Cignition Children's Privacy Policy

1. Contact Information

If you have questions or concerns about this Policy or our children’s privacy practices, you may contact us at:

Cignition, Inc.
21 Hillbrook Drive
Portola Valley, CA 94028
attn: Privacy

Email Address: support@cignition.com

2. Personal Information Collection

We collect a limited set of personal information from children necessary to provide our educational services. The categories of personal information we may collect include:

• User Name. A user name selected by or on behalf of the child during account creation.
• Persistent Identifier. An electronic persistent identifier generated by our system to track educational progress and adjust gameplay. Our system cannot associate persistent identifiers with particular students. Persistent identifiers are used solely for educational gameplay purposes, including modifying gameplay to adjust to the student’s ability level.
• Online Contact Information. Email address provided by a parent, legal guardian, or LEA.
• Usage and Performance Data. Data generated through the child’s use of our educational applications, including progress, scores, and performance metrics within the Platform.
• Session Media: Video/Audio recordings of live tutoring sessions for internal quality assurance and safety.

Publicly Available Information

The Platform does NOT enable children to make personal information publicly available. There are no public profiles, chat rooms, message boards, or other features through which a child could publicly disclose personal information.

3. How We Use Children's Information

We use children’s personal information solely to provide and improve our educational services. Specific purposes include:

• Creating and maintaining student accounts on the Platform;
• Delivering personalized learning experiences through the Platform;
• Tracking educational progress and adjusting gameplay to the student’s ability level;
• Generating reports for parents, legal guardians, and/or LEAs or schools regarding student progress and performance.

We do NOT use children’s personal information for marketing, profiling, targeted advertising, or for any commercial purpose unrelated to the provision of educational services.

We may use anonymous and aggregated data (from which individual children cannot be identified) to measure student performance and improve our applications, products, and services.

4. Disclosure of Children's Information

We may disclose children’s personal information only in the following limited circumstances and to the following categories of third parties:

1. Service Providers (hosting, data management, customer support). We may share children’s personal information with service providers who perform functions on our behalf solely to provide services to Cignition. These service providers are contractually prohibited from using children’s personal information for any purpose other than providing services to Cignition.
   
   
2. LEAs and School Districts. When services are provided under a written agreement with an LEA or school district, we disclose relevant student information to the applicable LEA or school district to fulfill our obligations under such agreement, including providing educational progress reports and performance data.
   
   
3. Legal Authorities. We may disclose children’s personal information to legal authorities when required by law, such as in response to a subpoena, court order, or other legal process, or when we believe disclosure is necessary to protect the rights, safety, or property of Cignition, our users, or others.
   
   
4. Tutors. For tutoring services, a student’s first name and relevant educational information are shared with the assigned tutor solely for the purpose of providing tutoring services.

We Do Not Sell Children’s Personal Information

Cignition does not sell children’s personal information for any purpose.

No Disclosure for Targeted Advertising or Non-Integral Purposes

We do not disclose children’s personal information to third parties for targeted advertising or for purposes not integral to the provision of our educational services. In the event we were to contemplate any such disclosure in the future, we would first obtain separate verifiable parental consent, as required by the COPPA Rule.

5. Data Retention and Deletion

We collect children’s personal information for the purpose of providing educational services, including creating and maintaining student accounts, delivering personalized learning experiences, tracking educational progress, and generating reports for parents, guardians, and LEAs.

Active Accounts: We retain children’s personal information to maintain active student accounts, track ongoing educational progress, generate performance reports, and fulfill our contractual obligations to parents, guardians, and LEAs. We do not retain children’s personal information longer than is reasonably necessary to fulfill these purposes.

Inactive Accounts:

• LEA/School District Accounts: Children’s personal information collected in connection with services provided under a written agreement with an LEA or school district is retained for the period authorized by the LEA under the written agreement. Upon termination or expiration of the agreement, children’s personal information will be deleted within ninety (90) days, unless a longer period is required by applicable law.
• Direct (Parent/Guardian) Accounts: Children’s personal information collected in connection with direct accounts is retained during the period of active use of the services, plus a reasonable period thereafter. Upon receipt of a deletion request from a parent or legal guardian, children’s personal information will be deleted within ninety (90) days, unless a longer period is required by applicable law.

