Kiddom’s Privacy Policy

FOR RESIDENTS OF THE EUROPEAN UNION (“EU”) – GENERAL DATA PROTECTION REGULATION (“GDPR”)

This privacy policy describes how we collect, use, and share your Personal Data. If you are a resident of the EU, you are subject to the GDPR, which is effective as of May 25, 2018, and the following terms apply to you. Kiddom is the Controller of and responsible for your Personal Data, which we have grouped together as follows:

• Identity Data includes full name, title, username, and 3rd-party authentication identifier such as Google ID (if used).
• Contact Data includes email address(es), billing address, school name, school address, and and telephone number(s).
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, operating system, platform, and other technical specifications of the devices you use to access the Service which is voluntarily shared with us by said devices.
• Profile Data Optional avatar or photo.
• Usage Data includes information about how you use our Service such as times you access the Service and other metrics quantifying your engagement with the Service.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions relating to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

LAWFUL BASES TO PROCESS YOUR PERSONAL DATA

This privacy policy describes above the Personal Data we collect from you and how we use it. We will only use your Personal Data as permitted by law. Most commonly, we will use your Personal Data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you. Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.

Specifically, we have a lawful basis for processing each type of Personal Data described in this privacy policy, which are as follows:

1. The lawful basis for collecting your Identity, Profile and Contact Data to register you as a user is that it is necessary for our legitimate interests in providing the Service and the legitimate interests of the educational institution for its operations.
2. The lawful basis to collect your Identity, Contact, and Technical Data to administer and protect our business and the Service is that it is necessary for our legitimate interests such as running our business, provisioning of administration and IT services, network security, and fraud prevention.
3. The lawful basis to collect Technical and Usage Data to use data analytics to improve our Service, user relationships and experiences is that it is necessary for our legitimate interests: to keep our Service updated and relevant, to develop our business and to inform our marketing strategy.

As stated in this Privacy Policy, we perform age neutral verification, and require verifiable parental consent before collecting Children’s Personal Data. We do not knowingly collect or maintain Personal Data from persons in the EU under age 16.

We do not collect any Special Categories of Personal Data about you: details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data. Nor do we collect any information about criminal convictions and offenses.

We may have to share your Personal Data with the parties set out below for the purposes described in this Policy.

EXTERNAL THIRD PARTIES

• Service providers acting as processors who provide us hosting, security, analytics, support and marketing services
• Professional advisers including bankers and accountants who provide banking, accounting and financial services and software
• Third parties to whom we may choose to sell, transfer, or merge parts of our business. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

INTERNATIONAL PROCESSING

We are based in the United States, which is where all your data will be processed.

DATA SECURITY

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, accessed in an unauthorized manner, altered, or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to have such access. They will only process your Personal Data per our instructions and they are subject to a duty of confidentiality. Procedures to deal with any suspected Personal Data breach require us to notify you and any applicable regulator of said breach where we are legally required to do so.

DATA RETENTION

We will only retain your Personal Data for as long as necessary to fulfill the purposes for which we collected it, including the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Data, we consider its amount, nature, sensitivity, potential risk of harm from unauthorized access, whether we can achieve our contractual obligations to you without it, and the applicable legal requirements as they relate to said retention. In some circumstances you can ask us to delete your data. In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS UNDER THE GDPR

Under certain circumstances, EU residents have rights under data protection laws in relation to their Personal Data. If you are an EU resident, you have the right to:

• Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your Personal Data where we are relying on a legitimate business interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at privacy@kiddom.co. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

COMPANY CONTACT INFORMATION

Company Name: Kiddom Inc. dba Kiddom
Data Protection Officer: Ghislain “Aus” Lacroix
25 Kearny Street, Suite 500, San Francisco, CA 94108

Please contact us with any questions or comments about this Privacy Policy, your Personal Data, our third party disclosure practices, or your consent choices by email: privacy@kiddom.co