Children's Personal Data Retention Policy

1. Purpose of This Policy

This Data Retention Policy describes the purposes for which children’s personal information is collected, the business need for retaining such information, and the timeframes for deleting such information, consistent with the requirements of the Children’s Online Privacy Protection Act (“COPPA”) and its implementing regulations, as amended.

We retain children’s personal information only for as long as is reasonably necessary to fulfill the specific purpose for which the information was collected and do not retain such information indefinitely.

2. Scope

This policy applies to all personal information collected online from children under the age of 13 through our websites, applications, products, and services that are subject to COPPA (collectively, the “Services”).

3. Purposes of Collection and Business Need for Retention

We collect and retain children’s personal information for purposes allowed under COPPA, including internal operational purposes and any additional purposes for which a parent or legal guardian has provided verifiable parental consent consistent with COPPA requirements. These purposes include, as applicable:

To operate, manage, and provide the Services in ways that allow your child to participate in classes, activities, and other features of the platform
To respond to requests, questions, or issues related to your child’s use of the Services, including providing customer support and troubleshooting
To send service‑related and administrative communications necessary to support your child’s use of the Services, such as technical notices, updates, security alerts, and changes to our policies
To help protect the safety and integrity of the Services, including preventing and addressing fraud, misuse, violations of our terms or policies, and other harmful or unlawful activity
To monitor and analyze how the Services are used by children so we can maintain functionality, improve performance, and ensure the Services work as intended
To conduct internal research and analysis relating to children’s use of the Services in order to improve our educational offerings, features, and overall user experience
To verify eligibility and deliver prizes or rewards to your child in connection with promotions or activities they have entered, where permitted and with appropriate consent
To carry out other purposes that are specifically disclosed at the time your child’s information is collected, or that are carried out with your consent or at your direction

Children’s personal information is retained only where there is a documented business need directly tied to one or more of these purposes.

4. Categories of Information and Retention Timeframes

Third Party Recipient	Business Address	Categories of Personal Information Disclosed
Meta Platforms, Inc. (Facebook, Instagram)	1 Meta Way, Menlo Park, CA 94025	Identifiers, commercial information, internet or other electronic network activity information, geolocation data, education information, inferences drawn from any of the previous categories
TikTok, Inc.	5800 Bristol Parkway, Suite 100, Culver City, CA 90230	Identifiers, commercial information, internet or other electronic network activity information, geolocation data, education information, inferences drawn from any of the previous categories
Google LLC	1600 Amphitheatre Parkway, Mountain View, CA 94043	Identifiers, commercial information, internet or other electronic network activity information, geolocation data, education information, inferences drawn from any of the previous categories

Retention periods may vary based on the nature of the data, the purpose of collection, and applicable legal requirements, but in all cases retention is limited to what is reasonably necessary and does not permit indefinite retention.

5. Deletion Practices

When children’s personal information is no longer reasonably necessary for the purpose for which it was collected, we delete the information using reasonable measures designed to protect against unauthorized access or use.

Deletion may include permanent removal, anonymization, or aggregation, provided that the information can no longer reasonably be used to identify a child.

6. Prohibition on Indefinite Retention

We do not retain children’s personal information indefinitely. We periodically review our data holdings and retention practices to ensure continued alignment with this policy and applicable legal requirements.

7. Parental Rights

Parents may request access to, deletion of, or information about their child’s personal information as provided under COPPA. Requests are handled in accordance with our Children’s Privacy Notice and applicable law.

8. Policy Review and Updates

We review this Data Retention Policy on a periodic basis and update it as necessary to reflect changes in our practices, legal requirements, or the Services. Material changes will be reflected in the effective date above and, where required, communicated to parents.