This Privacy Notice for US Residents (the “Notice”) supplements the information contained in the Privacy Policy of Novakid Inc. (the “Company” or “Novakid”) and applies solely to visitors, users, and others residing in the United States (“User” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act (“CCPA”), as amended by other relevant federal and state data privacy laws, such as those enacted in Connecticut, Delaware, New Jersey and other jurisdictions with similar requirements (the “Applicable Legislation”). Any terms defined in the privacy laws of the United States have the same meaning when used in this Notice.

This Notice does not apply to employment-related personal information that may be collected from US-based job applicants, contractors, or similar individuals. This Notice also applies to business-to-business interactions, to the extent required by applicable law.

1. INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

• Publicly available information from government records;
• De-identified or aggregated consumer information;
• Information excluded from the scope of Applicable Legislation.

We collect the following categories of information from users:

• Identifiers: name, email address, telephone number;
• Commercial information: products or services purchased, obtained, or considered, or other purchasing or consumption histories or tendencies;
• Internet or other similar network activity: IP address, unique device identifier, browser characteristics, domain and other system settings, search queries, device characteristics, operating system type, language preferences, referring URLs, actions taken on our website, page requested, content consumed (e.g., viewed, uploaded, and shared), dates and times of website visits, gender, age range, approximate location and other information associated with other files stored on your device;
• Audio and Visual information. This may include audio, electronic, visual information and face imagery (e.g., video recordings of the classes provided). Audio and video recordings are used solely to deliver and improve our educational services and not to create or use biometric identifiers.

We obtain the categories of personal information listed above from the following sources:

• Directly from you. For example, when you create an account to access or utilize our services.
• Indirectly from you. For example, behavior data is collected when you use or utilize our services.
• Directly and indirectly from activity on our website. For example, from submissions through our website or website usage details collected automatically.
• From third parties that interact with us in connection with the services we perform.

2. USE OF PERSONAL INFORMATION

We may use or disclose the personal information we collect for the following business or commercial purposes:

• To fulfill or meet the reason for which you provided the information. For example, if you share your name and contact information to ask a question related to our services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our responses.
• To personalize our service experience and deliver content and service offerings relevant to your interests, including targeted offers, third-party sites, via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our services, the related databases and other technology assets, and the business itself.
• For testing, research, analysis, and product development, including developing and improving our services.
• To respond to law enforcement requests and, as required by applicable law, court orders or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the Applicable Legislation.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing notice of said use.

3. SHARING PERSONAL INFORMATION

We may disclose your personal information to a third party for a business purpose as described in our Privacy Policy. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except for the performance of the contract. 

We share your personal information with third parties that may include:

• Payment service providers;
• Cloud service providers;
• Software development providers;
• Marketing and analytics partners;
• Customer support services providers;
• Learning services providers;
• Professional advisers, including consultants, accountants, auditors, and solicitors.

We do not sell or share sensitive personal information. We do not sell your personal information in exchange for monetary compensation. We may share your personal information by allowing certain third parties to collect your personal information via automated technologies on our services for cross-context behavioral advertising purposes. This kind of sharing may be considered a “sale” under the CCPA when the personal information is exchanged for non-monetary consideration. You have the right to opt out of these types of disclosures of your information.

The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We use certain advertising and analytics tools that may constitute “targeted advertising” under applicable state laws and “sharing” under the CCPA. You can opt out via opt-out preference signals supported by your browser or extension. Where required by applicable law, you may opt out of the sale or sharing of your personal information and of targeted advertising. We honor browser- or device-based opt-out preference signals as a valid request to opt out, to the extent required by the Applicable Legislation. We will apply your signal to the browser/device and, where feasible, to your account.

In addition to the potential third parties identified above, we may disclose personal information about you to the following additional categories of third parties: governmental entities and third parties in connection with corporate transactions (e.g., mergers, acquisitions, joint ventures, reorganizations, divestitures, dissolutions or liquidations).

4. YOUR RIGHTS

Some US states have enacted privacy laws that grant their residents specific rights regarding personal data. If you are a resident of one of these states, you have a right to:

• Access your personal data. You may request access to and obtain a copy of the personal data we maintain about you.
• Correct inaccuracies in your personal data. You may request that we correct inaccuracies in your personal data, taking into account the nature of the data and our purpose for processing it.
• Delete your personal data. You may request the deletion of personal data that we have collected from or about you, subject to certain exceptions.
• Opt out of processing for the purposes of the sale of personal data, targeted advertising, or profiling.

