SpeakClub Privacy and Children's Privacy Policy

The operator responsible for information collected through SpeakClub is:

FiverKids LLC d/b/a SpeakClub Sea Side Drive, 324 00 Union City, CA

Email: contact@Fiverkids.com

SpeakClub provides an online Platform through which Families may engage independent communication Coaches.

Some Coaches are located in India or other countries outside the United States.

SpeakClub purchasing and Family accounts must be created and controlled by an adult.

A child may not independently:

• Create a purchasing account
• Accept the Terms
• Provide payment information
• Give recording consent
• Establish private communication with a Coach
• Authorize public use of their image, voice or work
• Authorize marketing use of personal information

Parents or guardians provide information about the Student and control the Student's participation.

For Students under 13, SpeakClub provides required notice and obtains verifiable parental consent before collecting personal information directly from the child, except where a limited legal exception applies.

We may collect the following from a parent, guardian or authorized adult.

Contact and account information

• Name
• Email address
• Telephone number
• Mailing address where reasonably necessary
• Password or authentication information
• Country
• Time zone
• Communication preferences

Transaction information

• Program selected
• Purchase amount
• Billing dates
• Payment status
• Installment schedule
• Refunds
• Credits
• Chargebacks
• Transaction identifiers

Complete payment-card information is generally processed by our payment provider and is not ordinarily stored by SpeakClub.

Preferences and requests

• Schedule
• Coach preferences
• Language preferences
• Student goals
• Program interests
• Support requests
• Feedback
• Reviews
• Recording and media-consent choices

Depending on the Program and information supplied by the Family, we may collect:

• First name
• Last initial or last name where necessary
• Age
• Birth month or year where needed to determine age
• Grade
• Country or time zone
• Languages spoken
• Communication experience
• Speaking goals
• Reading or writing level
• Vocabulary or grammar needs
• Debate or presentation interests
• Schedule
• Coach preferences
• Attendance
• Class history
• Assignments
• Speech topics
• Writing samples
• Reading responses
• Practice activity
• Coach notes
• Progress information
• Rubric scores
• Platform messages
• Customer-support information
• Safety reports
• Technical information associated with Platform use

We ask Families not to provide unnecessary sensitive information.

If a Family voluntarily provides information concerning a disability, learning need, health condition or requested accommodation, we use it only as reasonably necessary to:

• Respond to the request
• Support the Student
• Protect the Student
• Comply with law

SpeakClub is not a medical or clinical provider and does not use this information to diagnose a condition.

We may collect, host or process Student Content such as:

• Speeches
• Speech outlines
• Stories
• Essays
• Poems
• Debate arguments
• Presentations
• Reading responses
• Vocabulary exercises
• Grammar exercises
• Assignment submissions
• Practice reflections
• Coach feedback
• Student-created images or slides

Student Content may contain personal information when the Student includes it.

Families and Students should not include unnecessary sensitive information concerning the Student, Family or another person.

SpeakClub and the assigned Coach may review Student Content where reasonably necessary to:

• Deliver Coaching Services
• Provide feedback
• Track progress
• Maintain lesson continuity
• Prepare progress reports
• Operate a private portfolio
• Investigate a complaint
• Enforce safety and academic-integrity rules

A Program may collect audio or video Practice Recordings in which a Student practices a speech, story, presentation or debate exercise.

A Practice Recording may contain:

• The Student's image
• The Student's voice
• The Student's name
• The Student's speech or written work
• The Student's home background
• Vocal and visual delivery information

Before collecting a Practice Recording from a Student under 13, SpeakClub will provide required notice and obtain verifiable parental consent.

Practice Recordings may be accessible to:

• The Family
• The assigned Coach
• Authorized SpeakClub personnel
• Service providers supporting storage or playback

Practice Recordings are private unless the Family separately authorizes public use.

We do not use a Student's image or voice for biometric identification or facial-recognition purposes unless separately disclosed, legally permitted and specifically consented to.

