Kinjo Privacy Policy

Last Updated: June 23 2022

Kinjo is committed to the privacy and security of your personal data. We believe that you have a right to know what data we collect about you or your child and how that data is used. If you have any questions about Kinjo’s privacy philosophy or any of the terms and conditions of this privacy policy, please contact us at legal@kinjo.com.

This Privacy Policy explains how Kinjo Learning, Inc., together with its affiliates (“Kinjo,” “we,” “our,” or “us”) collects, uses, discloses and otherwise processes personal information in connection with our website, kinjo.com (the “Site”) and the mobile application for parent users (the “Parent App”) (collectively, the “Service”). 

A note about Kinjo’s Child App and Children’s data: The Child App and our collection, use and disclosure of personal information provided by children under 13 are governed by a different and separate Children’s Privacy Policy, which you can read here.

1. WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE? 

Personal Information:  When we use the term “personal information,” we mean any information that can be used to identify you, directly or indirectly, as an individual person.

We collect personal information in connection with your visits to and use of the Service. This collection includes information that you provide in connection with the Service, information from third parties, and information that is collected automatically, such as through the use of cookies and other technologies.  For further information on your choices regarding your information, see the “Control Over Your Information” section below.

A. Information You Provide to Us Directly 

We collect and use personal information you provide in the following ways:

• Your Account Registration and Profile Information. We collect personal information that a parent or legal guardian of a child (“Parent”) provides when registering for an account to use our Service (a “Parent Account”). This may include your first and last name, email address, phone number, mailing address, billing and payment card information. We may also collect full name and email address for any referrals you provide to us of parents/legal guardians who may be interested in the Service. We use this information to administer your account, provide you with the relevant services and information, connect you to your child’s account (“Child Account”) on our Kinjo mobile app for children (“Child App”), communicate with you regarding your account and the Service, and for customer support purposes.  

• Your Child’s Information. We collect personal information from Parents about their children. For example, we may collect the following information from Parents in connection with a Child: your child’s first name, your child’s preferred pronoun, your child’s birth month and year, and your child’s interests and strengths. We also may collect information on goals from the Parent about their child in connection with the Service. The Child App and our practices in connection with personal information provided by children under 13 are governed by our Children’s Privacy Policy.

• Account, Usage and Activity Information from Roblox. In order to provide the Service, we request that either the Parent or child user connect their Roblox account to the Service. If a Parent/child chooses to link their Roblox account, we collect Roblox login credentials, account information, and information associated with the Roblox users’ use of and activities through their Roblox account. For example, we collect the following information directly from the Roblox account linked to the Service: Roblox username, display name, avatar, and account ID; friends’ Roblox usernames; and games played on Roblox. 

• Messages and User Content.  You may provide us information through your communications with us or your use of the Service (collectively, “User Content”).  User Content and any information contained in the User Content, including personal information you may have included, is stored and collected as part of the Service. We use the User Content to operate, improve, personalize, and optimize the Service, and to manage and deliver advertising to Parents.  

• Inquiries.  If you communicate with us through any form, we may collect your name, email address, mailing address, phone number, or any other personal information you choose to provide to us.  We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users, and to manage and grow our organization.   
• Payment and Billing Information.  If you make a purchase through your use of the Service information is collected in connection with your payment, invoice or billing statement.  Please note that we use third party payment processors to process credit card payments made to us. As such, all such information is provided directly by you to our third-party processor. The payment processor’s use of your personal information is governed by their privacy notice.  

• Other Data You Share.  We also collect personal information at such other points on our Service that state that personal information is being collected so that we may provide the features or functionality for which we collected the personal information and for other purposes described in this Privacy Policy.  We may also collect your personal information or data if you submit it to us in other contexts (e.g., if you provide us with a review).

B. Information We Collect Automatically through Use of the Service 

We use various technologies to automatically collect certain personal information about the device or browser you use to navigate our Service, including:

• Web Logs.  Our web servers keep log files that record data every time a device accesses those servers.  As such, when you access our Service, we will automatically collect information such as your browser type and version, device and connection information, the Internet Protocol (IP) address used to connect your device to the Internet, and standard web log information.  
• Location Information.  We may collect a general geographic location based on your IP address when accessing our Service.  
• Cookies and Pixel Tags.  We, and our third-party partners, automatically collect certain types of usage information when you visit our Service, read our emails, or otherwise engage with us.  We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology (collectively, “tracking technologies”).  For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID (that allows us to uniquely identify your browser, mobile device, or your account), and other such information.  We also collect information about the way you use our Service, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the Service, whether you open emails or click the links contained in emails, and other actions you take on the Service.  Most internet browsers allow you to remove or manage cookie functions and adjust your privacy and security preferences.  For information on how to do this, access the “help” menu on your internet browser, or access http://www.aboutcookies.org/how-to-control-cookies.  Please note, however, that disabling our cookies may mean that you will not be able to take full advantage of the Service.

