Privacy Policy

Effective: June 7, 2024

Introduction

IQClub, Inc. ("Company," “IQClass,” “we,” “us,” “our”) understands your concerns about how your and your child's Personal Data are handled and shared. Please carefully read our Privacy Policy to understand how we manage both your and your child’s Personal Data.

When you access the IQClass website or use any related pages, features, content, or applications offered periodically by Company (collectively referred to as the "Services"), or when you use any of our Services, you acknowledge and agree to the practices and policies outlined in this document. Furthermore, you consent to the collection, use, and sharing of your data as described in this Privacy Policy.

Your interaction with IQClass’s Services is always governed by our Terms of Use, which includes this Privacy Policy. Any undefined terms in this Policy are defined in the Terms of Use.

Scope of This Privacy Policy

This Privacy Policy describes our handling of Personal Data. The term “Personal Data” refers to information that identifies or can be linked to a specific individual. It encompasses what are commonly called “personally identifiable information” or “personal information” in legal terms, under relevant data protection laws.

The term "Personal Data" in this text refers exclusively to the Personal Data of individual Service users who are above the age of consent for children. The phrase "Children's Personal Data" refers solely to the Personal Data of users under the Age of Consent. General references to "data" or "information" are applicable to all users.

Our Company collects both Personal Data and Children’s Personal Data when either you or your Child under the Age of Consent utilizes the Services. Please note, this policy does not govern the activities of entities that the Company does not own or manage, or the actions of people not employed or directly overseen by the Company.

Should you have any inquiries regarding this privacy policy or the management of your Personal Data or Children's Personal Data, you are encouraged to contact us via email at [email protected].

How is children's Personal Data treated?

The Children's Online Privacy Protection Act (COPPA) mandates that online services obtain parental consent before they intentionally collect personally identifiable information from children under 13 years old. Similarly, the EU General Data Protection Regulation (GDPR) stipulates that data controllers must secure consent from parents or guardians for children under 16 before collecting and processing their Personal Data.

We refrain from deliberately gathering or soliciting Personal Data from any child under 13 years in the United States, or under 16 years in the European Economic Area or United Kingdom, referred to here as a "Child under the Age of Consent," without first acquiring verifiable parental consent ("Parental Consent"). We collect only the necessary data ("Required Information") to seek Parental Consent. This Required Information is used solely to obtain Parental Consent until such consent is given. Further details on Parental Consent can be found in the "Data about Children" section.

A Child under the Age of Consent must not register for the Services or disclose any Personal Data to us except the Required Information needed for us to obtain Parental Consent. Service interactions must occur through an account set up by a Parent who has provided Parental Consent.

If you suspect that a Child under the Age of Consent has provided us with Personal Data beyond what is required for obtaining Parental Consent, please reach out to us at [email protected]. We ensure minimal collection of Personal Data from Children under the Age of Consent, necessary only for their participation in the Services, and do not retain this data longer than needed for its intended purpose.

If you are the Parent of a Service user who is a Child under the Age of Consent, you may request at any time via [email protected] that we (a) cease collecting Personal Data from your child, (b) delete any previously collected Personal Data, or (c) cease sharing your child's Personal Data with third parties but continue collecting and using it for Service-related purposes as outlined.

If you are a child whose parent has signed up for the Service, be aware that your parent may access all associated account data, including progress reports and usage statistics from your activities within the Services.

What Personal Data Does Company Collect?

The Personal Data you supply is utilized to deliver the Services, respond to inquiries, send updates about products, and communicate with you regarding Company's offerings and promotions, including new items and special features. The Children's Personal Month you supply is used exclusively for creating a personal account, enabling access to progress reports that monitor your child's performance and development. Choosing not to provide certain information might limit your ability to use many of our special features.

You have the ability to review, alter, halt collection, or delete your Personal Data or, if you are a parent, your Child under the Age of Consent's Personal Data as specified below at any point by logging into your account and accessing options to edit your profile and/or account information.

