Last Updated: 3/28/24

Your privacy is important to us. This privacy statement explains our collection, use, and disclosure of personal data. This privacy statement applies to Knowt Inc. and to our controlled affiliates and subsidiaries (“Knowt”). References to our “services” in this statement include our websites, apps, and other products and services.

Please also refer to our Terms of Service, available here https://knowt.com/terms, which are incorporated as if fully recited herein. Terms defined in the Terms of Service that are not defined herein shall have the same definition as in the Terms of Service.

California consumers can find specific disclosures, including “Notice at Collection” details, by clicking here.

PERSONAL DATA WE COLLECT COOKIES, MOBILE IDs, AND SIMILAR TECHNOLOGIES OUR USE OF PERSONAL DATA OUR DISCLOSURE OF PERSONAL DATA CHOICE AND CONTROL OF PERSONAL DATA CHILDREN’S PRIVACY SCHOOL INFORMATION EUROPEAN DATA PROTECTION RIGHTS CALIFORNIA PRIVACY RIGHTS RETENTION OF PERSONAL DATA LOCATION OF PERSONAL DATA SECURITY OF PERSONAL DATA CHANGES TO THIS PRIVACY STATEMENT HOW TO CONTACT US

PERSONAL DATA WE COLLECT

The personal data we collect depends on how you interact with us, the services you use, and the choices you make.

We collect information about you from different sources and in various ways when you use our services, including information you provide directly, information collected automatically, information from third-party data sources, and data we infer or generate from other data.

Parents’ consent is required for the collection, use, or disclosure of children’s personal information. We will not collect, use, or disclose your child’s personal information if you or your child’s school tells us you do not consent to the collection, use, or disclosure of your child’s personal information. For more information, refer to the “Children’s Privacy” section below.

Information you provide directly. We collect personal data you provide to us. For example:

• Name and contact information. When you sign up for our services, we collect your name, username, email address, and birthdate. If you sign up for a subscription, our service provider Stripe may also collect your postal address and phone number in order to process your payment.

• Demographic data. In some cases, such as when you register or participate in surveys, we request that you provide age, gender, and similar demographic details.

• Other profile information. We collect information about your interests, biographic information, education level, intended use of our service, links to social media accounts, and classes for your profile. In some cases, where we offer services to schools, subject to our agreements with those schools, we may collect or receive information that may be considered “student records,” which may include academic performance relating to a student’s use of our Services.

• Payment information. We collect and process financial information (e.g., payment card numbers, bank account information, security access code) through a third-party service provider, Stripe, to process payments for our services. Stripe will collect credit or debit card or payment account information. This may be considered sensitive personal information.

• Content and files. We collect the photos, documents, or other files you upload to our services; and if you send us email messages or other communications, we collect and retain those communications Finally, if you leave reviews or comments on our service or notes and flashcards, we collect the content of those reviews and comments.

• Sensitive Personal Information.
• Account access information. We collect information such as a username in combination with a password, security or access code, or other credential that allows you access to your Knowt account.
• Payment information, as described above.

Information we collect automatically. When you use our services, we collect some information automatically. For example:

• Identifiers and device information. When you visit our websites, our web servers automatically log your Internet Protocol (IP) address and information about your device, including device identifiers (such as MAC address); device type; and your device’s operating system, browser, and other software including type, version, language, settings, and configuration. As further described in the “Cookies, Mobile IDs, and Similar Technologies” section below, our websites and online services store and retrieve cookie identifiers, mobile IDs, and other data.

• Geolocation data. Depending on your device and app settings, we collect geolocation data (city, state, and country) when you use our apps or online services.

• Usage data. We automatically log your activity on our websites, apps and connected products, including the URL of the website from which you came to our sites, pages you viewed, how long you spent on a page, access times, and other details about your use of and actions on our website.

Information we create or generate. We infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics (“inferences”). For example, we infer your general geographic location (such as city, state, and country) based on your IP address.

Information we obtain from third-party sources. We also obtain the types of information described above from third parties. These third-party sources include, for example:

• Third-party partners. Third-party applications and services, including social networks you choose to connect with or interact with through our services, accounts you connect to our services such as Google, or when you use our extension to obtain information, such as the page you visited, the content of the page, and other types of usage data, from other sites and services, such as Canvas, Puja, or Zoom. We may receive any personal information that you permit these organizations to share with Knowt.

