This Privacy Policy (the “Policy”) forms an integral part of the Novakid General Terms and Conditions and the Terms of Service. It explains how Novakid Inc., a Delaware corporation, 548 Market St 8291, San Francisco, CA 94104-5401, USA (“Novakid”, “Company”, “we”, or “us”), together with its affiliates and authorized third parties, collects, stores, uses, and otherwise processes personal data.

This Policy applies to all natural persons who interact with Novakid in connection with our services, including but not limited to:

• Educational services, such as online classes (“Online Classes”), AI-powered features and tools (“AI Tools”), and other interactive tools and related educational activities;
• Website located at novakidschool.com and its subdomains (the “Website”);
• Novakid’s mobile application (“Application”);
• Account registration for your child on the Website or Application (“Registration”) and virtual chatting with Novakid (“Chatting”), online-streaming activities related to our educational services (“Streaming Activities”), and other integrated services provided by Novakid.

Information regarding the collection and processing of personal data of individuals who apply to Novakid as teachers is provided in and governed by a separate Teacher Privacy Policy.

Novakid collects and processes personal data in accordance with applicable data protection laws, including but not limited to:

(i) European Union Residents. Regulation (EU) 2016/679 of the European Parliament and of the Council (“GDPR”), including the guidelines and recommendations issued by the Article 29 Working Party (“WP29”) and of the European Data Protection Board (“EDPB”).

(ii) Brazilian Residents. Brazil’s Law No. 13,709, of August 14, 2018 on the Brazilian General Data Protection Act (in Portuguese: Lei Geral de Proteção de Dados) (“LGPD”).

(iii) United States Residents. All applicable federal and state privacy laws, as it further detailed in Company’s Privacy Notice for US Residents.

(iv) Residents of the other jurisdictions. For the collection and processing of personal data of individuals residing in other countries, where the personal data regulations are in place and apply to the foreign entities, Novakid is in compliance with those regulations as well.

The Company acts as the data controller for all personal data collected or processed through its services. This includes personal data uploaded, provided, or otherwise disclosed when using our services or interacting with us via any device.

Before you or your child starts using Novakid services, we aim to ensure you fully understand how Novakid collects and uses your personal information and what rights are available for you and your child in relation to personal data, including in connection with AI-powered features described herein. If you have any concerns about how your personal data is used as described in this Policy, please contact us using the information provided in Section 14 before deciding whether to continue using services.

Please read and make sure you understand this Policy. If you do not agree with this Policy or our practices, you may not use our Website or our services.

1. DEFINITIONS

The following definitions are determined according to the GDPR:

Personal data: shall mean any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Consent: shall mean any freely given, specific, informed and unambiguous indication of the will of the Data Subject by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

Data controller: shall mean the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

Data processing: shall mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Data processor: shall mean a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

Third party: shall mean a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;

Personal data breach: shall mean a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;

Recipient: shall mean a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with European Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

Supervisory authority: shall mean one or more independent public authorities provided by each Member State which is responsible for monitoring the application of the GDPR in order to protect the fundamental rights and freedoms of natural persons in relation to processing and to facilitate the free flow of personal data within the European Union;

Supervisory authority concerned: shall mean a supervisory authority which is concerned by the processing of personal data because: (a) the controller or processor is established on the territory of the Member State of that supervisory authority; (b) data subjects residing in the Member State of that supervisory authority are substantially affected or likely to be substantially affected by the processing; or (c) a complaint has been lodged with that supervisory authority.

2. WHAT INFORMATION DOES NOVAKID COLLECT?

The information we collect from users helps Novakid personalize and improve the services, enable account creation, and provide information about our services. We may collect the following types of information from you:

2.1 Information you provide to us:

2.1.1 At Registration:

When you register on our Website or Application, we collect the following personal data:

• Full name,
• E-mail address,
• Phone number.

Please note that the e-mail address provided does not require the inclusion of personal data, such as your name. You may choose any e-mail address that does not reveal your identity.

After Registration, you must add the following personal data to your Novakid Account in order to use our services:

• Your children’s data (name, age, gender).

2.1.2 While Chatting:

We collect the following personal data uploaded during Chatting with Novakid on the Website or via other messaging platforms (e.g., WhatsApp) when contacting Novakid support:

• E-mail address,
• Any other personal information provided by you during Chatting.

