Children’s Policy Disclosure

Last Modified: November 11, 2020

Children’s privacy is important to LI2EI, LLC. (“LI2EI”, “we”, “our”, or “us”). This Children’s Privacy Policy describe how we handle personal information we collect from children under the age of 13 (“child” or “children”) and uses terms that are defined in the LI2EI Privacy Policy at https://www.li2ei.com/privacy. This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), and outlines our practices in the United States regarding children’s personal information when such child creates an account at www.li2ei.com (“Site”) and/or uses our software-as-a-service solution and mobile application that enables educators and parents to provide students with access to educational content, track progress and provide alternative methods of learning while motivating students to learn for rewards (collectively, the “Services”).

Types of Child Personal Information Collected

Children may share, and we may collect personal information that requires verifiable parental consent under COPPA (collectively, “Child Personal Information”). Child Personal Information may be collected directly from a child through use of an account or passively by using the Services and may include, for example: name, birthdate, gender, contact information (including phone numbers and e-mail addresses), location, preferences and behavior (such as comments, responses and questions asked), and /or academic performance information. LI2EI may collect and store persistent identifiers (for example cookies and ‘IP’ addresses) from children without parental consent for the purpose of supporting the internal operation of the Services or as otherwise permitted by COPPA. In the event we discover we have collected Child Personal Information in a manner inconsistent with COPPA, we will either delete the information or immediately seek the parent’s consent for such collection.

Collection of Parent Email

Consistent with the requirements of COPPA, on any child-targeted site or application, or in any instance where we ask for age and determine the user is age 12 or under, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at privacy@li2ei.com. We will not use parent contact information provided for parental consent purposes to market to the parent, unless the parent has expressly opted into email marketing or has separately participated in an activity that allows for such contact.

Use of Child Personal Information

We may use Child Personal Information to provide and improve our Services, communicate information and enforce parental consent. LI2EI will not require a child to disclose more information than is reasonably necessary to participate in the Services and will retain Child Personal Information only so long as reasonably necessary to provide the Services, ensure the security of our Services or as required by law.

Disclosure of Child Personal Information

We may share or disclose Child Personal Information only in a limited number of instances, as described in our Privacy Policy at https://www.li2ei.com/privacy/ which may include sharing Child Personal Information in the following manners:

• We may share information with our Educational Account administrators (such as a child’s classroom teacher and school) for the purpose of tracking and evaluating your child’s academic progress,
• We may share information with third-party Service Providers (as defined in our Privacy Policy) as reasonably necessary for them to provide the Services, or to perform a business, professional, or technology support function for us. We also may share aggregated or anonymized information with third parties to help improve our Services or to help these third parties develop their own products and/or service offerings.
• We may share information in connection with a business transfer, such as a merger or sale of all of our assets.
• We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or public agency’s (including schools or children services) request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.

We do not knowingly use, collect, or disclose Child Personal Information without parental permission. Consistent with the requirements of COPPA, we will ask for a parent or guardian consent before we collect any Child Personal Information.

Email Consent. In the event we wish to collect personal information from a child, COPPA requires that we first seek a parent or guardian’s consent. We may do so by the use of a credit card, debit card, or other online payment system in connection with a monetary transaction by a parent for our Services. Alternatively, we may also do so by email where we will explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. We will ask that a parent indicate consent in a return email message, along with including additional contact information so we may complete the verification of the parent. If we do not receive parental consent within a reasonable time, we will delete the parent contact information and any other information collected from the child in connection with that activity.

Educational Account consent in lieu of a parent. With regard to Educational Accounts, COPPA allows school administrators to act in the stead of parents to provide consent for the collection of personal information from children. LI2EI will send the parent or guardian a letter through the child’s school and/or classroom teacher that will explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. Schools should always notify parents about any activities where children’s information is collected. For more information on parental rights with respect to a child’s educational record under the Family Educational Rights and Privacy Act (FERPA), please visit the FERPA site.

If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have not received a letter providing notice or seeking your consent, please feel free to contact us at contact@li2ei.com.

As a parent you can review your child’s personal information, direct us to delete it and prohibit any further collection or use of your child’s personal information. To withdraw permission for a child to use the Services or request the deletion of Child Personal Information please contact us at contact@li2ei.com. Please keep in mind that a request to delete records may lead to termination of an account or the Services.

Information Collected by Third Parties

This disclosure does not apply to the practices of any third-party services (including any websites and/or services linked to and/or from the Services). Before using any third-party service, you should review the applicable terms and polices to determine their appropriateness for your child, including the service’s data collection and use practices.

Parental Choices and Controls

At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular account, and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service.

Where a child has registered for an account, parents may access, change, or delete the personally identifiable information that we have collected from their children by contacting us at privacy@li2ei.com.

A valid request to delete personal information will be accommodated within a reasonable time. Please include the child’s username and the parent’s email address and telephone number. To protect children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting access to any personal information.

Changes

We will generally notify all users of any material changes to this policy, through a notice on the platform. However, users should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy.