Calling All Kids Privacy Policy

Effective Date: May 1, 2024

Welcome to Calling All Kids, which is owned and operated by Calling All Kids LLC, a California limited liability company (CAK). We are committed to providing an entertainment and learning environment where your child’s privacy is protected. This Privacy Policy describes the ways in which CAK and any of its subsidiaries (collectively, we, our, us, or the Company) collect, use, and disclose information about you and the children who use your Account through Calling All Kids, and any other websites, applications, and online services (Apps) that link to this policy (collectively, the Services). The Services are directed toward preschool-through elementary school-aged children, although they may be accessible and used by individual persons of all ages. Please read this Privacy Policy closely. By using the Services, you agree to the handling of your and your child’s information in accordance with this Privacy Policy. If you provide us with your information (directly or indirectly through our service providers), we treat your information according to this Privacy Policy. We will use your Personal Information only in accordance with this Privacy Policy. If we need to use your Personal Information for any other purpose, other than as disclosed herein, we will update this Privacy Policy, as explained under Section 11 (Changes to Our Privacy Policy) below.

Summary of Key Points

You should read this entire Privacy Policy and our Term & Conditions, but here are some key points:

Personal Information (PI) is defined in this policy to mirror the text of the California Consumer Privacy Act (CCPA) and means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
We take your privacy seriously, and we never monetize your PI, though we may use it to provide you special promotions and offers and as otherwise indicated in this privacy policy.
During CAK registration, we ask you to provide certain information on the child with whom you wish to use the Services. Should you have more than one child with whom you desire to use our Services, you are able to add additional Kid Profiles after the registration process is complete, by accessing the Account menu and selecting the Kid Profiles tab. During the initial registration process, the only information we may ask you to provide about the child you have selected to use the Services is the child’s nickname, the nickname by which the child refers to you (i.e. “Mommy”, “Dada”, etc.), the child’s gender, and the child’s birth day, month and year. It may also be possible that we ask you to provide a recording of you pronouncing the child’s name; this is to improve the accuracy of the voice commands that you may choose to use in our Services.
Other than in the places and for the purposes explicitly disclosed in this Privacy Policy, we do not knowingly collect any PI directly from Child Users under age 13. Please see Section 2 (Information Collection) for more information about how we safeguard payment information.
Because the security of your PI is important to us, we only ask for PI when it serves a business purpose and try to limit the collection of PI to only what is necessary to accomplish those purposes. We also use commercially reasonable physical, technical, and administrative security measures designed to safeguard all information collected by the Services.
Adult Users (as defined below) may contact us at any time as described in Section 12 (Contact Us) to request that we provide for their review, or delete from our records, any PI they have provided about Child Users associated with their Accounts, or to cease collecting PI from those Child Users. For information about when we automatically delete PI due to Account cancellation or inactivity, please see Section 6 (Account Cancellation and Reactivation; Data Retention).

Table of Contents

Types of Accounts, Services and Users
Information Collection
How We Use Information
When We Disclose Information to Third Parties
How to Access, Change or Delete Account Information
Account Cancellation and Reactivation; Data Deletion
State-Specific Privacy Rights
Links to Other Services
Location of Information Processing
Security
Changes to Our Privacy Policy
Contact Us

1. Types of Accounts, Services, and Users

How we collect, use, and disclose information depends on the type of Account and the type of User, as they are described in our Term & Conditions. This privacy policy applies to all Accounts. Users of the Services include Child Users (any child under age 18 who uses the entertainment and learning portion of the Services) and Adult Users (including parents and legal guardians of Child Users), collectively referred to as Users.

2. Information Collection

There are two general categories of information that we collect.

A. Information Users Provide to Us

As more fully set forth below, we and our third-party service providers collect information that Users provide when using the Services, including when Adult Users sign up for the Services, create an Account, or contact us with a question, comment, or request, and when Child Users participate in the Services. We will only use or disclose this information in accordance with this policy and applicable law. Please see Section 4 (When We Disclose Information to Third Parties) below for more information and how we limit disclosure of Child User information.

