Effective date: April 1, 2023
Previous version: February 1, 2022

PRIVACY POLICY OF NOVAKID INC.
This Privacy Policy (the “Policy”), an integral part of the Novakid General Terms andConditions, explains how Novakid Inc. (registered seat: 548 Market St 8291, San
Francisco, CA 94104-5401, USA; hereinafter: “Novakid”, “Company”, “we”, or “us”)
collects, stores, uses, and discloses personal information from its users and their students(“you”, “user”) in connection with our online learning service (“Online Classes”) andwebsite located at novakidschool.com and it’s subdomains (the “Website”), as well as in
Novakid’s mobile application (“Application”) operated by the Company including
registering an account for your child on the Website (“Registration”) and virtual chattingwith Novakid (“Chatting”). This Policy also contains information about the collecting of thepersonal data regarding the natural persons who apply as teachers to Novakid (“Applying
as a Teacher”) or who take a training course or/and take part in any other professional
development activities offered on academy.novakidschool.com (“Professional Learning
Activities”).
The processing and collecting of personal data by Novakid shall be in harmony with thedirectly applicable data protection laws in effect:(i) In case of personal data processing, the Regulation (EU) 2016/679 of theEuropean Parliament and of the Council (hereinafter: “GDPR”), furthermore therecommendations of the Article 29 Data Protection Working Party (hereinafter:“WP29”) and of the European Data Protection Board (hereinafter: “EDPB”) shallapply.
(ii) For the collection and processing of personal data of Brazilian individuals, Brazil’s
Law No. 13,709, of August 14, 2018 on the Brazilian General Data Protection Act (inPortuguese: Lei Geral de Proteção de Dados, hereinafter: “LGPD”) shall apply.
(iii) Furthermore, in respect of Californian individuals Novakid complies with the
Senate Bill No. 1121 California Consumer Privacy Act of 2018 (hereinafter:“CCPA”).
(iv) For the collection and processing of personal data of individuals residing in othercountries, where the personal data regulations are in place and apply to the foreign
entities, Novakid is in compliance with those regulations as well.

The Company is the data controller of any data which constitutes personal data, and which
is uploaded when using our services.
The Company bound in honor to protect personal data, especially children’s personal data;
therefore, the Company will keep confidential the personal data received and take allnecessary steps to secure data processing.
Before your child starts using Novakid, we want to make sure you understand how Novakid
collects and uses your personal information and what rights are available for you and yourchild in relation your personal data. Please make sure that you read Novakid’s Children’s
privacy policy, an integral part of the Novakid General Terms and Conditions, (hereinafter:“Children’s Policy”) for your child before he or she starts the online classes.
Please read and make sure you understand this Policy. If you do not agree with this Policy
or our practices, you may not use our Website or our services.

1. DEFINITIONS
The following definitions are determined according to the GDPR:‘personal data’: shall mean any information relating to an identified or identifiable natural
person (‘data subject’); an identifiable natural person is one who can be identified, directly
or indirectly, in particular by reference to an identifier such as a name, an identification
number, location data, an online identifier or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity of that natural person;‘consent’: shall mean any freely given, specific, informed and unambiguous indication of
the will of the Data Subject by which he or she, by a statement or by a clear affirmative
action, signifies agreement to the processing of personal data relating to him or her;‘data controller’: shall mean the natural or legal person, public authority, agency or otherbody which, alone or jointly with others, determines the purposes and means of theprocessing of personal data; where the purposes and means of such processing aredetermined by European Union or Member State law, the controller or the specific criteria
for its nomination may be provided for by Union or Member State law;‘data processing’: shall mean any operation or set of operations which is performed on
personal data or on sets of personal data, whether or not by automated means, such ascollection, recording, organization, structuring, storage, adaptation or alteration, retrieval,consultation, use, disclosure by transmission, dissemination or otherwise making available,alignment or combination, restriction, erasure or destruction;‘data processor’: shall mean a natural or legal person, public authority, agency or otherbody which processes personal data on behalf of the controller;‘third party’: shall mean a natural or legal person, public authority, agency or body otherthan the data subject, controller, processor and persons who, under the direct authority of
the controller or processor, are authorized to process personal data;‘personal data breach’: shall mean a breach of security leading to the accidental or
unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal datatransmitted, stored or otherwise processed;‘recipient’: shall mean a natural or legal person, public authority, agency or another body,to which the personal data are disclosed, whether a third party or not. However, publicauthorities which may receive personal data in the framework of a particular inquiry inaccordance with European Union or Member State law shall not be regarded as recipients;
the processing of those data by those public authorities shall be in compliance with theapplicable data protection rules according to the purposes of the processing;‘supervisory authority’: shall mean one or more independent public authorities provided
by each Member State which is responsible for monitoring the application of the GDPR inorder to protect the fundamental rights and freedoms of natural persons in relation toprocessing and to facilitate the free flow of personal data within the European Union;‘supervisory authority concerned’: shall mean a supervisory authority which is concernedby the processing of personal data because: (a) the controller or processor is establishedon the territory of the Member State of that supervisory authority; (b) data subjects residingin the Member State of that supervisory authority are substantially affected or likely to be
substantially affected by the processing; or (c) a complaint has been lodged with thatsupervisory authority.

