Last Updated September 15, 2022

At Zamio, we believe in the power of gamification to support children’s mental health. This Privacy Notice explains how Zamio, brought to you by Activate Potential LLC dba Zamio (“Zamio,” “us” or “we”), treats the information we collect from you and your child when you use the Zamio online gamified courses and content, visit zamio.co or our other online channels, or interact with us online or offline (collectively, our “Services”) and how you can exercise your privacy rights related to information about yourself or your child.

YOUR CONSENT TO OUR PRIVACY PRACTICES

Your child may only use Zamio’s Services if you consent our privacy practices as described in this Privacy Notice as the parent or legal guardian of a child who wants to use the Services (the child’s “Grownup”). If you do not agree with this Privacy Notice, do not use, or permit your child to use, our Services.

BY ACCESSING OR USING OUR SERVICES, YOU CONSENT TO THIS PRIVACY NOTICE AND OUR TERMS OF USE.OUR PROMISE TO YOU

At Zamio, our mission is to offer children a simple (and fun) way to sky-rocket their self-esteem. We understand that children need a secure and private environment to explore their confidence, resilience, and emotional intelligence. To your child’s mental wellness and achieve our mission, we offer this summary of our promise to you:

Zamio’s Services are private by default. Other users never have access to your account information. Zamio is committed to protecting children online. A child’s Grownup must register with Zamio and give prior consent before the child can use our ServicesYou can always control your information associated with your account and Grownups can always access and adjust their child’s information. Grownups are encouraged to talk to their children about online safety and set boundaries for using our Services. We only retain information for the period necessary to provide you and your child with the Services you select, and we securely delete information when we don’t need it any longer.Any statistics or reporting that we do is 100% anonymous. Zamio wants to hear from you! If you have questions about our privacy practices, please contact us at hello@zamio.co.This Privacy Notice is part of and governed by our Terms of Use. We may provide additional, separate notices to you about our privacy practices, each of which will be considered part of this Privacy Notice. Note that this Privacy Notice does not apply to any third-party platforms or services or to any third-party services linked or accessible from our Services.

KEEPING CHILDREN SAFE ONLINE

Zamio’s Services are designed to help children build confidence, resilience, and emotional intelligence through fun, interactive, and gamified online experiences. Zamio is committed to providing children with a safe online experience when using our Services. That is why we require a child’s Grownup to register with Zamio and give their prior consent before the child can use our Services. If your child uses our Services, you will always have visibility into their activities and options to access and make changes to the child’s information. Children should always check with their Grownups before sharing information online, and we encourage families to discuss guidelines for internet use.

GROWNUPS ARE RESPONSIBLE FOR MONITORING THEIR CHILD’S ACTIVITIES ON THE SERVICES.

Zamio will never knowingly collect Personal Data from a child under age 16 without their Grownup’s consent. If we discover that a child under 16 has submitted Personal Data to us without Grownup consent, we will delete their Personal Data from our systems. If you become aware of any unauthorized submission of information to Zamio, please contact us at hello@zamio.co.

DEFINING PERSONAL DATA

As used in this Privacy Notice, “Personal Data” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Data falls within certain categories, for example:Identifiers (e.g., name, email, telephone number, address, username); Sensitive Personal Data (e.g., government identification number; precise geolocation; racial or ethnic origin; religious beliefs; health information; contents messages when we are not the recipient; in some cases, information about a known child);Legally protected information (e.g., race, citizenship, marital status, sex);Employment-related information (e.g., current or past employment);Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);Biometrics (e.g., DNA, face/voice prints, health data) and audio, electronic, visual, thermal, or olfactory information;Inferences drawn from Personal Data to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, and aptitudes;Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies); andInternet or other similar activity (e.g., browsing history; content interactions). Information that is not protected as Personal Data includes publicly available information; aggregated information (meaning data summaries or reports with Personal Data removed); and anonymized information that cannot be linked back to an individual. Collecting and Using Personal Data

