KIDS AND TEENS PRIVACY POLICY

We at Roundglass LLC and Roundglass Wellbeing Private Limited (including all the associated/related/group companies) ("Roundglass," "we," "us," or "our") created this Kids and Teenagers Privacy Policy ("Kids and Teens Privacy Policy") because we know that you care about how information you provide to us is used and shared. This Kids and Teens Privacy Policy applies to all the platforms offered by us and our affiliates through the various websites and mobile and other applications (the “Platform”) owned and operated by Roundglass.

“Child/Children/Kid(s)” in context of this Privacy Policy and for the Platform offered by Roundglass shall be defined as:

(i) any user of the EEA and its member states under the age of 16, unless otherwise lowered through applicable laws of a member state,

(ii) any user of the United States of America under the age of 13,

(iii) any user of India under the age of 18,

(iv) for any other countries, any user not able to provide valid consent as defined under the specific laws applicable to that country.

A ‘Teenager/Teen’ in context of this Privacy Policy and for the Platform offered by Roundglass shall be defined as:

(i) any resident of the EEA and its Member States above the age of 16 and under the age of 18,

(ii) any resident of the United States of America above the age of 13 and under the age of 18

We strive to educate parents, Children and Teenagers about how to appropriately safeguard their privacy when using our Services. We are committed to complying with all applicable laws, rules and regulations, which require us to inform parents and legal guardians about our information collection and use practices across different jurisdictions. Such applicable laws also require that we obtain explicit parental consent before we allow Children or Teenagers to access and/or use our Services. We urge Kids and Teens to check with their parents before entering information through our Platform and/or Services, and we recommend that parents discuss with their Kids and Teenagers the restrictions regarding the online release of Personal Information (as defined below) to anyone they don't know.

We do not directly allow Kids or Teens to make an account on our Platform. For you to have your own account, we need permission from your parents or legal guardian to collect, use or disclose your information as described in this Kids and Teens Privacy Policy and the Roundglass Privacy Policy. By visiting our Platform and/or using our Services or by providing parental consent, both parents and Kids/Teens are agreeing to the terms of this Kids and Teens Privacy Policy, Roundglass Privacy Policy , and the accompanying Terms of Use. Capitalized terms not defined in this Kids and Teens Privacy Policy shall have the meaning stated in our Terms of Use.

1. Information We Collect.

Personal Information

We do not collect any Personal Information from you unless you voluntarily provide it to us.

We collect Personal Information from you in the following ways: (i) when you sign up to become a user of the Platform; and (ii) when you access the Platform and provide Information in connection with your use of the Platform, or otherwise utilize certain aspects of the Platform as described below:

a. For you to have your own account on our Platform, we will ask you to provide us with a parent’s or guardian’s online contact information and enter their account credentials in order to obtain parental consent. When you sign up to become a User of the Platform (a "User"), you will be asked to provide us with certain Personal Information, such as your first name, last name, email address, mobile number (only for users located in India), year of birth, and password. Additionally, you may also opt to add the following details in your profile: profile image, address, professional information and a brief introduction about yourself. In this Kids and Teens Privacy Policy, we refer to this information as "Personal Information." If you are a Child or Teen User, please do not send any Personal Information to us if we have not obtained prior consent from your parent or guardian on your behalf. If we learn we have collected Personal Information from a Child or Teen User without parental consent, or if we learn a Child or Teen User has provided us Personal Information beyond what we request from them, we will delete that information as quickly as possible. If you believe that a Child or Teen User may have provided us Personal Information in violation of this Kids and Teens Privacy Policy, please contact us at privacy@roundglass.com. By providing the parental consent, the parent or guardian agree and acknowledge that they are legally capable and authorized to provide the consent on behalf of the Kid/Teen.

b. Location Information when you visit the Platform, either provided by a mobile device or associated with your Internet Protocol (IP) address.

c. If you sign in through Google, you are authorizing Roundglass to collect, store, and use, in accordance with this Kids and Teens Privacy Policy, any and all information that you agreed that Google, Inc. would provide to Roundglass through Google's Application Programming Interface ("API"). Such information may include, without limitation, your first and last name, Google username, Google profile picture, headline, unique identifier and access token, and email address.

d. If you register or visit the Platform through Facebook or another social media website, you are authorizing Roundglass to collect, store, and use, in accordance with this Kids and Teens Privacy Policy, any and all information that you agreed that the social media website would provide to Roundglass through its API. We do not receive or store your passwords for your social media accounts.

e. If you choose to purchase or subscribe to a feature or Service of Roundglass that requires a fee, you will be required to provide us with your or parent’s payment information, including, without limitation, bank account numbers, credit card or debit card numbers, account details, ACH information, and similar data (collectively, "Payment Information"). Payment Information that you or your parent or guardian provide is stored by our third-party payment processor and is subject to the payment processor’s privacy policy.