If you are an educator or a school, by providing student information (“Student Data”) or other information to IQClass, you explicitly grant, and assert and warrant that you possess all the necessary rights to grant, IQClass a non-exclusive, royalty-free, worldwide license for the duration of the Agreement to use, transmit, distribute, modify, reproduce, display, and store the Student Data solely for (i) delivering the Services as envisioned by the Agreement, and as otherwise mentioned here, (ii) maintaining, supporting, evaluating, improving, and developing our products, applications, and services, and (iii) enforcing our rights under the Agreement.

We gather the following types of data from our customers:

Children’s Personal Data

Profile Information: We collect specific data such as screen name, age, and gender about children below the consent age from parents during account setup. For more details on the types of data we collect from these children, please refer to the table further below.

If you are an educator or school administrator, you may submit the full names of students to monitor their progress and identify them distinctly. Alternatively, you can opt to use a unique identifier other than the student’s name for this purpose. You also have the option to provide usernames and passwords for each student account.

Educators can also use a QR code based login for student access. This method involves students scanning a QR code with their device's camera. The QR code scan does not collect any images, videos, or personal data, focusing solely on reading the encoded information which lacks personal data.

Activity Data: We collect information on how children under the age of consent engage with our services, including their performance and activity in games and educational content. We use this data to send progress reports and to suggest games and activities tailored to their needs.

Voice Recordings: Children under the age of consent, or their parents, may record their voice while interacting with a digital book, helping in their reading learning process. This audio is stored locally on your device and isn't uploaded to our servers. It is also automatically erased when you turn to the next page of the book. Using the voice record feature is optional, and the device’s microphone can be disabled without hindering access to the digital books.

Parent al Consent: IQClass secures verified parental consent prior to gathering any personal data from children under the age of consent. If consent is not granted by the parent, we refrain from collecting, using, or disclosing any personal data pertaining to the child.

Contact and Payment Information

We gather various details such as your email address, account password, zip code, phone number, and payment details like credit card information - all crucial for delivering the Services. For educators or school administrators, we also collect your school's name to enable school-specific features and secure the integrity of our Services intended for educational use.

Parents and teachers have the option to register for the Services using their existing Facebook or Google accounts. If you opt to register this way, we receive your full name from the social network or Google that manages your account.

In addition to the above, you might provide further Personal Data when you reach out for product support or technical assistance, including alternative contact methods which we will use to respond to your inquiries and handle your requests. When utilized by an Educational Institution, student information could be accessible during customer support or troubleshooting scenarios. Personal Data such as Student Names, Teacher Email Addresses, and login times could be viewed by our Product Support Staff within our service.

Push Notifications

We may send practice reminders to parents and teachers via our mobile apps. These notifications are exclusively for adults and must be set up through the adult sections of our mobile apps. You have the option to unsubscribe from these notifications or adjust their frequency at any time through the app or your device settings.

Activity Data

We collect and store certain information each time you interact with or utilize our Services. Our company automatically logs details such as your IP address, type of browser, cookie specifics, and the requested pages on our servers.

Our Services utilize cookies and technologies like pixel tags, web beacons, clear GIFs, and JavaScript, collectively known as “Cookies”. These small data files are stored on your devices like computers, tablets, or smartphones when you access our Services. Information collected by us may be enhanced with data we receive from third parties, who may also set Cookies on your device(s). Currently, our Services do not accommodate “Do Not Track” signals from browsers due to our use of Cookies.

The data gathered through cookies and during your interaction with our Services are used for understanding user demographics; trending analysis; authentication and securing the Services; improving and personalizing your user experience; and overall enhancement and management of our Services.

This technology also enables us to know if you have opened an email from us, which assists in making our communications more relevant and useful. Should you wish to stop receiving emails from us, you can easily unsubscribe by following the instructions provided in the emails.

Advertising Our advertising campaigns are analytics-driven, utilizing technologies such as cookies to enhance performance. We do not display third-party ads nor use third-party cookies to trace Children Under the Age of Consent for advertising aims. Additionally, there is no targeted advertising using Student Data or Children’s Personal Data.
To learn more about our usage of Cookies, please visit our Cookie Policy.

