Cambly Kids Children’s Privacy Policy

Effective Date: July 12, 2023

Welcome to Cambly Kids, an online educational service made available by Cambly Inc. (“we,” “us,” or “our”) through our website at https://www.cambly.com/kids/student. This Children’s Privacy Policy describes our practices involving the online collection, use, and disclosure of personal information from children in connection with their use of Cambly Kids.

Cambly Kids will handle personal information collected from children as described in this Children’s Privacy Policy. Please note, however, that some portions of Cambly Kids, such as the sign-up pages, direct notice to parents, and credit card payment pages, as well as the separate general-audience Cambly website and mobile application, are directed to parents of children and other adults. Any personal information we collect through these non-child-directed Cambly services and pages will be treated in accordance with the general-audience Cambly Privacy Policy, which can be accessed here: https://www.cambly.com/static/legal/pp.html.

We are committed to complying with the Children’s Online Privacy Protection Act (“COPPA”) and other applicable privacy laws. As discussed below, we obtain consent from a parent or legal guardian where required by applicable law before collecting, using, and/or disclosing personal information from a child through their use of Cambly Kids. We encourage parents to take an active role in protecting their children’s privacy and online experience at all times.

We can be contacted here or at:

Cambly Inc.

Attn: Cambly Kids

440 N. Barranca Ave. #4343

Covina, California 91723

We provide important information for individuals located in the European Economic Area, United Kingdom, and California below.

What Information Do We Collect from Children?

We collect personal information from children when they use Cambly Kids.

For a child to access and use Cambly Kids, 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 Cambly Kids, the parent or legal guardian is required to provide the child’s first name, age, 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, we may collect:

Tutoring activity data including:

the child’s progress and performance data generated based on the child’s interaction with Cambly Site.
video records of the child’s sessions with tutors, as well as messages between the child and the tutor. Cambly Kids captures this so that Cambly administrators can review and communicate with the child about his or her English learning progress.

A Cambly Kids user ID, which is an internal number that we use to track information associated with the account and the child’s activity.
Persistent identifiers, including cookies, IP addresses, MAC addresses, and data associated with web beacons, which we use to provide and improve Cambly Kids, for error logging, for analytics, and to collect usage information and information about the child’s browser, software and operating system, device type, and similar information. Like many websites, Cambly Kids 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 Cambly Kids may not operate correctly.

We will not ask for more personal information from children than is reasonably necessary for children to participate in Cambly Kids. 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 Cambly Kids.

How Do We Use the Information We Collect from Children?

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

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 Cambly Kids to children.
To personalize the content that children see based on personal characteristics or preferences.
To analyze and draw insights based on your child’s use of Cambly Kids. We use this information for a range of internal purposes, such as error logging, security, helping us improve Cambly Kids, and developing new products and services.
To comply with our legal obligations or as permitted by law;
We may combine children’s personal information collected through Cambly Kids with other information that we or third parties collect about children in other contexts—such as our communications with parents or legal guardians via email or phone, or customer service records related to a child’s user account.

How and to Whom Do We Disclose Information from Children?

We do not sell children’s personal information, and we do not 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 Cambly Kids.

We may disclose the personal information that we collect from children as described below.

Affiliates and subsidiaries. We may disclose your information to Cambly affiliates and subsidiaries.
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. 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 progress and offer feedback. Children also can communicate directly with tutors outside a video chat session on Cambly Kids, such as through direct messages.
Service Providers. We may use third-party service providers, contractors or agents to assist us in making Cambly Kids available or to help us improve Cambly Kids. 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.” A list of our service providers is available here.
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Aggregated and De-Identified Information. We may report aggregated, anonymous data relating to activity on Cambly Kids to third parties or the general public. By way of example only, this may include the provision of reports regarding child engagement with Cambly Kids and/or English-learning progress for such purposes as educational research, to evaluate the educational benefit of using Cambly Kids, to improve Cambly Kids, or to show the efficacy and usage when marketing Cambly Kids. Such aggregated, anonymous data will not contain any children’s personal information, including persistent identifiers.
Business Transaction. In the event of a transaction, such as a merger, sale of capital stock or assets, reorganization, capital investment, consolidation, or similar transaction (or the due diligence in contemplation thereof) involving Cambly Kids, the information we possess, including personal information collected from children, 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 Cambly Kids 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 Cambly Kids, our users, and/or third parties.