Adult Users

Adult Users are asked to provide certain PI about themselves when registering for any Account. There are two methods for an Adult User to register a new Account: (1) enter a valid email address and a password; (2) select one of the Social login methods. Social login (also known as social sign-on or social SSO) is an authentication method that enables users to log in to apps using their existing social network accounts to confirm their identity. In our Services, Adult Users may select from one of the following Social login options: Google, Apple, or Facebook. The Adult User is then prompted to grant permission to whichever option they select to share their identity details with the App. CAK provides this option since it allows Adult Users to access our Services without the need to create a new set of credentials from scratch. When an Adult User signs up via one of the social login options, the user is redirected to the corresponding social media authentication page where they have the option to grant consent that the Calling All Kids app will receive their email and name. If they grant this permission, the social media authentication generates an encrypted token for us which we use to retrieve the user’s email and name from the corresponding social media platform. At no point do we ever see or store users’ social media passwords.

Regardless of which of the two registration methods an Adult User follows to register for our App, they will still be required to enter a child’s nickname, the nickname by which the child refers to them (i.e. “Mommy”, “Dada”, etc.), the child’s gender, and the child’s birth day, month and year. It may also be possible that we ask the Adult User to provide a recording of them pronouncing the child’s name; this is to improve the accuracy of the voice commands that you may choose to use in our Services. Towards the end of the registration process for first-time users, they may be given the option to purchase a paid subscription to access advanced features of our Services. Therefore, the other information provided at registration depends on the type of Account or Adult User. For example:

Payment information is collected from Adult Users who purchase a paid Account by Stripe, our third party payment provider with whom we have integrated. We do not store any payment information and all such information is managed and stored within the Stripe (or other payment provider’s) cloud storage system.

The email address of an Adult User is also collected when the Adult User registers for an Account.

Adult Users who register for an Account will be asked to provide the nickname of the Child User, name by which the Child User refers to the Adult User, birth day, month and year of the Child User, and gender of the Child User who will be accessing the Services through their Accounts. While it is mandatory to enter all of this information, the Adult User has the ability to select “N/A” from the Gender field if they do not wish to provide information concerning the Child User’s gender.

Adult Users who register for an Account also have the option of uploading an image in place of their Child Users icons to further personalize the in-App experience. For example, if an Adult User wishes, they may replace the generic avatar silhouette representing their Child User with an actual photograph of that Child User’s face by uploading an image file in the Kid Profile section of the Account menu. This is an optional feature.

If you submit any information relating to other people in connection with the Services, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy. In addition, you represent that the uploading of and the content contained within the file(s) you choose to upload conform to the laws of all administrative levels (i.e. federal, state, local, etc.) of your location.

Child Users

While the Kid Profile creation section of our Services is intended for Adult Users, it is possible for Child Users to create or upload certain free-form content—such as photographs, audio or video files, and artwork—and save it in the Services, by following the same process that Adult Users would use, described in the previous section.

We encourage you to use the Services with your Child Users and to view and monitor any content created or uploaded (if applicable) by them. If you would like to review all Account information about your Child Users, you can access this information by clicking on the Account menu followed by clicking on the Kid Profile tab in the Services.

Interactive Features

For Accounts who choose to enable it, we may offer interactive features for Child Users (Interactive Features). Adult Users can opt in to allow their Account to access Interactive Features via voice and/or text, or they can decline. If an Adult User opts into Interactive Features, Users can then ask questions and have a conversation and or converse with animated characters within the Services about entertainment and educational topics.

Interactive Features may be used in two ways:

Voice

Interactive Features offers speech-to-text and voice assistant capabilities, which requires enabling microphone access on the device being used for the Services. If the microphone is enabled, User(s) can use Interactive Features via voice in addition to via typed inputs. We collect audio files with recordings of Users’ voices solely to provide the Services and as a replacement for written words. Once the voice recordings are used to provide the Services, (whether or not converted to text), they are immediately deleted. We do not store any dialogue or responses provided during the conversations, but instead, use such response to immediately trigger the Services. The Interactive Features only use the microphone to listen for responses for discrete periods lasting no more than 5 seconds each. If a valid response is not provided, the Services will respond with a default response.

