Mobile App Privacy Policy

Effective: June 10, 2022

Introduction

Edwards Insight, LLC (“Company”, "us", "we", or "our") operates the Name That Syllable, Name That Spelling Rule, and Name That Cutting Pattern mobile applications (hereinafter referred to as the "Services"), which are intended for use by students aged 4 and above. As a parent or guardian, we know that you care about how your and your child's Personal Data (as defined below) is used and shared. Please read this Privacy Policy to learn how we treat your and your child’s Personal Data.

This Privacy Policy informs you of our policies regarding how we treat your and your child’s Personal Data, including the collection, use and disclosure of Personal Data when you use our Services. By using the Services, you agree to the collection and use of information in accordance with this Privacy Policy.

Definitions

Business: Business, for the purpose of the CCPA, refers to the Company as the legal entity to the extent that it collects Consumers’ personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.

CCPA: CCPA refers to the California Consumer Privacy Act.

Company: Company (referred to as either "Company", "us", "we" or "our" in this Agreement) refers to Edwards Insight, LLC, Houston, Texas.

Consumer: Consumer, for the purpose of the CCPA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

COPPA: COPPA refers to the Children’s Online Privacy Protection Act.

GDPR: GDPR refers to the EU General Data Protection Regulation.

Services: Services are the Name That Syllable, Name That Spelling Rule, and Name That Cutting Pattern mobile applications operated by Company.

Service Provider: Service Provider means any natural or legal person who processes Personal Data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Services, to provide the Services on behalf of the Company, to perform services related to the Services or to assist the Company in analyzing how the Services are used.

Personal Data Personal Data means any information that identifies or relates to a particular individual and includes information referred to as “personally identifiable information” or “personal information” or “personal data” under applicable data privacy laws, rules or regulations. For the purposes of the COPPA, for example, term “personal information” means individually identifiable information about an individual collected online, including— (A) a first and last name; (B) a home or other physical address including street name and name of a city or town; (C) an e-mail address; (D) a telephone number; (E) a Social Security number; (F) any other identifier that the Commission determines permits the physical or online contacting of a specific individual; or (G) information concerning the child or the parents of that child that the website collects online from the child and combines with an identifier described in this paragraph. For the purposes of the CCPA, for example, “personal information” means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you. For purposes of the GDPR, “personal data” means any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Usage Data: Usage Data is data collected automatically either generated using the Services or from the infrastructure of the Services itself (for example, the date an app visit). See “Types of Data Collected” below.

You: You means the individual accessing or using a Service, the parent or guardian of such individual if the individual is a child, or the company or other legal entity on behalf of which such individual is accessing or using a Service, as applicable.

Information Collection and Use

Children’s Personal Data

COPPA requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13 years of age. Moreover, the GDPR requires that data controllers obtain consent from the holders of parental responsibility over children who are under 16 years of age before such controllers knowingly collect and process Personal Data from such children. Under the CCPA, the Consumer (between 13 and 16 years of age) must affirmatively authorize the sale of their Personal Data. If the child is under the age of 13 years old, a parent or guardian must affirmatively authorize the sale of the child’s Personal Data.

We do not knowingly collect Personal Data from anyone under the age of 16. Our services do not require the creation of accounts or allow users to interact with one another.

If you are a child under 16 years of age, you may not disclose any Personal Data to us before we obtain consent from your parent or guardian.

If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us at alison@edwardsinsight.com. If we become aware that we have received Personal Data from children under 16 years of age without verification of parental consent, we will take steps to remove that information.

If you are a parent/guardian of a user of our Services who is a child under 16 years of age, you may contact us at any time at alison@edwardsinsight.com to discuss our Privacy Policy.

Types of Data Collected

We may collect information to provide, improve, and analyze our Services, including the following types of information from you:

Usage Data: When you access the Services with a mobile device, we may collect certain usage information from App Store Connect and Google Play Console automatically, including, but not limited to: the type of mobile device you use (e.g., iPhone, iPad); your mobile device marketing name (e.g., iPhone 8, Galaxy X1Q); your mobile device operating system (e.g., iOS, Android) and version; number of app downloads/installs by date, type of mobile device, mobile device marketing name, country, or carrier (e.g., AT&T, Verizon); number of active use sessions by date, type of mobile device, and country; and information for financial reports, including, for example, (i) units sold and USD earned by country, and (ii) purchase transactions by transaction date, time, mobile device marketing name, country, state, postal code, and currency. We do not link App Store Connect or Google Play Console to any third-party services. In other words, we do not enable any features for third-party advertising, marketing, or analysis of Personal Data. For example, we do not subscribe to Google Ads, Google Marketing Platform, Google Analytics, or Firebase, and we do not link our Services in the Google Play Console to Google Ads, Google Marketing Platform, Google Analytics, or Firebase.

Correspondence From You: Other than Usage Data, we do not collect Personal Data unless you send us an email or otherwise contact us and include Personal Data.