If you choose to contact us through WhatsApp, we will process the personal data you provide in your messages. Please note that WhatsApp is a third-party service with its own privacy practices, and your use of WhatsApp is subject to its applicable privacy policy and terms.

2.1.3 When participating in Online Classes:

We collect the following personal data uploaded during Online Classes:

• Video (including audio) of the participants of Online Classes,
• Details your child discloses about family members (e.g., parents, siblings and extended family),
• Homework or any educational progress submitted via the Website,
• Attendance records,
• Level of proficiency in the English language,
• Any other personal data shared directly or indirectly during Online Classes (including but not limited to personal information of third parties, racial or ethnic origin, religion or beliefs).

2.1.4 When you provide data voluntarily:

We may collect the information that you provide on a voluntary basis for participating in contests, projects, or promotional campaigns organized by Novakid, sending feedback or requests about the services and/or Application, or taking part in opinion polls, surveys, or research activities. Depending on the activity, the personal data may include, but is not limited to:

• E-mail address,
• Phone number,
• Feedback, comments, or opinions,
• Any other personal information provided by you voluntarily in the course of your communication with us.

2.1.5 When collecting your inquiries:

We collect the following personal data when you sign up for an account on the Website for uploading your inquiries and other questions:

• Full name,
• E-mail address,
• Username,
• Profile photo,
• Any other personal information submitted by you voluntarily in connection with your questions and inquiries (e.g., images, audio files, video files, text files, etc. that are directly connected to your interaction with the Website).

Please note that by uploading your inquiries or questions, along with any attached files, you acknowledge and agree to the potential publication of these inquiries and related materials on the Website, and that the associated data will be made available to the other users.

2.1.6 When using AI Tools

When you use the AI-powered tools integrated into our Website or Application, or customer support services, we may collect:

• The content of your inputs and prompts, including audio recordings,
• Any personal details voluntarily provided in connection with the use of AI Tools (e.g., personal preferences or any other data),
• Metadata associated with AI interactions (e.g., session start and end time, duration).

AI Tools are not used for profiling or automated decision-making producing legal or similarly significant effects.

2.1.7 When Interacting with us on Social Networks

When you interact with us through our official pages on social networks (including, but not limited to Facebook, Instagram, YouTube, and other similar platforms), we may collect and process the following data:

• The content of your communications with us (such as comments, messages, reactions, posts, or other interactions),
• Any personal details voluntarily provided by you in your communications with us, which may include your name, contact details, preferences, or other identifying information.

2.1.8 When Participating in Calls

When you participate in customer support calls, sales calls, or other mobile calls organized by Novakid, we may collect and process the following personal data:

• Voice recordings,
• Audio content of the conversation,
• Any personal information voluntarily provided by you during the call.

2.1.9 When a manager participates in Online Classes

In certain cases, a customer support manager may join an Online Class for a limited period of time in order to introduce and explain features of the Website and services, provide relevant assistance and answer questions, and provide information about and recommend our products and services, and discuss available plans and offers. During such participation, we may collect the following personal data:

• Full name,
• Audio and video data of participants during the Online Class,
• Information voluntarily provided by you in connection with your interest in, or potential purchase of, Novakid services,
• Questions, comments, or feedback provided during the Online Class.

Please note, participation of the manager does not affect access to or ability to participate in the Online Class. Where applicable, you may object to such participation as described in Section 11 of this Policy.

2.1.10 When participating in the Referral Program or our Contests

When you take part in the Novakid Referral Program, we process the personal data needed to operate the program, including your account and referral link identifiers, referral attribution data, records of qualifying purchases and rewards, and, where we are required to withhold or report tax on a reward, the tax information reasonably necessary for that purpose. We do not disclose the personal data of a referred person to the referrer. When you take part in a Novakid contest, we process the data you provide to enter and to receive a prize (such as your e-mail address and any materials you submit) and, if you win, we may publish your name and information about your win, together with the materials you submitted, on our Website and social media where you have consented. Where submitted materials relate to a child (for example, a photo or video of the entrant’s own child), we rely on the consent of the child’s statutory representative to the processing, and, where applicable, publication of the child’s image and related information.

