Education and Children’s Privacy Notice

Last Updated: Oct 10, 2024

Robolink, Inc. (“Robolink”, “our”, “us”, or “we”) provides learning robotics materials to schools and individuals (our “Services”). We provide these Services via our dedicated online portals that contain lessons, content and materials (“Education Portals”). In order to provide the Education Portals and our Services, we collect limited personal information.

When we use the term “personal information”, we mean individually identifiable information about you, the user. This includes, for instance, your name or email.

Is this Privacy Notice for You?

If you are using our Education Portals, you’ve come to the right place to learn about how we protect your personal information!

Our Education Portals are directed to mixed audiences, meaning that this may include children under 13 (“Child Users”). Our Education Portals include the following tools and URLs:

This Education and Children’s Privacy Notice (“Privacy Notice”) describes how we collect and use your personal information when you visit the Education Portals and use our Services. Please read it carefully!

Overview

You can use our Education Portals without creating an account or logging into an existing account. If you don’t create an account, we will collect limited information about your device and usage of the Education Portals via cookies – we explain this in more detail here. If you do create an account, we collect limited information. If you are a Child User, we provide your parent or legal guardians (“Parent”) control over the data that we collect.

Below is a quick overview of our data collection practices, which are described in greater detail in this Privacy Notice.

What you need to know

  • Collection of Information. Because our Education Portals may be used by Child Users, we take special steps when collecting and processing information through our Education Portals, by limiting the personal information that we collect and how we use that information. We also provide Parents control over the data that we collect.
  • Usage and Disclosure of Information. We use the information that we collect solely to provide our Education Portals and our Services, and to support the internal operations of our business and Services. These limited purposes include maintaining and analyzing the functioning of the Education Portals, providing our Services (e.g., tracking your progress), and providing customer service. When you visit Education Portals, we also collect certain usage data, to support our internal operations, enforce our Terms of Use, and comply with applicable laws. We do not use that information to target children with ads and we do not share, sell, or transfer your information. We only disclose your information to our service providers who help us support the internal operations of the Education Portals.
  • Children’s Privacy. We explain this in more detail in the Children’s Privacy section of this Privacy Notice. It is located here and provides additional information about how Child Users can use our Education Portals and Services and how we process the information from Child Users.
  • Schools. When educational institutions and teachers (“Schools”) use our information in an educational setting, we have special agreements in place that restrict our use of any information obtained about student users (“Students”). In addition to the information in this Privacy Notice, the Additional Information about Schools and Student Use describes our obligations to Schools and their Students in more detail.

Information about Robolink

The operator of the Education Portals is Robolink, Inc. You can contact us at privacy@robolink.com if you have any questions. We are located at:

8920 Kenamar Dr, Ste 209

San Diego, CA 92121

1. Information We Collect

We collect information in the following ways, depending on how you use the Education Portals:

  • From you directly, such as when you create an account.
  • From others, such as when we work with Schools in an educational setting, or from your Parent if you are a Child User.
  • Automatically, including information about how you use the Education Portals and the devices you use to access them. To gather this information, we use cookies, as explained below.

a. Information you provide to us

Visiting the Education Portals

You may visit and use our Education Portals without submitting any personal information, in which case we will only collect information via automated means (i.e., cookies), as explained below.

Creating an Account

If you create an account, we collect the following information from you:

  • Educators or Students over the age of 13: username, email address and password;
  • Parents: first and last name, username, email address and password.
  • Child Users: Child Users may not create an account on their own. Please review the Additional Information about Children’s Privacy section below for information on our collection of information when you create an account.

Using Zumi

If you use a Zumi device, you will be asked to connect your device using a username that is stored locally on the device – Robolink does not store and cannot access this information.