• Service providers. Third parties that collect or provide data in connection with work they do on our behalf, for example companies that determine your device’s location based on its IP address.

• Your school and educators. If you use our service through your school, your educators or school administrators may disclose information about your academic performance and activities to us as part of their use of our websites, apps, and services. They may also provide us with any of the information we would otherwise collect from you.

When you are asked to provide personal data, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or fully functional.

COOKIES, MOBILE IDs, AND SIMILAR TECHNOLOGIES

We use cookies, web beacons, mobile analytics and advertising IDs, and similar technologies to operate our websites and online services and to help collect data, including usage data, identifiers, and device information.

What are cookies and similar technologies?

Cookies are small text files placed by a website and stored by your browser on your device. A cookie can later be read when your browser connects to a web server in the same domain that placed the cookie. The text in a cookie contains a string of numbers and letters that may uniquely identify your device and can contain other information as well. This allows the web server to recognize your browser over time, each time it connects to that web server.

Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website or email. When your browser opens a webpage or email that contains a web beacon, it automatically connects to the web server that hosts the image (typically operated by a third party). This allows that web server to log information about your device and to set and read its own cookies. In the same way, third-party content on our websites (such as embedded videos, plug-ins, or ads) results in your browser connecting to the third-party web server that hosts that content. We also include web beacons in our email messages or newsletters to tell us if you open and act on them.

Mobile analytics and advertising IDs are generated by operating systems for mobile devices (iOS and Android) and can be accessed and used by apps in much the same way that websites access and use cookies. Our apps contain software that enables us and our third-party analytics and advertising partners to access these mobile IDs.

How do we and our partners use cookies and similar technologies?

We, and our analytics and advertising partners, use these technologies in our websites, apps, and online services to collect personal data (such as the pages you visit, the links you click on, and similar usage information, identifiers, and device information) when you use our services, including personal data about your online activities over time and across different websites or online services. This data is used to store your preferences and settings, enable you to sign-in, analyze how our websites and apps perform, track your interaction with the site or app, develop inferences, deliver and tailor interest-based advertising, combat fraud, and fulfill other legitimate purposes. We and/or our partners also share the data we collect or infer with third parties for these purposes. For more information about the third-party analytics and advertising partners that collect personal information on our services, please see the “Our Disclosure of Personal Data” section of this statement.

We do not collect cookies and similar technologies for advertising purposes from children.

What controls are available?

There are a range of cookie and related controls available through browsers, mobile operating systems, and elsewhere. See the “Choice and Control of Personal Data” section below for details.

OUR USE OF PERSONAL DATA

We use the personal data we collect for purposes described in this privacy statement or as otherwise disclosed to you. For example, we use each of the categories of personal data we collect for the following purposes:

• Product and service delivery. To provide and deliver our services, including troubleshooting, improving, and personalizing those services.

• Business operations. To operate our business, such as billing, accounting, improving our internal operations, securing our systems, detecting fraudulent or illegal activity, and meeting our legal obligations.

• Product improvement, development, and research. To develop new services or features and conduct research, including for the training of the AI models that power our services.

• Personalization. To understand you and your preferences to enhance your experience and enjoyment using our services.

• Customer support. To provide customer support and respond to your questions.

• Communications. To send you information, including push notifications, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.

• Marketing. To communicate with you about new services, including through push notifications, offers, promotions, rewards, contests, upcoming events, and other information about our services and those of our selected partners (see the “Choice and Control” section of this statement for information about how to change your preferences for promotional communications).

• Advertising. To display advertising to you (see the “Cookies” section of this statement for information about personalized advertising and your advertising choices).

We use the following sensitive personal information to deliver our products and services, for business operations, for customer support, and for communications (such as, for example, to provide invoices and confirmations): payment information and account access information.

We combine data we collect from different sources for these purposes, and to give you a more seamless, consistent, and personalized experience.

OUR DISCLOSURE OF PERSONAL DATA

We share information as directed by users (e.g., to post comments), as needed to provide the services (e.g., to facilitate payments for child users who are not using our service through their schools), and with our children’s teachers or tutors and with other students when children use the classroom feature, and in the event of in-school use, we share student information with their school. We share student-generated flashcards and notes with other Knowt users.

In addition, we disclose each of the categories of personal data described above, to the types of third parties described below, for the following business purposes:

• Public information. You may select options available through our services to publicly display and disclose your name and/or username and certain other information, such as your profile, demographic data, social media username or alias, content and files, or geolocation data.