2.2 Information Collected Automatically:

We receive and store certain types of technical information whenever you interact with our Website, services or Application.

2.2.1 When using the Website

Novakid automatically receives and records information on our server logs from your browser, including your IP address, unique device identifier, browser characteristics, domain and other system settings, search queries, device characteristics, operating system type, language preferences, referring URLs, actions taken on our Website, page requested, content consumed (e.g., viewed, uploaded, and shared), dates and times of Website visits, gender, age range, approximate location and other information associated with other files stored on your device.

2.2.2 When using the Application

Novakid may automatically collect certain technical, diagnostic, usage and interaction information, including application and technical information, analytics and product-usage information, communication and engagement information, crash and diagnostic information, and information relating to your use of the Application. We may also automatically collect and record certain information in our server logs when you or your child access or use the Application, including the date and time of access, activities performed in the Application, time spent using the Application and frequency of use, content accessed, search terms used, and links or other elements clicked or tapped.

3. WHAT ABOUT COOKIES?

We use cookies and similar technologies to improve and optimize the Website. A “cookie” is a small text file which is sent to the browser of the visitor and stored on the hard drive of the visitor. Cookies don’t damage the visitor’s computer. Some “cookies” are necessary for the Website to function, while others help us analyze usage and deliver personalized content or marketing. For further information, including the types of cookies we use, their purposes, and how to manage them, please read our Cookie Policy.

4. HOW DOES NOVAKID USE THE COLLECTED INFORMATION?

We process personal data related to you and your child for the specified and explicit purposes. For each processing activity, Novakid determines the applicable legal basis, taking into account the nature and purpose of the processing:

4.1 Processing necessary for the performance of a contract

We process the following personal data where such processing is necessary for the performance of our contract with you for the product and service fulfillment:

• Full name,
• Children’s name, age, and gender,
• E-mail address and phone number,
• Communication data necessary for the service delivery (responding to service-related questions, technical support, operational updates),
• Educational and service-related information (attendance, homework, level of proficiency).

The above obligatory or optional personal data you provide is used for purposes such as fulfilling the obligations defined in the General Terms and Conditions or Terms of Service and providing the service, responding to your questions, requests relating to the service, customizing the visualized content, communicating with you about operational matters, service updates, sales offers relating to special services and new features, and responding to problems or technical issues relating to our services.

4.2 Processing necessary for our legitimate interests

We process personal data where such processing is necessary for the purposes of our legitimate interest, provided that such interests are not overridden by your or your child’s interests, rights and freedoms. 

Depending on the specific processing activity, our legitimate interest may include enhancing experiences through customer support services and product improvements, maintaining and developing our customer relationships, protecting our legal rights, ensuring the quality and effectiveness of our products and services, preventing fraud and misuse, maintaining and improving the quality, security, and usability of our Website and Platform, and sending marketing communications about our services, special offers, and new features, where permitted by applicable law, conducting research and surveys, analyzing the use of our services, and ensuring effective service delivery and quality assurance.

We also rely on our legitimate interest to operate the referral program, to verify referral attribution and eligibility, and to detect and prevent referral fraud and abuse, including through automated checks. Where such checks materially affect a referral reward, you may request review by a member of our staff.

The following personal data is processed:

• Full name,
• Email address,
• Phone number,
• Usage data and analytics,
• Video (including audio) of the participants of Online Classes,
• Technical and device data (e.g., device and browser identifiers and characteristics),
• IP address and approximate location,
• Referring and destination URLs,
• Referral attribution data, records of qualifying purchases and rewards,
• Session recordings,
• Pages and content viewed or interacted with,
• Aggregated and directly provided feedback data,
• Recording of customer support calls and sales calls,
• Other technical and usage information reasonably necessary for the purposes described above.

The users always have the right to object to this processing. However, objecting to such data processing might affect Novakid’s ability to carry out tasks above for the benefit of the user.

4.3 Processing necessary for compliance with legal obligations

We process personal data where necessary to comply with our legal obligations, including to prevent fraudulent transactions, assist law enforcement, respond to lawful requests, such as subpoenas, and meet tax, accounting, or other statutory record-keeping requirements. 

Where the law requires us to retain certain personal data, we will retain it only for the period required by the applicable laws or regulatory obligations. 