There are two types of Interactive Voice Features, both of which are optional, since the User’s phone will prompt the User with pop-up permission request message similar to “Allow Calling All Kids Permission to Access Microphone?”. The User can decline permission but still use our Services, with the only difference being that their experience will not be as personalized, or that they’ll need to manually enter text instead of being able to use the hands-free speech-to-text function to convert their speech to text): (1) Premium Users have the option to add custom lines to the scripts before each phone call starts. Even if they accept CAK’s request to access their microphone, they can still opt out of this option. Before accessing the core function of the Services (placing a simulated phone call), the Premium User is shown a pop-up window that allows the Premium User to either enter text manually using their smartphone’s keypad or, by tapping a microphone icon, they can speak into their mobile device’s microphone and their speech will start being transcribed in real time inside the text box. After they tap “Save”, any text they entered either manually or via the Speech-to-Text function is then inserted into the script and the Character speaks it in the simulated call that takes place immediately afterwards. (2) Basic and Premium Users will have their calling experience improved should they grant CAK access to their device’s microphone, because the Character they select will be able to listen to and understand basic Adult User and Child User responses in real-time during each phone call, and the Character will adapt their follow-up responses accordingly. A Basic and Premium User can still use the app even if they decline CAK access to their device’s microphone, however in this case, a neutral follow-up response will be used by the selected Character after each User response.

Text

If Interactive Features are enabled but microphone access is not enabled, Child Users can use Interactive Features only via typed inputs and certain portions of the Services may not operate as planned.

Inputs from Users, whether submitted directly or generated by converting audio recordings to text, are (i) filtered to try to remove profanity, clear instances of Child User PI (or any PI), or other inappropriate language; (ii) retained by us as we retain other User data as described in this Privacy Policy, and without being associated with any Child User’s PI; (iii) used for purposes of supporting the Child User’s ongoing experience and further developing and improving the Services; and (iv) retained by our generative AI model provider(s) for approximately 30 days for abuse and misuse monitoring purposes.

Filtering technology may not block collection or retention of all profanity, PI, or other inappropriate language that Users choose to communicate in using Interactive Features. All Users, including Child Users, should avoid sharing PI in using Interactive Features. If we determine that any PI has been collected and retained through Interactive Features, we will delete such PI upon discovery.

The preceding section applies equally to all Users.

In the future, we may introduce additional features that will include voice and or text inputs. These features will conform to this policy, unless there are any material differences to the manner in which PI is processed, and if so, we will update this policy as set forth in.

B. Information We Collect from All Users

We and our third-party service providers collect PI directly from Users of the Services in the form of the actions they take and activities they complete when using the Services. For example, we may collect information about patterns of usage, which activities a User commences and completes, when a User starts and stops an activity, which types and areas of the Services the User frequents, the number of interactions between characters, how many rewards the User earns, what virtual items the User selects to exchange for such rewards, and the User’s choice of Avatar and related customizations.

We and our third-party service providers also use a variety of technologies, such as cookies (small text files that the Services save on your computer or mobile device), to automatically collect certain technical information from your computer or mobile device over time and across different websites, including when you use the Services, such as your browser type, operating system, device type, the page served, your IP address, the approximate geolocation of your computer or mobile device, and the websites you visited prior to visiting the Services. When you download and use one of our Apps, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.

We and our third-party service providers may use the information collected through these technical methods for several purposes, including delivering content, tracking and enhancing our Users’ experience with the Services, and delivering advertising to visitors to http://www.Calling-All-Kids.com when they visit other websites and applications. For example, when you return to the Services after logging in, cookies help the Services recognize who you are without having to log back in. The information collected through these technical methods are used only to support the internal operations of the Services. We do not allow third-party advertising networks to collect information about Users who are logged in to their Accounts. More information about the use of cookies is set forth below.

Cookies

We use cookies, which are small text files placed on your device, to collect certain Internet log information and visitor behavior information. More information about cookies is available at www.aboutcookies.org. We use cookies to recognize your device and to provide and improve our Services as described below. We may use the following cookies:

Essential Cookies

These cookies are essential to provide you with services available through the Services and enable you to use some of its features. For example, they allow you to log in to secure areas of our Services and help the content of pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies

These cookies allow us to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details, and remembering the changes you make to other parts of Services, which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to reenter your preferences every time you visit our Services.

Analytics and Performance Cookies

These cookies are used to collect information about traffic to our Services and how Users use the Services. The information gathered does not identify any individual visitor. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information, and to monitor the level of activity on our Services.

If you do not want the Services to collect information through cookies, you can set your web browser to reject cookies from the Services. Each browser is different, so you should check your browser’s Help menu to learn how to change your cookie preferences. However, please note that if you reject or block cookies from the Services, the Services may not function as intended. For example, you will not be able to remain logged into your Account, and therefore, you would have to log in during each page transition.

