Our Privacy Notice online explains how we, Outschool, Inc., collect and use personal data when you use our online services (such as classes, groups, etc.), including apps (together, our “Services”). This Notice specifically addresses the U.S. Children’s Online Privacy Protection Act (COPPA). But in general, this information applies to all learners where local law regulates activities to children under certain ages. For COPPA, this is under 13 years.

For more information about COPPA and general tips about protecting Children’s online privacy, please visit the U.S. Federal Trade Commission’s (FTC's) consumer information site at https://www.ftc.gov/business-guidance/privacy-security/childrens-privacy.

We collect almost all personal data about Children directly from Parents / Guardians, but we do collect data from Children.

• Once we have verified parental consent of Parents / Guardians, we collect information directly from Children in our platform.

• We collect a little information from Children under a "limited consent" (see more below) when Children sign up for Outschool directly and alert Parents / Guardians.

Once Parents / Guardians set up an account, they will create Learner accounts for their Child and may provide optional information such as the type of schooling the Child receives, time zone, preferences, and other information such as ethnicity or learning challenges. These Child accounts are called "Learner Mode" and have restrictions in place with less permissions than the Parent / Guardian level.

Children should only use the Learner Mode. They must be in Learner Mode to attend classes, engage in groups, participate in challenges and join online activities with other Children.

Children cannot enroll themselves in activities that require payment, but they may join free challenges (like drawing a dragon) or Learner groups (like an onboarding group).

Parents / Guardians will receive notice via email for all Services, whether paid or free, and can un-enroll their Children at any time. Parents / Guardians can always see the Child Learner accounts, but cannot themselves participate in Learner activities.

Mobile apps

Parents / Guardians can choose permissions to allow push notifications to, and camera and photo access by Children. Parents / Guardians should consider enabling parental controls to help prevent Children from changing permissions they have chosen.

What can Children do with Outschool?

We may allow Children to mark activities they like or want to attend and we may infer a Child’s interest in topics from these records in order to make recommendations and offerings using AI (machine learning). Children also share information during classes or in activities as well as when reporting emergency safety and compliance issues.

• Our activities take place over online videos in which video images and audio of the Children are recorded, along with chats and messages.

Certain information is required that we need to provide the Services. Other information is optional and if not provided, Parents / Guardians and Children will still be able to participate with Outschool without any changes in the quality of Services.

Verified accounts

Once we obtain verified parental consent, we may use and share personal data collected from Children for many of purposes described in ourPrivacy Notice and emphasized in this Notice. We recommend activities and new features to Parents / Guardians and Children based on their engagement with us.

• We may send these messages within our platform or mobile apps to Children and Parents / Guardians through push notifications if Parents enable this feature.

• We may also send this information via email to Parents / Guardians, along with surveys or other information related to Outschool.

• We do not, however, send marketing emails to Children. Children may receive other emails, such as a notification that class is starting.

  • If your Child receives marketing emails, please notify us immediately so we can make sure it is marked in our system that the Child is using the Parent / Guardian email address.

• We do use technology, like cookies and other trackers, to help us gather information about activities once logged into Outschool, but we do not allow third-party analytics or advertising providers to collect personal data for their own purposes in the Learner mode. Please see our Privacy Notice and Cookie Page for more information on our general website.

Information is shared to:

• Teachers can see information such as:

  • Account and profile information provided by Parents / Guardians or Children

  • Video verification (read more in our Help Center article)

  • Child communications to the teacher (Parents / Guardians will receive a copy)

• Teachers, other Learners, and Guests can see information such as:

  • Video image and voice audio and potentially background images of their home and family members (recorded and shared, too)

    • Children’s communications, posts, uploads, content, responses, opinions, etc.

  • Sometimes, Teachers or other Learners may need assistance such as an interpreter available during sessions or may have guests or other Teachers.

Basically, if Children engage in any activity, what they do is available to the other participants, whether children, Teachers, assistants, or guests and may be available to other Parents / Guardians, as well as Outschool employees, contractors, partners, and vendors.