4.4 Processing based on consent

Where required by applicable law, we process personal data on the basis of your consent. Depending on the specific processing activity, consent may cover the collection, use, analysis and publication of user feedback, testimonials and reviews, participation in our events, surveys or research activities where consent is required, the use of non-essential cookies and similar tracking technologies, receiving newsletters and other marketing communications. Where you take part in our contests, your consent may also cover the publication of your name and of information about your win, and of the materials you submit, on our Website and social media; where a submission relates to a child, we rely on the consent of the child’s statutory representative.

You may withdraw your consent at any time by using the relevant settings, unsubscribe mechanism or other means made available by Novakid.

4.5 We apply data minimization and purpose limitation principles and process only the information reasonably necessary for the relevant purpose. Where it is feasible, we use aggregated, anonymized or pseudonymized information for analytics and statistical purposes. We do not collect personal data in advance and store it for potential future purposes unless required or permitted by the applicable laws. We use analytics, marketing and other third-party service providers to operate and improve the Website and services. Details of the specific third-party technologies and providers, including cookies and SDKs, are set out in our Cookie Policy.

4.6 Data integrity and purpose limitation: Novakid will only collect and retain personal data which is relevant to the purposes for which the data is collected, and we will not use it in a way that is incompatible with such purposes unless such use has been subsequently authorized by you. We will take reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete, and current. We may occasionally contact you to determine that your data is still accurate and current. To secure your personal information processed, we save your personal information to backup archives every 24 hours.

4.7 Novakid may use AI-powered Tools in a limited, purpose-specific and controlled manner to support platform functionality, security, improvement of its services and quality assurance. Depending on the specific processing activity, Novakid will rely on an applicable legal basis under GDPR, including its legitimate interests. We may use AI-powered Tools to transcribe customer support calls or sales calls solely for the purpose of quality assurance, service improvement, internal analytics, and operational improvement. We do not use AI-generated transcription data for profiling within the meaning of Article 4(4) GDPR. We do not use such transcripts to make automated decisions within the meaning of Article 22 GDPR. Where any AI-powered processing requires consent or another specific legal basis under applicable law, Novakid will obtain or rely on such legal basis accordingly.

5. HOW LONG WE RETAIN YOUR PERSONAL DATA?

We will retain your personal data for so long as it is needed to fulfill the purposes outlined in this Policy or until you withdraw your consent, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements, further for the establishment, exercise or defense of legal claims).

When we have no longer or no legal basis to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. WILL NOVAKID SHARE ANY OF THE INFORMATION IT RECEIVES?

6.1 Information about our users is an integral part of our business, and we may share such information with our affiliated entities. Except as expressly described below, we neither rent nor sell your information to other people or nonaffiliated companies unless we have your permission.

6.2 Novakid shall not ensure access for a third party to personal data provided by you without your prior consent, except in cases when data transfer is necessary for the performance of the contract or for enforcing Novakid’s legitimate interest or prescribed by law.

6.3 Every teacher providing services to Novakid is considered a data processor according to the regulations of the GDPR. The teachers have access only to the personal data of the children they are teaching in order to minimize the processing of personal data.

6.4 Novakid may share certain personal information with third-party vendors in the EU or in third countries that may include:

• Payment service providers,
• Cloud service providers,
• Software development tools and analytics service providers,
• Marketing partners,
• Customer support services providers,
• SMS service providers,
• Prize fulfillment and reward providers,
• Learning services providers,
• AI and Technology service providers,
• Professional advisers, including consultants, accountants, auditors, solicitors.

Novakid may also share your information with public authorities, courts, or government representatives as necessary in accordance with applicable laws and regulations.

We will require that these third parties maintain at least the same technical and organizational measures of data protection and confidentiality. Those third parties will never use your personal information for any other purpose except to provide services in connection with the Website and our services.

6.5 We may disclose your personal data to some US companies, in particular to Stripe Inc., Intercom Inc. and Google LLC, for the purpose of providing services to you. We take steps to ensure adequate safeguards are in place to protect your data; that includes implementing the European Commission’s Standard Contractual Clauses for transfers of personal data between these third-party service providers and partners.

