NovaKid Children’s Privacy Policy

Updated 25 January 2019.

Welcome to NovaKid (“NovaKid,” “we,” “us,” or “our”)! We care a lot about your child’s online privacy and safety. This Children’s Privacy Policy is designed to comply with the U.S. Children’s Online Privacy Protection Act (“COPPA”) and other similar laws regarding children’s online privacy. This Children’s Privacy Policy contains important information about our practices involving the online collection, use, and disclosure of personal information from children under the age of 12 in connection with the NovaKid online educational service (the “NovaKid Site”) accessed through our website at https://www.novakidschool.com/. For the purposes of this Privacy Policy, “child” or “children” means a child or children under the age of 12.

NovaKid will handle children’s personal information as described in this Children’s Privacy Policy. Please note, however, that some portions of the NovaKid site—such as the sign-up pages, direct notice to parents, and credit card payment pages—as well as the separate general-audience NovaKid website and mobile application, are directed to parents of children and other adults. Any personal information we collect about other users through these non-child-directed NovaKid services and pages will be treated in accordance with the general-audience NovaKid Privacy Policy.

NovaKid is committed to compliance with COPPA and other children’s privacy laws. As discussed below, we obtain consent from a parent or legal guardian before collecting, using, and/or disclosing to third parties any personal information collected from a child. We take children’s privacy seriously, and we encourage parents to take an active role in protecting their children’s privacy and online experience at all times. NovaKid can be contacted at:

  • NovaKid Inc.
  • US 548 Market St 8291
  • San Francisco, CA 94104-5401
  • support@novakidschool.com
I. What Information Do We Collect from Children?

We will not collect, use, and/or disclose any personal information about children without the consent of a parent or legal guardian.

For a child to access and use the NovaKid Site, a parent or legal guardian must log the child into a sub-account created and maintained through the account of the parent or legal guardian. Prior to logging a child into the NovaKid site, the parent or legal guardian is required to provide the child’s first name, year of birth, and English language proficiency level. Upon creation of the sub-account, the parent or legal guardian also must consent to the collection of personal information from the child.

After a parent logs a child into the child’s sub-account, we (and in some cases our service providers) collect personal information from the child both directly and automatically. More specifically:

  • A child may edit his or her name, age range, English proficiency level, and avatar, in which case we will collect that information directly from the child.
  • We collect the child’s progress and performance data generated based on the child’s interaction with the NovaKid Site.
  • We collect video records of the child’s sessions with tutors, as well as messages between the child and the tutor.
  • We assign to each child’s account a NovaKid user ID, which is an internal number that we use to track information associated with the account and the child’s activity.
  • We also collect persistent identifiers, including cookies, IP addresses, MAC addresses, and data associated with web beacons. As discussed below, we use these identifiers for a variety of purposes, including error logging, analytics, and to collect usage information, such as when, how often, and for how long the child uses the NovaKid Site, as well as such information as the child’s “clicks” and pages viewed when using the NovaKid Site. We also may associate these identifiers or other personal information with information about the child’s hardware and software attributes, such as data about the child’s browser software and operating system, device type, and similar information. Like many websites, the NovaKid Site does not currently respond to “do not track” browser headers. However, you can take steps to limit cookie tracking by erasing cookies from the child’s computer or other device and by setting the child’s browser to block all cookies or warn the child before a cookie is stored. However, if you choose to block or delete cookies, certain features of the NovaKid Site may not operate correctly.

We will not ask for more personal information from children than is reasonably necessary for children to participate in the NovaKid Site. Further, although children interact directly with tutors, we do not allow children to have the option or ability to make personal information more publicly available through the NovaKid Site.

II. How Do We Use the Information We Collect from Children?

We use the information we collect from children for internal purposes, as follows:

  • We may use collected information for the purposes for which the child provided the information, including, for example, to monitor the child’s educational progress, to provide parents and legal guardians with information and reports about the child’s performance, and to create and maintain the sub-account for the child. We also use the collected information as necessary to provide the features and functionality of the NovaKid Site to children.
  • We may use the collected information, including persistent identifier information, to personalize the content that children see based on personal characteristics or preferences.
  • We may also use persistent identifiers and other information to analyze and draw insights based on your child’s use of the NovaKid Site. We use this information for a range of internal purposes, such as error logging, helping us improve the NovaKid Site, and developing new products and services.
  • We may combine children’s personal information collected through the NovaKid Site with other information that we or third parties collect about children in other contexts—such as our communications with parents or legal guardians via e-mail or phone, or customer service records related to a child’s user account.
III. How and with Whom Do We Share Information from Children?

NovaKid does not sell children’s personal information, and we do not share or disclose children’s personal information for marketing purposes, including to third parties for their own direct marketing purposes. Moreover, as noted above, children do not have the option or ability to make personal information publicly available through the NovaKid Site.