• Service providers. We provide personal data to vendors or agents working on our behalf for the purposes described in this statement. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions.

• Financial services & payment processing. When you provide payment data, for example to make a purchase, our payment processor, Stripe, will collect payment and transactional data and disclose to banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, or other related financial services.

• Corporate transactions. We may disclose personal data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.

• Legal and law enforcement. We will access, disclose, and preserve personal data when we believe doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement, national security, or other government agencies.

• Security, safety, and protecting rights. We will disclose personal data if we believe it is necessary to:
• protect our customers and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone;
• operate and maintain the security of our services, including to prevent or stop an attack on our computer systems or networks; or
• protect the rights or property of ourselves or others, including enforcing our agreements, terms, and policies.

We also share the content of flashcards you create with Other Users.

Third party analytics and advertising companies also collect personal data through our website and apps including identifiers and device information (such as cookie IDs, device IDs, and IP address), geolocation data, usage data, and inferences based on and associated with that data, as described in the “Cookies” section of this statement. These third-party vendors may combine this data across multiple sites to improve analytics for their own purpose and others.

For example, we use Google Analytics on our website to help us understand how users interact with our website; you can learn how Google collects and uses information at www.google.com/policies/privacy/partners. Likewise, we use Freestar for the purposes of placing advertising on the Knowt website and in Knowt apps, and Freestar will collect and use certain personal information as described above for advertising purposes. To learn more about Freestar’s processing of personal information, please see their privacy policy at https://freestar.com/privacy-policy/.

Our third-party providers of similar technologies are:

Some of these providers are our service providers. Other data disclosures to some of these third parties may be considered a “sale” or “sharing” of personal information as defined under the laws of California and other U.S. states. Please see the “Choice and Control” and “California Privacy Rights” sections below for more details.

Please note that some of our services also include integrations, references, or links to services provided by third parties whose privacy practices differ from ours. If you provide personal data to any of those third parties, or allow us to share personal data with them, that data is governed by their privacy statements.

Finally, we may disclose de-identified information in accordance with applicable law.

CHOICE AND CONTROL OF PERSONAL DATA

We provide a variety of ways for you to control the personal data we hold about you, including choices about how we use that data. In some jurisdictions, these controls and choices may be enforceable as rights under applicable law.

Access, portability, correction, and deletion. If you wish to access, correct, or delete personal data about you that we hold, you may access your account by logging into the Knowt services you use.

If you are unable to access, copy, correct, or delete certain personal data we have via the means described above, you can send us a request by using contact methods described at the bottom of this privacy statement.

Communications preferences. You can choose whether to receive promotional communications from us by email. If you receive promotional email messages from us and would like to stop, you can do so by following the directions in that message or by contacting us as described in the “Contact Us” section below. If you receive a sales call from us, you can ask to be placed on our do-not-call list. These choices do not apply to certain informational communications including surveys and mandatory service communications.

Targeted advertising. To opt-out from or otherwise control targeted advertising, you can use the opt-out controls offered by the organizations our advertising partners may participate in, which you can access at:

• United States: NAI (http://optout.networkadvertising.org) and DAA (http://optout.aboutads.info/)

• Canada: Digital Advertising Alliance of Canada (https://youradchoices.ca/)

• Europe: European Digital Advertising Alliance (http://www.youronlinechoices.com/)

You can also use the other cookie or mobile ID controls described below.

These choices are specific to the device or browser you are using. If you access our services from other devices or browsers, take these actions from those devices or browsers to ensure your choices apply to the data collected when you use them.

Data sales. Some privacy laws define “sale” broadly to include some the disclosures described in the “Our Disclosure of Personal Data” section above. To opt-out from such data “sales,” you can employ the browser or platform controls referenced below.

Browser or platform controls.

• Cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our website. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated.

• Global Privacy Control. Some browsers and browser extensions support the “Global Privacy Control” (GPC) or similar controls that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales and/or targeted advertising, as specified by applicable law. We currently have not implemented GPC. If you have questions about data rights, please contact us at team@knowt.com

• Mobile advertising ID controls. iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs.

• Do Not Track. Some browsers include a "Do Not Track" (DNT) setting that can send a signal to the websites you visit indicating you do not wish to be tracked. Unlike the GPC described above, there is not a common understanding of how to interpret the DNT signal; therefore, our websites do not respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, cookie controls, and advertising controls described above or contact us at team@knowt.com.