How We Use Data Collected

The Company uses the information we collect only to support the internal operations of the Services as follows:

Usage Data:

• Providing support for the internal operations of the Services, including to develop, improve, and maintain our Services, including to monitor and analyze the usage of our Services.

o In conjunction with third-party analytics providers, such as App Store Connect Analytics and Google Play Console Statistics, for statistical reporting and analysis and identifying usage trends and payments.

• The Company does not use or disclose Usage Data in an effort to contact you, does not use or disclose Usage Data for advertising, and does not use or disclose Usage Data to create a profile on you.

Correspondence From You: Other than Usage Data, we do not collect Personal Data unless you provide Personal Data when contacting us. In such a case, we may use Personal Data when responding to correspondence that we receive from you or when contacting you when requested.

The Company does not engage in advertising based on any information collected from you.

Sharing of Data Collected

We neither rent nor sell Personal Data to anyone. We never share Personal Data with any third party other than as described below:

• With Service Providers: We may share Usage Data with Service Providers, such as analytics providers, to support the internal operations of the Services, such as to develop, improve, maintain, monitor, and analyze the use of our Services. See “How We Use Data Collected” section above and “Analytics Providers” section below. Any independent contractors we contract with are subject to confidentiality obligations.

• With Your consent: We may disclose Personal Data you disclose to us for any other purpose with your consent.

Transfer of Personal Data

Your information, including Personal Data and Usage Data, is processed at the Company’s place of business in Houston, Texas and in any other places where Service Providers involved in the processing are located. This information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

By using a Service, you consent to the transfer of your information in accordance with this Privacy Policy.

The Company will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Data Retention and Deletion

We store any Personal Data and Usage Data for as long as it is necessary to provide the Services to you and others, including those described above, or otherwise as long as allowable under law.

Please note that users of the Services do not create accounts, so you have no account associated with Personal Data.

To the extent that we receive any Personal Data from you, you have the right to ask us to delete such Data by contacting us at alison@edwardsinsight.com.

Business Transactions

Over time, the Company may grow and reorganize. We may share your information, including Personal Data with affiliates such as a parent company, subsidiaries, joint venture partners or other companies that we control or that are under common control with us, in which case we will require those companies to agree to use your Personal Data in a way that is consistent with this Privacy Policy.

In the event that the Company is involved in a merger, reorganization, dissolution, sale of business or assets or similar event, information disclosed to or collected by may be transferred to the Company’s successor, or to the purchaser of such assets, as applicable. We will provide notice on our website (https://edwardsinsight.com/) of any change in ownership.

Legal Requirements

To the extent we have any Personal Data, the Company may disclose your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of the Company

• Prevent or investigate possible wrongdoing in connection with the Services

• Protect the personal safety of users of the Services or the public

• Protect against legal liability

Security and Safety of Your Personal Data

The security of your Personal Data is important to us, but no method of electronic transfer or storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

But remember, we do not collect any data other than Usage Data and any Personal Data that you may provide to us when you are communicating with us. Users of the Services do not create accounts. Furthermore, users of the Services cannot create content and cannot interact with other users.

Further, to the extent that we have your Personal Data that includes contact information, and the Company becomes aware of any data breach, we will notify you using such contact information.

Analytics Providers

Third-party analytics vendors may collect, store, use, process, and transfer information about your activity on our Services in accordance with their Privacy Policies.

Specifically, we use Google Play Console Statistics and App Store Connect Analytics. Google Play Console is a platform that Google provides for Google Play mobile app developers to publish and monitor their app’s performance, including Usage Data. Similarly, App Store Connect is a platform that Apple provides for App Store mobile app developers to publish and monitor their app’s performance, including Usage Data. The Company uses Google Play Console Statistics and App Store Connect Analytics to monitor Usage Data, as indicated in the “Types of Data Collected” section above.

The Company does not link App Store Connect or Google Play Console to any third-party services. We only use Usage Data and any Personal Data to support the internal operations of the Services and do not enable any features for third-party advertising or marketing. For example, we do not subscribe to or use Google Ads, Google Marketing Platform, Google Analytics, or Firebase, and we do not link our Services in the Google Play Console to Google Ads, Google Marketing Platform, Google Analytics, or Firebase.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy. You may opt-out of certain Google features through your mobile device settings, such as your device privacy settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy.

For more information on the privacy practices of Apple, please visit the Apple Customer Privacy Policy web page at https://www.apple.com/legal/privacy/, choose “Privacy Policy,” and choose a language. You may opt-out of certain Apple features through your mobile device settings, such as your device privacy settings or by following the instructions provided by Apple in their Apple Privacy Policy (https://www.apple.com/legal/privacy/en-ww/) and App Analytics & Privacy Policy (https://www.apple.com/legal/privacy/data/en/app-analytics/).