SpeakClub may record a Class where recording is part of the disclosed Program or is used for:

• Parent visibility
• Student progress review
• Safety
• Quality review
• Dispute resolution
• Coach feedback

Before recording, SpeakClub will provide notice and obtain required parental and participant consent.

A recording notice will describe:

• What will be recorded
• The purpose
• Who may access it
• How long it will ordinarily be retained
• Whether recording is optional or integral to the Program

Class Recordings will not be used for advertising, social media or public marketing without separate optional media consent.

Coaches and Families may not independently record Classes without appropriate authorization.

Families and Coaches communicate through Platform Messaging.

We may collect and store:

• Message content
• Attachments
• Dates and times
• Sender and recipient
• Delivery status
• Safety flags
• Support history

Platform messages may be reviewed for:

• Child safety
• Customer support
• Quality review
• Fraud prevention
• Dispute resolution
• Enforcement of Platform rules
• Legal compliance

Families and Students should not use Platform Messaging to share unnecessary personal, financial or sensitive information.

SpeakClub generally does not provide a Coach's personal email address or telephone number to a Family or Student.

SpeakClub limits the personal contact information made available to a Coach.

Coaches are contractually required to use Platform Messaging for Platform-introduced Coaching Engagements and may not:

• Contact a Student privately
• Contact a Family through personal email or telephone
• Request a Student's personal contact information
• Move communication to WhatsApp, social media, text messaging or another private service
• Request direct payment

Platform notifications may be sent to a parent's email address or telephone number, but responses must occur through Platform Messaging unless SpeakClub authorizes another method.

A proposed Coach may receive limited information reasonably necessary to decide whether to accept an engagement, including:

• Student age or age range
• General learning goals
• Requested Program
• Proposed schedule
• Time zone
• General communication needs

After accepting an engagement, the Coach may receive additional information reasonably necessary to provide Coaching Services, including:

• Student first name
• Relevant Class history
• Assignments
• Practice Recordings
• Progress information
• Parent-visible messages
• Accommodation requests where appropriate

The Coach may be located in India or another country.

Coaches are contractually prohibited from using Student information for:

• Private contact
• Independent marketing
• Off-Platform solicitation
• Public posting
• Unrelated services
• Another unauthorized purpose

During a Class, a Coach may see or hear:

• The Student's name
• The Student's image
• The Student's voice
• The Student's shared screen
• Student speeches or writing
• Information voluntarily discussed during Class

Families should position the Student's device and prepare the shared screen to avoid showing:

• Personal messages
• Email
• Passwords
• Financial information
• Private photographs
• Medical information
• Precise location
• Unrelated files
• Confidential information concerning another person

The assigned Coach may use information obtained during Class only to deliver the accepted Coaching Services and meet applicable safety or legal obligations.

In a group Class or private showcase, other participating Students and Families may see or hear:

• The Student's first name or display name
• Image
• Voice
• Speech
• Presentation
• Writing or other work

Participants are prohibited from privately contacting, recording or publishing another child without permission.

SpeakClub will obtain separate optional parental consent before publicly displaying or publishing a Student's identifiable:

• Image
• Voice
• Full name
• Testimonial
• Speech
• Writing
• Presentation

Public-media consent is separate from consent needed to provide ordinary Classes.

When an adult or Student uses the Platform, we may automatically collect:

• IP address
• Browser type
• Device type
• Operating system
• General location inferred from IP
• Pages viewed
• Features used
• Date and time
• Referring page
• Session identifiers
• Error logs
• Security events
• Cookie identifiers
• Portfolio activity
• Playback activity
• Performance information

We use this information to:

• Operate the Platform
• Authenticate users
• Maintain security
• Remember preferences
• Diagnose errors
• Prevent fraud
• Improve performance
• Understand general usage

We do not intentionally collect precise geolocation from Students.

We may use the following technologies.

