Privacy Policy

Effective Date: August 20th, 2013

Welcome to the iLearn With educational program. This “Program” is composed of two elements: the iLearn With applications (the “Applications”) and a progress tracking and recommendation service (the “Service”). This “Privacy Policy” explains how Tribal Nova, Inc., with offices at 4200, Boulevard St.-Laurent, Ste. 1203, Montreal (Quebec), Canada H2W 2R2 (“Tribal Nova”, “us”, “we” or “our”) collects, uses, shares, processes, transfers and protects your personal information in relation to the Program. Please note that by using the Program, you consent to our practices as set forth in this Privacy Policy. Please also review the Terms of Use, which you accept by using the Program.

The Program is intended for parents to use in connection with their pre-literate preschool aged children and as such is a general audience service intended for adults. Adult supervision is appropriate and the Program is not appropriate for use by older, literate children.

Collection and Use of Information

1. Following is a description of the personal information Tribal Nova may collect from you and how we use that information:

(a) Your email address

By creating a Program account and providing your email address you consent to receive communications related to your account, the Service and our other products and services, including without limitation:

1. We may send you an email confirming your account creation or otherwise related to your account.

2. We may send you emails when your child achieves certain milestones in the Program such as passing a level.

3. We may send emails containing information about the Program such as parent tips, new apps becoming available or prize promotions.

4. We may send you emails regarding other educational products developed by Tribal Nova or our parent company Houghton Mifflin Harcourt Publishing Company and/or its affiliates (collectively, “Affiliates”).

5. We may alert you if there is an issue with your account or any other circumstance that could result in a disruption of service.

At any time, you may choose to stop receiving promotional email communications by clicking on the Unsubscribe link at the bottom of any email. We will honor your request to remove you from the list in a timely manner.

(b) Your child’s username

A “username” is a nickname that you create for each child who uses the Program. This username can be fictional and should not include the child’s family name. (Using a fictional username can help protect your child’s identity.) It is used solely for the purpose of personalizing the Program for your child and personalizing the learning progress reports for you. Tribal Nova will not, under any circumstances, use the username for the purpose of advertising products to you or your child.

(c) Your child’s birthday

This information is not required to be submitted to Tribal Nova in order to access or otherwise use the Service. If provided by you, it is designed solely to allow you to compare your child’s success rate with the success rate of children of a similar age. This information will only be used for internal operational purposes and will not be sold or rented to third parties for their use and will not be used to advertise products to you or your child.

(d) Your child’s learning profile

Because we track your child’s learning progress for you, we collect data on each child’s usage of various games in the Program and associate it with the accounts you have set up for your children. Except when providing this information to you, we only use this usage data in a de-identified, anonymous way. This data allows Tribal Nova to provide your child with the appropriate level of challenge in learning games and also helps us to evaluate the efficacy of our interactive curriculum and improve our services. Tribal Nova’s current policy is to retain profile data for as long as feasible (generally several years or longer) in order to enable users to keep having access to this information, but we undertake no obligation to do so. If you wish Tribal Nova to erase this data, please email support@ilearnwith.com, and we will make commercially reasonable efforts to do so.

2. In addition, we may collect non-personal information such as usage information and demographic information, which will only be treated as personal information as described in this Privacy Policy to the extent that it is combined with your personal information. To the extent it is not so combined, or is anonymized or de-identified, you consent to our unrestricted use and transfer of such information.

Sharing of Your Information

Tribal Nova will not, under any circumstances sell or rent your personal information to any party other than our Affiliates for their own purposes, except that we may transfer your personal information and other data about you: (i) to a subsequent owner, co-owner or operator of the Program or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process. Tribal Nova may engage other companies to provide services on its behalf, including, but not limited to, hosting, billing, marketing, and customer support for the Program. We only provide these companies the minimum information reasonably required to perform the service, and they are prohibited from using that information for any other purpose. Notwithstanding anything to the contrary, Tribal Nova and its Affiliates may disclose your personally identifying information, and other data about you, if required to do so by law or in the good-faith belief that such action is necessary to: (a) conform to legal requirements or comply with a legal governmental request; (b) protect and defend the rights or property of Tribal Nova, its Affiliates or its or their licensors; (c) enforce the Terms of Use; or (d) act in urgent circumstances to protect data security.

Children Under the Age of 18

Tribal Nova requires that a parent or legal guardian register for the Program and manage the account. The Program is not intended to collect personally identifying information from any person under the age of 18 and is intended to be purchased and used by parents of pre-literate children in association with such children. If you believe that a child under the age of 13 has submitted any personal information to us, please contact us at support@ilearnwith.comso that we may delete it. Adult supervision of a preschool aged user’s use of the Program is recommended at all times and children should not be given access to the parent center.

Advertising

The Program will contain no third party advertising or product placement. We may, however, cross-promote other products and services of Tribal Nova and its Affiliates to you via the Program, including in the form of ads. We may use third party vendors to assist us in doing so, including to track which products and services you have obtained from us and our Affiliates already so that we do not promote something you already have and to track and limit the number of ads and promotional messages we send you.

Cookies and Tracking Technologies

We may use various now and later existing methods and technologies to store or collect usage information and associate it with you (“Tracking Technologies”), such as “Cookies”. A Cookie is a data file that we or others may put on your device that captures and retains certain usage that is associated with a persistent identifier. We use this information to facilitate and improve our operations and services, such as so that we can automatically sign you in so that you do not have to enter a username and password each time you use one of our Applications. No personal information (aside from a persistent identifier) is ever stored in a Tribal Nova cookie, even if you have entered personal information in other parts of the Program. Some tracking technologies may be disabled by you through device settings and otherwise, but the Program may cease to operate fully or correctly if Cookies and other Tracking Technologies are disabled. We obtain your consent to our information storage or collection Tracking Technologies by providing you with transparent information about this practice in our Privacy Policy.

Transfer of Information to the United States

Our Program is operated from our offices in Canada and our servers in the United States. If you are located outside of the United States, please be aware that information we collect, including personal information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Program or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.

Security

We incorporate commercially reasonable safeguards to help protect and secure your personal information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Program and provide us with your information at your own risk.

Modifications to the Privacy Policy

We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Program indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected personal information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

Contact Us and Data Choices

If you have any questions or concerns regarding this Privacy Policy, or want to review, modify or delete your personal information, please email support@ilearnwith.com. We will make commercially reasonable efforts to respond to and comply with such requests. If you ask for your personal information to be deleted, your Services account will be terminated and we may retain de-identified data and customary business records. You can terminate ongoing data collection by uninstalling the Applications and ceasing to use the Service.