Hoot Reading Web App Privacy Policy

Last Updated: 11/29/2021

Hoot Reading, Inc. (“Hoot Reading,” “we,” “us”), owns and operates the web-based Hoot Reading application (the “Services”) that provides personalized, online reading support for young readers from certified instructors. This Privacy Policy is intended to inform our parent and student users (collectively, “Users,” “you,” “your”) about how we may collect, use, and disclose your personal information. It also describes your choices regarding use, access, and changes to your personal information.

By accessing or using the Services, you acknowledge that you have read, understood and agree to this Privacy Policy.

Contents

Information We Collect

We only collect information about an individual with the individual’s knowledge and consent. Generally, this means we collect personal information directly from Users using the Services. Occasionally, we may collect personal information from third party sources, but only with the knowledge and consent of the individual or where otherwise authorized by law.

We may collect and process all or some of the following information about you:

Information Collected From Parents
First name, last name, email address, phone number, Country, State/Province, and password, as well as confirmation that you have an appropriate device to run the Hoot Reading app.
How We Use This Information
We use this information to set up your account, contact you for appointments you schedule with us and to send you updates about your child’s progress.
Information Collected From Parents
Your child’s name, month and year of birth, grade, hobbies or interests, math or reading level, math strengths and challenges, and if your child has attention issues we should be aware of.
How We Use This Information
We use this information to select an appropriate learning level to begin the lessons, match and introduce the child to their teacher(s), and identify books we think your child may be interested in reading.
Information Collected From Children
Audio and video of your child, as part of the video calls they have with our educators, text chat with educators as part of their lessons, books read, and reading progress and preferences.
How We Use This Information
We use this information to deliver the learning experience to the child, and to monitor and assess our educators.

Parents also have the option to provide us with their photo, and additional information about their child, including their reading level and additional information, including learning challenges and accomplishments, that may be helpful to our educators. We use this information to deliver the learning experience for the child. We may also collect personal information for other purposes where we have a legal duty or right to do so.

A Note About Children:
We operate in compliance with applicable privacy laws including the Children's Online Privacy Protection Act (COPPA). We collect only the minimally required Personal Information from children in order to provide the Services, and do not condition a child’s access to or participation in the Services on providing more Personal Information than is necessary. We use Personal Information from children only to provide the Services.

Before we collect Personal Information from children under the age of 13 in the US, or otherwise under the age of consent in your country, we obtain permission from the verified parent or legal guardian. Parents or legal guardians may contact us at any time to revoke their consent, review the information we have collected from their child, request that we collect no additional information, or request that we delete their child’s information. You may contact us at help@hootreading.com to exercise these rights. Please be aware that we may request certain information from you to reasonably verify your identity before fulfilling your request.

Usage Information and Cookies:
When Users access our Services, our servers automatically collect the Internet Protocol (“IP”) address associated with your browser. We may also collect additional information such as a geographic location (including city, state, or country), device ID, login timestamp, browser type and version, and the operating system of the device. We use this information to help us provide the Services in the local language, to diagnose technical problems and to administer the Services. We also analyze the information for aggregate trends about how our Services are used, and to help us improve our Services. We do not attempt to re-identify this anonymous information.

To collect this information, we use these tracking technologies:

Cookies. Cookies are small data files sent by a website and stored on the computer or device at the request of that site. Cookies store information related to a user's browser to enable us to recognize the browser on return visits and to remember your preferences.

Click tracking: Click tracking allows us to capture “clickstream data” about your use of our website, including the pages you visit and the content you view. This includes the full URL clickstream, including the date and time of your interaction, time spent, response times, browsing activity (including scroll positions, clicks, mouse movements), search queries, and the URL of the website you visited immediately beforehand. We use clickstream data to better understand your needs and preferences so that we can improve the Website experience.

By using Hoot Reading, you agree to the use of these technologies.

Third Party Cookies:
We use third-party service providers to assist us in collecting and analyzing usage information. Most browsers can be set to detect browser cookies and to let a user reject them, but refusing cookies may make it difficult to use certain areas of the Web App. A list of companies that use cookies on our Website, the services they provide, and information on how you may opt out of certain cookies is included in our Cookie Notice. To learn more about browser cookies, including how to manage or delete them, refer to the Tools, Help, or similar section of your web browser.

