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PRIVACY POLICY

This is the privacy and data protection policy and notice of Nick Academy, which is owned, controlled and operated by KFFE Kids Fun Exploration Experience Ltd. 

KFFE Kids Fun Exploration Experience Ltd. (“KFFE”, “we”, “our” or the “Company”) respects the privacy of its clients, partners, employees, mobile application users and website visitors, and is committed to protecting the personal information you share with us about you or the child/ren associated with your Nick Academy account (these and any others with respect to whom we collect personal data, are collectively referred to as “client” or “you” or “Data Subjects”).

Nick Academy is a mobile-based application for children ages 6-12 aiming to teach them a wide variety of curricula through combination of games and pedagogical content (the “App”). Alongside the App, Nick Academy also includes a web-based parental dashboard, which enables them to monitor their child’s progress on the App and access other educational parental content (the “Website”/ “Parental Dashboard”) (collectively, the “Services”/“Nick Academy Platform”).

This policy and notice (the “Privacy Policy”) explains the types of information we collect from you or your child, that we receive about you or that you may provide in the course of your interest in our Services, business transactions, conferences, when you visit our website and when you or your child use our App. We are transparent about our practices regarding the information we collect, use, maintain and process and describe our practices in this policy and notice. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

For the purposes of EU General Data Protection Regulation (the “GDPR”) and other applicable privacy laws, Kfee is a data controller (“Controller”) in relation to the personal data of our Data Subjects.

  1. WHICH INFORMATION DO WE COLLECT?

Summary: we collect various categories of personal data in order to meet our contractual obligations, and also to meet various legitimate interests, such as fraud prevention and marketing. Some of the Data we collect will be anonymized in order to contribute to children-related educational research.

We collect data about you and your child in connection with your transactions with us, or in processing data for our clients. We also collect data about our employees and Website and App visitors. One type of data collected is non-identifiable and anonymous information (“non-personal data”). We also collect several categories of personal data (“Personal Data”), as described below.

Personal Data which is being gathered consists of any details which are personally identifiable and which are provided consciously and voluntarily by you through your use of our website, including the Parental Dashboard (as described below), through your registration on our App, through your child/ren’s use of our App, by email, or other ways in which you communicate and interact with us.

Personal information gathered from adult users (i.e. parent/legal guardian) generally includes: email address, username and password, and other information you provide to Kfee.

Note that when users make in-app purchases or purchase subscriptions, this is handled by the relevant app store that acts as an independent controller.We do not share personal data with the app stores. The relevant app store (eg Google or Apple) is a separate data controller.

After you register for an adult Nick Academy account, we will also collect from you details regarding the child authorized by you to use the Platform, for the purpose of creating a sub-account for your child. This will also apply for multiple children if you choose to authorize more than one child. This data includes your child’s profile name and year of birth, which will serve to customize the App to your child’s age level.

While the App provides a limited availability of free activities for children prior to registration, no personal data is collected at this point. Note that each child sub-account is associated with an adult account, and your child will not be able to gain access to the complete Nick Academy Platform, nor will your child’s personal data be collected prior to an adult’s registration and sign-in to the Platform.

In this regard we acknowledge that the U.S. Children’s Online Privacy Protection Act (“COPPA”) in the United States prohibits online service providers from knowingly collecting personal information from children under 13 years of age without verifiable parental consent (“Consent”). Such consent will be collected from adult users by their registration to the platform, through implementation of suitable age assurance tools.

Also note that the Nick Academy Platform will not enable your child to make his/her personal data publicly available.

Following your registration and sign-in, when your child uses our App, further personal data will be collected regarding your child’s app activities, including your child’s chosen avatar, as well as child performance, achievements and usage analytics, such as your child’s progress in each core subject, course and game completion status, awards, daily time usage, total time spent on the App, level and number of courses and activities completed.

This child-performance data will appear on the Parental Dashboard in order to help you to track your child’s performance. This data will also enable us to customize, adapt, and personalize the App to your child’s learning needs and preferences.

We also collect messages you send to your child through the Parental Dashboard. Such messages will be based on fixed templates and can be located and managed in your Parental Dashboard Inbox.