2. WHAT INFORMATION DOES NOVAKID COLLECT?
The information we gather from users enables Novakid to personalize and improve theservices, to allow the users to set up accounts on the Website or get information about ourservices. We collect the following types of information from our Teachers and Users:
2.1 Information you provide to us:
2.1.1 At Registration:
We collect the following personal data uploaded during the registration on the Website:● Full name,● E-mail address,● Phone number.
Please note that the e-mail address provided does not require the inclusion of personaldata, such as your name. You are free to choose an e-mail address that contains
information about your identity.

After the Registration you must add the following personal data to your Novakid Account inorder to use our services:● Your children’s data (name, age, gender).
2.1.2 While Chatting:
We collect the following personal data uploaded during the Chatting on the Website:● E-mail address,● Any other personal information provided by you during Chatting.
2.1.3 When participating in Online Classes:
We collect the following personal data uploaded during Online Classes:● Video (including audio) of the participants of Online Classes,● Parental, sibling and extended family details,● Homework or any educational progress submitted via the Website,● Attendance,● Level of proficiency in English language,● Any other personal data shared directly or indirectly during Online Classes (including
but not limited to personal information of third parties, racial or ethnic origin, religion
or beliefs).
2.1.4 When Applying as a Teacher:
We collect the following personal data uploaded during Applying as a Teacher:● Full name,● Teaching experience,● Photo and video about the data subject,● Birthday (age),● Languages spoken,● Gender,● E-mail address,● Nationality,● Skype ID,● Phone number,● Previous work experience,● Educational information,● Residency information,

● Information on other teaching certificates.
2.1.5 When you provide data voluntarily:
We may collect the information that you provide for participating in a contest or/and project,sending the feedback about services or/and application, taking part in opinion polls. This
information may include:● E-mail address,● Phone number,● Any other personal information provided by you voluntarily.
2.1.6 When engaging in Professional Learning Activities:
We collect the following personal data when you engage in the Professional Learning
Activities:● E-mail address,● Full name,● Teaching experience,● Phone number,● Nationality,● Any other information provided by you voluntarily.
2.2 Information Collected Automatically:
We receive and store certain types of information whenever you interact with our Website,
services or Application.
2.2.1 When using the Website
Novakid automatically receives and records information on our server logs from yourbrowser including your IP address, unique device identifier, browser characteristics, domain
and other system settings, search queries, device characteristics, operating system type,language preferences, referring URLs, actions taken on our Website, page requested,
content consumed (e.g., viewed, uploaded, and shared), dates and times of Website visits,
gender, age range, approximate location and other information associated with other files
stored on your device.
2.2.2 When using the Application
Novakid automatically receives and records information on our server logs from your phone
you installed the Application on, including usage information related to it: the date and time
you access the Application, activities in the Application, time spent in the Application and its
regularity, visited content, search terms used, links clicked/tapped on.