Notwithstanding the foregoing, we may retain children’s personal information for a longer period if required by applicable law or legal obligation.

6. Parental Consent

We obtain verifiable parental consent before collecting, using, or disclosing personal information from children.

Consent Methods: We may obtain verifiable parental consent through the following methods:

1. Direct Purchase: When a parent or legal guardian purchases services directly from Cignition, consent is obtained during the account creation process, which includes providing payment information through a transaction and an affirmative acknowledgment of this Children’s Privacy Policy.

2. LEA/School District Channel: When services are provided under a written agreement with an LEA or school district, the LEA provides consent on behalf of parents solely for the collection of children’s personal information for an educational purpose and no other commercial purpose.

3. Other Permitted Methods: We may also obtain verifiable parental consent through other methods permitted under the COPPA Rule, including email with additional verification steps (such as a delayed confirmation or follow-up communication) and the “text plus” method (text message combined with additional verification steps).

Consent Is Not a Condition of Participation: We do not condition a child’s participation in any activity on the disclosure of more personal information than is reasonably necessary to participate in such activity.

Separate Consent for Third-Party Disclosures: We will obtain separate verifiable parental consent before disclosing children’s personal information to any third party for targeted advertising or for purposes not integral to the provision of our educational services.

7. Parental Rights

Under COPPA, parents and legal guardians have the following rights with respect to their child’s personal information:

• Right to Review: You have the right to review the personal information we have collected from your child.
• Right to Request Deletion: You have the right to request that we delete the personal information we have collected from your child.
• Right to Refuse Further Collection: You have the right to refuse to permit further collection, use, or disclosure of your child’s personal information.

How to Exercise Your Rights: To exercise any of the rights described above, please contact us using the contact information provided in Section 1 of this Policy. You may reach us by email at support@cignition.com or by mail at the address listed above.

We will respond to your request within a commercially reasonable timeframe. We may ask you to verify your identity before fulfilling your request to protect the security of your child’s information.

Effect of Revoking Consent: If you revoke your consent for the collection, use, or disclosure of your child’s personal information, your child will no longer be able to use Cignition’s services. Upon revocation, we will promptly delete your child’s personal information from our systems, except to the extent retention is required by applicable law.

8. Information Security

Cignition maintains a written information security program designed to protect the confidentiality, security, and integrity of children’s personal information. Our information security program includes administrative, technical, and physical safeguards that are designed to protect children’s personal information from unauthorized access, destruction, use, modification, or disclosure.
While we implement commercially reasonable measures to protect children’s personal information, no method of transmission over the Internet or method of electronic storage is completely secure. We continuously review and update our security practices to address evolving threats.

9. Google Account Login on FogStoneIsle.com

FogStoneIsle.com uses Google login to facilitate student access to the Platform.

Information Received: When a student logs in through Google, we may receive the student’s name, email address, and profile picture, as permitted by the Google account settings configured by the parent, guardian, or LEA.

Use of Information: Information received through Google login is used solely for the purposes of authenticating the student and creating or linking the student’s account on the Platform. We do not access Google passwords, Google Drive, Gmail, or any other Google services.

Third-Party Terms: Use of Google login is subject to Google’s Privacy Policy and Terms of Service. We encourage parents and guardians to review Google’s privacy practices.

10. Changes to This Children's Privacy Policy

We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will post the revised Policy on our website and update the “Effective Date” at the top of this Policy.

If we make material changes to this Policy that affect how we collect, use, or disclose children’s personal information, we will endeavor to provide prior notice to parents and guardians through email or other reasonable means before such changes take effect.

We encourage you to review this Policy periodically to stay informed about how we protect children’s personal information.