We may disclose aggregated, de-identified data relating to activity on Cambly Kids with third parties or the general public. By way of example only, this may include the provision of reports regarding child engagement with Cambly Kids and/or English learning progress for such purposes as educational research, to evaluate the educational benefit of using Cambly Kids, to improve Cambly Kids, or to show the efficacy and usage when marketing Cambly Kids. Such aggregated, de-identified data will not contain personal information collected from children.

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 personal information from children 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 Cambly Kids to review the type of information collected from children or to change their consent to the collection, use, and disclosure of their child’s personal information. Parents or legal guardians may also ask us at any time to stop collecting personal information from their child 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 Cambly Kids.

To contact us about these parental rights, please send us a request here or contact us at:

Cambly Inc.

Attn: Cambly Kids

440 N. Barranca Ave. #4343

Covina, California 91723

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.

Security

We implement security measures to protect the information we collect from Cambly Kids. It is important that you protect and maintain the security of your account credentials and notify us immediately of any unauthorized use of your account. Please understand that no data transmission over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us.

Data Retention

Absent a request to delete data, we keep your information until we determine it is no longer necessary to fulfill the purpose for which the information was collected. The length of time for which we retain information depends on the purposes for which we collected and use it and your choices, after which time we may delete and/or aggregate it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Personal information collected from children may remain in our backup servers for a reasonable period 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 personal information collected from his or her child 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.

Consent to Transfer

Our computer systems are currently based in the United States, so your personal information will be processed by us in the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using Cambly Kids, you agree to this Children’s Privacy Policy and you consent to the transfer of all such information to the United States, which may not offer a level of protection equivalent to that required in the European Union, United Kingdom, or certain other countries, and to the processing of that information as described in this Children’s Privacy Policy.

Third-Party Websites

Cambly Kids may link to third-party websites from companies other than Cambly, such as to relevant online resources. We are not responsible for the privacy practices or content of such other websites. If you have any questions about how these other websites use your information, you should review their policies and contact them directly. We are not responsible for the actions of third parties.

Regional Privacy Disclosures

As explained in Section 4 above, parents have rights to review, delete, and control their child’s personal information. Certain regions in which we operate require us to make additional disclosures regarding our privacy practices.

European Economic Area, United Kingdom, Turkey, and Brazil:

The laws of some jurisdictions such as the laws of the European Union require data controllers to tell you about the legal ground that they rely on for using, sharing, or disclosing your information. We are the data controller of the personal information covered by this Children’s Privacy Policy. To the extent those laws apply, our legal grounds are as follows:

Contractual Commitments: We may use or disclose information to honor our contractual commitments to you (e.g. to comply with our User Agreement, which you accept by browsing or otherwise using Cambly Kids).
With Your Consent: Where required by law, and in some other cases, we use or disclose information on the basis of your consent.
Legitimate Interests: In many cases, we use or disclose information on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, analyzing and improving our business, providing security for Cambly Kids, preventing fraud, and managing legal issues.
Legal Compliance: We need to use and disclose information in certain ways to comply with our legal obligations.

You and your child may have the following rights, under certain circumstances. To exercise any of your rights please send us a request here. Your local laws may permit you to request that we:

Provide access to and/or a copy of certain information we hold about your child
Prevent the processing of your information for direct marketing purposes (including any direct marketing processing based on profiling)
Update or rectify information which is out of date or incorrect
Delete certain information that we are holding about your child
Oppose, cancel or restrict the way that we process and disclose certain information
Transfer your child’s information to a third-party provider of services
Revoke your consent for the processing of your child’s information

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request that you provide us with information necessary to confirm your identity before responding to your request as required or permitted by applicable law.

If you have unresolved concerns, you may lodge a complaint with your local data protection authority. However, we encourage you to contact us first, and we will do our best to resolve your concern.

California Notice at Collection

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”) requires us to provide some additional information to California residents. This Section only applies to you if you are a California resident. It applies to personal information we collect on or through Cambly Kids.

Categories of information we collect

California law requires us to disclose information regarding the categories of personal information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as those terms are defined by applicable law) for which the information was collected, and the categories of parties with whom we disclose personal information. Section 1 above describes the information we collect from and about you, Section 2 describes the purposes for which we use this information, and Section 3 describes when and to whom we disclose data. The CCPA requires us to list the personal information we collect by category along with the purposes of its use and the unaffiliated parties to which it is disclosed.