You may also opt to turn on the camera functionality and take photos. If you do so, any photos will be stored on your device – Robolink does not store and cannot access this information.

b. Automatically collected information

When you visit and interact with the Education Portals, we automatically collect information about your device, browser, and activity:

    • Cookies. We use cookies to automatically collect information. Information that we get from cookies (or similar technologies) serves different purposes: to maintain and analyze how the Education Portals work, identify any suspicious activities so we can try to protect users from fraud and other inappropriate activities, or understand how you use the Education Portals and track your progress. We may rely on cookies placed by authorized service providers, such as Google Analytics.
      We do not use any tracking technologies for behavioral advertising on our Education Portals. Robolink does not serve behavioral advertising to or retarget ads to Child Users or any users who visit the Education Portals.
      Most browsers provide choices with respect to these technologies. For example, by modifying your browser preferences, you may have the choice to accept all cookies or be notified when a cookie is set. You can learn more about cookies and how they work at www.allaboutcookies.org, or by visiting your browser preferences.Through the use of cookies, we collect:

      • Device and usage information. We collect information about the device you use to connect to the Education Portals. This information includes your device’s IP address, your device type, browser type, internet service provider, operating system, and unique device identifiers. This also includes activity and usage information, such as the frequency with which you use the Education Portals, how long you stay connected, the pages that you navigate to, any links that you view, and other ways that you interact with the Education Portals.
      • Location Information. When you access the Education Portals, we may collect information about your device’s location by inferring your general location via your device’s IP address. Location information does not include street name and name of city or precise geolocation.
    • Do not track. Although we do our best to honor the privacy preferences of our users, we do not respond to “Do Not Track” signals from your browser at this time. For more information about “Do Not Track”, visit www.allaboutdnt.com.
    • We do not use persistent identifiers such as your IP address to track your activities over time and across different websites and online services.
    • Robotics devices such as Zumi or Drones. These devices may collect sensor data to detect colors and air pressure. Robolink does not have access to this information in an identifiable manner.

c. Information received from third parties

From time to time, we process personal information from third parties, which may include information from Schools when the Services and Education Portals are used in an educational setting, as described in Additional Information about Schools and Student Use. We may also receive information from Parents who create accounts for Child Users.

2. Google Analytics

We use Google Analytics to analyze traffic to the Education Portals. Google Analytics helps us understand how visitors and users engage with the Education Portals. To learn more about Google Analytics’ data practices, please visit Google’s support page. You may also opt-out by clicking here.

Our Google Analytics configuration is set to disable information collected via Google Analytics from being shared with Google products and services.

3. How We Use Your Information

We use your personal information to:

  • Operate and administer the Education Portals and our Services. We use your personal information to provide, administer and manage the Education Portals, including to register your account and enable you to log in if you choose to do so, and track your progress.
  • Provide support and communicate with you. When we respond to your inquiries or support requests, we will use your personal information to assist you, as well as any additional information that you provide. We also use your information to send you important updates about changes to this Privacy Notice or other terms and policies, and information about your transaction(s).
  • Measure and analyze the functioning of the Education Portals. We use information to analyze how our users use the Education Portals. This includes using information to identify issues and bugs, change existing features or test new features.
  • Maintain security and prevent fraud. We use personal information to:
    • Maintain the security and integrity of the Education Portals;
    • Detect, prevent, investigate, and protect our users, the business, and others from fraud, unauthorized transactions, and other unsafe activity; and
    • Protect the safety, rights, or property of any person and our business.
  • Comply with our legal obligations. To comply with applicable laws and regulations and valid legal requests, we may use your personal information. This includes tax and reporting obligations.
  • As otherwise necessary or appropriate. We will use your personal information for other purposes at your direction or with your consent.

