Privacy Policy

The following Privacy Policy outlines how your personal information is
collected, used, disclosed, and otherwise processed by Edsoma, Inc. (“Edsoma,”
“we,” “our,” or “us”) when you visit
https://edsoma.com, our mobile apps, or
any other site or application where this Privacy Policy is posted
(collectively, the “Services”). Edsoma is located at Edsoma Inc., 2021 Eagles
Ridge Dr, Weatherford, TX 76087, United States, and is responsible for the
content of the site as well as the collection and management of user
information. By accessing or using our Services, you signify that you have
read and understood our practices with respect to your personal information as
described in this Privacy Policy.

If your child uses an Edsoma product at school, please read our
Student Privacy Policy.

Please click here for details on the personal
information we collect from a child who uses our product at home.

Personal Information Collection and Use

We collect personal information you provide through our Services or give to us
in any other way, including over the phone or on paper. In connection with
these activities, we collect the following:

Contact and Other Information

We receive personal information, including but not limited to your name and
email address, and occasionally your telephone number, when you communicate
with us through the Services through the “Contact Us” page, make a purchase,
enter a contest, sweepstakes, or other promotion, apply for a job, or
otherwise communicate with us. We use such personal information for the
purposes described in this Policy or as otherwise disclosed to you by us. For
example, we use your personal information to provide the Services to you. We
also use your contact information to communicate with you about the Services
and answer your questions, issues, or concerns you or other users have; to
send you marketing communications, including news about products and services
offered by us and our selected partners; or to respond to employment
opportunities for which you’ve applied.

Audio Recordings

We may collect audio recordings as a necessary part of providing our reading
assistant service to our users. We do not create a voiceprint from such
recordings or otherwise use them to seek to identify an individual.

Social Network Information

When you interact with us through a social media site or third-party service,
such as when you like, follow, share, or connect to Edsoma content on or
through Facebook, Twitter, TikTok, Instagram, YouTube, or other sites, we may
receive information from the social network including your profile information
and any other information you permit the social network to share with third
parties. We use this information to communicate or interact with you on the
social network, to better understand the demographics of our visitors, and to
personalize content and advertising. The information we receive from these
third-party sites is dependent upon that third-party’s policies and your
privacy settings on that third-party site. You should always review and, if
necessary, adjust your privacy settings on third-party websites and services
before linking or connecting them to our website or Services.

Information Collected Through Tracking Technologies

When you use the Services, we collect information about such use, including
the browser or device you use to access the Services, read our emails, or
engage with us. This information is typically collected through a variety of
tracking technologies, including cookies, web beacons, embedded scripts, and
similar technology (collectively, “tracking technologies”), and we may utilize
third-party services to assist us with this effort. For example, we collect:

• Information about your browser or device, such as your IP address, browser
  type, Internet service provider, platform type, device type, operating
  system, date and time stamp, a unique ID that allows us to uniquely identify
  your browser, mobile device, or your account, and other such information. We
  may also collect information about your geographical location data at the
  city level or may approximate your location by analyzing other information
  like an IP address.
• Information about how you access and use the Services, such as the site from
  which you came and the site to which you are going when you leave our
  website, the pages you visit, the links you click, how frequently you access
  the Services, and other actions you take on the Services.

We collect and use this information for internal purposes to (a) provide
access to features on our sites and applications; (b) provide customized
content and information; (c) provide and monitor the effectiveness of our
Services; (d) perform analytics and detect usage patterns; (e) diagnose or fix
technology problems; (f) detect or prevent fraud or other harmful activities;
(g) otherwise to plan for and improve our Services; and (h) to otherwise
support the operations of the Services.

Analytics

We may collect analytics data or use third-party analytics tools, such as
Google Analytics, to help us measure traffic and usage trends for the Services
and to understand more about our users by monitoring aggregate metrics such as
total number of visitors, traffic, usage, and demographic patterns on our
website. You can learn more about Google’s practices at
https://policies.google.com/privacy
and view its currently available opt-out options at
https://tools.google.com/dlpage/gaoptout.

Your choices to control tracking technologies

If you would prefer not to accept cookies, most browsers will allow you to (i)
change your browser settings to notify you when you receive a cookie, which
lets you choose whether or not to accept it; (ii) disable existing cookies; or
(iii) set your browser to automatically reject cookies. Please note that not
accepting cookies may negatively impact your experience using the Services, as
some features and services on our Services may not work properly. Depending on
your mobile device and operating system, you may not be able to delete or
block all cookies or block non-cookie technologies, and browser settings that
block cookies may have no effect. You may also be able to set your email
options to prevent the automatic downloading of images that may contain
technologies that would allow us to know whether you have accessed our email
and performed certain functions with it.

Do Not Track Signals

Although we do our best to honor the privacy preferences of our users, we are
unable to respond to Do Not Track signals set by your browser or mobile
application at this time.

Sharing of Personal Information

We share personal information in the following ways:

Service Providers

We share personal information with third-party service providers who perform
services on our behalf and under our instructions to support our Services’
operations. For example, we may share personal information with service
providers for auditing, compliance, corporate governance functions,
identifying and serving contextual advertisements, mailing services, contest
and sweepstakes fulfillment, and web hosting.