Social Media Cookies

These cookies are used when you share information using a social media sharing button; “like” button on our Services; or you link your account or engage with our content on or through a social networking website, such as Facebook, Twitter, or Google+. The social network will record that you have done this.

Except as otherwise provided in this policy, such as when a resident of a state that offers additional privacy protections has opted out of sharing PI for valuable consideration, by continuing to use our Services, you are accepting our use of these cookies that make advertising and communications more relevant to you and your interests and further help us to improve our Services.

Push Notifications and SMS: Additionally, if you downloaded the App on your mobile device to access the Services, as part of your use of the Services, we may ask if you would like to receive push notifications, which may include alerts and notifications, badges, banners, and sounds on your mobile device. You may choose to stop receiving push notifications at any time by changing the settings on your mobile device. If you provide us with your mobile phone number, we may send you SMS text messages about your Account. Please note that your carrier may charge you for the text messages you receive. To permanently stop receiving SMS text messages from us (if you are located in the U.S. or Canada) text STOP, CANCEL, or UNSUBSCRIBE in reply to any SMS text message sent by us.

Location: We have access to and store the country of each user’s location. At no point do we store more granular locational data such as street addresses, cities, provinces, or first-level administrative divisions like states and regions. Since we offer our services in multiple languages and in multiple locales, it is imperative that we serve the correct locale-specific content (i.e. language, product offerings) to our users based on their country of residence.

3. How We Use Information

We will never monetize the PI of any User of the Services by providing it to a third party in exchange for money, except as described in this policy in the context of a sale of the Company.

We and our third-party service providers may use the information collected from Users as follows:

Adult User Information Information collected from Adult Users may be used:

To permit you to register for and use the Services or to allow you to provide Feedback. For certain Accounts, to complete and fulfill your purchase, such as to process your payments, communicate with you regarding your purchase, and provide you with related customer service.
To respond to your inquiries and fulfill your requests, retrieve your password, or provide technical support. To provide marketing communications that we believe may be of interest to you. While it is never our intention to send any marketing messages to children, if you believe a Child User has received such a marketing communication, please contact us as described in Section 12 (Contact Us). You can always choose to stop receiving these marketing messages by simply following the instructions contained in the message or, if the communication is by phone, by informing the caller of your desire not to receive further phone communications. For all Accounts, you may not opt out of receiving administrative messages from us regarding your Account, such as password reset emails and customer support messages.
To deliver our advertising to you based on your visits to the Services, for example, when you visit third-party websites and applications or via postal mail. You may opt out of receiving online interest-based advertising from our interest-based advertising providers by visiting http://www.aboutads.info/choices. For more information about web browser “do not track” signals, visit www.allaboutdnt.com . Certain state residents have additional rights under their state data privacy laws. For more information about these rights, please see Section 8.
To measure the effectiveness of our advertising to adults.

Child User Information: Information collected from Child Users may be used:

To measure a Child User’s performance in activities and to adapt a Child User’s experience to the Child User’s entertainment or learning needs.
To analyze, provide progress reports on, or provide an assessment of a Child User’s performance to the Adult User on the Account.

Both Adult and Child User Information: Information collected from both Adult and Child Users may be used:

To allow us to assess and improve the Services, its educational content, and other services we provide (for example, to improve our content and User experience); to research, evaluate, and improve the educational efficacy of the Services; and to inform our understanding of the Services’ User base.
To customize, adapt, and personalize Users’ viewing and content-consumption experience; for example, by measuring a Child User’s performance in activities and adapting the Child User’s experience to their entertainment or learning needs.
To maintain and analyze the functioning of the Services.
As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to detect violations of and enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates, including the security of the Services; (f) to protect our rights, privacy, safety, or property, or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain (collectively, [a-g] are Other Uses and Disclosures).

4. When We Disclose Information to Third Parties

PI collected from both Adult and Child Users will not be disclosed except for the following purposes, which include our operations purposes:

To third parties who perform certain services for us, such as processing credit cards, conducting research on the educational impact of the Services, or filtering User inputs in using Interactive Features, provided that the service providers agree to keep the information confidential and to use it only for purposes that are permitted by this Privacy Policy. By continuing to use the Services, you are intentionally directing us to transmit the information submitted to us by Adult Users to our affiliates and business partners for business purposes, such as executing transactions and preventing fraud.
As we believe to be necessary or appropriate as set forth above in Other Uses and Disclosures and in other instances substantially similar to those listed in this Section.
When we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. If required or permitted to do so under the law, and if deemed necessary or warranted, we may provide notice to Users prior to the disclosure.
Subject to confidentiality agreements, the terms of this Privacy Policy, and applicable law, information may be disclosed to service providers, advisers, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, transfer, or license all or a portion of our assets in bankruptcy or otherwise. This means that if some or all our assets are acquired or otherwise transferred or licensed, including in bankruptcy, that such acquirer shall be subject to the same commitments stated under this Privacy Policy.