4. When We Disclose Your Information

We disclose your personal information to support the internal operations of our Education Portals and Services. We may disclose personal information as follows:

  • To our affiliates. We may disclose your personal information to and among our affiliates, subsidiaries, and other companies under common control and ownership for purposes consistent with this Privacy Notice.
  • To our service providers. We disclose your personal information to third parties that provide services to us. This includes services that assist with cloud storage and system hosting, information security, fraud prevention, payment processing, analytics, and legal matters. Our list of service providers can be accessed here.
  • To Schools that use the Education Portals in an educational setting. We may disclose users’ information to Schools that use the Education Portals in an educational setting, as described in more detail below.
  • To comply with legal requirements. We will disclose personal information when we believe that the disclosure is reasonably necessary to comply with applicable laws and regulations, as well as valid legal processes or legal requests.
  • In connection with a change of control. Over time, Robolink may grow and reorganize. We may share your information, including personal information with affiliates such as a parent company, subsidiaries, joint venture partners or other companies that we control or that are under common control with us, in which case we will require those companies to agree to use your personal information in a way that is consistent with this Privacy Notice.
    • In the event of a change to our organizations such that all or a portion of Robolink or its assets are acquired by or merged with a third-party, or in any other situation where personal information that we have collected from users would be one of the assets transferred to or acquired by that third-party, this Privacy Notice will continue to apply to your information, and any acquirer would only be able to handle your personal information as per this Privacy Notice (unless you give consent to a new privacy notice). We will provide you with notice of an acquisition within thirty (30) days following the completion of such a transaction, by posting on our homepage and by email to your email address that you provided to us. If you do not consent to the use of your personal information by such a successor company, subject to applicable law, you may request its deletion from the company.
    • In the unlikely event that Robolink goes out of business, or files for bankruptcy, we will protect your personal information, and will not sell it to any third-party.
  • To others, at your direction or as necessary. We will disclose your personal information to other parties at your direction or with your consent. We may also disclose your personal information to other parties if we believe it necessary or appropriate to:
    • Protect our business;
    • Protect our rights, privacy, safety, or property, or those of others; or
    • To allow us to pursue available legal remedies or limit damages that we may sustain.

If we disclose your personal information for reasons not listed above, we will notify you of such disclosure at the time of information collection as required by applicable laws.

5. Third-Party Websites

Some links on the Education Portals may redirect you to third-party websites and services that Robolink does not operate. How these websites and services use your personal information is governed by their own privacy policies. We encourage you to review and understand their privacy policies before disclosing any personal information to them.

6. Information Security & Data Retention

We implement and maintain reasonable administrative, physical, and technical measures designed to safeguard and protect personal information under our control from unauthorized access, use, and disclosure. Nevertheless, because no data transmission or storage system is completely secure, we cannot guarantee the security of your information.

Here are some ways to protect your personal information:

  • Create a username that does not reveal your identity
  • Create (and keep) a strong password – do not reuse passwords
  • Keep your password to yourself!

We retain personal information only as long as is reasonably necessary to fulfill the purpose for which it was collected.

7. Processing in the United States

Robolink operates its business, including the Education Portals, in the United States and processes personal information in the United States. As such, when you visit the Education Portals or submit information, your personal information may be processed outside of the country or region in which you reside.

8. Additional Information about Children’s Privacy

Age Verification and Parents

The section below supplements this Privacy Notice and explains how we collect information from Child Users on the Education Portals and in connection with our Services.

IT IS IMPORTANT THAT YOU READ THIS IF YOU ARE A CHILD USER OR A PARENT, TO UNDERSTAND HOW WE COLLECT AND USE YOUR INFORMATION.

As explained in more detail below, if you are a Child User and want to create an account, you will need to provide your Parent’s email so that we can contact them. Only your Parent will be able to create an account for you.

a. Age Verification

All users on the Education Portals, including Parents, teachers, and Students, may view lessons, content, and documentation without creating an account (or logging in). However, users cannot track their progress when they are not logged in (note that the documentation portal does not allow or require user registration).

This is how it works:

  • Users who are not Parents or teachers and who wish to register on the Education Portals as “Students” are asked to enter their date of birth for purposes of complying with COPPA.
  • If a user’s response indicates that the Student is a Child User, the Child User is prompted to submit a Parent’s email address so that Robolink may contact the Child User’s Parent via email with information about how to create the account.
  • Robolink does not knowingly permit Child Users to create an account without the consent of a Parent (or School).