Usage Information

Like most websites, we use automatic data collection technology when you visit the Platform to record information that identifies your computer, to track your use of our Platform, and to collect certain basic information about you and your surfing habits. This information includes information about your operating system, your IP addresses, device information, browser type and language, crash reports, logged activities, activity frequency, duration of activities, completion status of activities, streaks, session duration, feature usage, amount of time spent on particular pages, what sections of a website you visit, login times, and similar information concerning your use of the Platform and the Services (the "Usage Information").

We collect this Usage Information by using cookies and pixel tags (also called web beacons or clear gifs). Cookies are small packets of data that a website stores on your computer's hard drive so that your computer will "remember" information about your visit. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of website users. You can reject cookies by following the directions provided in your internet provider's "help" file. If you reject cookies, you may still visit the Platform, but may not be able to use some areas of the Platform and/or the Services.

We do not collect Personal Information in this way, but if you've provided us with Personal Information, we may associate that information with the information that is collected automatically. Automatic data collection may be performed on our behalf by our Services providers.

2. How We Use Your Information.

We may use your Personal Information and Usage Information in a manner that is consistent with this Kids Privacy Policy and the context of our relationship with you. We will use your Personal Information and Usage Information collected through the Platform for the following purposes:

a. To enable you to use the Platform;

b. To identify you when you sign in to your account;

c. To keep your parents or guardians informed about your usage of the Platform;

d. To respond to your requests and to provide you with the Services

e. To respond to your inquiries and contact you about changes to the Platform and/or the Services. To keep a record or monitor your communications with us/our support team to help resolve any issues you might be facing and have complained about and, also for the purpose of monitoring quality, security, and training;

f. To send you notices (for example, in the form of emails, mailings, and the like) regarding products or Services you are receiving, to inform your parents about your log-in activities, and for billing and collection purposes;

g. To send you information we think you may find useful or that you have requested from us;

h. To enhance and improve the Platform or the Service, such as through personalized features and content;

i. To contact you with information pertaining to the content on the Platform and for other promotional offers, marketing communications, and deals that we think you may be interested in;

j. To analyze the use of the Platform and the Service and the people visiting to improve our content and Platform and the Service;

k. To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required by law;

l. For any other purposes disclosed at the time the information is collected or to which you consent; and

m. As otherwise specifically described in this Kids and Teens Privacy Policy.

n. We will use your Payment Information to process your authorized payments for our Services.

3. Disclosure of Information/Personal Information.

We do not disclose your Personal Information to third parties for their direct marketing purposes. However, there are instances in which we may disclose information we collect on the Platform to third parties in order for us to operate the Platform and provide the Services. A list of the types of third parties to whom we disclose information can be found below. The other organizations to whom we disclose Information are obligated to use such Information only for the purposes stated below. Your parents/guardian give explicit consent on your behalf towards the following disclosures:

a. Disclosures to Partners.

We may disclose the information we collect to our partners so that they are better able to prepare the content which is made available by us from time to time for your best user experience. In all cases, we will require our partners to whom we provide information to comply with our instructions and policies and to use the information solely for the purposes for which we have retained them. Disclosure of information to these service providers is done to help us serve you better.

b. Disclosures to Other Affiliated Companies.

We may disclose information to our affiliates for purposes such as and including but not limited to:

i. Fulfilling your requests; and

ii. Offering you other products or services that we think may be of interest to you

c. Disclosure for Processing the Payment.

We will share your or your parent’s Payment Information with a third-party service provider as necessary to process your payment. The third-party service provider stores your or your parent’s Payment Information; we do not store this information. Storage by the third-party service provider of your or your parent’s Payment Information is subject to the privacy policies and practices of the third-party service provider and is not subject to the terms of this Kids and Teens Privacy Policy. By providing your Payment Information, you acknowledge and agree to use of such information by the third-party service provider for purposes of processing your payment to us.

