) below.

I. 12. Changes to Our Privacy Policy

We constantly try to provide the best services, and accordingly our Privacy Policy will change from time to time. If we update this Privacy Policy, we will notify you by posting the revised Privacy Policy on the Services, and for certain revisions that materially expand the ways in which we use or share the information previously collected from you through the Services, either display an alert next to the Privacy Policy, display an alert upon login to the Services, or directly communicate with you (e.g., via the email address associated with your Account).

J. 13. Contact Us

Little Pal Asia Limited. is in the Hong Kong. Little Pal Asia Limited. is the operator of all the Services. You may contact us below if you have any questions, complaints, or other issues related to this Privacy Policy and issues related to your or a User’s information for which you are responsible:

For all Accounts

Mailing address:
Little Pal Asia Limited.
Attention: Legal Department
11F, Hollywood Centre
Nos. 77-91 Queen’s Road West
Hong Kong
Telephone Number: +1800.633.3331