Coursiv Junior — Privacy Policy

This Privacy Policy details the collection, use, and disclosure of information across all our online products and services that link to it. This includes www.coursiv-junior.com and its subdomains (the “Website”), our Digital products and all related online and offline services, transactions, or interactions (collectively, the “Services”). This policy applies to information collected from you and the children accessing the Services through your account and is an integral part of our Terms and Conditions.

For specific information on Coursiv’s practices regarding the collection, use, and sharing of information from children, please refer to the “Children’s Privacy” section below.

As a parent you may only register your own child(ren) and affirm that any child user associated with their account possesses legal parental or guardian permission to use the Services. If you believe that a child under 16 (GDPR) or under 13 (COPPA) may have provided us personal information without adequate consent, please contact us at privacy@coursiv-junior.com.

“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

“EEA” includes all current member states to the European Union and the European Economic Area. For the purpose of this policy EEA shall include the United Kingdom of Great Britain and Northern Ireland.

“Process”, in respect of personal data, includes to collect, store, and disclose to others.

Table of Contents

1. Personal Data Controller
2. Categories of Personal Data We Collect
3. For What Purposes We Process Your Personal Data
4. Online Analytics and Advertising
5. Under What Legal Bases We Process Your Personal Data (EEA users)
6. With Whom We Share Your Personal Data
7. Security
8. How You Can Exercise Your Privacy Rights
9. California Privacy Rights
10. Children’s Privacy
11. Changes to This Privacy Policy
12. International Data Transfers
13. Data Retention
14. How “Do Not Track” Requests Are Handled

1. Personal Data Controller

Edulagoon Digital Corp. will be the controller of your personal data.

2. Categories of Personal Data We Collect

Information you provide to us

We collect information that adults choose to share with us, including data they provide voluntarily through the Services. For example, if you are an adult user of the Services or visitor to the Website, when you:

• 2.1 Creating an account or requesting information about the Services. We may collect your contact information, such as your name and email address. As registration data, we may collect your child’s first name, age, interests, and gender, as well as the password and parental code you create to access account settings.
• 2.2 Authenticating your identity. We may collect your name, email address, password, parental code and other information/documentation to verify your identity and permission for your child to use the Services.
• 2.3 Interacting with the Services. We may collect information about you and your child’s activity completion, interests, and use of our Services, as well as any other information you provide within the Services.
• 2.4 Contacting us for support. We may collect your name, email address and any information you provide in your outreach.
• 2.5 Paying for services or products. When you make payments through the Services, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used.

Adults provide Coursiv with basic information about the child as listed above and allow the child to use the adult’s account on the adult’s devices. Coursiv then collects information about the device (as identified below), account login information, information related to the status of the child’s completion of activities offered through the Services (“Child Activity Data”) and related automatically collected information. Once you, as an adult, are onboarded and authenticated, your child may begin to use the Services.

Information we collect automatically

We may automatically collect, receive, and store certain information when you access or interact with the Services. This includes data collected directly by us or through our service providers, using various technologies such as cookies, tracking pixels, and similar tools.

• 2.6 Data about how you found us. We collect data about your referring URL (that is, the place on the Web where you were when you tapped on our ad).
• 2.7 Device and Location data. We collect data from your device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system and its version.
• 2.8 Usage data. We record how you interact with our Services. For example, we log your taps/clicks on certain areas of the interface, the features, and content you interact with, how often you use the Services, how long you are in the Services, and your subscription orders.
• 2.9 Cookies and similar tracking technologies. Our products employ technologies (cookies, SDKs, etc.) to process your data to enhance your user experience, optimize ads, and analyze traffic. Disabling these technologies may affect the functionality of certain features, although our products will remain usable.

Cookies are classified by origin: first-party cookies are set by our websites under our domain and sub-domains; third-party cookies are cookies used within our Services which are set by other organizations. You can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. We respect your right to privacy and provide you with the option not to allow data processing that is not required for providing you the services you request.