We moderate communications for compliance with our community standards and guidelines and for safety reasons.

Video recordings

We record video, audio, and written communications of Children and Teachers during classes. The class recordings are made available to the Teacher for the class and may be shared to the entire class (and their Parents / Guardians) to view. Where the Teacher is an organization, recordings may be accessed by the entire Teacher organization, and access would not necessarily be limited to one Teacher.

• We may use recordings to provide feedback to Teachers, for customer support, for operational needs (such as a glitch in the recording) and for compliance, enforcement, and safety purposes.

• We will obtain additional parental consent before we use recordings for promotional or other unexpected purposes.

We request that Teachers not copy the recordings or share the recordings with anyone aside from those who are permitted to have them, and also request that recordings not be downloaded or re-shared. We expect all participants to abide by our standards of conduct, but we cannot control or monitor what such third parties (other parents, etc.) ultimately do with recordings.

Third-party sites and tools

Some Teachers may ask Child Learners and their Parents to use third-party sites and services. Parents should review the privacy notices for those third party sites and services to understand their privacy practices. These third parties are not our service providers, and we are not responsible for and may not have reviewed those third-party sites and services.

Limited consent accounts

Children may have tried to sign up with an account on their own. If so, Parents will receive an email verifying agreement to these limited activities. The information we collect is limited, such as they can like classes and choose an avatar, but Learners (Children) cannot enroll in classes and their information is not shared to Teachers or other Learners.

• Parents can “upgrade” the account to full access. Once Parents provide verified parental consent for Children to enroll in classes, groups, or other activities, it includes agreement to carry over the information from these limited activities to the full Child Learner account. This information includes classes they may have liked, free challenges they may have participated in, etc.

If you do not agree with carrying over the information, please let us know at Privacy@outschool.com.

Parental consent and rights

We send a direct notice with these privacy disclosures and obtain verifiable parental consent from Parents / Guardians before collecting, using, and sharing Personal Data from their Children as described in this COPPA Notice. We follow the required processes to obtain verified parental consent to set up full accounts. Where activities are paid by an organization, other verification methods may be used to verify a parent's identity or the school may qualify to grant consent.

No consent / revoke consent

If Parents / Guardians do not consent or withdraw consent, then we will not collect, use, or disclose any personal data about their Child, except as needed for legal compliance and enforcement purposes, and their Child will not be allowed to use Outschool in any way.

Deletion

Parents / Guardians can also request that we delete the personal data we have collected in connection with that account.

• Please keep in mind that a request to delete records may lead to termination of an account, membership, or other services.

• However, if we need to keep the data for other valid reasons, such as fraud, compliance, and safety, we will not delete the information. We will continue to protect it and delete it when appropriate.

• In addition, we will exercise commercially reasonable efforts to delete personal data collected from Children when it is no longer needed for the purpose for which it was collected.

• We will not generally be able to guarantee a deletion from backups, but when feasible we will. If the backups are used for restoration, we will re-delete the records, based on the record of deletion requested.

Review and update information

Parents / Guardians may review and update certain of their Child’s information by logging into their account. In a Parent / Guardian account, a Parent / Guardian can review topics of interest we have inferred based on their Child’s likes and past classes or activities. Parents can choose to opt-out of recommendations based on their Child’s history of participation and instead choose the learning topics they want to see.

About teachers

We have adult teachers who have been reviewed and approved to teach classes and sometimes work with other activities, such as groups. Teachers are not employees; they work with us as contractors. Please note that in some cases, classes are taught by a Teacher that is actually an organization, group, or team of teachers.

Outschool employees may also moderate or engage with certain classes or activities.

Contact us

Please contact the Privacy Office with any questions or concerns about our COPPA Notice or practices or any rights you have at:

• Email: privacy@outschool.com

• Mailing: Outschool, Inc. 2261 Market Street #4545 San Francisco, CA USA 94114

• Phone: +1 (415) 968-1685

This Notice was last updated 08 December 2022. The prior version was part of the overall online Privacy Notice and was revised to include mobile apps and limited consent accounts, along with formatting, presentation, and language.