Essential cookies

Used for:

• Login
• Security
• Account functions
• Scheduling
• Purchases
• Platform preferences

Analytics technologies

Used to understand how adult visitors and Families use the website and improve performance.

Advertising technologies

SpeakClub does not use children's personal information for targeted advertising or cross-context behavioral advertising.

SpeakClub does not knowingly allow advertising providers to build behavioral profiles of Students.

If advertising technologies are used on adult-facing marketing pages, they are not authorized for use inside Student learning areas to target advertising based on children's activity.

Where required, adult visitors will receive cookie controls or privacy choices.

For Coach applicants and Coaches, SpeakClub may collect:

• Name
• Address
• Email
• Telephone number
• Date of birth
• Country
• Identity documents
• Photograph
• Professional history
• Communication or teaching experience
• Education
• Certifications
• Languages
• References
• Interview information
• Background-screening information
• Availability
• Preferred compensation
• Accepted engagements
• Class records
• Family feedback
• Complaints
• Platform messages
• Payment and bank information
• Tax information
• Device and security information

Coach screening and payment information is used for legitimate business, safety, contractual and legal purposes.

Public Coach profiles display only information approved for profile use.

We may receive information:

• Directly from a Family
• Directly from a Coach
• From a Student with parental authorization
• Through Platform activity
• From payment providers
• From video-conferencing providers
• From recording and storage providers
• From background-screening providers
• From references
• From customer-support providers
• From fraud, security or analytics providers
• From schools or organizations where authorized

We may use personal information to:

Provide services

• Create and manage accounts
• Match Families with Coaches
• Allow Coaches to accept or reject engagements
• Schedule Classes
• Process payments
• Distribute Coach compensation
• Provide Platform Messaging
• Operate recordings and portfolios
• Provide progress reports
• Run group Classes and showcases
• Track attendance and credits
• Provide customer support

Personalize services

• Recommend a Coach
• Understand Student goals
• Recommend age-appropriate learning paths
• Support lesson continuity
• Adjust account settings
• Suggest Programs

Protect users

• Enforce the Child Safety Code
• Review Platform messages
• Investigate reports
• Prevent private Coach–Student contact
• Detect fraud
• Protect Platform security
• Suspend inappropriate accounts
• Address academic-integrity concerns

Communicate

• Send booking confirmations
• Send Class reminders
• Send Platform-message notifications
• Provide billing notices
• Respond to support requests
• Provide policy updates
• Send marketing to adults who have not opted out

Improve the Platform

• Analyze Program performance
• Diagnose errors
• Improve matching
• Improve progress tools
• Develop features
• Conduct aggregated or de-identified analysis

Meet legal obligations

• Maintain transaction records
• Respond to lawful requests
• Protect legal rights
• Enforce contracts
• Meet tax and accounting requirements
• Comply with child-safety and privacy obligations

We may disclose personal information as described below.

Proposed and assigned Coaches

We disclose limited information to a proposed or assigned Coach where necessary to:

• Evaluate a proposed match
• Accept or reject the engagement
• Deliver Classes
• Review relevant prior learning
• Provide feedback
• Communicate through Platform Messaging
• Support the Student

Service providers

We may use providers for:

• Website hosting
• Cloud storage
• Audio and video processing
• Payment processing
• Email and notifications
• Video conferencing
• Scheduling
• Customer support
• Background screening
• Fraud prevention
• Security
• Analytics

Service providers may use information only to provide specified services or as otherwise permitted by law and applicable agreements.

Safety and legal disclosures

We may disclose information where reasonably necessary to:

• Protect a child
• Investigate misconduct
• Respond to an emergency
• Prevent fraud
• Comply with legal process
• Respond to law enforcement
• Report to child-protection authorities
• Enforce agreements
• Protect another person's rights

Business transactions

Information may be disclosed in connection with a proposed or completed:

• Merger
• Financing
• Acquisition
• Reorganization
• Asset sale
• Bankruptcy
• Transfer of the business

Any recipient remains subject to applicable privacy obligations.