COLLECTION AND USE OF PERSONAL DATA

Collection and UseZamio only collects, uses, retains, and discloses Personal Data as reasonably necessary and proportionate to provide you with the Services, for purposes described in this Privacy Notice, or for other purposes that we disclose to you and are compatible with the context of how we collected the Personal Data. We collect your Personal Data (a) with your consent as informed by this Privacy Notice and freely given at the time you provide the information; (b) if we have a legitimate interest in doing so; or (c) as authorized or required by law. Over the last 12 months, we have collected identifiers, commercial history, and internet and similar activity from: Grownup registration, with consent. Before your child can use our Services, you must register with Zamio as the child’s Grownup and create an account with your name, email address, and phone number. Zamio collect this information with your consent, and we use it to administer your account and to provide you and your child with access to the Services. We may also use this information to communicate with you about your or your child’s use of the Services and to analyze usage trends. Child registration, with consent. Once your Grownup account is created, your child can register for access to the Services through your account. Zamio only collects the child’s name or username, and we collect and track data from your child’s use of the Services. A Grownup can access, update, or delete their child’s Personal Data at any time, and Grownups always have the option to revoke consent or restrict the child’s access to the Services. Your communications with Zamio. We will collect your name and email if you contact us by any means, whether to inquire about our Services, sign up for our email newsletters, for customer service, or for another purpose. We may also ask for other information as necessary to respond to your inquiry. If you choose to complete a survey or enter a giveaway, we will also collect any information you include in your responses. We use this information for the purposes stated at the time of collection, to provide you with our Services, and to communicate with you or send you direct marketing communications in compliance with law.Your Interactions with the Services. Zamio uses cookies and related technologies to automatically collect data from your interactions with our Services. Some of the data we collect may be protected as Personal Data. For example, we may collect data about your (i) device information (e.g., IP address, operating system, browser type, device ID, language, mobile network information, caller ID); (ii) content engagement or online traffic data; or (iii) stored information (e.g., metadata). We use this information to facilitate your use of certain features, analyze trends, provide and improve our Services, and detect security incidents. Your Subscription Payment. Zamio does not collect or maintain any payment information. We use PCI-DSS compliant payment processors to process all subscription payments and other purchases on the Services. Your payments are also subject to our payment processor’s privacy practices and terms of use. Zamio never sees your payment information, and we do not process your transactions.We will not collect additional categories of Personal Data or use already collected Personal Data for purposes that are materially different, unrelated or not reasonably necessary or compatible with the original purpose without notice and consent to you as required by law. In addition to the specific uses described above, Zamio reserves the right to use the Personal Data collected to: (i) protect your privacy and enforce this Privacy Notice; (ii) comply with a law, regulation, legal process or court order; (iii) monitor your compliance with any of your agreements with us; (iv) if we believe it is necessary, to identify, contact or bring legal action against persons or entities who may be causing injury to you, to Zamio, or to others; or (v) fulfill any other purpose to which you consent.

ZAMIO USES COOKIES

Zamio uses cookies on the Services for functionality, analytics, security, and marketing purposes. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your browser. Session cookies allow our systems to uniquely identify you during a session or while you are logged in. They exist only during an online session and disappear from your device when you close your browser or turn off your device. Persistent cookies track aggregate and statistical information about user activity, and display advertising on sites provided by other entities. These cookies remain on your device after you have closed your browser or turned off your device.We use cookies to recognize your device and to store your preferences. Some third-party cookies allow us to collect information about your online activities over time and across third-party websites. The cookies we use on the Services include:Necessary cookies including Onboardme.io and Xperiencify other cookies that are essential for the Services to function.Functionality cookies like Wix & Xperiencify and other cookies that provide specific functionality on the Services. Analytics cookies such as Xperiencify and Onbordme.io to track and analyze use and performance of the Services.Marketing cookies from Google & Facebook.Most web browsers automatically accept cookies. If you prefer, you can edit your browser options to block or disable cookies. You can also adjust your browser settings to notify you when you are sent a cookie. Most browsers offer a Help tool that will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. You can also install third-party plugins to control cookie behavior.

RETENTION OF PERSONAL DATA

Zamio only retains Personal Data for the minimum period necessary to provide our Services or achieve our business goals. For example, we will retain a Grownup and their child’s Personal Data as long as the Grown Up's account remains active. Zamio reserves the right to retain data for longer periods as required by law or court order or if doing so is critical to our business, however Zamio securely deletes data at the conclusion of the Grown Up’s account being deleted.