When you use the Internet, we or our third party partners, as well as certain companies not affiliated with us, including ad networks, web analytics companies and social networking platforms may use technologies, such as those described above, to collect information about your online activities over time and across our and other websites. We and they may use this information to measure the effectiveness of our advertising and to target advertisements for products and services that may interest you. In addition to the tracking technologies described above, other companies may also use clear GIFs and other tracking technologies.

As with many organizations, we do not honor “Do Not Track” signals transmitted by web browsers as there is no industry standard for implementing such programs. To find out more about DNT, please visit http://allaboutdnt.com.

For more information about third-party advertisers and how to prevent them from using your information, visit the NAI’s consumer website at http://www.networkadvertising.org/choices, http://www.aboutads.info/choices, or http://www.youronlinechoices.com/uk. If you do want to opt out using these tools, you need to opt out separately for each of your devices and for each web browser (such as Chrome, Edge Firefox, Safari or others) that you use on each device.

How We Use and Disclose Personal information:
WE DO NOT SELL OR RENT DATA. We do not access or disclose your Personal information except as described above or in the following circumstances:

To provide, maintain, and administer the Services, including to create User accounts, provide the reading lessons, create progress reports for parents, and as needed, by sharing Personal Information with third-party service providers who provide certain features, such as server maintenance, analytics, and cloud storage on our behalf.

To provide customer support, including to resolve a problem or support issue, notify Users about changes to the Services, and to otherwise communicate and solicit feedback on your experiences with the Services.

Our legal bases for these practices are fulfillment of our legitimate interests and performance of a contract, to enable us to perform our obligations and provide you with access to our Services.

To protect our rights or the rights and safety of our Users, or as necessary in the event of a court order, regulatory inquiry or other lawful request. Unless legally prohibited from doing so, we will direct any such request to the User or notify the User before responding unless to do so would prejudice the prevention or detection of a crime.

In relation to a known or suspected violation of our terms of use, fraud prevention or other unlawful use: including to share Personal Information with entities assisting us in investigation and as may be required by applicable law.

Our legal bases for these practices are to fulfill our legal obligations and legitimate interests, such as to allow us to ensure the legality of our Services and to cooperate with law enforcement and regulatory authorities.
In the event of a reorganization, merger, sale, assignment, bankruptcy, or similar business change, in which case we may need to transfer your Personal Information to that re-organized entity or new owner after the sale or reorganization for them to use in accordance with this Privacy Policy.
Our legal basis for these practices is fulfillment of our legitimate interests, to change our business.
To provide parents with updates and offers about our Services. At any time, you may unsubscribe or opt-out of further communication on any electronic marketing communication by using the link labeled “unsubscribe” available in each email communication or by contacting us at help@hootreading.com.
Our legal basis for these practices is your consent, where such consent is required.

We may also use or disclose personal information for other purposes where we have a legal duty or right to do so.

We may create deidentified data from User information by removing, obfuscating and/or otherwise altering the Personal Information. We may use deidentified data for legally permissible purposes.

Accuracy and Completeness of Personal Information
We make every reasonable effort to ensure that personal information is accurate and complete. This may involve requesting further information or updates from you. We rely on you to notify us if there is a change to your personal information that may affect your relationship with Hoot Reading.

How You May Modify Your Personal Information
At any time, you may access, change, or delete your Personal Information by contacting us at help@hootreading.com. We may take steps to verify your identity before fulfilling your request.

Third Parties
For more information on the cookies and analytics that we use, see the Terms of Use and Privacy Policy of the third parties in our Cookie Notice.

We may engage with third party partners to facilitate our delivery of the Website and to provide certain features on our behalf, such as data hosting, analytics, content delivery, maintenance, email and marketing management, job applications, security, and similar functions. These third parties may require a limited amount of information, including Personal Information, in order to deliver their services.

We may also share aggregated demographic information that is not linked or linkable to personal information with our partners.

We do not disclose more Personal Information than is necessary for a third party to facilitate our delivery of the Services or to provide features on our behalf. All third parties receiving Personal Information agree to process that information in compliance with this Privacy Policy, and use it only to support our delivery of the Services.

Security
We maintain commercially reasonable physical, technical, and administrative safeguards to protect the security, integrity and availability of your Personal Information. We host Personal Information in secure, third-party cloud-based environments that use firewalls, encryption of Personal Information in transit and at rest, and other industry-standard technologies in an effort to prevent interference or access from outside intruders. The Internet, however, is not perfectly secure. We are prepared to take appropriate and timely steps in the event of any incidents involving personal information in accordance with applicable privacy laws.