Children’s Privacy. Our services are directed to children only with the involvement of a parent or legal guardian. We do not knowingly collect personal information from children under thirteen (13) without verifiable parental consent consistent with COPPA. We do not sell or share personal information of consumers we know are under sixteen (16); where required, we will seek an opt-in from the minor (ages thirteen to sixteen (13-16)) or the minor’s parent/guardian before any activity that would constitute a sale or sharing under the Applicable Legislation.

Additionally, if you are a California resident, this section describes your rights according to the CCPA and explains how to exercise those rights:

1. Right to know what information we collect. Right to access.

You have a right to request that we disclose to you the categories of personal information we have collected about you; the categories of sources from which we collect personal information; the purpose for the collection, use or sale of personal information; the categories of third parties with whom we share that personal information; the specific pieces of personal information we collected about you over the past twelve (12) months.

2. Right to delete personal information.

You have a right to request the deletion of any personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. If we cannot delete your personal information, we will give you a reason as to why we cannot do so.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated by the consumer within the context of a business’ ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
• Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
• Debug to identify and repair errors that impair the existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.
• Comply with the Applicable Legislation.
• Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the business’ deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if the consumer has provided informed consent.
• Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business and compatible with the context in which the consumer provided the information.

3. Right to opt-out of sale or sharing of personal information.

We do not sell the personal information of Users, as indicated in the CCPA or other applicable state privacy laws, including of those we have verified to be under sixteen (16) years of age. For the purpose of this Notice, “sell” means the sale of your personal information to an outside party for monetary or other valuable consideration, subject to certain exceptions in the CCPA and other applicable state privacy laws.  Since we do not sell your personal information, you do not have to go through any steps to opt out or opt into the sale of your information.

4. Right to correct inaccurate personal information.

You have the right to request that we correct the personal information we maintain about you if that information is inaccurate.

5. Right to limit use and disclosure of sensitive personal information.

This right is limited to sensitive personal information for the purpose of inferring characteristics about an individual. We do not collect sensitive personal information, nor do we use sensitive personal information for the purpose of inferring characteristics about that individual.

5. EXERCISING ACCESS, DATA PORTABILITY, AND DELETION RIGHTS

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at policy@novakidschool.com.

Only you or someone legally authorized to act on your behalf may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, email address used to register with the Company, and telephone number;
• 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 personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

6. RESPONSE PERIOD AND FORMAT

We acknowledge receipt of your request within ten (10) business days (for California) and aim to provide a substantive response within forty-five (45) calendar days of receipt. If we need more time, we may extend the response period once by an additional forty-five (45) days, and we will notify you of the reasons and the extension within the initial forty-five-day (45-day) period. Please note that certain categories of information may be subject to different, shorter timelines; in such cases, we will follow the applicable requirements. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

For data portability requests, we will provide your personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another entity without hindrance, in accordance with applicable law.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why that decision was made and provide you with a cost estimate before completing your request. If we deny your request, you may appeal the decision by emailing policy@novakidschool.com with the subject line “Privacy Request Appeal.” We will respond within the timeframe required by applicable law (typically forty-five (45) days, extendable where permitted) and include how you may contact your state Attorney General if you remain unsatisfied.

7. NON-DISCRIMINATION

We will not discriminate against you for exercising any of your privacy rights under the Applicable Legislation. Unless permitted by law (for example, in connection with a disclosed, bona fide loyalty or rewards program or a financial incentive program that is reasonably related to the value of your data), we will not: (a) deny you goods or services; (b) charge you different prices or rates, including through discounts or other benefits, or impose penalties; (c) provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price, rate, level, or quality.

8. RETENTION PERIOD

We retain each category of personal information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

9. CHANGES TO THIS PRIVACY NOTICE

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated notice on our website and update the notice’s effective date. Your continued use of our services following the posting of changes constitutes your acceptance of such changes.

10. CONTACT INFORMATION

If you have any questions regarding this Notice or information we hold about you, you may contact us via email at policy@novakidschool.com or in writing at 548 Market St 8291, San Francisco, CA 94104-5401, USA.

In order for us to take the appropriate action, please describe the nature of your request or inquiry in reasonable detail.