DISCLOSURES OF PERSONAL DATA

Zamio will only disclose Personal Data to the third parties as described in this section, with your permission, or as required by law. In the last 12 months, we have disclosed Personal Data for a business purpose to: Our Service Providers. Zamio relies on trusted third party service providers for certain features of the Services, such as website and digital course hosting platforms, email and data hosting services, analytics services, and payment processors. Our service providers may have access to Personal Data as needed to perform their contractual obligations to us. We prohibit our service providers from selling or disclosing the Personal Data we provide, and we require all service providers to maintain confidentiality standards and appropriate technical and organizational measures to ensure the security of your Personal Data. Law enforcement and other governmental agencies, as permitted or required by law.Other third parties, as permitted by applicable law, for example: if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); to comply with a legal requirement or a court order; when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.Aggregated and Deidentified Information. Zamio reserves the right to share aggregated, anonymized, or de identified information about any individuals with non affiliated entities for marketing, advertising, research, or other purposes, without restriction.

YOUR OPTIONS AND CONTROLS

Zamio provides you with options to access and control how we collect and use your and your child’s Personal Data on our Services: Your Account. You can access, correct, update, or delete certain Personal Data on your account by logging in and saving your changes or adjusting your settings. If you require assistance or want to revoke a consent you previously gave us, please contact hello@zamio.co.Emails. We may send you informational or support emails related to your or our child’s use of our Services. Depending on your communication preferences, we may also send you marketing emails. If you do not wish to receive emails from us, you can unsubscribe or change your preferences via the links provided in the emails or send a request to hello@zamio.co. Please note that if you opt-out of marketing communications we may still send you service or support emails related to your account.Device Settings. You can control the data we collect through cookies and related technologies by adjusting your device settings or your cookie preferences on the website.Texting. If you provide your wireless number, you consent to Zamio sending you informational or service text messages. However, we will only send you marketing text messages if you opt-in to receive these notifications from us. For all text messages, the number of texts you receive will depend on the Services you use and the information you request from us. You can unsubscribe from our text messages by replying STOP or UNSUBSCRIBE to any of these text messages. Messaging and data charges may apply to any text message you receive or send. Please contact your wireless carrier if you have questions about messaging or data charges.Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests.Block Location Tracking. You can stop all collection of information by an app by uninstalling it. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an app by uninstalling the app or withdrawing your consent through your device settings.Privacy Requests. Depending on where you live, you may have specific rights under consumer privacy laws. Please see our supplemental notices below. If you wish to exercise your privacy rights, or if you want to express concerns, revoke your consent, lodge a complaint, or request information, please contact Zamio at hello@zamio.co.We only assist with or fulfill a privacy request when we have sufficient information to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Data, and to properly understand, evaluate, and respond to the request. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We endeavor to respond to privacy requests in accordance with the requirements of the law applicable to your jurisdiction. If we do not fulfill your request within the legally required timeline, you can appeal our response by contacting hello@zamio.co.

CONSENT TO CROSS-BORDER DATA TRANSFERS

Zamio is a United States company using technical infrastructure in the United States. If you access the Services from outside the United States, please be aware that your Personal Data may be transferred to, processed, stored, and used in the United States or other jurisdictions. When your information is moved from your home country to another country, the laws and rules that protect your Personal Data in the country to which your information is transferred may be different from those of the country where you live. For example, if your information is in the United States, it may be accessed by government authorities under United States law. Zamio is committed to transferring Personal Data using a lawful data transfer mechanism. However, we do not warrant that Zamio is appropriate or authorized for use in any other jurisdictions. Each Customer is solely responsible for determining whether their use of the Services complies with applicable laws. By allowing us to collect Personal Data about you, you consent to the transfer and processing of your Personal Data as described in this section.

ZAMIO’S DATA SECURITY

Zamio has implemented and maintains reasonable security measures to secure your Personal Data from accidental loss and unauthorized access, use, alteration, and disclosure. For example, Zamio will be limiting access to certain employees only, who are in charge of customer experience and customer engagement, not allowing any third party cookies or data scraping. Our security measures are appropriate to the volume, scope, and nature of the personal data processed and designed to meet our duty of care with respect to your Personal Data.Please bear in mind that submission of information over the Internet is never entirely secure. You are responsible for keeping your device access and login information confidential. You are also encouraged to install anti-virus and anti-malware software on your devices and keep all software updated to avoid security risks. We cannot guarantee the security of information you submit via our Services while it is in transit over the Internet, and any such submission is at your own risk.