d. Disclosures to Third Parties

i. We do not sell, trade, or otherwise transfer to outside parties your Personal Information without your express consent. We may provide your Personal Information to website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this Information confidential and adhere to our instructions and policies. We may, additionally, release your Personal Information: (a) when we, in good faith, believe that it is necessary to protect our rights or property, (b) to any successor or purchaser in a merger, acquisition, liquidation, dissolution, or sale of assets, or internal restructuring, or (c) when we, in good faith, believe that access, use, preservation or disclosure of the Information is necessary to comply with any applicable law, legal process or enforceable governmental request, to enforce applicable agreement, including investigation of potential violations, detect, prevent, or otherwise address fraud, security or technical issues or protect against harm to the rights, property or safety of our users or the public at large, as may be required or permitted by law. We also permit consultants and lawyers who may advise us in the course of litigation or arbitration concerning the Platform to have access to your usage data and Personal Information, if required. Your consent will not be required for disclosure in these cases, but we will attempt to notify you, to do so. However, non-personally identifiable Information forming part of your Personal Information may be provided to other parties for marketing, advertising, or other users without any prior intimation to you and/or your express consent.

ii. In accordance with applicable Laws, we may share your usage data, Personal Information, and/or non-personal information with third parties to (a) assist us and such concerned third parties in studying the user behavior and accordingly evaluating and improving the quality of the Services provided through the Platform; (b) determine your preferences and/or the Platform to suit your needs in a more targeted way, and (c) promote the Platform to third parties.

iii. For purposes of clarity, the usage data may be provided to anyone on an aggregate and anonymous basis for analytical purposes.

iv. We may permit our third-party agents, service providers, vendors, and sub-contractors (such as vendors and suppliers that provide us with technology, services, data analysis, research, advertising, and marketing assistance and/or content in connection with our operation and maintenance of the Platform) to access your Personal Information, in connection with performing services for us and/or to operate the Platform. However, such third-party agents are not authorized to use that Personal Information for their benefit and are required to strictly adhere to our instructions and policies.

e. Aggregate Data

We reserve the right to transfer and/or sell aggregate or group data about the Platform users (including usage data where the same is not linked to Personal Information) for lawful purposes. Aggregate or group data is data that describes the demographics, usage, or other characteristics of the Platform users as a group, without disclosing Personal Information. We may share anonymized aggregate data with the schools, employers or the party sponsoring the subscription of the User. We may also share aggregate data with our partners – like publishers, advertisers, or connected applications. For example, we may share Information publicly to show trends about the general use of our services through the Platform.

4. How We Protect Your Information.

The security of your personal information is important to us. We take commercially reasonable steps to protect the Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the internet. In particular, email sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via email. We and our service providers take appropriate security measures to protect against unauthorized access or disclosure of the information collected by us. We review our security measures periodically and are committed fully to securing your Information and protecting your privacy.

The safety and security of your Information also depends on you. Where we have given you or your parent or guardian (or where you or your parent or guardian have chosen) a password for accessing the Platform or certain functions therein, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

5. How We Store Your Information.

Any Personal Information we obtain about and from you will be stored in accordance with jurisdiction specific applicable law, and standards. Roundglass is a global company, and the Platform and the Services are operated from the United States as well as India. Please be aware that, by using our Platform and checking the box to accept our Agreement and Kids and Teens Privacy Policy, your parent or guardian, on your behalf, consent to the collection, transfer, storage, and processing of Personal Information to, from, and in United States, India, or any other country where Roundglass or its affiliates, subsidiaries, or service providers maintain facilities. The registration process and act of checking the box will be construed as obtaining prior written consent from your parent or guardian on behalf of you through electronic communication.

6. Accessing and Modifying Account Information.

If you have registered with our Platform, your parent or guardian may access, modify, or delete your Personal Information by logging into our Platform using your username and password and visiting your account profile page. Your parent or guardian may also send us an email to the Privacy/Grievance Officer at privacy@roundglass.com to exercise your afore-mentioned rights. We may not accommodate a request to change Information if we believe the change would violate any law or legal requirement or cause the Information to be incorrect.

We strive to help parents ensure that their kids have a safe experience using our Services. Parents or legal guardians can review any Personal Information collected about their child or teen, have this information deleted, request that there be no further collection or use of their child's or teen’s Personal Information, and/or allow for our collection and use of their child’s or teen’s Personal Information while withholding consent for us to disclose it to third parties.

7. Cookies.

Cookies are small information files that are placed on your computer or mobile device when you visit a website. We, like many other websites, use cookies to make our Platform work, to work more efficiently, to enhance your experience, and/or to measure your usage of the Platform. With the help of cookies, we may present you with customized offerings or content that may be of interest to you. We may also use cookies to recognize you on subsequent visits or to remember your username, so you do not have to re-enter it each time you visit the Platform. You may be able to set your browser to notify you when you receive a cookie or to prevent cookies from being sent. Please note, however, that, by not accepting cookies you may limit the functionality we can provide to you when you visit our Platform. For more information on the types of cookies used by Roundglass and your rights regarding these cookies, please refer to our Cookie Policy.