If you are a Parent and discover that your child under the age of 13 has registered without your consent, please contact us at privacy@robolink.com to request that we delete your Child User’s personal information from our systems.

b. Parental Consent and Account Creation

Parents may follow the instructions contained in an email sent by Robolink to the Parent’s email address provided by the Child User at registration.

Once a Parent of a Child User creates a Parent account, they can create a Child User student account for their Child User. For Child User student accounts, we only collect username and password and the Parent whose account it is associated with. Only the Parent account can create a username for a Child User student account. Parents can revoke a Child User’s permissions to use the Education Portals at any time by deleting the account. To do so, Parents can log into their account and delete any Child User account associated with theirs.

We strongly recommend that Parents select a username that does not relate to or identify the real name of the Child User. The Child User’s username can only be changed by the Parent.

If a Parent does not create an account after receiving the email and links from Robolink, Child Users can continue to access the materials on the Education Portals without registering for an account.

Limited Information Collection, Use and Sharing

a. Information We Collect About Child Users

Robolink collects username and password for the Child User account. Robolink also collects device and usage information via cookies (as explained here). This is information about the Child User’s use of the Education Portal and includes lessons completed and progress only if the Child User is logged in.

Robolink limits its collection of personal information from Child Users:

  • Child Users cannot input additional information about themselves, and Child Users cannot make their information publicly available.
  • Child Users cannot receive emails from Robolink – any such emails are sent to the Child User’s Parent associated with the Child User’s account.

b. How We Use and Share Child User Information

We use personal information to provide the Education Portals and our Services only, as described in section 3 (“How We Use Your Information”) above. We use the Parent’s email address to communicate messages about the Child User’s account. Robolink does not use Child Users’ personal information for non-educational commercial purposes (e.g., advertising).

We disclose information as set forth here in more detail. This includes:

  • To our service providers who work on our behalf and help us operate and administer the Education Portals and our Services
  • To a Parent or with a Parent’s consent
  • To Schools, if applicable (please see the section titled Additional Information about Schools and Student Use for more information)
  • In connection with business transfers (e.g., mergers and acquisitions, bankruptcy sales) under certain circumstances
  • To comply with applicable laws and fulfill our own legal obligations, and when reasonably necessary to protect the security and safety of our users, Education Portals and Services, or when permitted by law.

Robolink uses Google Analytics for the sole purpose of providing support for its internal operations.

c. No Third-Party Tracking for Targeted Advertising

Robolink does not use advertising cookies or tracking technologies on the Education Portals, and specifically does not serve any targeted advertising to Child Users. We do not disclose personal information of Child Users for direct marketing purposes or for targeted advertising purposes. In addition, we have taken steps to ensure that there is no Ad Partner technology on the Education Portals.

d. Accessing, Modifying or Deleting your Child’s Account

As a Parent, you have the ability to access and control information about your Child User. You can log into your Parent account, and review , delete or update the information associated with your account, including a Child User’s information. Please contact privacy@robolink.com if you need further assistance. We will require proper authentication before proceeding with any request.

In some cases, administrative controls, including the ability to delete an account, are held by the School, in which case you must direct your request to the School. For more information, please review the Additional Information about Schools and Student Use section below.

To learn more about COPPA, you can visit the Federal Trade Commission’s COPPA website: https://www.ftc.gov/news-events/topics/protecting-consumer-privacy-security/kids-privacy-coppa.