NOTICE OF UNITED STATES CONSUMER PRIVACY RIGHTS

In the United States, consumer privacy rights are provided under state laws and federal laws provide protections relative to certain industries or data uses. This section provides informational notices for under privacy laws for states like California, Colorado, Connecticut, Nevada, Utah, Virginia, and other states that require companies to inform consumers about their privacy rights and provide a method to exercise those rights. Residents of states offering privacy protections (each a “Consumer”) may be entitled to some or all of the privacy rights listed below:Right to Access. You have the right to request confirmation that we have collected Personal Data about you and that we provide you with access to that Personal Data. If you submit an access request, we will provide you with copies of the requested pieces of Personal Data in a portable and readily usable format. Please note that Zamio may be prohibited by law from disclosing certain pieces of Personal Data, and we may be limited in the number or frequency of requests we must fulfill. Right to Correct. You have the right to request that we correct inaccurate Personal Data about you on our systems. If you become aware that the Personal Data that we hold about you is incorrect, or if your information changes, please inform us and we will update our records.Right to Delete. You have the right to request that we delete your Personal Data that we collected and retained, with certain exceptions. Zamio may permanently delete, deidentify, or aggregate the Personal Data in response to a request for deletion. No Selling or Sharing. Some states entitle consumers to opt-out of the sale or sharing of Personal Data or targeted advertising practices. Zamio does not sell your Personal Data or share your Personal Data with third parties for cross-contextual behavioral advertising purposes. If this changes in the future, we will update this Privacy Notice and provide you with a method to opt-out. No Profiling. You have the right to opt-out of automated profiling. Zamio does not process your Personal Data to evaluate, analyze, or predict your interests and preferences or otherwise use automated profiling to produce significant effects that concern you. If this changes in the future, we will update this Privacy Notice and provide you with a method to opt-out. Limited Use and Disclosure of Sensitive Personal Data. You have the right to opt-out or limit our use of your sensitive Personal Data. Zamio does not seek to collect sensitive Personal Data about any individual, and in no case do we disclose any sensitive Personal Data for the purpose of inferring characteristics about an individual or otherwise use sensitive Personal Data without consent. If this ever changes in the future, we will update this Privacy Notice and provide you with methods to opt-out or limit our use and disclosure of sensitive Personal Data. Right to Disclosure. You may request that we disclose information to you about our collection and use of your Personal Data, such as: (a) the categories of Personal Data we have collected about you; (b) the categories of sources for the Personal Data we have collected about you; (c) our business purpose for collecting, using, processing, sharing or selling that Personal Data, as applicable; (d) the categories of third parties with whom we share that Personal Data; and (e) if we sold or shared your Personal Data under the CCPA, two separate lists stating: (i) sales or sharing, identifying the Personal Data categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained. Certain laws may limit the number or frequency of requests we must fulfill. Right to Nondiscrimination. We will not discriminate against you for exercising your privacy rights. For example, unless permitted by law we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services; (iii) provide you a different level or quality of goods or services; (iv) retaliate against you as an employee, applicant for employment, or independent contractor for exercising your privacy rights; or (v) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under applicable privacy laws.Right to Disclosure of Marketing Information. California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California residents to request certain disclosures regarding Personal Data sharing with affiliates and/or third parties for marketing purposes.Consumers can exercise the rights provided under the laws applicable to them by submitting a Privacy Request, subject to applicable exceptions and limitations.