3. For What Purposes We Process Your Personal Data

3.1 We process adults’ personal data to:

• Provide our Services — This includes enabling both you and your child to access and use the Services, customizing the experience, and preventing or resolving technical issues. To host personal data and enable our Website to operate and be distributed we use Amazon Web Services.
• Manage your account and provide you with customer support — We process your personal data to respond to your requests for technical support, service information or to any other communication you initiate, including notifications or emails about the performance of our Services, security, payment transactions, and notices regarding our Terms and Conditions or this Privacy Policy.
• Communicate with you regarding your use of our Services — We communicate with you, for example, by emails, using the details you provide, including your name. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails.
• Research and analyze your use of the Services — This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Services and our new products.
• Analyze how visitors use our Services and to measure effectiveness of advertising — We use Google Analytics and Amplitude for this purpose. Both tools process data according to their respective privacy policies.
• Send you marketing communications — We may process your personal data for our marketing campaigns, provided we receive consent or otherwise establish a legal basis. You can opt out at any time.
• Personalize our ads — We and our partners, including Facebook and Google, use your personal data to tailor ads.
• Process your payments — We use SolidGate and other third-party services to process payments. We will not store or collect your payment card details ourselves.
• Enforce our Terms and Conditions and to prevent and combat fraud.
• Comply with legal obligations.

3.2 We process Child Activity Data to:

• Support educational progress and personalization — We process children’s activity data to measure their performance in activities, adapt learning experiences to meet their individual needs, and provide adults with progress reports and educational insights. We do not conduct behavioral profiling of children.
• Improve and analyze the Services — Children’s activity data helps us to improve the content, functionality, and usability of the Services.
• Resolve technical issues and ensure security.
• Comply with legal obligations — We may process children’s data when necessary to comply with applicable laws and defend legal rights.
• Fulfill educational service requests with parental consent — Any processing beyond what’s necessary for the Services is conducted only with verifiable parental consent and is clearly disclosed at the point of collection.

4. Online Analytics and Advertising

We do not use third-party advertising or analytics tools on any child-accessible portions of our Services. Tools such as Facebook Pixel, Google Ads, and TikTok Pixel are restricted to adult-only sections. No Child Activity Data or any device identifiers from child users are collected or processed for advertising or behavioral analytics purposes.

How to Opt Out of Personalized Advertising

• iOS: Settings → Privacy → Advertising → Personalized Ads.
• Android: Google Settings → Ads → “Opt out of interest-based ads”.
• macOS: System Preferences → Security & Privacy → Privacy → Apple Advertising → deselect Personalized Ads.
• Windows 10: Start → Settings → Privacy → turn off “Let apps use advertising ID”.

Additional opt-out resources: Network Advertising Initiative, Digital Advertising Alliance, DAA Canada, Digital Advertising Alliance (EU).

5. Under What Legal Bases We Process Your Personal Data

This section applies only to EEA and UK-based users. Our legal bases for processing Personal Data are as follows:

• Your consent — Where we rely on this basis, you may have the right to withdraw your consent at any time (e.g., for marketing emails, via the unsubscribe link).
• To perform our contract with you — We rely on this basis to provide our Services, manage your account, communicate with you, and process your payments.
• For our (or others’) legitimate interests — We rely on legitimate interests to research and analyze use of the Services, send marketing communications, personalize ads, customize your experience, and enforce our Terms and Conditions.
• To comply with legal obligations.

6. With Whom We Share Your Personal Data

Service Providers

• Cloud storage providers: Amazon Web Services
• Data analytics providers: Facebook, Google, Amplitude
• Payment processing providers: Solidgate, PayPal, ApplePay, GooglePay
• Communication services providers: FreshDesk

Advertising Partners

We may share information about the adult’s interaction with our Services with partners in relation to personalizing advertising (social media networks, marketing agencies, email delivery services, Facebook, Google, ActiveCampaign). We do not share Child Activity Data with advertising partners.

Law Enforcement Agencies and Other Public Authorities

We may use and disclose personal data to enforce our Terms and Conditions, protect our rights, and respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities.

Third Parties as Part of a Merger or Acquisition

As we develop our business, we may buy or sell assets or business offerings. Customer information is generally one of the transferred business assets in these types of transactions.

We do not share Child Activity Data with third parties for marketing or promotional purposes and do not advertise to children.

7. Security

We recognize the importance of implementing a variety of security safeguards designed to protect the confidentiality of your information. No data transmission over the Internet or other network is completely secure. As a result, while we strive to protect information you transmit on or through our Services, you do so at your own risk.

When you create an account, you are prompted to create a password and parental code. You are responsible for maintaining the confidentiality of your account credentials. If you suspect someone else is using your account, please contact us immediately at privacy@coursiv-junior.com.