6.6 We only transfer personal data collected from individuals located within the EU only where the European Commission has adopted an adequacy decision for the destination country, or strictly under data processing agreements (DPA) or Standard Contractual Clauses (SCCs) approved by the European Commission. In all these cases, we ensure that personal data is protected by appropriate technical and organizational measures and that processing is carried out in accordance with the GDPR.

6.7 Google User Data. Some Novakid features may let you connect your Google account, in particular, connecting Google Calendar. When you connect a Google account, we access the following Google user data through Google API Services (including Google Workspace APIs), strictly with your consent and limited to the scopes shown on the Google consent screen. This data is used solely to provide the connected feature (e.g., displaying your class schedule alongside your calendar) and is not processed by, or shared with, any AI or machine-learning model.

The use of raw or derived user data received from Workspace APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Such data is not used to serve advertisements and is not sold, transferred, or disclosed to third parties, except as necessary to (a) provide or improve the user-facing features of the application, (b) comply with applicable law, or (c) with your consent.

7. IS INFORMATION ABOUT ME SECURE?

We take commercially reasonable measures to protect all collected information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Please understand that you can help keep your information secure by choosing and protecting your password appropriately, not sharing your password, and preventing others from using your computer. Please understand that no security system is perfect and, as such, we cannot guarantee the security of the Website, or that your information won’t be intercepted while being transmitted to us. If we learn of a security system breach, then we may either post a notice, or attempt to notify you by email and will take reasonable steps to remedy the breach.

8. LINKS TO THIRD-PARTIES

On our Website we can embed links to third-party websites. It must be understood that when you click on any of these links or use their widgets, any personal data you provide will be protected under the third-party policies and terms. We have no control and responsibility for services, privacy policies, or terms of any third-party websites and/or services.

9. SOCIAL NETWORK INTEGRATIONS

If you choose to use a third-party platform or social network to access or register an account on the Website or Application, this third party may provide your personal data to us if you so allow. These platforms and/or social networks are not controlled by or affiliated with Novakid. Accordingly, we advise you to review the applicable privacy policies and terms of use of those platforms or social networks carefully in order to understand how they process your personal data and what information might be shared with us.

At any time, you may make changes to the data that these third parties share with us by changing your settings for these platforms or social networks, or stop allowing the Website or Application to interact with those platforms or social networks.

10. CHILDREN’S PRIVACY

10.1 Novakid is committed to protecting the privacy of children who use our services including our Website and Application.

This Policy and Novakid’s privacy practices are in accordance with the United States’ Children’s Online Privacy Protection Act of 1998 (“COPPA”) as well as the Council of Europe’s Recommendation CM/Rec(2018)7 of the Committee of Ministers to member States on Guidelines to respect, protect and fulfill the rights of the child in the digital environment (“Guidelines”).

For information on how to protect your child’s privacy online, please make sure to read the following documents before Registering on the Website:

• The Federal Trade Commission’s guidelines on Protecting Your Child’s Privacy Online,
• UNESCO’s guidance for students, teachers and parents on personal data and privacy protection in online learning.

10.2 At Registration, Novakid obtains the consent of the statutory representative for collecting the personal data of minors. Novakid asks for the phone number and e-mail of the statutory representative to make sure that no child registers on the Website or Application. Novakid does not collect personal information directly from children at Registration. If we learn that we have collected personal information directly from a child under 16 (sixteen) without the consent of their statutory representative, we will take steps to delete such information from our files as soon as possible. If you are aware of anyone under 16 (sixteen) registered on the Website, please contact us at policy@novakidschool.com.

10.3 At any time, you can withdraw your consent to Novakid collecting further personal information from your child and can request that we delete the personal information we have collected in connection with you or your child from our records. You can request the deletion of your data by contacting Novakid via the chat services after you log in or at policy@novakidschool.com. Please keep in mind that a request to delete records may lead to termination of your Account, which disables the accessibility of Online Classes in the future.

10.4 As your and your child’s personal data are processed by the teachers of Novakid, we have concluded a data processing contract with them in order to prevent fraudulent or inappropriate activities as well as to regulate the teacher’s data processing activities during the provision of our Services. If you think that a teacher steps over legal and/or ethical limitations during the data processing or he or she processes your data incorrectly or unlawfully, please contact us at policy@novakidschool.com.