With consent

We may disclose information for another purpose where the parent, adult user or Coach provides appropriate consent.

SpeakClub, MyChessCoach, MyCodeCamp and MathPros are operated by FiverKids LLC.

FiverKids may use shared systems, personnel and providers for:

• Account administration
• Payment processing
• Customer support
• Security
• Fraud prevention
• Legal compliance
• Business operations

We do not automatically enroll a Student in another FiverKids program.

We do not use a child's personal information for cross-brand targeted advertising.

An adult may receive information about another FiverKids educational service where permitted by law and may opt out of marketing.

SpeakClub does not sell children's personal information.

SpeakClub does not disclose children's personal information for targeted advertising or cross-context behavioral advertising.

SpeakClub does not condition a child's participation on providing more personal information than is reasonably necessary for the activity.

SpeakClub does not knowingly sell personal information in exchange for money.

If adult-facing advertising practices change in a way that creates a legal opt-out right, we will provide required notice and choices before implementing that practice.

SpeakClub is operated from the United States.

Coaches and service providers may operate in other countries, including India.

Personal information may therefore be accessed, processed or stored outside the Family's state or country.

Privacy laws in another country may differ from those in the Family's jurisdiction.

We use contractual restrictions, access controls and other safeguards intended to limit use to the purposes described in this Policy.

A Coach outside the United States may access only the information reasonably necessary to evaluate and deliver the accepted Coaching Engagement.

SpeakClub is directed in part to children under 13.

For a Student under 13, SpeakClub will:

• Provide the parent with notice of relevant information practices
• Obtain verifiable parental consent where required
• Collect no more information than reasonably necessary
• Allow the parent to review the child's information
• Allow the parent to request correction or deletion
• Allow the parent to withdraw consent
• Protect confidentiality and security
• Retain information only as long as reasonably necessary
• Restrict disclosure to Coaches and providers that need it
• Avoid targeted advertising based on the child's information

The proposed or assigned Coach's access to limited Student information is necessary to evaluate or provide Coaching Services and is disclosed to the parent.

Where required, SpeakClub uses a method reasonably designed to confirm that the person providing consent is the child's parent or legal guardian.

The method may depend on:

• The information collected
• How it will be used
• Whether it will be disclosed
• Applicable law

Consent may be obtained through:

• An approved electronic process
• Payment-related verification
• Signed consent
• Video interaction
• Another legally permitted method

SpeakClub will retain appropriate consent records.

Consent necessary for service delivery is separate from optional consent for:

• Public testimonials
• Marketing photographs
• Advertising videos
• Public showcase recordings
• Social-media posts
• Other secondary uses

Declining optional marketing consent will not prevent the Student from receiving ordinary Coaching Services.

A verified parent or legal guardian may request to:

• Review information collected from the child
• Correct inaccurate information
• Delete the child's information
• Withdraw consent to future collection
• Prevent further use
• Ask what categories are collected
• Ask which parties receive the information
• Delete Practice Recordings
• Remove eligible Student Content from a private portfolio
• Withdraw future public-media permission

Submit a request to: contact@Fiverkids.com

We may request information reasonably necessary to verify identity and parental authority.

Withdrawing consent or requesting deletion may make some or all Coaching Services unavailable where the information is necessary to provide them.

We may retain limited information where reasonably necessary for:

• Safety investigations
• Security
• Fraud prevention
• Transaction records
• Legal claims
• Compliance with law
• Enforcement of agreements

SpeakClub does not create public Student profiles containing full identifying information unless appropriate notice and consent are provided.

A Student's name, image, voice, speech, writing, testimonial or progress information will not be made publicly available through SpeakClub unless:

• The parent receives appropriate notice
• The parent provides appropriate consent
• Publication is limited to that consent

Where reasonably possible, public activities should use:

• A first name only
• A nickname
• A non-identifying username
• A general age or grade
• No precise location or school name

A parent may withdraw permission for future public use.