• Mobile Device Identifiers.  When you access our Service from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), or Google AdID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data (with your permission) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address.   

We use or may use the data collected through these technologies to:  (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Service; (b) provide custom, personalized content and information, including targeted content and advertising on our Parent App (see “Our Third-Party Data Collection and Online Advertising Practices” below); (c) provide and monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Service; (e) diagnose or fix technology problems; and (f) otherwise to plan for and enhance our Service.  

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.  Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly.  Depending on your mobile device and operating system, you may not be able to delete or block all cookies.  You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.   

On our Parent App, we and our third-party partners may also use cookies and tracking technologies for advertising purposes.  For more information about tracking technologies on our Parent App, please see “Our Third-Party Data Collection and Online Advertising Practices” below.

C. Information From Third-Party Sources 

We may receive personal information about you from third parties and combine this information with other information we have.

• Single Sign-On. We may use single sign-on (“SSO”) to allow a user to authenticate their account using one set of login information, including through Google, Apple or Facebook. We will have access to certain information from those third parties in accordance with the authorization procedures determined by those third parties, which may include, for example, your name, username, email address, and language preference. We use this information to operate, maintain, and provide to you with registration and the features and functionality of the Service. You may revoke our access to your account at any time by updating the appropriate settings in the account preferences of your third party account.
• Information We Receive from Third-Party Sites You Connect to Our Service. We may receive personal information about you from third parties (e.g., from Roblox, as explained above) and combine that with information we collect through our Service. The data we receive from these third-party sites is dependent upon that third party’s policies.
• Information from Other Sources.  We may obtain information from other sources, including through third-party information providers, business partners, or through transactions such as mergers and acquisitions.  We may combine this information with other information we collect from or about you.  In these cases, our Privacy Policy governs the handling of the combined personal information.  We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.  We may also collect information about you that is publicly available.

2. HOW WE USE YOUR INFORMATION

We use the information we collect for purposes described in this Privacy Policy or as otherwise disclosed to you on our Service or in connection with our Service.  For example, we use your information: 

• To set up your Parent Account or Child Account and deliver the features and functionalities of the Service;
• To send you transactional information, including confirmations, technical notices, product and services information, updates, security alerts, support and administrative messages, and information about your transactions with us;
• To communicate with you such as to respond to your comments and questions, provide customer service or feedback, or for any other purposes in connection with the Service;
• To provide you with news about products and services offered by us;
• To operate, maintain, test, enhance, update, monitor, diagnose, fix and improve our Service;
• To conduct research and analytics to understand our visitors and customers, and tailor our product offerings;
• To provide website visitors and Parents with advertisements based on your interests, purchase history, and through tracking technologies;
• To prevent, investigate or provide notice of fraud or unlawful or criminal activity, unauthorized access to or use of personal information, our data system services, and to meet governmental and institutional policy obligations; 
• To investigate and resolve disputes and security issues and to enforce our Terms of Service;
• In the event of a business transaction, such as a merger or acquisition, or in the event of bankruptcy; 
• To enforce and comply with legal obligations and contractual requirements; and
• For any other lawful, legitimate business purpose.  

3. HOW WE DISCLOSE YOUR INFORMATION

We may share your personal information with: 

• Your Child(ren). If you register for a Parent Account and connect it with a Child Account, your child(ren) may be able to review certain information about your Parent Account such as your name and email address.
• Affiliates.  We may share personal information with other companies and brands owned or controlled by Kinjo and other companies owned by or under common ownership as Kinjo, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns.  These companies will use your personal information in the same way as we can under this Privacy Policy.
• Service Providers.  We may share personal information with third-party service providers that perform services on our behalf, as needed to carry out their work for us, which may provide – for example – mobile application development or web hosting services, or payment processors through our Service for payment, invoicing and billing purposes.
• With Notice, With Consent, or at Your Direction.  We may disclose personal information with any other entity disclosed to you at the time we collect your information or with your consent or at your direction.  
• Business Transfers.  We may disclose personal information with other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings.
• Regulatory or Legal Requirements, Safety and Terms Enforcement.  We may disclose personal information to third parties as required by law or subpoena or if we reasonably believe that such action is necessary: (a) to comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Kinjo, our visitors, or others. We may also disclose personal information to governmental regulatory authorities as required by law, including for tax or accounting purposes, in response to their requests for such information or to assist in investigations.  

We may also share information with others in de-identified, aggregated, or otherwise anonymized form that does not reasonably identify you directly as an individual.   