Categories of personal information (see Section 1 above for more information)	Purposes of use (see Section 2 above for more information)	Categories of other parties to whom we disclose the information for business and operational purposes (see Section 3 above for more information)
Identifiers Such as name and other account information	For the purposes for which the child provided the information To provide the features and functionality of Cambly Kids To personalize content To analyze and draw insights about Cambly Kids	Affiliates and subsidiaries Parents or legal guardians Tutors Service providers Professional advisors Business transfers Entities for legal and security purposes
Internet or other network or device activity Such as an IP address, unique device identifiers, advertising and app identifiers, browsing history, or other usage data or persistent identifiers	For the purposes for which the child provided the information To provide the features and functionality of Cambly Kids To personalize content To analyze and draw insights about Cambly Kids	Affiliates and subsidiaries Service providers Professional advisors Business transfers Entities for legal and security purposes Others with your consent
General location information Such as your general location inferred from an IP address	For the purposes for which the child provided the information To provide the features and functionality of Cambly Kids To personalize content To analyze and draw insights about Cambly Kids	Affiliates and subsidiaries Service providers Professional advisors Business transfers Entities for legal and security purposes Others with your consent
Audio or visual information Such as tutoring activity data	For the purposes for which the child provided the information To provide the features and functionality of Cambly Kids To personalize content To analyze and draw insights about Cambly Kids	Affiliates and subsidiaries Parents or legal guardians Tutors Service providers Professional advisors Business transfers Entities for legal and security purposes
Protected classification and demographic information Such as information from our users that reveals information related to protected classifications, such as ethnicity or nationality	For the purposes for which the child provided the information To provide the features and functionality of Cambly Kids To personalize content	Affiliates and subsidiaries Service providers Professional advisors Business transfers Entities for legal and security purposes Others with your consent
Other information any other information you provide to us that directly or indirectly identifies you, such as information you include in emails or other communications to us	Purposes of use will depend on the additional information you provide	Disclosure will depend on the additional information you provide

Some of the categories of personal information above may also be “sensitive personal information” under the CCPA. We may collect the following types of “sensitive personal information”: (1) account log-in and password or other credentials allowing access to your Cambly Kids account; and (2) information you may voluntarily provide that may reveal race/ethnic origin or other protected classifications.

We collect the categories of personal information identified above from the child, the child’s parent or through the child’s use of the Services.

Your Child’s CCPA Rights

California residents may have certain rights. California law may permit the parent of a child to request that we:

Provide you the categories of personal information we have collected or disclosed about the child; the categories of sources of such information; the business or commercial purpose for collecting, “selling,” or “sharing” the personal information of your child; the categories of third parties to whom we disclose or “sell,” or with whom we “share,” personal information of your child; and the categories of personal information we “sell” or “share.”
Provide access to and/or a copy of certain information we hold about the child.
Delete certain information we have about the child.
Correct inaccurate personal information we maintain about the child.

Parents may have the right to receive information about the financial incentives that we offer to you, if any. Parents also have the right to not be discriminated against (as provided for in applicable law) for exercising certain rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services. If you ask us to delete it, you or your child may no longer be able to access or use the Services.

If you would like to exercise any of these rights on behalf of your child, please submit a request through this form or at [email protected]. You will be required to verify your identity before we fulfill your request. If you have an online account with us, logging into your account will serve to verify your identity and request, although we may request additional information if we believe your account has been compromised. If you do not have an account with us, or if we have reason to suspect that the security of your account is compromised, we will request additional information from you to match with our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought.

You can also designate an authorized agent to make a request on your child’s behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your child’s behalf. You will still need to verify your identity directly with us.

The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA.

Do Not Sell or Share My Personal Information. California residents may opt out of the “sale” or “sharing” of their personal information, as those terms are defined by the CCPA. Cambly Kids does not “sell” or “share” personal information collected from children.

California Do-Not Track Disclosure

Cambly does not currently recognize or respond to browser-initiated Do-Not-Track signals, as the Internet industry is currently still working on Do-Not-Track standards, implementations and solutions.

California Shine the Light Disclosure

California Civil Code Section 1798.83 permits customers of Cambly who are California residents to request certain information, once per year, regarding our disclosure of their personal information (as defined by California law) to third parties for their own direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such sharing. We do not currently share personal information with third parties for their own direct marketing purposes.

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 Cambly Kids 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.

Questions or Comments

For questions or comments regarding this Children’s Privacy Policy, please contact us here or:

Cambly Inc.

Attn: Cambly Kids

440 N. Barranca Ave. #4343

Covina, California 91723

+1(415) 830-5109

[email protected]