Promotional Partners

From time to time, we may share personal information with third parties with
whom we partner to provide contests and sweepstakes or other promotions. If
these promotional partners will use your personal information in a manner
which differs from this Privacy Policy, we will identify the Partner and its
relevant practices in the Official Rules of the contest or sweepstakes.

Law Enforcement, Regulators, and Other Parties for Legal Reasons

We may share personal information:

• in connection with the establishment, exercise, or defense of legal claims;
• to comply with laws or to respond to lawful requests and legal process;
• to protect the rights and property of us, our agents, customers, and others,
  including to enforce our agreements, policies, and terms of use;
• to detect, suppress, or prevent fraud;
• to reduce credit risk and collect debts owed to us;
• to protect the health and safety of us, our customers, or any person; or
• as otherwise required by applicable law.

Business Transaction or Reorganization

We may share personal information as part of a corporate business transaction,
such as in connection with or during the negotiation of any merger, sale of
company assets, financing, or acquisition of all or a portion of our business.
We may transfer personal information to a third party as one of the business
assets in such a transaction. We may also disclose personal information in the
event of insolvency, bankruptcy, or receivership. You will be notified via
email and/or a prominent notice on any affected Service of any change in
ownership, as well as any choices you may have regarding Personal Information
about you as a result of the transaction.

Third Parties with Your Consent

We may share personal information about you with other third parties, as
disclosed to you when we collect your personal information, and with your
consent.

We may also share information with others in an aggregated or otherwise
anonymized form that does not reasonably identify you directly as an
individual.

We do not sell personal information, including as defined by Chapter 603A of
the Nevada Revised Statutes.

Control Over Your Information

Email Communications Preferences

From time to time, we may send you marketing emails including information
about products/services we offer. If you wish to unsubscribe from marketing
emails, simply follow the instructions in any such email you receive. Note
that you may not opt out of service-related communications and other
transactions (e.g., account verification, changes/updates to features of the
Services, technical and security notices).

Modifying or Deleting Your Information

If you have any questions about reviewing, modifying, or deleting your
information, or if you want to remove your name or comments from our website
or publicly displayed content, you can contact us directly at
support@edsoma.com. We may not be able
to modify or delete your information in all circumstances unless required by
applicable law.

Children’s Privacy

The Children’s Online Privacy Protection Act (COPPA) gives parents control
over the personal information online services may collect from their children
who are under age 13. Our reading assistant service is intended for users of
all ages and their families, and we take special precautions to protect the
privacy of our users, regardless of age. Our Services are designed to comply
with COPPA.

Our Services generally collect only limited amounts of personal information,
if any. Below, we describe the instances in which we could potentially collect
personal information from children under 13. These instances do not require
parental consent under COPPA:

Support for the internal operations of our Services

We may automatically collect a persistent identifier and other device and
usage information when a user visits our website or uses the Services, such as
an IP address or a partial IP address (and city-level location derived from
such an address), browser, or device type, and an identifier which allows us
to uniquely identify the browser, device, account, or application, as well as
account usage information such as the day/time stamp, referring/exit pages and
URLs, pages viewed, and similar information. We use this information only for
our internal purposes, in order to provide access to features, secure the
Services, customize content, improve our sites and applications, generate
reporting on website usage and other analytics, and otherwise support our
Services. We do not use persistent identifiers or other information described
in this paragraph for any other purpose, including for targeted advertising or
to create a profile about a child user.

Email inquiries and support services

If we receive an email or customer support inquiry from a child under 13, we
may use the information in order to respond one time to the request and then
delete it. We do not direct promotional email communications to anyone we know
to be under the age of 13.

We may also use or disclose the personal information of a child under 13 in a
limited number of circumstances:

• We share personal information with our trusted third-party service providers
  to provide services for us, which may include, for example, analytics
  providers and hosting services.
• We may use or share personal information if we have a good faith belief that
  use or disclosure is reasonably necessary to (a) satisfy any applicable law,
  regulation, legal process, or enforceable governmental request; (b) enforce
  applicable Terms of Service, including investigation of potential violations
  thereof; (c) detect, prevent, or otherwise address fraud, security, or
  technical issues; (d) protect the rights, property, or personal safety of
  Edsoma, its users, or others; or (e) as required by law.
• We may use or share aggregated or de-identified information in a manner that
  cannot be reasonably used to identify an individual user.
• We may use or share personal information in connection with a corporate
  business transaction, as set forth under “Business Transactions or
  Reorganization” above.

If you are the parent or legal guardian of a child under 13 from whom you
believe we have collected personal information, you may contact us at
support@edsoma.com to request to
review the personal information we have collected from your child, to ask that
we delete it, or to block our further collection of personal information from
your child. We may verify your identity before honoring your request.