Sources from Which the Company Collects Information

Categories of Personal Data Sources

We gather Personal Data from these categories of sources:

Yourself

Directly from you when:
- You register for an account or utilize our interactive services and tools.
- You provide information voluntarily in free-text format via our services or as responses in surveys or questionnaires.
- You communicate with us by email or through other contact methods.
Automatically when you use the Services:
- Through Cookies (as explained in the "Cookies" section).
- When using location-enabled browsers or downloading our mobile applications, we might collect data about your location and mobile device.
- Upon downloading and installing our applications or software, we collect information transmitted by your computing device to provide relevant Services, such as status information related to log-ins and updates.

Public Records

From governmental entities or other public sources.

Third Parties

Educators or School Administrators
- May provide student information such as names or identifiers for tracking educational progress and account management. They may also supply us with usernames and passwords for student accounts.
Vendors
- Analytic providers help analyze your interaction with our Services; other third parties assist in customer support.
- Some vendors collect information that helps us generate leads and build user profiles.
- Advertising Partners
  - These partners provide data about how you interact with our websites, apps, products, services, and marketing materials, aiding in promotional efforts.
- Social Networks
  - If you connect your social network accounts to our Services or log in through a third-party service, some information from those accounts may be shared with your account here.

How the Company Utilizes Collected Information

The Business or Commercial Reasons for Gathering Personal Data

Service Provision, Customization, and Enhancement
- Creating and managing your account or profile.
- Processing orders or transactions; handling billing.
- Delivering the products, services, or information you requested.
- Fulfilling the purpose for which the information was provided.
- Providing support and help for the Services.
- Enhancing the Services through testing, research, internal analytics, and product development.
- Customizing the Services and content based on user preferences.
- Ensuring fraud protection, security, and debugging.
- Addressing other business needs as mentioned at the time of collection or as outlined by relevant data privacy laws like the California Consumer Privacy Act (CCPA).
Marketing the Services
- Promoting and marketing the Services.
- Advertising our products and assessing and enhancing advertisement effectiveness.
Communication
- Addressing communications from you, contacting you when necessary or upon request, and providing information about IQClass or the Services.
- Sending emails and other communications that match your preferences or that might interest you, such as updates, new features, and promotional offers.
Fulfilling Legal Requirements and Enforcing Agreements
- Meeting our legal responsibilities under laws, regulations, court orders, or other legal procedures, such as for security incident prevention and investigative purposes.
- Safeguarding the rights, property or safety of you, IQClass, or others.
- Enforcing agreements with you.
- Addressing any assertions that a posting or other content infringes on third-party rights.
- Settling disputes.

We will not collect additional categories of Personal Data or use the Personal Data already collected for purposes that are substantially different, unrelated, or incompatible without notifying you.

Will the Company Share Any of the Information It Receives?

Your Personal Data and Children's Personal Data are crucial to our operations. We do not rent or sell your Personal Data or Children's Personal Data to anyone. We only share your Personal Data and Children's Personal Data as outlined below. Children's Personal Data is shared exclusively with service providers and never with any other third parties. Usage data, such as performance on tests and games available through our Services, is shared only in aggregate and anonymous forms that do not personally identify users. Furthermore, our platform does not provide chat rooms or community features where Children's Personal Data might be shared or posted publicly.

We use APIs from other companies and individuals to perform tasks on our behalf, which may involve sharing your Personal Data or Children's Personal Data to deliver products or services. Examples include sending billing receipts and weekly progress reports, or providing user support services. Unless specified otherwise, these third parties are not allowed to use your Personal Data or Children's Personal Data for any purpose other than completing the tasks assigned to them. We also ensure these companies commit to maintaining the confidentiality and security of the Personal Data shared with them. Should you have any privacy concerns about these third parties, please contact IQClass using the contact details provided at the bottom of this page, and we will address your inquiries.

Your information may be disclosed to the types of service providers and other parties listed in this section. For further details, please see the state-specific sections below.