Email web beacons. Most email clients have settings that allow you to prevent the automatic downloading of images, including web beacons, and the automatic connection to the web servers that host those images.

Except for the automated controls described above, if you send us a request to exercise your rights or these choices, to the extent permitted by applicable law, we may decline requests in certain cases. For example, we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or other rights of another person, would reveal a trade secret or other confidential information, or would interfere with a legal or business obligation that requires retention or use of the data. Further, we may decline a request where we are unable to authenticate you as the person to whom the data relates, the request is unreasonable or excessive, or where otherwise permitted by applicable law. If you receive a response from us informing you that we have declined your request, in whole or in part, you may appeal that decision by submitting your appeal using the contact method described at the bottom of this privacy statement.

CHILDREN’S PRIVACY

Knowt offers an educational platform to help students study and learn. Although our primary audience is older students, our service may have younger users. The Children’s Online Privacy Protection Act (“COPPA”) is a US federal law that requires that website operators provide parents and/or legal guardians with certain information and obtain parental consent prior to permitting children under the age of 13 to access and use their services. Please refer to the Knowt COPPA Notice to Parents for more information about what information we collect from Knowt students who are younger than the age of 13.

For more information about COPPA and your child’s rights to online privacy, visit the Children’s Privacy section of the FTC’s website here (or you may visit www.ftc.gov and search “Children’s Privacy”).

If you have questions about our collection, use, and disclosure of your child’s personal data, or if you would like to request access to, correction, or deletion of your child’s personal data, please contact us at: team@knowt.com. Please include “COPPA QUESTION” in the subject line of your email.

SCHOOL INFORMATION

Where our services are used within a school setting, the Family Educational Rights and Privacy Act (FERPA) is a US federal law that protects the privacy of Students Records, including personal data. FERPA, along with the Illinois Student Online Personal Protection Act (“SOPPA”), the New York State Education Law §2-d, and similar laws were enacted to ensure that parents or legal guardians, and students (18 and older), have certain rights with respect to Student Records that may be in our possession or under our control. We address these rights in our agreements with schools, educators, and education agencies.  In general, parents, legal guardians, and eligible students have the following:

• An expectation that Student Records will not be sold or released for any commercial purpose;

• The right to inspect and review the contents of the Student Records and request changes or correction to them or delete inaccuracies; and

• The right to control the disclosure of information, except in specific and limited cases where applicable law allows for disclosure without consent.

Generally, these rights are exercised by schools on behalf of the parents, legal guardians, and eligible students. If you have questions about exercising these rights, please email us at team@knowt.com with “STUDENT RECORD REQUEST” in the subject line. You may also contact your school to exercise these rights.

EUROPEAN DATA PROTECTION RIGHTS

If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:

• You can request access to, and rectification or erasure of, personal data;

• If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format;

• If the processing of personal data is based on your consent, you can withdraw consent for future processing at any time;

• You can object to, or obtain a restriction of, the processing of personal data under certain circumstances; and

• For residents of France, you can send us specific instructions regarding the use of your data after your death.

To make such requests, please use the contact information at the bottom of this statement. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns. To contact our Data Protection Officer, please see the contact information below.

We rely on different lawful bases for collecting and processing personal data about you, for example, with your consent and/or as necessary to provide the services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests.

CALIFORNIA PRIVACY RIGHTS

If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (CCPA), you have certain rights with respect to that information.

Notice at Collection. At or before the time of collection, you have a right to receive notice of our practices, including the categories of personal information and sensitive personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details in this statement by clicking on the above links.

Right to Know. You have a right to request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information. Note that we have provided much of this information in this privacy statement. You may make such a “request to know” by emailing us at team@knowt.com.

Rights to Request Correction or Deletion. You also have rights to request that we correct inaccurate personal information and that we delete personal information under certain circumstances, subject to a number of exceptions. To make a request to correct or delete, email us at team@knowt.com.

Right to Opt-Out / “Do Not Sell or Share My Personal Information”. You have a right to opt-out from future “sales” or “sharing” of personal information as those terms are defined by the CCPA.