Additionally, we may obtain location data related to the geographic location of your laptop, or other digital device on which the Nick Academy website or Parental Dashboard is used.However, we will not collect geographic location data of the App.

You do not have any legal obligation to provide any information toKfee, however, we require certain information in order toperform contracts, or to provide any Services. If you choose not to provide us with certain information, then we may not be able to provide you with some or all of the Services.

When you contact us or submit requests for information or support via theParental Dashboard, App, email etc., Kfee will collect details, including also your name, phone number, email, country and other information provided by you.Kfee uses this information to offer Kfee’s Services and support.

  1. HOW DO WE COLLECT PERSONAL DATA OF YOURS ON KFEE SERVICES?

Summary: we collect Personal Data when you send it to us, or when a vendor, distributor or other business partner, sends it to us; we collect Personal Data through our Website, App and Services, and through our interactions with you.

We collect Personal Data required to provideServices when you register interest, or when you provide us such information in meetings or conferences, by entering it manually or automatically, in the course of registering for a Nick Academy account and children sub-accounts, or when otherwise corresponding or engaging with us. We also collect Personal Data when you call us for support, in which case we collect the information you provide us.

We also collect Personal Data through your use of our Website and App. In other words, when you are using the Parental Dashboard, or when you or your child are using our App, we are aware of it and gather, collect and record the information relating to such usage, either independently or through the help of third-party services as detailed below. This includes technical information and behavioral information such as the user’s Internet protocol (IP) address used to connect your device to the Internet, your uniform resource locators (URL), operating system, type of browser, browser plug-in types and versions, screen resolution, Flash version, time zone setting, the user’s ‘clickstream’ on the website, the period of time the user visited the website, methods used to browse away from a page, and any phone number used to call our clients’ service number. We likewise may place cookies and pixel tags on your browsing devices during your use of our Platform (see ‘Cookies’ section below).However, note that targeting and marketing tools will not be implemented on the App.

  1. WHAT ARE THE PURPOSES OF PERSONAL DATA WE COLLECT?

Summary: we process Personal Data to provide the Services and meet our obligations, protect our rights, and manage our business.

We will use Personal Data to provide and improveour Services to our clients, our clients’ child(ren) and others and meet our contractual, ethical and legal obligations. We strive to ensure that all Personal Data that we process remains accurate, complete and relevant for the stated purposes for which it was processed, including for example:

Processing which is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract:

  • carrying out our obligations arising from any contracts entered into between you andKfee and/or any contracts entered into with Kfee and to provide you with the information, support and Services that you request fromKfee.

In particular, this includes processing of personal data in order to enable us to provide the Services. For example, your login credentials and device details will be used to present content; your child’s year of birth will be used to customize the App to your child’s age level. Likewise, your child’s app performance data will enable us to help you to track your child’s performance via the Parent Dashboard, as well as to customize, adapt, and personalize the App to your child’s learning needs and preferences.

In this regard, note that data pertaining to children is collected in order to fulfill the contract between Kfee and the child’s parent / legal guardian and such data will be collected only after the parent / legal guardian has agreed to the Terms of Use by registering for the Platform and has created a sub-account for the child.

Processing which is necessary for the purposes of the legitimate interests pursued by Kfee or by a third party of providing an efficient and wide-ranging service to clients, where those interests are not overridden by your or your child’s fundamental rights and interests:

  • notifying you about changes to our Services and/or to our fee structure;
  • soliciting feedback in connection with the Services;
  • tracking use of the Platform and Services to enable us to optimize them;
  • contacting you electronically with parental educational content, commercial and marketing information about new features, events or additional Services offered byKfee which may be of interest to you, including in other locations. Note that we will not contact your child/ren with any marketing information or use their personal data for marketing purposes;
  • anonymizing your child’s Personal Data in order to conduct research with regards to the Platform’s educational impact and other educational-related research purposes;
  • for security purposes and to identify and authenticate your access to the login zone.