Service Providers: These entities assist us in providing the Services or conduct business functions on our behalf, including:

Hosting, technology, and communication providers.
Security and fraud prevention consultants.
Customer support and service vendors.
Product fulfillment and delivery providers.
Payment processors, including our processing partner Stripe, Inc. (“Stripe”), who collects necessary payment card information to process payments. More details about Stripe’s handling of your Personal Data can be found in their privacy policy and terms of service.

Analytics Partners: These entities analyze web traffic or service usage and include:

Companies that monitor how users find or were directed to the Services.
Companies that observe user interactions with the Services.

Advertising Partners: These entities assist in marketing our services and providing tailored offers, including:

Advertising networks.
Marketing services providers.

Parties You Authorize, Access or Authenticate:

Third party services accessed through our services.
Social media platforms.
Other users you interact with through our Services.

Sharing with Affiliated Businesses

As IQClass expands or restructures, your information, including both Personal Data and Children’s Personal Data, may be disclosed to our affiliated entities such as parent companies, subsidiaries, joint venture partners, or other companies under our control. We will ensure these affiliates adhere to the usage guidelines for your information as stipulated in this Privacy Policy.

In cases where IQClass undergoes a merger, reorganization, dissolution, sale of assets, or similar events, your information may be passed on to our successors or asset purchasers. We commit to informing you via email and through a prominent notice on our website within thirty days of the transaction’s close about any changes in the ownership or usage of your Personal Data, and we will outline any available options regarding your Personal Data.

User Profiles

Children under the Age of Consent are prohibited from submitting or uploading personal contributions as outlined in our Terms of Use, and under no circumstances will such data be displayed to third parties via user profiles. Email addresses serve the purpose of managing user submissions and communication on our platform, but these addresses will not be disclosed to other users unless there is mutual consent within shared groups or invitations, or the user opts to display their email in their profile.

Promotional Offers

We may send you promotional offers on behalf of other entities without disclosing your name and address, ensuring that no promotions are directed towards child users. Should you prefer not to receive these offers, you can opt-out by unsubscribing via the provided email instructions, through our website’s account management tools, or by sending a request to [email protected].

Legal Obligations

We may need to share your Personal Data or Children’s Personal Data with third parties as part of legal processes as described in the “Meeting Legal Requirements and Enforcing Legal Terms” section of our data collection policies.

Protection of Company and Others

We may disclose Personal Data or Children's Personal Data if necessary to protect the rights, property, or safety of the Company, our employees, our users, or others. This includes sharing information for fraud protection and risk reduction purposes.

Data that is Not Personal Data

We may generate Anonymized Data by removing identifiers from Personal Data and Children’s Personal Data. This Anonymized Data may be used and shared with third parties for legitimate business purposes such as service analysis, improvement, and promotion, ensuring that such data sharing does not reveal user identity.

With Your Consent

Apart from the circumstances described, we will alert you when your Personal Data or Children’s Personal Data might be shared with third parties, and you will have the chance to stop such sharing.

Communication Choices

As long as you are utilizing the Services, we will send you email communications. These emails cover a range of topics, including new features and updates, performance reports, reminders, promotional events, and account-related information.

You have the option to opt-out of receiving emails through settings in your IQClass account or by clicking the unsubscribe links provided in the email communications. Please be aware that opting out of certain emails may affect our ability to deliver essential service updates, like performance reports detailing your child’s progress with the Services.

It's important to note that even after opting out, there are still some critical emails that you will receive as long as your account remains active. These include emails regarding payments and significant updates related to legal or security matters.

California Resident Rights

If you are a California resident, you are entitled to certain rights under this section. Refer to the “Exercising Your Rights under the State Privacy Laws” section provided below for guidance on how to exercise these rights. We might process Personal Data of our customers’ end users or employees as part of delivering services to our customers. If your Personal Data is being processed by us as a service provider, please contact the organization that initially collected your Personal Data to discuss your rights regarding this data.

In instances where this section conflicts with other sections of this Privacy Policy for California residents, the provisions that offer greater protection of Personal Data will prevail. If you have questions about this section or need clarification on whether the following rights apply to you, reach out to us at [email protected].