11. YOU AND YOUR CHILD’S PRIVACY RIGHTS

11.1 Access and Retention:

If you have an account registered on the Website or through the Application, you can log in to view and update your account information. You have the right to obtain confirmation of whether or not we are processing personal data relating to you or your child, have communicated to you such data so that you could verify its accuracy and the lawfulness of the processing, and have the data corrected, amended or deleted where it is inaccurate or processed in violation of the GDPR.

We encourage you to contact us at policy@novakidschool.com with your questions or concerns, or to request edits to your and your child’s personal information, or to have it removed from our database. Requests to access, change, or remove any personal data you provided to us will be handled within 30 (thirty) days. Response time might be extended up to 90 (ninety) days where requests are complex or numerous. However, we will inform you in writing within 30 (thirty) days of the receipt of the request and explain why the extension is necessary.

11.2 Additional Rights for EU Territory:

If you are from the territory of the EU, you may have the right to exercise additional rights available to you under applicable laws, including:

(a) Right of Erasure: In certain circumstances, you may have a broader right to erasure of personal information that we hold about you – for example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for record-keeping purposes, to complete transactions or to comply with our legal obligations.

(b) Right to Object to Processing: You may have the right to request Novakid to stop processing your personal information and/or to stop sending you marketing communications.

(c) Right to Restrict Processing: You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is inaccurate or unlawfully held).

(d) Right to Data Portability: In certain circumstances, you may have the right to be provided with your personal information in a structured, machine-readable and commonly used format and to request that we transfer the personal information to another data controller without hindrance.

11.3 Additional Rights for Brazilian individuals

If you are a Brazilian individual, you have the following rights in addition to the rights described in Section 11.1 of this Policy:

(a) Right of erasure: If you exercise this right, we will respond to you immediately, or if that is not possible, we will send a reply to you to indicate the reasons of fact or law that prevent the immediate adoption of the measure. If we are not the data processors of the data you requested the erasure of – whenever possible – we will indicate who the processing agent is.

(b) Right to be informed: You have the right to obtain information about what types of processing we carry out on your personal information.

(c) Right of access: If you request the provision of your personal data processed by us, we will grant you access to such data within 15 (fifteen) days of your request, if the data requested is more than the simplified request version.

(d) Nondiscrimination: We do not process your data for unlawful or abusive discriminatory purposes. In certain circumstances, you have the right to request a review of our data processing, and the supervisory authority (the Brazilian National Authority for Protection of Data (hereinafter: “ANPD”) may carry out an audit to verify discriminatory aspects.

(e) Data portability: Your data might be transferred to another service or product supplier in accordance with the regulations of the ANPD and subject to commercial and industrial secrets.

You also have the right to complain to the ANPD about our collection and use of your personal data. For more information, please contact the ANPD.

11.4 Data protection officer

If you would like to exercise the rights included in Section 11 of this Policy, please contact our data protection officer (hereinafter “DPO”) at dpo@novakidschool.com or at 548 Market St 8291, San Francisco, CA 94104, USA. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.

For any complaints that we can’t resolve directly, please contact our European Representative, Weiszbart and Partners Law Firm (address: 1052 Budapest, Kristóf tér 3. III. flr., Hungary; e-mail address: weiszbartandpartners@gmail.com).

If you don’t agree with our decision, you have the right to an effective judicial remedy or to lodge a complaint with any European Data Protection Authority. You also have the right to complain to the EU Data Protection Authority about our collection and use of your personal data. For more information, please contact your local EU Data Protection Authority. The list of European National Data Protection Authorities can be found here.

12. MODIFICATIONS TO THIS POLICY

If our privacy practices change, we reserve the right to modify this Policy. We will post a modified version on the Website. So please review it regularly.

13. FOR THE USERS IN THE UNITED STATES

If you are a user residing in the USA, the Company’s Privacy Notice for US Residents applies to you. We will not share any personal data with third parties for their direct marketing purposes to the extent prohibited by applicable legislation. If our practices change, we will do so in accordance with applicable laws and will notify you in advance.

14. HOW TO CONTACT US

If you have any questions concerning this Policy or the services, please contact us at policy@novakidschool.com. You can also contact us at our office at 548 Market St 8291, San Francisco, CA 94104-5401, USA.