In addition, we may use third-party advertising networks and other affiliates in association with cookies, pixel tags, or IFrames, for Adult Users’ visits to the Services and to (1) deliver interest-based advertising to those Adult Users, including our advertising, when those Adult Users visit third-party websites; and (2) provide us with statistics about the effectiveness of our advertising on third-party websites. These third-party advertising networks may use this cookie information in accordance with their own privacy policies.

We do not disclose the PI of any Child User to third parties for any marketing or promotional purposes. This also means that we do not share the PI of children under the age of 16 for valuable consideration.

We also may disclose de-identified and/or aggregated User information for any other purpose as permissible by applicable law—for example, the distribution of de-identified User records to outside researchers or the distribution of reports containing aggregate User demographic and traffic patterns—provided that no individual Adult User or Child User or any specific end-user device can be readily identified.

5. How to Access, Change, or Delete Account Information

An Adult User can review or change the information they provided when they registered for the Services, including by adding or removing Child Users to or from the Account; by updating information through the Services’ User Profile and/or Kid Profile sections. In addition, Adult Users may contact us at any time as described in Section 12 (Contact Us) below to request that we provide for their review, or delete from our records, any PI they have provided about Child Users associated with their Accounts or that said Child Users may have inadvertently provided about themselves, or to cease collecting PI from those Child Users, as applicable. Please keep in mind that a request to delete PI may lead to cancellation of your Account or the inability to use certain Services.

When we change or delete any PI at your request, we will make good faith efforts to make the changes in our then-active databases as soon as reasonably practicable, generally within 24–48 hours. Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules. Please note that information may remain in backup or archive records, and we may retain certain data relevant to preventing fraud or future abuse or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable or de-identified data, Account recovery, or if required by law. All retained data will continue to be subject to the Privacy Policy in effect at that time.

6. Account Cancellation and Reactivation; Data Deletion

At any time, Adult Users may delete their Accounts through the User Profile Section of the Services.

For Accounts that have been deleted, we will delete all Child User PI in our active databases associated with the Account (Account Information), unless otherwise stated in this Privacy Policy. We will not use Child User PI for any other purpose other than for reactivation of the Account. We provide no guarantee and shall have no liability or obligation to ensure that all Account Information and related Services will be available or accessible or all learning or personalization features will be able to be recovered or resumed. If a User requests that PI be deleted, we will take commercially reasonable steps to satisfy that request. However, if the User is a resident of a state where additional privacy protections are required by law (see Section 7 for a list of these states), the provisions of Section 7 below shall govern.

Upon Account deletion, de-identified Adult and Child User information may nonetheless persist internally in our archive files or similar databases, and may still be used, on a de-identified basis, for our internal support, administrative, and record-keeping purposes including but not limited to allowing us to improve the Services and other services we provide through research, evaluation, and analytics as permissible by applicable law.

Please note that following a request to delete information or cancel your Account under Sections 5 or 6 of this Privacy Policy, information including PI may remain in backup or archive records, and we may retain certain data if required by law, relevant to preventing fraud or future abuse, or for legitimate business purposes, such as account recovery and customer support, and all are subject to our internal records retention periods. All retained data will continue to be subject to the Privacy Policy in effect at that time and applicable law.

7. State-Specific Privacy Rights

States with comprehensive consumer data privacy laws may provide residents with additional rights regarding our use of PI. The following Section applies to individuals who reside in specific jurisdictions that provide additional privacy rights, including California, Colorado, Connecticut, Utah, and Virginia (“Relevant States”).