3. WHAT ABOUT COOKIES?
The Company processes anonymous data in order to improve the Website, to bring it toperfection. During this procedure Novakid can incorporate “cookies”, which collect thevisitor’s first level domain name, the date and the exact time of access and otherinformations. The “cookie” alone can’t be used to reveal the identity of the visitor. The“cookie” is a small text file, which is sent to the browser of the visitor and stored on the hard
drive of visitor. Cookies don’t damage the computer of the visitor. The browser can be set toindicate when a cookie is received, so the visitor can decide to accept the so-called cookie
or not. The Company does not use cookies to collect or manage any information that would
allow the identification of the user. For further information, please read our Cookie Policy, an
integral part of the Novakid General Terms and Conditions.

4. HOW DOES NOVAKID USE THE COLLECTED INFORMATION?
We may use the information we collected, including your and your children’s personal
information - based on diverse purposes as well as the legal basis of the processing - asfollows:
4.1 We process the following personal data for the purpose and on the legal basis of theperformance of the contract, product and service fulfillment:● Full name,● Children’s name,● Children’s age,
● Children’s gender,● E-mail address,● Phone number.
The above obligatory or optional personal data you provide is used for purposes such as
fulfilling the obligations defined in the Terms of Use and providing the service, responding to
your questions, requests relating to the service, customizing the visualized content,
communicating with you about sales offers relating to special services and new features,and responding to problems relating to our services.
4.2 We process the following personal information based on the legitimate interest of theCompany for marketing purposes and to deliver e-mails:● Full name,● Email address,● Phone number,● Any other personal data provided to the data processors of Novakid,

Whenever Novakid processes data for its legitimate interest, Novakid always keeps yourpersonal data rights in high regard and will take them in account. The users always havethe right to object to this processing. However, objecting against such data processing might
affect Novakid’s ability to carry out tasks above for the benefit of the user.
4.3 We process personal data for the purpose and on the legal basis of compliance withlegal obligations to prevent fraudulent transactions, monitor against theft and otherwise
protect our customers and our business. We also process personal data for the purposeand on the legal basis of legal compliance and to assist law enforcement and respond to
subpoenas.
This means that in some cases the data processing is stipulated by the applicable laws andwe have an obligation to process and keep this data for the required time. This includes
employment data, billing data, data which is necessary to assist law enforcement etc.
4.4 We process the following personal data for the purpose and on the legal basis of thelegitimate interests of the Company, to improve the effectiveness of the Website, ourservices, and marketing efforts, to conduct research and analysis, including focus groups
and surveys and to perform other business activities as needed, or as described elsewherein this Policy:● IP address,● Browser information,● Contact information,● Content consumed on the Website,● Unique device identifier,● Browser characteristics,● Domain and other system settings,● Search queries,● Device characteristics,● Operating system type,● Language preferences,● Referring URLs,● Actions taken on our Website,● Page requested,● Content consumed (e.g., viewed, uploaded, and shared),● Dates and times of Website visits,● The link that you have been redirected to our Website from,● Gender,● Age range,● Approximate Location,● The type of web browser used,● Actions taken in the Application,● Dates and times of using the Application,● Time spent in the Application and the regularity of your visits,● Other software and hardware information,● Other information associated with other files stored on your device.
Where it is feasible, we anonymize personal data or use non-identifiable statistical data. We
do not collect personal data in advance and store it for potential future purposes unlessrequired or permitted by the applicable laws.
We use the following software services and applications for collecting anonymous data andperforming statistical analysis of the usage of Novakid platform:

Name

Registered seat

Country

Google Analytics
and Google
AdWords (Google
LLC.)

1600 Amphitheatre Parkway
Mountain View, CA 94043

United States of America

Facebook pixel(Facebook Inc.)

1601 Willow Road Menlo Park,CA 94025

United States of America

The Rocket
Science Group,
LLC (MailChimp)

675 Ponce de Leon Ave NE,
Suite 5000, Atlanta, GA 30308

United States of America

Microsoft Corp

1 Microsoft Way Redmond, WA
98052

United States of America

Yandex, LLC.

16, Leo Tolstoy Street Moscow,
119021

Russian Federation

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

5. HOW LONG WE RETAIN YOUR PERSONAL DATA?
We will retain your personal data for so long as it is needed to fulfill the purposes outlined inthis Policy or until you withdraw your consent, unless a longer retention period is required or
permitted by law (such as tax, accounting or other legal requirements, further for theestablishment, exercise or defense of legal claims).
When we have no longer or no legal basis to process your personal information, we will
either delete or anonymize it, or, if this is not possible (for example, because your personal
information has been stored in backup archives), then we will securely store your personal
information and isolate it from any further processing until deletion is possible.