Access

You have the right to request information regarding our collection and use of your Personal Data during the previous 12 months. Upon request, we will provide:

Types of Personal Data we have gathered about you.
Sources from which the Personal Data was gathered.
Purpose for collecting or selling your Personal Data.
Third parties with whom your Personal Data has been shared.
Specific pieces of Personal Data collected about you.

We will also disclose the categories of Personal Data that have been shared with third parties for business purposes within the last year, and if sold, the types of buyers of such data.

Deletion

You can request the deletion of your Personal Data that we have collected. This right is limited by certain exceptions under the CCPA. For instance, we might need to keep your Personal Data to fulfill services or complete transactions requested by you. If your deletion request falls under these exceptions, it may be denied.

Correction

You are entitled to request the rectification of incorrect Personal Data we have about you. As per the CCPA, this right is subject to exceptions. For example, we might find that the data in question is accurate based on the circumstances around it. If your correction request is challenged by these exceptions, we may deny your request.

Personal Data Sales Opt-Out and Opt-In

We do not and have not sold your Personal Data in the last 12 months. We are unaware of any sales of Personal Data involving minors under the age of 16.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

Exercising your CCPA rights will not result in discrimination against you. We will not withhold services, vary prices, or reduce service quality if you exercise your rights under the CCPA.

Colorado Resident Rights

If you are a resident of Colorado, you possess specific rights granted by the Colorado Privacy Act ("CPa"). Detailed instructions on how to exercise these rights can be found in the “Exercising Your Rights under the State Privacy Laws” section below. Please be aware that these rights are subject to certain limitations and exceptions as outlined in the applicable law, which may allow or obligate us to refuse your request.

If any discrepancies arise between this specific section and other parts of this Privacy Policy for residents of Colorado, the provisions offering greater protection to Personal Data will prevail to the extent of the conflict. If you have any questions about this section or if the following rights pertain to you, please contact us at [email protected].

Access
You are entitled to confirm whether we are processing your Personal Data, and to access and obtain a copy of your Personal Yet Data provided in a machine-readable format, twice per calendar year, as long as this is technically feasible.

Correction
You have the right to amend any inaccuracies in your Personal Data, taking into account the nature of the data and the purposes for which we process your Personal Data.

Deletion
You may request the deletion of your Personal Data.

Personal Data Sales and Targeted Advertising Opt-Out
Currently, we do not sell or use your Personal Data for targeted advertising purposes as described under the CPA.

We also do not sell or use for targeted advertising purposes the Personal Data of children under the age of 13.

Profiling Opt-Out
Your Personal Data is not processed by us for 'Profiling' purposes to make 'Decisions', as these terms are defined under the CPA. 'Profiling' refers to any type of automated processing of personal data to assess various personal aspects related to an identifiable individual's economic situation, health, preferences, interests, reliability, behavior, location or movements. A 'Decision' refers to any conclusions that have Legal or Similarly Significant Effects Concerning a Consumer, as outlined by the CPA.

Consent or “Opt-in” Required and How to Withdraw
As previously mentioned, parental consent will be sought to collect or process certain types of Children’s Personal Data. If you wish to revoke your consent, please refer to the instructions provided in the “Exercising Your Rights under State Privacy Laws” section.

We Will Not Discriminate Against You
We pledge not to process your Personal Data in ways that violate any state and federal laws prohibiting consumer discrimination.

Connecticut Resident Rights

If you are a resident of Connecticut, you possess the rights outlined in the Connecticut Data Privacy Act ("CTDPA"). For details on how to assert these rights, refer to the "Exercising Your Rights" section below. Take note that these rights may be subject to constraints and exceptions as prescribed by law, which might allow or compel us to refuse your request.

In cases where a discrepancy exists between this section and other sections of this Privacy Policy for Connecticut residents, the language that offers greater protection to Personal Data will prevail. Should you have questions regarding this section’s applicability to you, kindly reach out to us at [email protected].

Access
You are entitled to confirm whether we are processing your Personal Data and to access the data we hold.