Withdrawal may not require SpeakClub to retrieve material already lawfully printed or distributed where retrieval is impractical, but SpeakClub will stop new use and remove online material under its control where reasonably practicable.

We may send adults information about:

• SpeakClub Programs
• Free demos
• Workshops
• Showcases
• Offers
• New services
• Other FiverKids educational services

Adults may unsubscribe through the link in the message or by contacting us.

We do not send behavioral advertising directly to children.

Service messages, billing notices, safety communications and account notices may continue while the account remains active.

Where an adult has opted in, we may send messages concerning:

• Demo scheduling
• Class reminders
• Account activity
• Platform messages
• Billing
• Support
• Promotional offers

Message frequency varies, and message and data rates may apply.

Consent to receive marketing texts is not a condition of purchase.

Reply STOP to stop applicable messages and HELP for assistance.

Opting out of marketing texts does not prevent legally permitted transaction or safety communications through another channel.

We retain information only for as long as reasonably necessary for the disclosed purpose.

Family account information

Retained while the account is active and ordinarily for up to two years after the last Coaching Engagement, unless longer retention is needed for legal, fraud or safety purposes.

Student profiles and learning history

Retained while services are active and ordinarily for up to two years after the last Class to support continuity, reactivation and parent requests.

A parent may request earlier deletion, subject to lawful retention needs.

Student writing and assignments

Ordinarily retained while the Program is active and for up to two years afterward to support progress tracking and continuity.

Practice Recordings

Ordinarily retained while the Program is active and for up to 12 months after the last Class, unless the parent requests earlier deletion or longer retention is required for a safety or legal matter.

Class Recordings

Ordinarily retained for no more than 90 days unless:

• The recording is part of a disclosed private progress portfolio;
• A longer period was disclosed and consented to;
• It relates to a complaint, legal hold or safety investigation.

Private portfolio content

Ordinarily retained while the account is active and for up to 12 months after the last Class, unless the parent requests earlier deletion.

Platform messages

Ordinarily retained during the Coaching Engagement and for up to two years afterward for support, safety and dispute resolution.

Messages connected with a safety report may be retained longer.

Transaction and tax records

Retained for up to seven years or another period required for tax, accounting, payment or legal obligations.

Safety and misconduct records

Retained for as long as reasonably necessary to protect users, prevent repeat misconduct and address legal claims.

Serious safety records may be retained for up to seven years or longer where required by law.

Coach screening and payment records

Ordinarily retained during the Coach relationship and for up to seven years afterward for contractual, tax, safety and legal purposes.

Technical and security logs

Ordinarily retained for between 30 days and 18 months depending on operational, fraud and security requirements.

When information is no longer needed, we delete it, de-identify it or securely isolate it from ordinary use.

We may create aggregated or de-identified information that does not reasonably identify a Family, Student or Coach.

We may use it to:

• Analyze Program performance
• Improve Coach matching
• Understand general learning patterns
• Improve progress tools
• Improve Platform features
• Prepare business reports

We will not attempt to re-identify information maintained as de-identified except as permitted by law to test the de-identification process.

SpeakClub uses administrative, technical and organizational safeguards intended to protect personal information.

Measures may include:

• Role-based access
• Account authentication
• Encryption in transit
• Restricted Coach access
• Contractual confidentiality requirements
• Security logging
• Backups
• Provider review
• Incident-response procedures
• Child-safety requirements
• Written data-security and retention procedures

No system is completely secure. SpeakClub cannot guarantee that unauthorized access, loss or misuse will never occur.

Families should:

• Use strong passwords
• Protect account credentials
• Sign out of shared devices
• Avoid sharing sensitive information in messages
• Close private information before screen sharing
• Use a neutral background where appropriate
• Notify SpeakClub of suspected unauthorized access

If SpeakClub learns of an incident, it may:

• Investigate
• Restrict access
• Preserve records
• Reset credentials
• Suspend affected integrations
• Notify affected users
• Notify regulators or law enforcement
• Take corrective measures

Notifications will be provided where and when required by law.