We require Users to access the Services using unique identifiers and passwords. You are responsible for maintaining the confidentiality of your user name and password. If you become aware of any unauthorized use of your account or suspect a security breach, notify us at help@hootreading.com.

Data Retention
We retain personal information for as long as is necessary to provide the Services. After 5 years of account inactivity, we will delete Personal Information associated with the account.

At any time, Users may submit a written request to have their Personal information deleted. We will comply with such written requests within thirty (30) days.

We do retain non-Personal Information, including aggregated, de-identified data for legally permissible purposes.

Opt-Out Policy
We may send emails to parents with information about our Services that we believe may be of interest in accordance with applicable laws, including Canada’s Anti-Spam Legislation. Parents may opt out of receiving these email messages by contacting us at help@hootreading.com or by clicking on the “unsubscribe” link found at the bottom of every email that we send. We do not send these emails to children, and we do not send email messages on behalf of third parties.

If you have opted out of receiving communications from us, we may still send essential communications regarding the Services

Additional Information for Users from the European Union and the United Kingdom
When we provide Services to you, we operate in the capacity of a “data controller” under applicable EU and UK law. In those circumstances, our processing of your personal information is governed by this Privacy Policy as well as our Terms of Use. In some cases, we will ask for your consent so that we may process your personal information. In other circumstances, we may rely on a different lawful basis, as explained in the section, “How we Use and Disclose Your Personal Information.” Where our lawful basis is our legitimate interest, a balancing test is available upon request.

Storage of Personal Information:
If you are located outside of Canada, please be aware that your information will be transferred to, processed and maintained in Canada.

By submitting your Personal Information, you acknowledge that we may transfer, process and store your information in this way. Wherever the information is, it will be treated securely and in accordance with this Privacy Policy and applicable privacy laws of Canada. These laws may be different from the privacy laws in your country. However, this does not change our commitments to safeguard your privacy and we will comply with all applicable laws relating to the cross-border data disclosure of your Personal Information. In the absence of an adequacy decision regarding the safe processing of your Personal Information in Canada, or otherwise where required, we will implement Standard Contractual Clauses in our agreement with you and with our third parties, or rely on such other transfer mechanism to ensure that the transfer of your personal information outside of your country is lawful. You may request details of the transfer mechanisms that we rely on to transfer personal information outside of your country by emailing us at help@hootreading.com.

Additional Data Rights
Please note that the rules in your country may provide you with additional rights or may limit these rights. In all cases, our provision of the rights will comply with the applicable laws.

If you are based in the EU or UK, for example, you may have the right to access, update or correct your Personal Information, to request deletion of such Personal Information, and to object to certain processing, including that related to marketing, to receive a machine-readable copy of the personal information concerning you that you provided to us or request us to transfer such data to an applicable third party in certain circumstances.

In addition, where you provided your consent so that we might process your Personal Information, you may withdraw your consent by contacting us using the details provided in the “Contact” section, subject to any legal requirements. You may also restrict how we use your Personal Information while a complaint is being investigated. However, if consent is withdrawn, we may not be able to provide the Services.

Your exercise of these rights is subject to certain exemptions to safeguard the public interest (for example, the prevention or detection of crime) and our interests (such as the maintenance of legal privilege). To exercise your rights, please contact us using the information in the “Contact” section below.

Updates to This Policy:
As our Services evolve, we may make changes to this Privacy Policy. We will alert you to changes by providing notice within the Services or otherwise as required by law. Your continued use of the Services is your consent to the most recent version of the Policy.

The “last updated” note at the top of this policy indicates when it was last revised, and updates will become effective when they are posted. Please check back frequently for the most recent version.

Contact:
If you have any concerns or complaints about how we handle your Personal Information, or if you have questions regarding this Privacy Policy, please contact us at:
123 Handsart Blvd. Winnipeg, Manitoba R3P 0C4
help@hootreading.com
USA & Canada: 1(833)789-HOOT (4668)

You also have a right to lodge a complaint with a supervisory authority. Please contact us for the information for the relevant authority.

Definitions
Personal Information – information that identifies, describes, or relates to an identified or identifiable individual, or data that is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.