Processing which is necessary for compliance with a legal obligation to which Kfee is subject:

  • compliance and audit purposes, such as meeting our reporting obligations in various jurisdictions, anti-money-laundering, tax related obligations, and for crime prevention and prosecution in so far as it relates to our staff, clients, service providers, facilities etc;
  • if necessary, we will use Personal Data to enforce our terms, policies and legal agreements, to comply with court orders and warrants and assist law enforcement agencies as required by law, to collect debts, to prevent fraud, infringements, identity theft and any other service misuse, and to take any action in any legal dispute and proceeding.
  1. SHARING DATA WITH THIRD PARTIES

Summary: we share Personal Data with our service providers, partners, and group companies, and authorities where required.

We transfer Adult and Child Users’ Personal Data to:

Members of our Group: This includes individual or corporate representatives of Kfee, and any members of our group, which means our affiliate companies – whether wholly or partially owned by Kfee, and co-owned companies. 

Third Parties. We transfer Personal Data to third parties in a variety of circumstances. We endeavor to ensure that these third parties use your information only to the extent necessary to perform their functions, and to have a contract in place with them to govern their processing on our behalf. These third parties include business partners, suppliers, affiliates, agents and/or sub-contractors for the performance of any contract we enter into with you. They assist us in providing theServices we offer, processing transactions, fulfilling requests for information, receiving and sending communications, analyzing data, providing IT and other support services or in other tasks, from time to time. These third parties may also include analytics and search engine providers that assist us in the improvement and optimization of our App and Website, and our marketing.

Note that the personal data of your child will not be transferred to third parties for any marketing or promotional-related purposes. Third-party advertising and targeting tools may only implemented on the Nick Academy Website and Parental Dashboard and will not make use of your child’s personal data.

Third parties may also include research institutions or academic bodies that may help us conduct analysis of the child-performance information we collect on the App for children-related educational research purposes or in order to evaluate and improve the Services. Personal information used for research purposes will be de-identified prior to being transferred to such third-parties.

We periodically add and remove third party providers. At present, services provided by third-party providers to whom we transfer, or plan to transfer, Personal Data include also the following:

  • Website, Parental Dashboard and App analytics;
  • Document management and sharing services;
  • Client ticketing and support;
  • On-site and cloud-based database services;
  • CRM software;
  • Data security, data backup, and data access control systems;
  • Our lawyers, accountants, and other standard business software and partners.

The main third party services we use are listed below. For more information, please check the privacy policies of the relevant services.

In addition, we will disclose your Personal Data to third parties if some or all of our company or assets are acquired by a third party including by way of a merger, share acquisition, asset purchase or any similar transaction, in which case Personal Datawill be one of the transferred assets. Likewise, we transfer Personal Data to third parties if we are under a duty to disclose or share your Personal Data in order to comply with any legal or audit or compliance obligation, in the course of any legal or regulatory proceeding or investigation, or in order to enforce or apply our terms and other agreements with you or with a third party; or to assert or protect the rights, property, or safety ofKfee, our clients, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

For avoidance of doubt, Kfee may transfer and disclose non-Personal Data to third parties at its own discretion.

As described above, when users make in-app purchases or purchase subscriptions, this is handled by the relevant app store that acts as an independent controller.We do not share personal data with the app stores. The relevant app store (eg Google or Apple) is a separate data controller.

  1. WHERE DO WE STORE YOUR DATA?

Summary: we store your Personal Data across multiple locations globally

We store your Personal Data on servers owned or controlled by Kfee, or processed by third parties on behalf ofKfee, by reputable cloud-service providers (see the following section regarding international transfers).

  1. INTERNATIONAL DATA TRANSFERS (EU DATA SUBJECTS)

Summary: we transfer Personal Data within and to the EEA, USA, Israel and elsewhere, with appropriate safeguards in place.

EU and UK Personal Data is transferred to, and stored and processed at, a destination outside the European Economic Area (EEA). This includes transfer to our headquarters in Israel, a jurisdiction deemed adequate by the EU Commission, and to the USA, not currently deemed adequate. Where your Data is transferred outside of the EEA, we will take all steps reasonably necessary to ensure that your Data is subject to appropriate safeguards, including entering into data protection agreements that require the recipients to adhere to data protection laws and adequate data security. Transfers to Israel are made based on an adequacy ruling by the EU Commission. Transfers to the USA are made based on the Standard Contractual Clauses published by the EU Commissionor on the basis on contract. For more information about these safeguards, please contact us as set forth below.

