MILGO CHILDREN’S PRIVACY NOTICE

Last modified: May 28, 2024

Kayma Labs Ltd. (“Company,” “we,” or “us”) recognizes the importance of children’s privacy. This Children’s Privacy Notice (this “Notice”) covers our use of any information that reasonably can be used to identify a student or child under 18 years of age (each a “Student” and collectively, “Students”) or that reasonably relates to a Student who attends a Covered Institute (“Student Information”).  Student Information includes Personal Information, but not Anonymous Information or Aggregated Information. 

This Notice supplements our general Milgo Privacy Policy and is designed to comply with, among others, the Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”).

This Notice only applies to children under 18 years of age.  Our Milgo Privacy Policy applies to all, including Students up to 18 years of age or older, teachers, parents, school employees, and anyone else from whom we may collect information.  Unless otherwise specified, terms that are defined in our Milgo Privacy Policy have the same meanings as used in this Notice.  For the purposes of this Notice, “you” and “your” refers to the Covered Institute, or to the Parent of a Student. 

This Notice informs you of:

  • The types of Student Information we collect.
  • How we use the Student Information we collect.
  • Our practices for disclosing collected Student Information.
  • Our practices for notifying and obtaining consent for the collection of Student Information, including how a Parent may revoke consent.
  • All operators that collect or maintain information from Students through our website https://milgo.io/en and web application at app.milgo.io (“Milgo”).
1. Consent

Under COPPA, operators of online services directed at children under the age of 13 are required to obtain parental consent for the collection of Personal Information online from children under 13. Laws of other countries prescribe similar requirements for individuals who are under 18 years of age.  When a Covered Institute engages our services by implementing Milgo, we require the Covered Institute to obtain consent (including through teachers, administrators, school districts, employees, personnel, or other authorized agents of the Covered Institute) from Parents for the collection of Student Information from their children prior to implementing student engagement with Milgo.  This is in addition to the consent obtained by Milgo from registered Milgo users (such as teachers and school administrators) prior to their use of Milgo.  In this way, the Covered Institute consents to our collection and use of Student Information on Parents’ behalf.  By implementing student engagement with Milgo, the Covered Institute and Parents (1) authorize us to use the Student Information as described in this Notice and (2) acknowledge that it is the responsibility of the Covered Institute to provide appropriate notification and consent mechanisms where required by contract, regulation, and/or statute.

Covered Institutes and/or Parents may withdraw consent to our processing of a student’s Personal Information at any time.  However, withdrawing consent will result in the Student’s inability to continue using Milgo.

2. Information We Collect from Students

We collect Student Information:

  • Directly from Students;
  • Indirectly from the applicable Covered Institute (including through teachers, administrators, school districts, employees, personnel, or other authorized agents of the Covered Institute); and
  • Automatically from Students’ use of Milgo.Such information includes Personal Information.
Student Information We Collect Directly

Students do not register or create an account with Milgo to engage with its student-facing features.  Accordingly, Students will not have login credentials such as usernames or passwords. 

We collect Student Information directly from Students when they complete surveys, questionnaires, or other forms (collectively, “Surveys”) on Milgo at the instruction and under the guidance of their Covered Institute. This information may include:

  • first and last names;
  • gender;
  • age;
  • education information (e.g., grade, school, teacher, etc.);
  • any other data or information that identifies or assists in identifying an individual Student.

We specify whether information is required or optional when we request it.  The nature of our Surveys may allow Students to disclose additional Personal Information (including sensitive information) about themselves, such as in the case with an open-ended prompt or free response question.  We do not monitor such content, nor do we redact any such additionally-disclosed Personal Information (including sensitive information) before we share it with the Covered Institute.  We encourage the Covered Institute and Parents to educate their Students about safe internet use and the sharing of sensitive Personal Information.

Student Information We Collect Indirectly

We may also collect Student Information from the applicable Covered Institute.

Automatic Information Collection

We use technology to automatically collect information from Milgo users when they access and navigate through Milgo.  The information we collect through these technologies includes information that is temporarily stored by a web browser during a user’s session, such as pages visited, form inputs, session identifiers, and other temporary information that helps the browser provider a smoother and more stable experience (collectively, “Browser Session Data”).  We do not save or use the Browser Session Data of non-registered users (e.g., Students) after a session closes or a survey is submitted. For information about our automatic information collection practices in context of non-Student users, please see the “Information We Collection Through Automatic Data Collection Technologies” section of our Milgo Privacy Policy.

3. How We Use Student Information

We use the Student Information we collect to:

  • Improve and analyze our Services, including to respond to Covered Institute service requests or technical support issues.  If a Student runs into technical errors while using Milgo, we may receive a crash report along with certain logging information from the computing device utilized by the Student.  This may include the device’s operating system, hardware, and browser information.
  • Assess Students’ performance and needs through the information a Student distributes, shares, or provides through Surveys.
  • Provide the Covered Institute with our services, which include alerts, reports, logs, and other data analysis reports (collectively, “Reports”) regarding such shared information. Such Reports may be specific to a Student or provided on a class or school-wide basis to allow the Covered Institute to conduct comparative analyses of its Students.

We use the information we collect automatically through technology (see Automatic Information Collection) and other non-personal information (i.e., Anonymous Information and Aggregated Information) we collect to improve our services and to deliver a better and more personalized experience by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about the Covered Institute preferences, allowing us to customize the content according to individual institute’s needs.
  • Better understand how Students access and use Milgo and its features, including Surveys.
  • Improve Milgo, including to speed up Student’s usage.
4. Our Practices for Disclosing Student Information

We may disclose Anonymous Information and Aggregate Information about our users without restriction.
We do not share, sell, rent, or transfer Student Information other than as described in this section.
We may disclose Student Information:

  • To the applicable Covered Institute (including its teachers, administrators, school districts, employees, personnel, or other authorized agents of the Covered Institute) pursuant to a specific services agreement with such Covered Institute.
  • To Parents vis-à-vis the Covered Institute and its instructions.
  • To third parties we use to support the internal operations of our service (e.g., hosting and data storage service providers) and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.
  • If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Kayma, our Covered Institutes, or others, including to:

    • protect the safety of a child;
    • protect the safety and security of Milgo; or
    • enable us to take precautions against liability.
  • To law enforcement agencies or for an investigation related to public safety.

If Kayma is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Kayma’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the Student Information we have collected or maintain to the buyer or other successor.

Subject to the above, we do not disclose or transfer Student Information to third parties except for authorized educational purposes or as directed by the Covered Institute.  We prohibit our third-party service providers from using Student Information for any purpose other than providing the contracted service.

5. Accessing and Correcting Student Information

Parents have the right to control the Student Information we have collected from their children. This includes the right to review, to delete, and to tell us to no longer use it. If you think that we have collected Student Information without proper consent, please contact us at https://coda.io/form/milgo-Support_dDCRTuQ8mc3, and we will investigate the situation. If we learn that we have collected Student Information without proper consent, we will delete that information as quickly as possible.

6. Changes to this Notice

This Notice is current as of the date identified at the top of the page. We may change this Notice from time to time, so please be sure to check back periodically. If additional information is to be collected, you will be required to agree with our policies and practices at that time.

044007\00001\17045995v5

MILGO (KAYMA LABS LTD.)
CHILDREN'S PRIVACY NOTICE