4. OUR THIRD-PARTY DATA COLLECTION AND ONLINE ADVERTISING PRACTICES 

Please note that although we may permit third party advertising partners to collect information only on the Parent App for the purpose of displaying advertisements on other websites or online services on our behalf, we take many steps to avoid the collection of information for targeted advertising purposes when we believe the Kinjo services are being used by children. For example, we do not allow third party advertising networks to collect information for targeted advertising purposes on webpages with child-directed content or when a child user logs into or uses the Child App/Account. Please note that we may rely on cookies to identify whether you sign into a Child Account. and if you delete or block cookies, you may also delete the Kinjo cookie which prevents users from receiving targeted Kinjo advertisements on other websites or online services. Please review our Children’s Privacy Policy for more information.

For the Parent App (only), we participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your browsing history and your interests.  We permit third-party online advertising networks, social media companies, and other third-party services to collect information about your use of our Service over time so that they may play or display ads on our Service, on other apps, or services you may use, and on other devices you may use.  Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies.  We may share a common account identifier (such as an e-mail address or user ID) or hashed data with our third-party advertising partners to help identify you across devices.  We and our third-party partners use this information to make the advertisements you see in the Parent App more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.   

To learn more about interest-based advertising and how you may be able to opt out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (“DAA”) resources and/or the Network Advertising Initiative (“NAI”)’s online resources, at http://www.aboutads.info/choices or http://www.networkadvertising.org/choices, and you can opt out of receiving some interest-based advertisements on mobile apps by visiting http://www.aboutads.info/appchoices.  You may also be able to limit interest-based advertising through the settings menu on your mobile device by turning off “personalized ads” (iOS) or declining to opt-in to such advertising.  You may also be able to opt out of some – but not all – interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.  

Please note that if you use a different device, change browsers, or delete the opt-out cookies, you may need to perform the opt-out task again.  

5. CONTROL OVER YOUR INFORMATION

Modifying Parent Account Information.  You have the right to request to review, change, correct, or delete the information in your account and unlink/remove Roblox from the Service. You can make these requests by emailing us at support@kinjo.com. We may require you to verify your identity before we provide you with your information or make any requested changes. In limited circumstances, often due to legal or regulatory reasons, we may be unable to fulfill certain requests.

Accessing and Deleting Child Account Information. Parents may request to review or delete their Child user’s personal information by contacting us at legal@kinjo.com. Parents may also refuse to permit further collection of their Child user’s personal information by no longer providing the Child user access to the Services. We may request additional information to confirm that you are the Parent of the Child user when making these requests. Kinjo will retain the personal information collected from and about the user of the Child Account for as long as necessary to provide the Service and will de-identify or delete the personal information after the termination of the Parent Account in accordance with our standard data retention policy or until we receive a deletion request. Please refer to our Children’s Privacy Policy for more information.

We may be unable to delete, change, or correct any information we have collected from third parties, including Roblox. If you would like this information changed or corrected, please contact the third party that is the source of this information. If you have any questions about the source of information displayed in the Service, please contact us at support@kinjo.com.

How to Control Your Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications.  We make every effort to promptly process all unsubscribe requests.  You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).

Push Notifications. You can stop receiving push notifications from us by changing your preferences in the iOS notifications settings menu.

6. CHILDREN’S PRIVACY

The Site and Parent App are not directed toward individuals under the age of thirteen (13), and we do not knowingly collect or maintain personal information from anyone under the age of 13 on the Site and Parent App. If we become aware that a child under 13 has provided us with personal information via the Site or Parent App, we will delete this information from our files as quickly as possible or obtain parental consent. If you are the parent or legal guardian of a child under 13 who you believe has provided personal information to Kinjo via the Site or Parent App, please email us at legal@kinjo.com. 

Please see our Children’s Privacy Policy for information about how we collect, use and process personal information from children under 13 who use the Kinjo Child App.

7. LINKS TO OTHER WEB SITES AND SERVICES

The Service may contain links to and from third-party websites of our business partners, advertisers, and social media sites and our users may post links to third-party websites, such as Roblox.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies.  We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information.  We are not responsible for the privacy practices or the content on the websites of third-party sites.  

8. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Service, please contact us at legal@kinjo.com.   

9. CHANGES TO OUR PRIVACY POLICY

We may modify or revise this Privacy Policy from time to time and will notify you of any changes to this Privacy Policy by posting the revised Privacy Policy with an updated date of revision on our website. If we change this Privacy Policy in a material manner, we will do our best to notify you of the changes by posting a notice on our Site. Your continued use of the Service following the effective date of such update constitutes your acceptance of the revised Privacy Policy.