Under the Relevant States’ laws, we are required to disclose the categories of sources from whom we collect PI (explained below) and the third parties with whom we share it (explained above). We are also required to communicate information about rights you have under Relevant States’ laws, such as:

Right to Access Specific Information and Data Portability Right: You have the right to request that we disclose certain information to you about our collection and use of PI over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of PI we collected about you.
The categories of sources for the PI we collected about you.
Our business or commercial purpose for collecting or selling that PI.
The categories of third parties with whom we share that PI.
The specific pieces of PI we collected about you (also called a data portability request).
The business purpose for which PI was disclosed, and the PI categories that each category of recipient obtained if we disclosed PI for a business purpose.

Right to Correct Information: You have the right to request we update PI about you that is incorrect in our systems.

Right to Delete: You have the right to request that we delete the PI that we have collected from you, subject to certain exceptions. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) the PI from our records, unless an exception applies. Please note, however, that we may need or be required to keep such information for our legitimate business purposes or to comply with applicable law.

Right to Opt Out of the Sale or Sharing of Personal Information for Cross-Contextual Behavioral Advertising: As stated in the Summary of Key Points above, we will never monetize the PI of any User of the Services by providing it to a third party in exchange for money. Some Relevant States’ laws apply a broader definition of the term “sell” that includes disclosing PI to any third party for valuable consideration. When we work with our advertising partners, we disclose certain information such as cookies for their services, which are of value to us. You may be entitled to direct us to stop disclosing your PI to third parties for monetary or other valuable consideration. You can exercise such right to opt out by writing us at contact@calling-all-kids.com with “PI Opt Out” written in the subject line.

Right to Limit Sensitive Personal Information Use: You have the right to limit the use of sensitive PI regarding you.

Non-Discrimination: We will not discriminate against you for exercising any of your rights.

For details on exercising these rights, please see “Exercising Access, Disclosure, Data Portability, and Deletion Rights” below.

Information We Collect and Share

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 or household.

We have collected the following categories of PI from or about consumers within the last 12 months:

Category	Collected
Identifiers	NO
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)).	YES
Protected classification characteristics under California or federal law	NO
Commercial information	NO
Biometric information	NO
Internet or other similar network activity.	YES
Geolocation data	YES
Sensory data	NO
Professional or employment-related information	NO
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	NO
Inferences drawn from personal information	YES

In addition, we are required to provide you certain information about the business and commercial purposes for which we collect and share PI.

Business and Commercial Purposes for Which We Use Personal Information

We may use or disclose the PI we collect from each of the Categories of PI listed above for one or more of the following purposes:

To fulfill or meet the reason you provided the information;
To provide, support, personalize, and develop our Services;
To process your requests;
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and to monitor and improve our responses;
To provide customer service;
To understand how Users interact with our Services;
To conduct research, testing, analysis, and development;
To detect security incidents and prevent fraud;
To debug and repair errors;
To create, maintain, customize, and secure your Account with us;
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
As described to you when collecting your PI or as otherwise set forth in Relevant States’ laws;
To advance our commercial and economic interests, such as delivering interest-based advertising of our products and services to Adult Users and analyzing the effectiveness of our advertising; and/or
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which PI held by us about our Users/consumers is among the assets transferred.

Categories of Personal Information We Share

We may share your PI by disclosing it to a third party for a business purpose described below. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the PI confidential, and prohibit using the disclosed information for any purpose except performing the contract.

Our Retention of Personal Information

We retain PI for as long as necessary to provide the services and fulfill the transactions you have requested, or for other business purposes, such as complying with our legal obligations, resolving disputes, and enforcing our agreements. We decide how long we need PI on a case-by-case basis. We may consider the following factors when making retention decisions:

Whether we need to keep some of your PI to maintain your Account;
Whether we are required by law to keep some types of PI for certain periods of time to comply with our legal obligations; and
Whether we need some of your PI for other business purposes, such as to prevent harm and ensure safety and security of our Services, investigate possible violations of our terms and conditions of use, or protect ourselves.

If we determine your PI is no longer necessary using the factors above, we will generally destroy or anonymize that PI.

Exercising Access, Disclosure, Data Portability, and Deletion Rights

To exercise the access, disclosure, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either contacting us as set forth in Section 12 (Contact Us) below, or by visiting here: Privacy Portal

Only you or a person registered with the applicable Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your PI. You may also make a verifiable consumer request on behalf of your Child User(s).

