Children’s Privacy Notice

FiliLearn is designed to provide Filipino language and cultural learning opportunities for both adults and younger Learners.

Children’s information requires additional protection.

Where laws such as the Children’s Online Privacy Protection Act apply, FiliLearn will follow applicable requirements relating to parental notice, consent, collection, use, disclosure, security, and deletion.

Where FiliLearn knowingly collects personal information from a child under 13 in circumstances covered by United States children’s privacy law, appropriate parental or guardian authorization will be required before collecting personal information unless an exception permitted by law applies.

FiliLearn should not allow a child to simply check a box stating that they have parental permission when verifiable parental consent is legally required.

Depending on features used, information associated with a child account may include:

• Name
• Account information
• Email or parent managed email
• Age or date of birth
• Profile photo
• Learning activity
• Lesson progress
• Vocabulary progress
• XP
• Stories completed
• Pronunciation recordings
• Class bookings
• Class participation
• Teacher communications
• Live Class video and audio
• Classroom chat
• Technical information

FiliLearn should collect only information reasonably necessary for the educational feature being used.

Children should not be required to provide more personal information than is reasonably necessary to participate.

Where required, FiliLearn may ask a parent or guardian to authorize:

• Creation of the child’s account
• Collection of personal information
• Pronunciation recordings
• Live Class participation
• Camera and microphone use
• Classroom recording
• Other covered processing

Consent records may include:

• Parent or guardian identifier
• Child account
• Consent version
• Consent date
• Consent method
• Features authorized

Younger Learners may participate in live Live Classes where appropriate account and parental requirements have been satisfied.

Classes may include:

• Live video
• Live audio
• Teacher interaction
• Lesson materials
• Messaging
• Recording
• Classroom chat
• Attendance monitoring

Live Classes involving children may be recorded for legitimate purposes such as:

• Safety
• Quality assurance
• Teacher review
• Dispute investigation
• Technical review
• Compliance

Parents or guardians will receive appropriate recording disclosures where required.

Recordings involving minors are not intended to be publicly accessible.

Access is restricted to authorized FiliLearn personnel for legitimate purposes.

FiliLearn does not sell children’s classroom recordings.

A child may use voice recording features for pronunciation practice where permitted.

Such audio may be processed to provide educational feedback.

FiliLearn will not use a child’s pronunciation recording for unrelated targeted advertising.

FiliLearn does not sell children’s personal information.

FiliLearn does not use children’s classroom recordings for behavioral advertising.

Where separate parental permission is required for disclosure of children’s information to third parties, FiliLearn will obtain the required authorization before such disclosure unless an applicable exception applies.

Teachers should only access information about a child that is reasonably necessary to provide the educational service.

Teachers may not:

• Request unnecessary personal information
• Ask children to move conversations to unauthorized private channels
• Request private social media accounts
• Solicit personal meetings outside FiliLearn
• Share child information with unauthorized persons

Where applicable, parents or guardians may request to:

• Review information collected from their child
• Correct information
• Request deletion
• Withdraw consent
• Stop future collection
• Manage classroom participation
• Manage recording permissions where required

FiliLearn may verify the identity and authority of a person making such a request.

Children’s personal information should not be retained indefinitely simply because storage is available.

FiliLearn will establish retention periods based on the purpose for which information was collected and applicable legal requirements.

Information may be retained longer where reasonably necessary for:

• Safety investigations
• Legal obligations
• Disputes
• Fraud prevention
• Security
• Administrative holds

FiliLearn uses safeguards designed to restrict unauthorized access to children’s information.

Access to sensitive child related information should follow role based permissions.

FiliLearn may use service providers to operate educational functionality.

Providers may support:

• Hosting
• Video communication
• Authentication
• Audio processing
• Payments involving parent accounts
• Security
• Push notifications
• Email

FiliLearn should review the information these providers receive and limit disclosure where reasonably possible.

Parents and guardians may contact:

• HeyBuddy Enterprises LLC
• FiliLearn Child Privacy Team
• 9245 Laguna Springs Dr., Suite 200
• Elk Grove, California
• United States
• legal@heybuddysolutions.com

Use subject:

• FiliLearn Child Privacy Request