California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers (e.g., educational institutions). If we are processing your Personal Data as a Service Provider, you should contact the entity that collected your Personal Data in the first instance (e.g., the educational institution) to address your rights with respect to such data.

The “Information Collection and Use” section above details how we collect and use information. If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at alison@edwardsinsight.com.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

• The categories of Personal Data that we have collected about you.

• The categories of sources from which that Personal Data was collected.

• The business or commercial purpose for collecting or selling your Personal Data.

• The categories of third parties with whom we have shared your Personal Data.

• The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third-party recipient. We neither rent nor sell Personal Data to anyone.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Exercising Your Rights

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

Call us at: 713-425-2513

Email us at: alison@edwardsinsight.com

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Personal Data Sales Opt-Out and Opt-In

We neither rent nor sell Personal Data to anyone.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA.

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at alison@edwardsinsight.com. Please note that we neither rent nor sell Personal Data to anyone.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at alison@edwardsinsight.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and contact information. Please note that we neither rent nor sell Personal Data to anyone.

European Union Data Subject Rights

EU Residents

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.

The Company will be the controller of your Personal Data processed in connection with the Services. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of Services to customers (e.g., educational institutions), in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party (e.g., the educational institution) in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at alison@edwardsinsight.com.

Personal Data We Collect

The “Children’s Personal Data” and “Types of Data Collected” sections above details the Personal Data that we do and do not collect.

Personal Data Use and Processing Grounds

The “How We Use Data Collected” section above explains how we use any Personal Data.

Sharing Personal Data

The “Sharing Data Collected” and “Analytics Providers” sections above details how we share any Personal Data with third parties.

EU Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at alison@edwardsinsight.com.

If any request made under this section is clearly unfounded or excessive, we may reject the request or require a reasonable fee to honor the request. Additionally, we may not be able fully comply with your request if it jeopardizes the rights of others, or if it is not required by law. If we decide to reject your request, we will inform you of the reasons for not taking action and provide information on other possible remedies. If we decide that a reasonable fee is necessary, we will promptly inform you and will comply with the request upon receipt of this fee.

In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

We will respond to all requests within a reasonable timeframe. If our full response will ever take more than a month due to complexity or scope, we will notify you of this and keep you updated.

Review and update your data: You have the right to access and update any Personal Data that we have collected. Please submit a request using the contact information at the end of this section.

Delete your data: You also have the right to get your Personal Data deleted. This is sometimes known as the ‘right to be forgotten’. To request that we delete all personal data about you, please submit a request using the contact information at the end of this section.

Restrict Processing: You have the right to restrict how we process your Personal Data in certain circumstances. This is an alternative to requesting the deletion of your data. Rather than requesting we delete all your Personal Data, you may request that we limit our uses of your personal data to specific purposes. You may wish to request we restrict our processing if you contest the accuracy of your Personal Data and we are working to verify this information, or if you want us to retain your Personal Data in connection to a legal claim but cease processing it.

Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all our Services.

Data Portability: You have the right to obtain copies of your information in a structured, commonly used format. We may request more information to confirm your identity before providing any Personal Data.

Right to Object: You have the right to object to the processing of your Personal Data for direct marketing purposes or when our processing of your data is based on legitimate interests. Note, however, that we do not processing your Personal Data for marketing purposes. Beyond direct marketing, if you wish to exercise this right, you must give specific reasons as to why you object to our processing of your data, based on your particular situation. Even after receiving such a request, we may continue processing if it is necessary for the exercise/defense of a legal claim or if we can demonstrate a compelling legitimate ground for the processing.

Right to File Complaint: You have the right to lodge a complaint about the Company’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

Lawful Bases for Processing Personal Data

If you are an individual in the European Union (EU) or an EU citizen, we collect and process data about you only where we have legal bases for doing so under applicable EU laws. This means we collect and process your data only when:

• It is necessary for a legitimate interest (which is not overridden by your individual privacy interests), such as preventing fraud, improving the Services, and increasing the security of the Services and network infrastructure;

• You have consented to this collection and processing for a specific purpose;

• It is necessary to fulfil our contractual obligations; or

• It is necessary to comply with a legal obligation.

Some examples of our legitimate interests and the data being processed include:

• Improving our Services (analytics and activity logs)

Where we rely on your consent to process your Personal Data, you have the right to withdraw or decline consent at any time. If you wish to withdraw your consent, please contact us using the information in the Contact for Individual Rights Requests section.

Where we rely on our legitimate interests to process your Personal Data, you have the right to object. More information on exercising this right can be found in the EU Data Subject Rights section.

Contact for Individual Rights Requests

Please use the below information when submitting a request to exercise any of the above rights. Please do not submit requests across multiple communication channels. We will make all efforts to respond to your request within a reasonable timeframe.

Email: alison@edwardsinsight.com

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

If you have any questions about this Privacy Policy, you can contact us by email at: alison@edwardsinsight.com.