NovaKid may share or otherwise disclose the personal information that we collect from children as described below:

  • With Parents or Legal Guardians. A child’s account will be associated with the parent or legal guardian’s account, such that the parent or legal guardian can view and monitor his or her child’s progress. A parent or legal guardian can also access video recordings of his or her child’s lesson with tutors.
  • Tutors. As part of the NovaKid Site children can schedule and take lessons with tutors through video chat sessions. When a child engages in a video chat session with a tutor, the tutor will receive the child’s first name and any other personal information your child shares. The tutor, through his or her own tutor account, will be able to review the child’s learning and offer feedback. Children also can communicate directly with tutors outside a video chat session on the NovaKid Site, such as through direct messages.
  • Service Providers. We may use third-party vendors, service providers, contractors or agents to assist us in making the NovaKid Site available or to help us improve the NovaKid Site. For example, we use a service provider to provide the video connection for the children’s tutoring sessions, and we use database hosting and data storage providers. Such service providers may collect data themselves or obtain access to the personal information we collect from children to assist us in achieving the purposes discussed above in the section entitled “How Do We Use the Information We Collect from Children.”
  • Aggregated and De-Identified Information. We may report aggregated, anonymous data relating to activity on the NovaKid Site to third parties or the general public. By way of example only, this may include the provision of reports regarding child engagement with the NovaKid Site and/or English-learning progress for such purposes as educational research, to evaluate the educational benefit of using the NovaKid Site, to improve the NovaKid Site, or to show the efficacy and usage when marketing the NovaKid Site. Such aggregated, anonymous data will not contain any children’s personal information, including persistent identifiers.
  • Business Transfers. In the event of a merger, sale of capital stock or assets, reorganization, capital investment, consolidation, or similar transaction involving NovaKid, the information we possess, including children’s personal information, shall be transferred as a corporate asset to the acquiring entity. We will notify parents or legal guardians via email and/or post a prominent notice on the NovaKid Site of any change in ownership or uses of children’s personal information, as well as any choices available to the parent or legal guardian regarding the children’s personal information.
  • Legal. We will use and disclose children’s personal information where we, in good faith, believe that the law or legal process (such as a court order, search warrant, or subpoena) requires us to do so or in other circumstances where we believe it is necessary to protect the rights, property, or personal safety of NovaKid Kids, our users, and/or third parties.
IV. Parental Rights to Review, Delete, and Control Their Child’s Personal Information

When a child’s account is first opened, we obtain consent from a parent or legal guardian to the collection, use, and disclosure of children’s personal information as described in this Children’s Privacy Policy. We also encourage parents or legal guardians to log in to their child’s account to view the child’s activities and progress. Parents or legal guardians may also contact NovaKid to review the type of information collected from children or to change their consent to the collection, use, and sharing of their child’s personal information. Parents or legal guardians may also ask us at any time to stop collecting their child’s personal information and request that we delete any information we have already collected. However, such requests may result in termination of the child’s access to and use of the NovaKid Site.

To contact us about these parental rights, please send us an email at support@novakidschool.com or contact us at:

  • NovaKid Inc.
  • US 548 Market St 8291
  • San Francisco, CA 94104-5401

In any correspondence, please include the parent or legal guardian’s email address and the child’s name. To protect children’s privacy and security, we will take reasonable steps to verify a parent or legal guardian’s identity before granting access to any children’s personal information.

V. Data Retention

Absent a request to delete data, we will retain personal information collected online from a child for as long as there is a subscription maintained for the child, and for a period of five years after the child’s account becomes inactive. We retain this information after a subscription ends because when users reinstate their lapsed subscriptions, they generally want to resume lessons rather than losing their progress and starting over. Nonetheless, after five years of inactivity, all personal information collected from a child will be automatically deleted from our active servers.

Children’s personal information will remain in our backup servers for a period of two weeks from the date of any deletion request, after which it will be deleted and cannot be restored. As discussed above, a parent may request to delete his or her child’s personal information at any time during the period of the subscription or after the subscription ends.

In the event we discover that we have collected information from a child in a manner inconsistent with legal requirements, we will either delete the information or seek parent or guardian consent for that collection.

VI. Effective Date and Changes to this Policy

This Children’s Privacy Policy is current as of the Effective Date set forth above. We may update this Children’s Privacy Policy from time to time to reflect changes in the NovaKid Site or our information processing practices. When we make any changes to our practices under this Children’s Privacy Policy, we will change the Effective Date. If we make a material change to this Children’s Privacy Policy, we will make reasonable efforts, taking into account available technology, to ensure that a parent receives direct notice of the changes to our practices.

VII. Questions or Comments

For questions or comments regarding this Children’s Policy, please contact us at support@novakidschool.com or:

  • NovaKid Inc.
  • US 548 Market St 8291
  • San Francisco, CA 94104-5401