We transfer Personal Data to locations outside of the EEA, including in particular USA and Israel, in order to:

  • store or backup the information;
  • enable us to provide you with the Services andfulfill our contract with you;
  • fulfill any legal, audit, ethical or compliance obligations which require us to make that transfer;
  • facilitate the operation of our group businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights;
  • to serve our clients across multiple jurisdictions; and
  • to operate our affiliates in an efficient and optimal manner.
  1. DATA RETENTION 

Summary: we retain Personal Data according to our data retention policy, as required to meet our obligations, protect our rights, and manage our business.

Kfee will retain Personal Data it processes only for as long as required in our view, to provide the Services and as necessary to comply withour legal and other obligations, to resolve disputes and to enforce agreements. We will also retain Personal Data to meet any audit, compliance and business best-practices.

When an account is closed, data will be stored for a period of up to seven years, and then will be anonymized or deleted. Likewise, some metadata and statistical information concerning the use ofour Services are not subject to the deletion procedures in this policy and will be retained byKfee. We will not be able to identify you from this data. Some data may also be retained on our third-party service providers’ servers until deleted in accordance with their privacy policy and their retention policy, and in our backups until overwritten.

  1. SERVICES AND WEBSITES DATA COLLECTION AND COOKIES

Summary: with your consent, we place cookies on your device. You control our use of cookies through a cookie management tool on our websites, or through your device and browser.

Kfee uses cookies, pixel tags and other forms of identification and local storage (together referred to as “tags/files” hereunder) to distinguish you from other users of the Platform. This helps us to provide you with a good user-experience when you browse the Platform and also allows us to improve our website, Platform and Services.

In many cases, these tags/files lead to the use of your device’s processing or storage capabilities. Some of these tags/files are set by Kfee itself, others by third parties; some only last as long as your browser session, while others can stay active on your device for a longer period of time.

These tags/files can fall into several categories: (i) those that are necessary for functionality or Services that you request or for the transmission of communications (functionality tags/files); (ii) those that we use to carry out website performance and audience metrics (analytics tags/files) and (iii) the rest (tracking across a network of other websites, advertising, etc.) (other tags/files).

Functionality tags are necessary for us to provide the Services. All other tags/files will only be placed on your device subject to your consent, managed through the cookie management tool.

Note that such tags/files will not make use of the personal data of your child for the purpose of advertising, marketing, targeting or other tracking/promotional related purposes.

Internet browsers allow you to change your cookie settings, for example to block certain kinds of cookies or files. You can therefore block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies, you may not be able to access all or parts of the website, due to the fact that some may be functionality cookies. For further information about deleting or blocking cookies, please visit:https://www.aboutcookies.org/how-to-delete-cookies/

To consult the list of cookies which we use on our website, please check your browser’s settings (see here for instructions:https://www.wikihow.com/View-Cookies) or view our cookie management tool.

  1. SECURITY AND STORAGE OF INFORMATION

Summary: we take data security very seriously, invest in security systems, and train our staff. In the event of a breach, we will notify the right people as required by law.

We take great care in implementing, enforcing and maintaining the security of the Personal Data we process.Kfee implements, enforces and maintains security measures, technologies and policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of Personal Data. We likewise take steps to monitor compliance of such policies on an ongoing basis.We use industry standard SSL (secure socket layer technology) encryption to transfer Personal Data. Likewise, we take industry standard steps to ensure ourWebsite, App and Services are safe. Other security safeguards include, but are not limited to, firewalls and physical access controls to buildings and files. 

Note however, that no data security measures are perfect or impenetrable, and we cannot guarantee that unauthorized access, leaks, viruses and other data security breaches will never occur.

Within Kfee, we limit access to Personal Data to those of our personnel who: (i) require access in order forKfee to fulfill its obligations, including also under its agreements, and as described in this Privacy Policy, and (ii) have been appropriately and periodically trainedwith respect to the requirements applicable to the processing, care and handling of the Personal Data, and (iii) are under confidentiality obligations, as may be required under applicable law.

Kfee shall act in accordance with its policies and with applicable law to promptly notify the relevant authorities and data subjects in the event that Personal Data processed byKfee is lost, stolen, or where there has been any unauthorized access to it, all in accordance with applicable law and on the instructions of qualified authority.Kfee shall promptly take reasonable remedial measures.