8. Links.

The Platform may contain content, services, advertising, and other materials that link to websites operated by third parties. We have no control over those other sites, and this Kids and Teens Privacy Policy does not apply to them. Please refer to the privacy policies of those sites for more information on how the operators of those sites collect and use your Personal Information.

9. Information Retention.

We will retain your Personal Information only as long as is necessary for the purposes to which you consent under this Kids and Teens Privacy Policy and in compliance with applicable law, after which we will delete it from our systems. If you withdraw a registration or cancel a subscription, we may retain your Personal Information in our records and we may continue to use and disclose that data in a manner consistent with this Kids and Teens Privacy Policy unless you request the deletion of the same.

10. Your Rights.

We value the confidentiality of your Personal Information and will take all commercially reasonable efforts to ensure that you can exercise your rights provided under applicable data privacy laws. You have the following rights in your Information:

a. Right to access : you have the right to request access to the Personal Information we store and process about you.

b. Right to correct : you have the right to rectify your inaccurate Personal Information including completion of incomplete Personal Information.

c. Right to erasure : you have the right to erase your Personal Information unless data retention for said category of data has been stipulated for a mandatory minimum period of time as per existing law.

d. Right to object : you have the right to object at any time to our processing of Personal Information. For example, if Users have requested to receive Information from us, e.g., Newsletters, but do not wish to receive further Information, you can easily opt out of receiving further Information from us.

e. Right to withdraw consent : as a rule, if the processing of your Personal Information is based on your consent, you may withdraw your consent at any time by unsubscribing from an email or sending us an email. Please note that this does not affect the processing of your Personal Information before the withdrawal of your consent.

f. Right to data portability : you have the right to receive your Personal Information collected and stored by us in a structured, commonly used, and readable format. You have the right to transmit this Personal Information to a third party without hindrance from us, if technically feasible.

11. Legal Basis For Processing Personal Information under GDPR.

If you are a resident of the European Economic Area (“EEA”), our legal basis for collecting and using the Personal Information described above will depend on which Services are you using on the Platform. Our Legal Basis for collecting and processing your Personal Information shall be as follows: /p>

a. Consent: basis your consent to process your Personal Information

b. Contractual Obligation: you have entered into a contract with us, and we need to use your Personal Information to provide you access to the Platform.

c. Legal Obligation: wherein we have to process your data to comply with a legal obligation we are subjected to.

d. Vital Interests: where it is necessary to process Personal Information to protect the vital interests of a natural person.

e. Legitimate Interests: where it is necessary for the purposes our legitimate interests provided, they do not override your rights in your Personal Information.

12. “Opting Out” – Consumer Selections Regarding Information Sharing.

We are committed to protecting your Personal Information, and to using or sharing it in ways that will improve or expand upon the Services we provide to you. By accepting the terms of this Kids and Teens Privacy Policy by checking the acceptance box on the Platform, you agree to the sharing of Personal Information as described above.

While browsing the Roundglass website, or our web or mobile applications and/or using the Services, you will not be provided with the opportunity to opt-out of the sharing of Personal Information until you register on the Platform.

The practices and policies contained in this Kids and Teens Privacy Policy replace all previous notices or statements with respect to the same subject.

13. Changes to This Kids and Teens Privacy Policy.

This Kids and Teens Privacy Policy is effective as of the date stated at the top of this Kids and Teens Privacy Policy. We may change this Kids and Teens Privacy Policy from time to time and will post any changes on the Platform as soon as they go into effect. By accessing the Platform or using the Services after we make any such changes to this Kids and Teens Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Kids and Teens Privacy Policy on a regular basis.

14. How to Contact Us.

If you have questions or complaints regarding this Kids and Teens Privacy Policy, you may contact our designated Grievance Officer via email as noted below:

Roundglass

Name: Mannat Wadehra

Designation: Grievance and Privacy Officer

Email: privacy@roundglass.com

or you can mail us at any of the following address

Roundglass LLC
1800 114th Avenue SE,
Bellevue, WA 98004
support@roundglass.com

RoundGlass Wellbeing Private Limited
9th Floor, Plot no. IT C-9,
IT Park, Sector 67, Mohali,
Punjab-160062
support@roundglass.com