SpeakClub may link to or integrate with third-party services such as:

• Video-conferencing platforms
• Recording or portfolio platforms
• Payment services
• Scheduling services
• Cloud-storage providers
• Communication services

Those providers may have their own privacy policies.

SpeakClub takes reasonable steps to use appropriate providers but does not control every third-party practice.

A parent should supervise the Student's use of any third-party account.

Where a school, district, library or other organization sponsors access to SpeakClub, additional agreements or privacy terms may apply.

The sponsoring organization may provide information such as:

• Student name
• Grade
• Class roster
• School email
• Program assignment

We use that information to provide the sponsored Program and comply with the applicable agreement.

SpeakClub does not claim that every direct-to-Family Program is governed by FERPA.

Where mandatory law or a school agreement applies, that law or agreement may govern the sponsored Program.

This section applies to California residents to the extent the California Consumer Privacy Act or another California privacy law applies to SpeakClub and the relevant information.

California residents may have the right to request:

• Categories of information collected
• Sources of information
• Purposes for collection and use
• Categories of recipients
• Specific pieces of information
• Deletion
• Correction
• Opt-out of sale or sharing
• Limitation of certain sensitive-information uses
• Equal treatment for exercising rights

SpeakClub does not sell children's personal information and does not share it for cross-context behavioral advertising.

Requests may be submitted to: contact@Fiverkids.com

Use the subject line: CALIFORNIA PRIVACY REQUEST

We will verify requests as required by law.

A parent or authorized agent may submit an appropriate request for a child.

Residents of certain states may have rights to:

• Access personal information
• Correct personal information
• Delete personal information
• Receive a portable copy
• Opt out of certain sales, targeted advertising or profiling
• Appeal a denied request

We will honor applicable rights based on the requester's jurisdiction and our legal obligations.

Submit a request or appeal to: contact@Fiverkids.com

Where applicable law provides these rights, a person may request:

• Access to personal information
• Correction
• Deletion
• Restriction of processing
• Data portability
• Objection to certain processing
• Withdrawal of consent
• Review of an automated decision where applicable

Depending on the processing activity, SpeakClub may rely on:

• Performance of a contract
• Parental or adult-user consent
• Compliance with legal obligations
• Legitimate interests such as security, support and service improvement, where those interests are not overridden by individual rights

A person may have the right to complain to their local data-protection authority.

International transfers may be supported through contractual protections or another lawful transfer mechanism where required.

Before responding, we may request information reasonably necessary to verify:

• Identity
• Account ownership
• Parental authority
• Scope of the request

Verification information is used only to process and protect the request.

We may deny or limit a request where:

• Identity cannot be verified
• Parental authority cannot be verified
• The request is fraudulent or abusive
• Retention is legally required
• A legal exception applies

We will explain a denial where required.

Where permitted by law, an adult may use an authorized agent to submit a privacy request.

We may require:

• Written authorization
• Verification of the adult's identity
• Direct confirmation of the request

An agent requesting information concerning a child must also demonstrate the parent's or guardian's authority.

SpeakClub will not unlawfully discriminate against a person for exercising a privacy right.

Exercising a right may affect the service where the information is necessary to provide it.

For example, deleting all Student recordings and account information may prevent continued portfolio access or Class delivery.

SpeakClub may update this Policy to reflect changes in:

• Services
• Technology
• Recording practices
• Safety practices
• Data practices
• Law

We will update the effective date.

We will provide additional notice and obtain new consent where required for a material change involving children's information.

For privacy questions or requests:

FiverKids LLC d/b/a SpeakClub Sea Side Drive, 324 00 Union City, CA

Email: contact@Fiverkids.com

For child-safety concerns, general support and legal notices, please contact us at the same email address.