Advertising

We do not permit third parties to collect information from our website or
application visitors over time for the purpose of serving targeted
advertisements on our Services or on other websites and services. We use
Google Analytics to help us measure traffic and usage trends for the Services,
and we have taken steps to minimize this tracking activity. For example, we
utilize Google’s “child-directed treatment” tag to alert Google that our
Services may be directed to an audience that includes children and have
enabled Google’s “restricted-data processing” by default.

In the event we discover we have inadvertently collected information from a
child in a manner inconsistent with COPPA’s requirements, we will either
delete that information or immediately seek parental consent. If you believe
that we might have collected personal information from a child under 13 in a
manner inconsistent with COPPA, please contact us at
support@edsoma.com.

Links to Third-Party Websites and Services

Our Services may contain links to other sites. When you leave our site and go
to another site, you are leaving the Edsoma environment, and those sites may
have their own privacy policies or no privacy policies at all. Edsoma is not
responsible for the privacy practices employed by other sites. We do not
sponsor, endorse, or otherwise recommend such sites or any products or
services they may offer. In short, once you leave our Site, we are no longer
responsible for the collection practices of the companies operating those
sites. We strongly recommend that you read their privacy policies to
understand how they collect, use, and share personal information.

Data Retention

We will retain your personal information only for as long as reasonably
necessary to maintain the Services, to fulfill contractual obligations, to
meet legal and accounting obligations, and for the purposes described in this
Privacy Policy.

Security of Personal Information

We take reasonable security measures designed to protect the personal
information we collect through the Services from unauthorized access, use, or
disclosure. However, no security system is impenetrable, and no data
transmission over the Internet can be guaranteed to be 100% secure.

Policy Changes

We may update this Privacy Policy from time to time. When we make changes to
this Privacy Policy, we will change the “Last Updated” date at the end of this
Privacy Policy. All changes shall be effective from the date of publication
unless otherwise provided in the notification.

How to Contact Us

Please contact us at the mailing address, email, or phone number below with
questions about our privacy policies and collection and use practices:

Edsoma, Inc.

Email: support@edsoma.com

Phone: 1-888-315-1275

Address: 2021 Eagles Ridge Dr, Weatherford, TX 76087, United States

Last Updated: April 25, 2024

Student Privacy Policy

We collect and use personal information about students pursuant to our
agreement with our school or school district customer, which controls the
information we collect and how we may use and disclose it. In that role, we
act as a “school official” for purposes of the Family Educational Rights and
Privacy Act (FERPA). We also comply with other applicable privacy laws,
including the Children’s Online Privacy Protection Act (COPPA), the California
Student Online Personal Information Protection Act (SOPIPA), and other state
education privacy laws.

We use and disclose student personal information to provide and support our
personalized instruction products and services at the direction of our school
and school district customers and pursuant to our agreements with them.
Without limitation, we do not:

• Sell student personal information.
• Serve targeted ads on our products or services.
• Use the information we collect from students for any targeted advertising
  purposes.
• Compile a profile of a student, except to support authorized school
  purposes, such as to customize our products and services to the student.
• Retain student personal information beyond the time period permitted by our
  agreements with our school or school district customers.

We may collect audio recordings directly from students. We will not create a
voiceprint from such recordings or otherwise use them to seek to identify an
individual. We may also receive information about students from a teacher or
school administrator, such as name, student ID number, grade level, and date
of birth.

We use a student’s personal information to:

• Allow the student to use our products and services.
• Recommend content or learning activities to the student.
• Permit the student’s teacher and school or district administrators to review
  the student’s performance, monitor progress, and tailor our products and
  services to the student.
• Provide reports to the student’s educators, school, and school district.

In addition, we may use and/or disclose student personal information
consistent with our contractual obligations to our school and school district
customers:

• To our trusted third-party service providers that provide services to us or
  on our behalf.
• If we have a good faith belief that use or disclosure is reasonably
  necessary to (a) satisfy any applicable law, regulation, legal process, or
  enforceable governmental request; (b) enforce applicable Terms of Service,
  including investigation of potential violations thereof; (c) detect, prevent
  or otherwise address fraud, security or technical issues; (d) protect the
  rights, property, or personal safety of Edsoma, its users, or others; or (e)
  as required by law.
• As part of a corporate business transaction, such as in connection with or
  during the negotiation of any merger, sale of company assets, financing, or
  acquisition of all or a portion of our business, we may transfer student
  personal information to a third party as one of the business assets in such
  a transaction. We may also disclose student personal information in the
  event of insolvency, bankruptcy, or receivership.

We may de-identify and/or aggregate student personal information so that it
cannot be reasonably used to identify an individual student. We may use
and/or disclose such de-identified and/or aggregated data for any purpose.

We also automatically collect certain information about how our Services are
used.

The parent or legal guardian of a student may have certain rights under
applicable law with respect to the student’s personal information. For
example, a parent or guardian may be permitted to request a copy of their
child’s personal information or request that it be deleted. Parents and
guardians may exercise these rights by contacting their child’s school. We
support our school and school district customers in fulfilling such requests.
If you have any questions about this Student Privacy Policy or our products or
services, please contact your child’s school or school district.