Children's Online Privacy Policy

CogniFit is committed to protecting the privacy of children who use our Services. This Children's Online Privacy Policy explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 16 ('child' or 'children'), and uses terms that are defined in our general Privacy Policy. This policy is in accordance with the U.S. Children's Online Privacy Protection Act ('COPPA'). For more information about COPPA and general tips about protecting children's online privacy, please visit OnGuard Online.

The information we collect from children, how we use it, and how and when we communicate with parents

Children are not permitted to access or use the Services unless their parent has consented in accordance with applicable law. Therefore, CogniFit allows children to register for the platform if the Services were purchased by another party – such as parent, educator, health professional, or researcher - for the children. In that case, CogniFit may collect information from children. Below we summarize potential instances of collection and outline how and when we will provide parental notice and/or seek parental consent. In any instance that we collect personal information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity request or allow the child to continue to participate in the activity, and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA's requirements, we will either delete the information or immediately seek the parent's consent for that collection.

Registration

Children can, in many cases, register with our Services to do brain fitness, play games, and engage in special features, among other things. During the registration process, we may ask the child to provide certain information for notification and security purposes, including a parent or guardian's email address, the child's name, gender, date of birth and email address. Please note that children can choose whether to share their information with us, but certain features cannot function without it. As a result, children may not be able to access certain features if required information has not been provided. We will not require a child to provide more information than is reasonably necessary in order to participate in an online activity.

About the collection of parent email address: Consistent with the requirements of COPPA, on any child-targeted site or application, or in any instance where we ask for age and determine the user is age 15 or under, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at privacy@cognifit.com. We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.

Content Generated by a Child

Certain activities on our Services allow children to create or manipulate content and save it with CogniFit. Some of these activities do not require children to provide any personal information and therefore may not result in notice to the parent or require parental consent. If an activity potentially allows a child to insert personal information in their created content, we will either pre-screen the submission to delete any personal information, or we will seek verifiable parental consent by email for the collection. Examples of created content that may include personal information are brain fitness programs or other open-text fields, and drawings that allow text or free-hand entry of information. If, in addition to collecting content that includes personal information, CogniFit also plans to post the content publicly or share it with a third party for the third party's own use, we will obtain a higher level of parental consent.

About Verifiable Parental Consent:

Email Consent. In the event CogniFit wishes to collect personal information from a child, COPPA requires that we first seek a parent or legal guardian's consent by email. In the email we will explain what information we are collecting, how we plan to use it, how the parent or legal guardian can provide consent, and how the parent or legal guardian can revoke consent.

High-Level Consent. In the event CogniFit collects personal information from a child that will be posted publicly, we will seek a higher level of consent than email consent. Such 'high-level' methods of consent include but are not limited to asking for a credit card or other payment method for verification (with a nominal charge involved), requiring a signed consent form by email attachment.

Teacher consent in lieu of a parent. With regard to school-based activities, COPPA allows teachers and school administrators to act in the stead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities. For more information on parental rights with respect to a child's educational record under the Family Educational Rights and Privacy Act (FERPA), please visit the FERPA site.

Chat

Certain features and activities allow children to communicate directly with other users by means of a chat system. We strongly encourage children who use these interactive features on our sites and applications never to provide personal information about themselves or any third party, and certainly never to attempt to circumvent our filters or moderation. We also recommend that parents carefully supervise their children when the children participate in online activities.

Messages

On occasion, in order to respond to a question or request from a child, CogniFit may need to ask for the child’s online contact information, such as an email address. The same way, in connection with certain activities or services we may need ongoing communication with the child. One example would be a newsletter that provides occasional updates about the services, cognitive assessment, brain training, activity, or features. The child or the parent can easily "unsubscribe" of each communication individually.

Push Notifications

Push notifications are notifications on mobile and other devices that are typically associated with downloaded applications, and which can communicate to the device holder even when the application is not in use. The child can only receive push notifications after registering for CogniFit, which requires a child to provide a guardian or parent email address as detailed in the Section Registration aforementioned.

Geolocation Data

If a child-directed CogniFit Service collects geolocation information that is specific enough to equate to the collection of a street address, we will first seek parental consent.

Persistent Identifiers

When children interact with us, certain information may automatically be collected, both to make our Services more interesting and useful to children and for various purposes related to our business. Examples include the type of computer operating system, the child's IP address or mobile device identifier, the web browser, the frequency with which the child visits various parts of our Services, the child's geographic location, and information regarding the online or mobile service provider. This information is collected using technologies such as cookies, flash cookies, web beacons, and other unique identifiers. This information may be collected by CogniFit or by a third party. This data is principally used for internal purposes only, in order to:

• provide children with access to features and activities on our Services
• customize content and improve our Services
• conduct research and analysis to address the performance of our Services
• generate anonymous reporting for use by CogniFit

In the event we collect (or allow others to collect) such information from children on our Services for other purposes, we will notify parents and obtain consent prior to such collection.

Please contact us at privacy@cognifit.com or at the mailing address below with questions about the operators' privacy policies and collection and use practices:

CogniFit, Inc.
Attn: Legal Department (Privacy Policy)
600 California Street, 11th Floor
San Francisco, CA 94108, USA

When information collected from children is available to others

Children may register for CogniFit after receiving an invitation from a teacher, school administrator, health care provider, or researcher. In these events and if the child registers, CogniFit seeks a parent or legal guardian's consent by email. The parent or legal guardian's may edits the child's privacy settings and decide if the child shares their information with the teacher, school administrator, health care provider, or researcher.

By default, the child's personal information is not posted publicly. In addition to those rare instances where a child's personal information is posted publicly we also may share or disclose personal information collected from children in a limited number of instances, including the following:

• We may share information with our service providers if necessary for them to perform a business, professional, or technology support function for us.
• We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or public agency's (including schools or children services) request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our Services; (iii) to protect the security or integrity of our Services, sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.

Parental choices and controls

At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular account, and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service.

Where a child has registered for a CogniFit.com account, we use two methods to allow parents to access, change, or delete the personally identifiable information that we have collected from their children:

• Parents can contact CogniFit customer support team to request access to, change, or delete their child's personal information by sending an email to support@cognifit.com.
• Parents with other inquiries can contact CogniFit at privacy@cognifit.com.

In any correspondence, please include the child's email address and the parent's email address. To protect children's privacy and security, we will take reasonable steps to help verify a parent's identity before granting access to any personal information.

Updates

Due to the changing nature of the Internet, this policy may be changed at any time at CogniFit's discretion. Therefore we recommend that you visit our Privacy Policy often so that you are always fully informed.

Updated: October 21, 2020