  1. DATA SUBJECT RIGHTS

Summary: depending on the law that applies to your Personal Data, you may have various data subject rights, such as rights to access, erase, and correct Personal Data, and information rights. We will respect any lawful request to exercise those rights.

Data subjects with respect to whose data GDPR applies, have rights under GDPR and local laws, including, in different circumstances, rights to data portability, rights to access data, rectify data, object to processing, and erase data. It is clarified for the removal of doubt, that where Personal Data is provided by aclient being the data subject’s employer, such data subject rights will have to be effected through thatclient, the data subject’s employer. In addition, data subject rights cannot be exercised in a manner inconsistent with the rights ofKfee employees and staff, with Kfee proprietary rights, and third-party rights. As such, job references, reviews, internal notes and assessments, documents and notes including proprietary information or forms of intellectual property, cannot be accessed or erased or rectifiedby data subjects. In addition, these rights may not be exercisable where they relate to data that is not in a structured form, for example emails, or where other exemptions apply. If processing occurs based on consent, data subjects have a right to withdraw their consent.

Under additional legislation, such as the U.S. Children’s Online Privacy Protection Act (“COPPA”), data subjects may have similar rights, such as theparents’ right to review the child’s personal information or have  itdeleted, and refuse to permit further collection or use of the child’s information.

A data subject who wishes to modify, delete or retrieve theirPersonal Data, may do so by contacting Kfee (privacy@nick.academy). Note that Kfee may have to undertake a process to identify a data subject exercising their rights. Kfee may keep details of such rights exercised for its own compliance and audit requirements. Please note that Personal Data may be either deleted or retained in an aggregated manner without being linked to any identifiers or Personal Data, depending on technical commercial capability. Such information may continue to be used by Kfee.

Data subjects in the EU have the right to lodge a complaint, with a data protection supervisory authority in the place of their habitual residence. If the supervisory authority fails to deal with a complaint, you may have the right to an effective judicial remedy.

  1. GENERAL

Minors. We do not knowingly collect or solicit information or data from or about children under the age of 16 without parental consent, or knowingly allow children under the age of 16 to register for the Nick Academy Platform or to use the App without parental consent.

During registration for the Platform, we make use of suitable age assurance tools in order to ensure that only adults may create an account.

While the App provides a limited availability of free activities for children prior to registration, no personal data is collected at this point. As noted above, each child sub-account is associated with an adult account, and your child will not be able to gain access to the complete Nick Academy Platform, nor will your child’s personal data be collected prior to an adult’s registration and sign-in to the Platform.

If you are under 16, do not register or attempt to register for the Nick Academy Platform or send any information about yourself to us without your parent / guardian’s consent. If we learn that we have collected or have been sent Personal Data from a child under the age of 16 without appropriate permissions, we will delete that Personal Data as soon as reasonably practicable without any liability to Kfee. If you believe that we might have collected or been sent information from a minor under the age of 16, please contact us at:privacy@nick.academy, as soon as possible.

Changes to this Privacy Policy. The terms of this Privacy Policy will govern the use of the Services, websites, and any information collected in connection with them. Kfee may amend or update this Privacy Policy from time to time. The most current version of this Privacy Policy will be available at: https://nick.academy/privacy-policy. Changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of our Services will constitute your active acceptance of the changes to and terms of the Privacy Policy.

Kfee aims to process only adequate, accurate and relevant data limited to the needs and purposes for which it is gathered. It also aims to store data for the time period necessary to fulfill the purpose for which the data is gathered.Kfee only collects data in connection with a specific lawful purpose and only processes data in accordance with this Privacy Policy. Our policies and practices areconstantly evolving and improving, and we invite any suggestions for improvements, questions, complaints or comments concerning this Privacy Policy, you are welcome to contact us (details below) and we will make an effort to reply within a reasonable timeframe.

Kfee’s data protection officer (DPO) may be contacted at:privacy@nick.academy

Our details:
KFFE Kids Fun Exploration Experience Ltd.
10 Nahalat Yitzhak Street, Tel Aviv, Israel.

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Last Revised: July 12, 2022