Correction
You can request correction of any inaccuracies in your Personal Data, appropriate to the nature of the data and our processing objectives.

Deletion
You have the right to request the deletion of Personal Data provided by you or collected about you.

Portability
You may request a copy of your Personal Data in a machine-readable format when processed automatically, where technically viable.

Personal Data Sales and Targeted Advertising Opt-Out
We currently do not sell or use your Personal Data for targeted advertising as defined under the CTDPA.

Profiling Opt-Out
We do not engage in "Profiling" your Personal Data as per the definitions of the CTDPA. "Profiling" refers to the automated processing of personal data to assess or predict personal aspects like economic status, health, preferences, interests, behavior, location, or movements of a person.

Consent or “Opt-in” Required and How to Withdraw
We require parental consent for collecting or processing certain Children's Personal Data. You may withdraw your consent by following the guidelines in the "Exercising Your Rights under State Privacy Laws" section.

We Will Not Discriminate Against You for Exercising Your Rights Under the CTDPA
We pledge not to discriminate against individuals who exercise their CTDPA rights. We will not deny you our services, offer different prices, or reduce the quality of services for asserting your rights under this regulation.

Utah Resident Rights

If you reside in Utah, you are entitled to specific rights under the Utah Consumer Privacy Act (UCPA). For guidance on how to exercise your rights, refer to the section titled "Exercising Your Rights under the State Privacy Laws" below. Note that there are certain conditions and exclusions under the applicable law, which may allow us or necessitate that we deny your request.

In case of any discrepancies between this section and other parts of this Privacy Policy for Utah residents, the provisions offering greater protection to Personal Data will prevail to the extent of the conflict. For inquiries regarding this section or to determine if the following rights apply to you, please contact us at [email protected].

Access
You can request confirmation on whether we are processing your Personal Data and if so, access your Personal Data.

Portability
You have the right to obtain a copy of your Personal Data in a format that is machine-readable, if it is technically feasible.

Deletion
You may request the deletion of your Personal data that you have supplied to us.

Opt-Out of Certain Processing Activities

Targeted Advertising:
We do not use your Personal Data for the purpose of targeted advertising.
Sale of Personal Data:
We do not currently sell your Personal Data as defined by the UCPa.
Processing of Sensitive Personal Data:
As previously noted, we will obtain Parental consent to collect or process certain types of Children's Personal Data. Should you choose to retract your consent, please refer to the instructions in the "Exercising Your Rights under State Privacy Laws" section.

We Will Not Discriminate Against You for Exercising Your Rights Under the UCPA
We commit not to discriminate against you for asserting your rights under the UCPA. Exercising your rights will not result in different prices or rates, denial of goods or services, or a reduced quality of goods or services.

Virginia Resident Rights

If you reside in Virginia, you possess rights as detailed in the Virginia Consumer Data Protection Act (VCDPA). For information on how to exercise these rights, reference the "Exercising Your Rights" section provided below. It's important to note that these rights are not absolute and are subject to certain limitations and exceptions as prescribed by law, which may allow or necessitate us to decline your request.

In cases of discrepancies between this section and other portions of this Privacy Policy, if you are a Virginia resident, the parts offering greater Personal Data protection will prevail in resolving the conflict. Should you have any inquiries regarding this section or need clarification on whether the following rights pertain to you, please reach out to us at [email protected].

Access

You can request confirmation on whether we are processing your Personal Data and gain access to the data if so.

Correction

You are entitled to amend inaccuracies in your Personal Data when such corrections are logically appropriate, considering the nature of the data and our processing objectives.

Portability

You can ask for a machine-readable copy of your Personal Data, provided it is technically feasible.

Deletion

You have the right to erase Personal Data that you have supplied to us or that we have acquired about you.

Consent or "Opt-in" Required and How to Withdraw

As mentioned earlier, we require parental consent to collect or process certain children's Personal Data. Instructions to withdraw your consent can be found in the "Exercising Your Rights under State Privacy Laws" section.

