Contents

• Collection of Information
• Use of Information
• Disclosure of Information
• Your Choices
• Children's Information
• Contact Us

Collection of Information

The information we collect about you and your child in connection with use of the App 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 and your children access our App, including data about the device and network you use (such as your hardware model, operating system version, mobile network, browser type, language, country, in-app behavioral data, 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, logins (sessions), the date and time your child used the App, and their learning progress through module completions and performance scores. 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 when you or your child use the App 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;
• Personalize your experience with us;
• Inform you about your child’s progress.
• Monitor and analyze trends, usage, and activities in connection with our products and services; and
• 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;

When We Provide Information to Others

We provide personal information to others as described in this Privacy Policy and in the following scenarios:

• Vendors and Service Providers. We make personal information available to our vendors, service providers, contractors and consultants who perform services on our behalf to help support the operation of the App, 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 may provide 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 provide personal information to others 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 may provide personal information to our professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• Corporate Transactions. We may provide or transfer personal information in connection with certain corporate transactions, including a merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• 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.

Children's Information

The App is intended for children between the age of 5 and 10 and their families. As a result, we are providing additional information about the collection of personal information from children under 13. All references to "children" or "child" shall mean children under 13 years of age, and all references to the term "parent" shall include legal guardians.

What information do we collect from children?

We collect identifiers associated with your child’s device, network information, and analytics related to your child’s App activity. See the "Collection of Information" section above for more information.

Does the App enable children to make personal information publicly available?

The App does not enable children or users to make any personal information publicly available.

How do we use personal information collected from children?

We use the personal information we collect from children to operate, maintain, analyze, protect, and improve the Neelo App and to support and personalize your child’s learning experience. See the "Information We Collect Automatically" section above for more information.

Disclosure practices regarding personal information obtained from children.

Neelo does not disclose personal information collected from your child to third parties but note that such information may be accessed by service providers and advisors who help support the operation of our services (e.g., payment processors and analytics providers).

Children's Data Retention Policy

We retain personal information collected from children only for as long as is reasonably necessary to fulfill the specific purpose for which it was collected. Below is our retention policy for data collected from children:

• Child App Behavioral Data (Gameplay time, module completions, scores, and in-app events)
• Purpose & Business Need: Used to provide the service, populate the parent-facing progress dashboard, send parent progress notifications, and perform longitudinal product analytics to improve our curriculum.
• Timeframe for Deletion: Retained in an identifiable format for up to 2 years to allow for product analysis, after which it is fully anonymized (stripped of child, parent, and device identifiers). If an account is closed or you revoke consent, this data is deleted or fully anonymized within 30 days.

(Note: Upon revocation of parental consent, all child personal information is fully deleted from our systems within 30 days.)

Parental Rights Regarding Children's Information

Parents have the right to review or have deleted any personal information collected from their child that is retained by Neelo or its service providers and to refuse to permit further collection or use of their child's personal information. You may do this by reaching out to us at privacy@tryneelo.com or at the address listed above. We may require that parents provide sufficient identification to fulfill their request.

Contact Us

The operator of the App is Neelo Inc. If you have questions about this Privacy Policy, please contact us at privacy@tryneelo.com, or contact us at

Neelo Inc.
96 Morton Street 5th Floor
New York, NY 10014