This Policy outlines our practices for collection, use, disclosure and parental consent for the personal information of children (users under the age of 13 in the US, or the relevant age of digital consent as otherwise defined by applicable laws).
We comply with applicable laws, including the U.S. COPPA and Kenya’s Data Protection Act, which require special protection for children’s personal information. For more information about COPPA and general tips about protecting Children’s online privacy, please visit OnGuard Online.
1. Information we collect
We collect information outlined in the “Collection of Information” section of this policy directly from parents or guardians (“Parents”) during sign-up. Additional information may be supplied by children as they use the product.
Parent-Supplied Information: We use Parent-Supplied Information in order to provide Parents and their children with custom tailored services, specifically an interactive, personal AI tutor, that adapts to a child’s interests and skill level.
If Individual Service Improvement is Enabled: Audio Recordings may be used to enhance and improve the Services specifically for your child, including:
- In-app reading support functions such as playback features and real time word accuracy analysis.
- Analytics to measure reading proficiency and learning progress such as analysis of words spoken per minute or identification of the most common mistakes, as well as adapting the learning experience to your child’s interests.
- Customizations to improve Ello App’s performance for your child, such as training Ello’s models and algorithms to better pick up your child’s speech patterns.
If General Service Improvement is Enabled: This requires explicit verifiable parental consent upon sign-up, and you can withdraw this consent. Audio Recordings may be used to improve our Services generally, including training our models. Unless the setting is enabled, we shall not use Audio Recordings for other purposes without a Parent’s express written consent.
Miscellaneous: All information pertaining to your child is treated as part of your personal information and may be shared as described in the “Who we share your personal information with” section below or pursuant to a Parent’s instructions.
2. Parental Consent
We obtain verifiable parental consent before collecting any child’s personal information, typically through a credit card transaction during subscription. In countries where the Service may be provided for free, we will collect parental consent through other means that comply with local jurisdictions. If consent is not provided within a reasonable time after notice, we will delete your online contact information from our records. If consent is not given, we will not process your child’s personal information and your child will not be allowed to use our Services.
3. Parental Rights and Controls
Parents may contact us at support@ello.com at any time to:
- Withdraw consent for further collection or processing of their child’s data.
- Request access, correction or deletion of their child’s personal information. Please note that a request to delete records may lead to termination of an account, membership, or other service.
5. Data Protection for Children
We apply heightened security measures for children’s data. We do not use children’s data for marketing or share it with third parties for advertising purposes. We delete children’s personal data when it is no longer needed for the purpose for which it was collected or when consent is withdrawn.
6. Is Ello a safe experience?
We are committed to providing a safe, age-appropriate experience. We aim to ensure any outbound links on the Services intended for users under 18 years are age-appropriate.