Note that the CCPA defines “sell,” “share,” and “personal information” very broadly, and some of our data disclosures described in this privacy statement may be considered a “sale” or “sharing” under those definitions. In particular, we let advertising and analytics providers collect identifiers (IP addresses, cookie IDs, and mobile IDs), activity data (browsing, clicks, app usage), device data, and geolocation data through our sites and apps when you use our online services, but do not “sell” or “share” any other types of personal information. If you do not wish for us or our partners to “sell” or “share” personal information relating to your visits to our sites for advertising purposes, you can make your request by , emailing us using the contact information at the bottom of this Statement, or using other controls described in the “Choice and Control” section of this statement. If you opt-out using these choices, we will not disclose or make available such personal information in ways that are considered a “sale” or “sharing” under the CCPA. However, we will continue to make available to our partners (acting as our service providers) some personal information to help us perform advertising-related functions. Further, using these choices will not opt you out of the use of previously “sold” or “shared” personal information or stop all interest-based advertising.

We provide minors under 16 years of age the ability to opt into sales and sharing of their personal information, as those terms are defined by the CCPA. Note, we do not sell personal information for money.

Right to Limit Use and Disclosure of Sensitive Personal Information. You have a right to limit our use of sensitive personal information for any purposes other than to provide the services or goods you request or as otherwise permitted by law.

Note that we do not use sensitive personal information for any such additional purposes.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

Further, to provide, correct, or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your account.

Finally, you have a right to not be discriminated against for exercising these rights set out in the CCPA.

Additionally, under California Civil Code section 1798.83, also known as the “Shine the Light” law, California residents who have provided personal information to a business with which the individual has established a business relationship for personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes.

Please be aware that we do not disclose personal information to any third parties for their direct marketing purposes as defined by this law.

California Customers may request further information about our compliance with this law by emailing team@knowt.com. Please note that businesses are required to respond to one request per California Customer each year and may not be required to respond to requests made by means other than through the designated email address.

California residents under the age of 18 who are registered users of online sites, services, or applications have a right under California Business and Professions Code section 22581 to remove, or request and obtain removal of, content or information they have publicly posted. To remove content or information you have publicly posted, you may delete such information from your profile and your files within the Knowt service. Alternatively, to request that we remove such content or information, please send a detailed description of the specific content or information you wish to have removed to team@knowt.com.

Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

RETENTION OF PERSONAL DATA

We retain personal data for as long as necessary to provide the services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and for other legitimate and lawful business purposes. We delete data when a parent, school, or user requests within the timeframes required under applicable law. When we no longer need your or your personal information, we will use commercially reasonable efforts to delete their personal information. For example, we delete data after a period of inactivity after which it is unlikely you will resume use of the account, so long as we are not under contractual or other legal obligations to retain such data.

LOCATION OF PERSONAL DATA

The personal data we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers process data, some of which may have laws that offer different levels of data protection than the country in which you reside. Currently, we primarily use data centers in the United States. The storage location(s) are chosen to operate efficiently and improve performance. We take steps to process and protect personal data as described in this statement wherever the data is located.

Location of Processing European Personal Data. We transfer personal data from the European Economic Area (EEA), United Kingdom (UK), and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use legal mechanisms, including contracts, to help ensure your rights and protections. To learn more about the European Commission’s decisions on the adequacy of personal data protections, please visit: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.

SECURITY OF PERSONAL DATA

We take reasonable and appropriate steps to help protect personal data from unauthorized access, use, disclosure, alteration, and destruction.

To help us protect personal data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.

CHANGES TO THIS PRIVACY STATEMENT

We will update this privacy statement when necessary to reflect changes in our services, how we use personal data, or the applicable law. When we post changes to the statement, we will revise the "Last Updated" date at the top of the statement. If we make material changes to the statement, we will provide notice or obtain consent regarding such changes as may be required by law.

HOW TO CONTACT US

If you have a privacy concern, complaint, or a question for Knowt, please contact us at team@knowt.com.

We also have the following contact details:

Knowt, Inc.

16192 Coastal Hwy, Lewes DE 19958

team@knowt.com

848-391-0575

To contact our Data Protection Officer:

you may submit a request to our Data Protection Officer Request Form: https://edpo.com/gdpr-data-request/, or by writing:

Avenue Huart Hamoir 71, 1030 Brussels, Belgium

For our UK representative: -

you may submit a request to our: https://edpo.com/uk-gdpr-data-request/ or write our UK representative at

8 Northumberland Avenue, London WC2N 5BY, United Kingdom