Children's Privacy Notice

ReadClub is a reading and language-learning service designed for children ages 2-12 ("Learners"). Because our service is directed to children, we comply with the Children's Online Privacy Protection Act ("COPPA") and its implementing Rule. This notice explains what personal information we collect from Learners, how we use it, how long we keep it, who we share it with, and the rights parents and legal guardians ("Parents") have. It supplements our Privacy Policy. If anything here conflicts with the Privacy Policy regarding children's information, this notice controls.

1. Who we are

The operator of ReadClub is:

2. What we collect from and about Learners

Only Parents can create ReadClub accounts. When you create a Learner profile, we ask you, the Parent, for your child's:

• First name or nickname (a nickname is fine; we do not need a legal name)
• Age or birth month/year (to select age-appropriate stories)
• Language(s) being learned and reading level
• Optional profile photo if you choose to upload one

While your child uses ReadClub, we collect:

• Voice recordings. When your child uses Read Aloud or Voice Tutor, we record their voice so the service can follow along, give pronunciation feedback, and let you review their progress. Recording happens only during these activities and is indicated on screen; we do not record in the background.
• Pronunciation profiles.From your child's recordings we create a profile of how your child pronounces sounds and words so feedback improves over time. Under COPPA, this may constitute a biometric identifier (a voiceprint), and we treat it with the same protections as the recordings themselves.
• Learning activity. Which stories your child reads or listens to, progress, quiz answers, credits used, and session length.
• Live Session recordings. If you enroll your child in a live class, sessions may be recorded (audio and video) for quality and so absent students can catch up. You will be told before any recorded session begins.
• Device and technical data. Device type, browser, IP address, and app performance data needed to run the service.

What we do NOT collect from Learners: precise geolocation, contact information (children cannot enter email addresses or phone numbers), or anything a child types in open text fields shared with other users. Learners have no public profiles, chat, or messaging.

We do not collect more personal information from your child than is reasonably necessary to provide ReadClub, and we will never make your child's participation contingent on providing more.

3. Parental consent: how it works

Before we collect personal information from your child, we obtain verifiable parental consent:

1. At sign-up, we show you a direct notice of the practices described here and in our Privacy Policy and ask you to affirmatively agree to our Terms of Service.
2. Before we record your child's voice in Read Aloud or Voice Tutor, we require separate Read Aloud recording consent through our in-product consent flow, verified with a Parental Gate PIN. Creating a Parent account alone is not sufficient consent for voice recording.
3. Separately, we would ask for your consent before disclosing your child's personal information to any third party for purposes that are not integral to providing ReadClub. You can use ReadClub without agreeing to any non-integral disclosure. Currently, we make no such disclosures, so no separate consent is requested.

We keep records of your consent, including the date and policy version when Read Aloud recording consent is granted. You may revoke consent at any time (Section 7).

4. How we use your child's information

• To provide the service: playing stories, following your child's voice during Read Aloud, giving Voice Tutor feedback, tracking progress, and running Live Sessions
• To show you (the Parent) your child's recordings, feedback, and progress
• To personalize difficulty and pronunciation feedback for your child
• To keep the service safe, secure, and working (debugging, fraud and abuse prevention, legal compliance)

What we never do with children's information:we do not sell it; we do not use it for targeted or behavioral advertising; we do not use it to build advertising profiles; and we do not use your child's voice recordings or any children's personal information to train AI models. Speech and language processing is used only to deliver the learning features your child is using.

5. How long we keep it (retention schedule)

We keep children's personal information only as long as reasonably necessary for the purpose it was collected, then delete it. We never retain it indefinitely.

If you delete a Learner profile or your account, we delete the associated children's personal information within 30 days, except where a longer period is required by law, and we require our service providers to do the same.

6. Who we share it with

We share children's personal information only with service providers that help us operate ReadClub, under contracts that require them to protect it, use it only to provide services to us, and never use it for their own purposes (including advertising or AI training):

We may also disclose information if required by law, to protect safety (see our Privacy Policy's child-safety reporting section), or as part of a merger or acquisition (in which case the new entity remains bound by this notice or we will seek new consent).

We do not disclose children's personal information to any third party for that third party's own purposes.

School use:When ReadClub is used through a school, the school may provide consent in place of a Parent, but only for the collection and use of student information for the school's educational purposes, never for commercial purposes. See our Teacher and School Administrators Addendum.

7. Your rights as a Parent

At any time, you can:

• Review the personal information we have collected from your child, including voice recordings and pronunciation profiles
• Delete it and direct us to delete it from our service providers
• Revoke consent and refuse further collection or use. If you revoke consent for voice features, your child can still listen to stories and use non-voice features where available, but Read Aloud and Voice Tutor will be disabled since they require recording
• Refuse third-party disclosure without losing access to the service (where the disclosure is not integral to providing it)

To exercise these rights, email privacy@readclub.co or support@readclub.co. Include your account email and your Learner's name. We will verify that you are the child's Parent before acting, and respond within 30 days.

8. How we protect it

We use administrative, technical, and organizational safeguards designed to protect children's information, including encryption in transit and at rest, access controls that limit employee access to children's data, and monitoring for suspicious activity. Our service providers that handle children's personal information are required to protect it under contract. No system is perfectly secure, but we treat children's data with our highest level of protection. See our Security page for more information.

9. Changes to this notice

If we materially change how we collect, use, or disclose children's personal information, we will notify Parents directly at the email on the account and obtain new consent where required before the change applies to your child's information.

10. Contact us

If you believe we have collected information from a child without proper consent, contact us immediately and we will delete it.