Opt-Out of Certain Processing Activities

Your Personal Data is not processed by us for targeted advertising purposes.
We do not currently sell your Personal Data, as defined under the VCDPA.
We do not currently use your Personal Data for profiling purposes.

To assert any of your rights regarding these specific processing activities, please see the instructions in the "Exercising Your Rights under State Privacy Laws" section.

We Will Not Discriminate Against You for Exercising Your Rights Under the VCDPA

We pledge not to discriminate against you for asserting your rights under the VCDPA. Exercising your rights will not result in denial of services, altered prices or rates, or reduced quality of services or goods from us.

Exercising Your Rights Under State Privacy Laws

To exercise your rights as outlined above, you, or your Authorized Agent if you are a resident of California, Colorado, or Connecticut, must send a request that (1) includes enough information for us to confirm your identity as the person whose Personal Data we have collected, and (2) clearly outlines the nature of your request to allow us to effectively review, evaluate, and respond. A request fulfilling these two criteria will be considered a “Valid Request.” We may not respond to requests failing to meet these criteria. We will use the Personal Data provided in a Valid Request solely to verify your identity and process your request. No account is necessary to make a Valid Request.

We aim to address your Valid Request within the legally mandated timeframe. We do not charge for processing a Valid Request unless it is deemed excessive, repetitive, or clearly unreasonable. If a fee is appropriate for your Valid Request, we will inform you about the fee and provide an explanation before fulfilling your request.

You can make a Valid Request through the following methods:

Email us at: [email protected].
Additionally, you may access some of your Personal Data through your account.

You are also allowed to designate an agent (an "Authorized Agent") to act on your behalf. You must give your Authorized Agent written permission to represent you, and we may request to see this permission when they submit a request on your behalf.

Appealing a Denial

If you reside in Colorado, Connecticut, or Virginia and we fail to act on your request within a reasonable timeframe, you may appeal our decision. Your appeal must (1) provide enough information that confirms you are the individual involved in the original request and (2) describe the foundation of your appeal. Note that your appeal rights are as stipulated by the CPA, CTDPA, or VCDPA, relevant to your state. We will address your appeal as swiftly as the law dictates. Appeals can be submitted through:

Email us at: [email protected] (include the title “[STATE OF RESIDENCE] Appeal”)

If your appeal is denied, you have the option to reach out to the Attorney General in your state via the following links: Virginia, Colorado, and Connecticut.

Other State Law Privacy Rights

California Resident Rights

In accordance with California Civil Code Sections 1798.83-1798.84, residents of California can contact us to prevent the sharing of their Personal Data with third parties for direct marketing purposes of those third parties. To make such a request, please reach out to us at [email protected].

Nevada Resident Rights

As a Nevada resident, you are permitted to opt-out of the sale of specific Personal Data to third parties who may license or sell this information. To exercise this right, please contact us at [email protected] with “Nevada Do Not Sell Request” in the subject line, and include your name and the email address associated with your account in your request. It is important to note that we currently do not sell Personal Data as defined in the Nevada Revised Statutes Chapter 603A.

Changes to this Privacy Policy

The Company may update this Privacy Policy periodically. The usage of collected information is governed by the Privacy Policy in place when such information is utilized.

Should there be substantial modifications in our handling of Personal Data or Children's Personal Data, we will inform you through an announcement on our Services, or via email. Additionally, where necessary, we will secure verifiable parental consent prior to implementing these changes.

Schools with memberships will receive prior notification about significant changes to our privacy practices, including those concerning new or enhanced data collection methods or new usage practices that may reduce your privacy and rights.

We advise you to review this Privacy Policy occasionally to keep yourself updated on how we collect, use, and share personal information through the Service. If you disagree with any modifications to the Privacy Policy, you have the option to close your account. Continuing to use the Service after updates to the Privacy Policy take effect signifies your acceptance of the amended Privacy Policy.

Questions or Concerns

If you have any questions or concerns about privacy in our Services, please send a detailed message to [email protected]. We will do our best to address your concerns.

IQClub, Inc., 3540 Toringdon Way, Suite 200, Unit #5087, Charlotte, NC 28277