Neelo App Privacy Policy

This Privacy Policy describes how Planet 9 Studio, LLC (d.b.a. Neelo) and our subsidiaries and affiliated companies (collectively, “Neelo,” “we,” or “us”) collect, use, disclose, and otherwise process information about you and your child when you (“you”) or your child (“your child”) access or use our Neelo mobile application, (our “App”). To view our Privacy Policy for the Neelo website, https://tryneelo.com, and our parent portal, visit https://www.tryneelo.com/web-privacy-policy. We may provide different or additional notices of our privacy practices for certain offerings, experiences, or services, in which case those notices will supplement or replace the disclosures in this Privacy Policy.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. If we make material changes, we will provide you with additional notice (such as by adding a statement to the App or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

CONTENTS

• Collection of Information
• Use of Information
• Disclosure of Information
• Your Choices
• Contact Us

COLLECTION OF INFORMATION

The information we collect about you depends on how you interact with us. In this section, we describe the categories of information we collect and the sources of this information.

Information You Provide to Us

We collect information you provide directly to us. For example, you provide us with your email address and password when you log-in to our App.

Information We Collect Automatically

We automatically collect information about your and your child’s interactions with us or our App, including:

• Device, Usage, and Activity Information: We collect information about how you access our App, including data about the device and network you use (such as your hardware model, operating system version, mobile network, browser type, and app version).
• Your Child’s App Usage: We collect information based on your child’s activity on our App. This could include information about the account your child uses to access the App, your child’s gameplay time, the date and time your child used the App, and their learning progress. Much of this information is used to populate what you can see on the Parent Portal, in order to track your child’s progress.
• Information Collected by Vendor Analytics SDKs: We use vendor analytics SDKs to collect information about your and your child’s interactions with the App. These technologies help us improve our App, personalize your experience, and analyze your interactions with us, including to see which areas and features of our App are popular.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your mobile network.

USE OF INFORMATION

We use the information we collect to allow you to track your child’s learning progress.

We also use the information we collect to:

• Provide, maintain, and improve our products and services;
• Develop new products and services;
• Personalize your experience with us;
• Send you technical notices, security alerts, support messages, and other transactional or relationship messages;
• Send you marketing communications;
• Monitor and analyze trends, usage, and activities in connection with our products and services;
• Detect, investigate, respond to, prosecute, and help protect against security incidents and other malicious, deceptive, fraudulent, or illegal activity, and help protect the rights and property of Neelo and others;
• For other business purposes, if used in an aggregated or anonymized manner that does not identify you; and
• Comply with our legal and financial obligations.

DISCLOSURE OF INFORMATION

We disclose personal information as described in this Privacy Policy and in the following ways:

• Vendors and Service Providers. We make personal information available to our vendors, service providers, contractors and consultants who perform services on our behalf, such as companies that assist us with payment processing, fraud prevention, customer service, analytics, and marketing.
• Law Enforcement Authorities and Individuals Involved in Legal Proceedings. We disclose personal information in response to a request for information if we believe that disclosure is in accordance with, or required by, any applicable law, regulation, or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
• To Protect the Rights of Neelo and Others. We may disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Neelo, our users, the public, or others.
• Professional Advisors. We disclose personal information to our legal, educational, financial, insurance, and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• Corporate Transactions. We disclose personal information in connection with, or during negotiations of, certain corporate transactions, including a merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Corporate Affiliates. Personal information is disclosed between and among Neelo and our parents, affiliates, subsidiaries, and other companies under common control and ownership.
• With Your Consent or at Your Direction We make personal information available to third parties when we have your consent or you intentionally direct us to do so.

We also disclose aggregated or de-identified information that cannot reasonably be used to identify you or your child. We maintain and use this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.

YOUR CHOICES

Account Information

You can access, correct, and delete certain information stored within your Neelo account at any time by logging in to your account at tryneelo.com and navigating to settings or emailing us at privacy@tryneelo.com.

Mobile Push Notifications

With your permission, we may send push notifications to your mobile device. You can deactivate these notifications at any time by changing the notification settings on your mobile device.

CONTACT US

If you have questions about this Privacy Policy, please contact us at privacy@tryneelo.com.