NOTICE OF EUROPEAN ECONOMIC AREA AND UNITED KINGDOM PRIVACY RIGHTS

This section provides the disclosures and notices required under the General Data Protection Regulation (“GDPR”) and its counterpart regulation applicable to residents of the United Kingdom. This section applies solely to residents of the European Economic Area (“EEA”) and the United Kingdom (“Data Subjects”). When serving our Customers, Zamio collects and processes Personal Data of Data Subjects as a controller. Data Subjects have the following rights over their Personal Data, subject to applicable limitations:Right to know how we process your Personal Data. We have set the required notices in this Privacy Notice. We may provide you with additional notices about other ways we process your Personal Data by sending you a notice via email or by another method. If you have questions or concerns, you can contact us any time at hello@zamio.co.Right to access your Personal Data. Upon request, we will provide you with a copy of your Personal Data and details about the types of Personal Data we process, why we process it, and any third parties we work with to collect Personal Data on our behalf. We may have one or more legally valid reasons to refuse your request in whole or in part, for example, to protect the rights of other individuals.Right to restrict processing of your Personal Data. You can request that we restrict the processing of your Personal Data if: (i) the data is inaccurate; (ii) the processing is unlawful; (iii) we no longer need the Personal Data; or (iv) you exercise your right to object.Right to rectify your Personal Data. If you become aware that the Personal Data that we hold about you is incorrect, or if your information changes, please inform us and we will update our records.Right to data portability. In some circumstances, we are required to provide your Personal Data to another organization at your request and in a structured, commonly used and machine-readable format.Right to erasure (a.k.a. the “right to be forgotten”). Upon your request, we must delete your Personal Data in certain circumstances and where required by law. This right is not absolute, and we may be entitled to retain and process your Personal Data despite your request. If you make this request, we balance certain legal, contractual, and business interests against your right to request the deletion of your Personal Data.Right to object to certain processing of your Personal Data. Upon your request, we will limit our processing of your Personal Data as you request in certain circumstances and where we are required to do so by law. Right not to be subject to automated decision-making. Zamio does not use automated decision-making to provide the Services. If this changes in the future, we will update this posting to describe our use of automated decision-making and your options to exercise your privacy rights related to your Personal Data processed using automated decision-making. Right to lodge a complaint with a supervisory authority. Data Subjects can submit requests, questions, or complaints to Zamio using the methods described under Privacy Requests. If, after contacting us, you feel a privacy issue has not been resolved, you have the right to file a complaint with a supervisory authority. We suggest the Data Protection Commissioner of Ireland.Data Subjects can exercise the rights provided under the laws applicable to them by submitting a Privacy Request, subject to applicable exceptions and limitations.

NOTICE OF CANADIAN PRIVACY RIGHTS

This section provides the disclosures and notices required under Canada’s Personal Data Protection and Electronic Documents Act (“PIPEDA”) and solely to residents of Canada where PIPEDA applies (“Canadian Consumers”). PIPEDA gives Canadian Consumers specific rights regarding Personal Data offering details on an identifiable person without the inclusion of name, title, telephone number, and business address of an employee of a business or organization. The rights afforded under PIPEDA are described below. Right to know why we collect, use, and distribute the Personal Data we process. We have set the required notices in this Privacy Notice. We may provide you with additional notices about other ways we process your Personal Data, such as by sending you a notice via email or by other means of communication.Right to expect us to collect, use, or disclose Personal Data responsibly and not for any other purpose other than which you consented. We set your expectations in this Privacy Notice and collect express or implied consent at various stages of collection or processing. If we collect or use your Personal Data based on your consent, we will also notify you of any changes and will request your further consent as needed. You may withdraw your consent at any time with reasonable notice by contacting us at hello@zamio.co.Right to accuracy of your Personal Data. We take steps to reasonably ensure that your Personal Data we are using is accurate. If you become aware that the Personal Data that we hold about you is incorrect, or if your information changes, please inform us and we will update our records.Right to access your Personal Data. Upon written request and identity authentication, we will provide you with your Personal Data under our control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We will make the information available within 30 days or provide written notice where additional time is required to fulfil the request. We may not be able to provide access to some or all of the Personal Data you request if limited by law or potential infringement of another’s privacy rights. If we must refuse an access request, we will notify you in writing, document the reasons for refusal, and outline further steps that are available to you.Canadian Consumers can exercise the rights provided under the laws applicable to them by submitting a Privacy Request, subject to applicable exceptions and limitations.

THIRD-PARTY SERVICES

You or your child may have the option to link from or access third-party services from Zamio’s Services. Please note that Zamio has no control over third-party websites, apps, devices, or systems, and you should exercise caution when deciding to disclose your Personal Data.

UPDATES

Zamio may update this Privacy Notice from time to time. We will notify you about material changes to this Privacy Notice by email or by other measures that are appropriate to provide you with notice. We will collect your consent to these changes to the extent required by applicable law.