For all requests, please clearly state that the request is related to “Your Privacy Rights,” indicate which type of request you are making, and provide your name and an email address or phone number where we may contact you. We are not responsible for notices that are not labeled or sent properly or that do not include complete information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected PI or an authorized representative. We will verify your request by asking you to provide information related to your interactions with us. We will not otherwise ask for PI from you that we would not otherwise maintain as part of providing our Services.
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 PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use PI provided in a verifiable consumer request to verify the requester’s identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide the PI that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

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 we made that decision and provide you with a cost estimate before completing your request.

To appeal a decision regarding a consumer rights request, please submit your appeal using our portal, email, telephone, or postal mail. Your appeal should include an explanation of the reason you disagree with our decision. Within 60 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Non-Discrimination
We fully support your privacy rights and will not discriminate against you for exercising them.

Notice of Financial Incentives
We may offer special incentives to users who enroll in certain promotions. The availability of these promotions to you at any given time will vary. If we offer such programs, we may ask for your PI (such as your email address) as a prerequisite to your participation in the promotion.

The promotions that may be available to you are email offers. When you subscribe to receive emails from the Company, we may offer you special savings in the form of digital coupons for free or discounted products and announcements of sweepstakes, contests, and giveaways. To participate in these email offers, you must provide a valid email address. You may opt in to the email offers by visiting our website or navigating through your Account. You may opt out of email offers and other programs at any time through the same means they are offered, or by contacting us as provided in Section 12 below.

The value we place on the PI that we collect in connection with these promotions is calculated by determining the approximate additional spending per promotion participant, compared to individuals for whom we do not have email addresses, or other collected information.

8. Links to Other Services

In certain sections of the Services, we may include links to external websites or applications (for example, Meta (Facebook)). However, to protect children from accessing these external websites, an Adult User will be required to enter a valid password. These websites and applications are governed by their own privacy policies or information collection practices, which may be substantially different from ours. We encourage you to review the privacy policies and information collection practices of any external websites and apps, as those parties’ practices would not be subject to this policy.

9. Location of Information Processing

The Services are controlled and operated by us from the United States. Your information may be stored and processed in any country where we have facilities or in which we engage service providers, including the United States, which may have data protection laws that are different from those of your country. In addition, your information may be subject to access requests from governments, courts, or law enforcement officials in countries where it may be processed, under the laws of those countries.

10. Security

The security of your PI is important to us, and we employ physical, technical, and administrative security measures designed to safeguard the information collected by the Services. We use industry standard SSL (secure socket layer technology) encryption to transfer PI. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to buildings and files. We also conduct periodic audits of our security (no less than annually) to apply best practices and reasonable industry standards. Account holders create a password in the registration process. You can help protect against unauthorized access to your Account and PI by selecting and protecting your password appropriately and limiting access to your mobile device or mobile app session, computer and browser by logging out or by signing off after you have finished accessing your Account. At registration, we assign a User ID to each Account and use those User IDs to authenticate logins, allow access to the subscription content, and monitor compliance. The User ID is also used to authenticate users when requesting technical support. Access to information is limited (through User/password credentials and two-factor authentication) to those employees who require it to perform their job functions.

All of the information and data from our customers is stored on AWS, including image and any audio files. This data is stored in Amazon’s S3 bucket with the default server-side encryption (SSE-S3).

However, no data transmission over the Internet can be guaranteed to be completely secure. If there is a breach of our security, we will notify you where required by law or deemed necessary and appropriate under the circumstances.

Please be aware, however, that no information system can be guaranteed to be 100 percent secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Services over networks that we do not control, including the Internet and wireless networks. If you have reason to believe that your interaction with us is not secure, please contact us as described in Section 12 (Contact Us) below.

11. Changes to Our Privacy Policy

We constantly try to provide the best services, and accordingly, our Privacy Policy will change from time to time. If we update this Privacy Policy, we will notify you by posting the revised Privacy Policy on the Services; and for certain revisions that materially expand the ways in which we use or share the information previously collected from you through the Services, we will either display an alert next to the Privacy Policy, display an alert upon login to the Services, or directly communicate with you (for example, via the email address associated with your Account).

12. Contact Us

Calling All Kids LLC is based in the United States of America and is the operator of all the Services. You may contact us below if you have any questions, complaints, or other issues related to this Privacy Policy and issues related to your or a Child User’s information for which you are responsible:

Mailing address:

Calling All Kids, LLC
Attention: Legal Department
5142 Hollister Ave #280

Santa Barbara, CA 93111

USA

Email address: contact@calling-all-kids.com