8. How You Can Exercise Your Privacy Rights

To be in control of your personal data, you have the following rights:

• Accessing / reviewing / updating / correcting your personal data: Request a copy or correction through privacy@coursiv-junior.com.
• Deleting your personal data: You can request erasure by sending us an email through privacy@coursiv-junior.com. In some cases we may be legally required to keep some data for a certain time.
• Objecting to or restricting the use of your personal data: Send requests through privacy@coursiv-junior.com.
• Right to data portability: Request your personal data in a machine-readable format through privacy@coursiv-junior.com.

If you are based in the EEA, you have the right to lodge a complaint with a supervisory authority. Our relevant supervisory authority is The Office of the Commissioner for Personal Data Protection in Cyprus (commissioner@dataprotection.gov.cy).

9. California Privacy Rights

This section provides additional details about how we process personal data of California consumers and the rights available to them under the California Consumer Privacy Act (“CCPA”) and California’s Shine the Light law. Therefore, this section applies only to residents of California, United States.

Unless certain exceptions apply, the CCPA allows you to request us to:

• Inform you about the categories of personal information we collect or disclose about you, the categories of sources, the business or commercial purpose, and the categories of third parties with whom we share personal information.
• Provide access to and/or a copy of certain personal information we hold about you.
• Delete certain personal information we have about you.
• Provide you with information about certain financial incentives that we offer to you, if any.

We may share certain information about you with our partners for purposes of targeted advertising or data analytics, which could be characterized as “selling,” “sharing,” or “targeted advertising” under California laws. You have the right to opt-out of such sale/sharing. Please note that we do not knowingly sell Child Activity Data or the personal information of minors under 16 years of age.

To exercise this right, look for a link titled “Your Privacy Choices” in the footer, menu, or profile section, depending on the specific product and device you are using.

California “Shine the Light” Disclosure: We do not share your personal information with third parties for their own direct marketing purposes within the meaning of that law.

10. Children’s Privacy

Coursiv aligns its processes with the Children’s Online Privacy Protection Act (“COPPA”). COPPA regulates the way in which online websites may collect and use information from children. We do not collect or use information in a manner that is inconsistent with COPPA.

We do not knowingly collect or request personally identifiable information from children under 13. We only collect persistent identifiers for the internal operation of our Services, so parental consent is not required. Account registration and the creation of a child’s profile must be completed by an adult. A parental code, established during this process, is required to access account settings and utilize certain features within our Services.

We collect Child Activity Data, device and account information, and automatically collected information while children use the Services, and use this information to: (i) support educational progress and personalization; (ii) improve and analyze the Services; (iii) resolve technical issues and ensure security; (iv) comply with legal obligations; (v) fulfill educational service requests with parental consent.

We may share this information with service providers (hosting, analytics, customer service, security and fraud prevention) and in connection with business transfers, legal obligations, or with the appropriate adult’s consent. Our Services do not allow children to make personal information publicly available.

Parents or legal guardians may contact Coursiv at privacy@coursiv-junior.com to review their child’s information, keep it accurate, current, and complete, delete it, or restrict further collection or use.

For processing children’s personal data, we rely on the legal basis of performance of a contract (with the parent), compliance with legal obligations, and where necessary, the parent’s explicit consent. All processing is limited to what is strictly necessary to provide our educational Services.

11. Changes to This Privacy Policy

This Privacy Policy is subject to change. We reserve the right to update or modify this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We encourage you to review this Privacy Policy frequently for any revisions or amendments. If we make material changes to how we collect, use, and disclose personal information from children under 16 years of age, we will, where necessary, notify you more prominently and/or obtain your prior consent, including parental consent.

12. International Data Transfers

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Services set forth in the Terms and Conditions and for purposes indicated in this Privacy Policy. If we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use: (i) Standard Contractual Clauses approved by the European Commission, or (ii) the European Commission adequacy decisions about certain countries.

13. Data Retention

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Services to you), which includes the period during which you have an account with the App. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Under certain accounting and tax laws we are required to store financial account data for long periods of time. Therefore, even if you submit a data deletion request, a small portion of the data that relates to our compliance obligations will be stored even after the request is satisfied.

14. How “Do Not Track” Requests Are Handled

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Except as otherwise stipulated in this Privacy Policy, the Services do not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

LAST UPDATED: October 31, 2025
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