9. Your Choices

You have certain choices and may exercise certain rights with respect to our use of your personal information. Please note that rights and requests may be subject to applicable exceptions.

a. Exercise your marketing choices

We may send you periodic marketing and promotional emails (and will obtain your consent to do so, where required by law). If you no longer wish to receive our marketing and promotional communications, you may opt-out of receiving them by following the opt-out or unsubscribe instructions included in any communication that you receive from us. Please note that even if you opt-out of receiving promotional communications from us, we may still send you administrative and transactional messages from which you cannot opt-out.

b. California Consumer Notice

Under California Civil Code Section 1789.3, California residents are entitled to the following specific consumer rights notice: if you have a question or complaint regarding our Education Portals, please send an email to privacy@robolink.com. You may also contact us by writing to us at the address provided below under Contact Information. California residents may contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs:

  • In writing at 400 R Street, Suite 1080, Sacramento, California 95814; or
  • By telephone at (916) 445-1254 or (800) 952-5210.

California Shine the Light Law. The “Shine the Light” requirements under California Civil Code §1798.83 do not apply to the individuals covered under this Privacy Notice because we do not engage in activities covered by this law.

10. Contact Information

You may contact us about this Privacy Notice or our privacy practices at privacy@robolink.com or by writing to us at:
Robolink, Inc.
8920 Kenamar Dr, Ste 209
San Diego, CA 92121

11. Additional Information about Schools and Student Use

This section supplements this Privacy Notice when Robolink collects personal information in connection with Schools’ use of the Services and Education Portals.

a. School Ownership of Information

When our Services and Education Portals are used by Schools (including school districts and teachers) as part of Schools’ educational programs, personal information about or relating to the Students may include information defined as “education records” by the Family Educational Rights and Privacy Act (“FERPA”) or similar state Student data privacy laws, depending on the School. We refer to this information as “Student Personal Information” throughout this section. FERPA is a federal law that prevents Schools from releasing certain information about your child to vendors such as Robolink absent certain restrictions and additional obligations.

When Schools provide Student information in connection with their use of the Services and Education Portals, we have special agreements in place with Schools that use the Services and Education Portals for educational purposes. Those agreements require us to comply with certain restrictions, including the following:

  • The School controls the personal information of its Students, and Robolink will use it only according to terms of the contract and for the purpose of benefiting the School;
    Robolink will assist the School in responding to requests from Parents or eligible Students to inspect and review personal information and categories of data being held, including correction;
  • Robolink will not share information obtained from the School with third parties, unless this is specifically consented to; and
  • Robolink is restricted from using the information for marketing, including behavioral advertising or targeting, or profile-building.

Robolink may use aggregated anonymized data and de-identified metadata for internal operations purposes such as improving the functioning of the Education Portals and Services and conducting research to validate and improve the Education Portals and Services.

b. Information Security and Breach Notification

If Robolink becomes aware of a systems security breach by an unauthorized party or that any user data was used for an unauthorized purpose, we will comply with relevant state and other data breach laws. We will notify users of any breach resulting in unauthorized release of data electronically, at minimum, and without unreasonable delay so that you can take appropriate steps. The notification will include: date of the breach, the types of information that were subject to the breach, general description of what occurred, and steps Robolink is taking to address the breach.

We work with Schools to protect Student Personal Information in compliance with FERPA and, for School Users who are under 13, COPPA, as explained in our section titled Additional Information about Children’s Privacy. If you have any questions general or about reviewing, modifying, or deleting the personal information of a Student, please contact your School directly. You may also contact us at privacy@robolink.com.

12. Changes to this Notice

The “Last Updated” date at the top of this page indicates when this Privacy Notice was last revised. We may from time to time update this Privacy Notice to reflect changes in our information handling and privacy practices or applicable law. We won’t reduce your rights under this Privacy Notice without your explicit consent. If we make any significant changes, we’ll provide prominent notice by posting a notice on the Education Portals and notifying you by email (using the email address you provided) within 30 days before the change takes effect, so you can review and make sure you know about them.

We encourage you to review this Privacy Notice from time to time, to stay informed about our collection, use, and disclosure of personal information. If you don’t agree with any changes to the Privacy Notice, you may terminate your account.

By continuing to use the Education Portals and Services after the revised Privacy Notice has become effective, you acknowledge that you accept and agree to the current version of the Privacy Notice.

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