6. WILL NOVAKID SHARE ANY OF THE INFORMATION IT RECEIVES?
6.1 Information about our users is an integral part of our business, and we may share suchinformation with our affiliated entities. Except as expressly described below, we neither rent
nor sell your information to other people or nonaffiliated companies unless we have yourpermission.
6.2 Novakid shall not ensure access for a third party to personal data provided by you
without your preliminary consent, except the cases, when data transfer is necessary for the
performance of the contract or for enforcing of Novakid’s legitimate interest or prescribed bylaw.
6.3 Every teacher providing services to Novakid is considered as a data processor
according to the regulations of the GDPR. The teachers have access only to the personal
data of the children they are teaching in order to minimize the processing of personal data.
6.4 Novakid may share certain personal information with third party vendors in the EU or inthird countries that may include:● Payment service providers;● Cloud service providers;● Software development tool and cloud services providers;● Marketing partners;● Customer support services providers;● Learning services providers;● Professional advisers, including consultants, accountants, auditors, solicitors.

Novakid may also share your information with public authorities, court or government
representatives as necessary in accordance with applicable laws and regulations.
We will require that these third parties maintain at least the same technical andorganizational measures of data protection and confidentiality. Those third parties will never
use your personal information for any other purpose except to provide services inconnection with the Website and our services.
6.5 We may disclose your personal data to some US companies, in particular to Stripe Inc.,
Intercom Inc. and Google LLC for the purpose of providing services to you. We take steps
to ensure adequate safeguards are in place to protect your data, that includes implementing
the European Commission’s Standard Contractual Clauses for transfers of personal data
between these third party service providers and partners. Please note, that above
mentioned companies comply with the EU-US and the EU-Swiss Privacy Shield
Frameworks, therefore transfer of your personal data to the aforementioned service
providers was deemed safe until July 16, 2020. Please note that according to the judgment
no. C-311/18 of the Court of Justice of the European Union, these companies are no longer
considered to provide appropriate safeguards for the personal data of European citizens.
For more information, you can read the judgment here.
6.6 We only transfer personal data collected from individuals located within the EU only withthe consent of the individuals to a third-party having a registered seat outside the EU / in the
USA acting as a data processor without the appropriate safeguards set out in the GDPR, orwhen it is necessary for the performance of the contract. Novakid will make every effort toensure that the personal data transferred is safe and secure and that the personal data isprocessed in a manner consistent with the GDPR.

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

8. LINKS TO THIRD-PARTIES
On our Website we can embed links to third-party websites. It must be understood thatwhen you click on any of these links or use their widgets, any Personal Data you provide
will be protected under the third-party policies and terms. We have no control andresponsibility for services, privacy policies, or terms of any third-party websites or/and
services.

9. SOCIAL NETWORK INTEGRATIONS
In case when you use a third party platform or social network to access or/and set up an
account on the Website, this third party may provide your personal data to us if you soallow. These platforms or/and social networks are not controlled by or affiliated with
Novakid. Therefore, read their privacy policy and terms of use carefully so that you
understand how they use your personal data and what might be shared.
At any time you may make changes to the data that these third parties share with us bychanging your settings for these platforms or/and social networks, or stop allowing theWebsite to interact with those platforms or/and social networks.

10. CHILDREN’S PRIVACY
10.1 Novakid is committed to protecting the privacy of children who use our services
including our Website and Application.
This Policy and Novakid’ privacy practices are in accordance with the United State’sChildren's Online Privacy Protection Act of 1998 (“COPPA”) as well as the Council ofEurope’s Recommendation CM/Rec(2018)7 of the Committee of Ministers to member
States on Guidelines to respect, protect and fulfil the rights of the child in the digital
environment (“Guidelines”).
For information on how to protect your child’s privacy online please make sure to read thefollowing documents before Registering on the Website:● The Federal Trade Commission’s guidelines on Protecting Your Child’s Privacy
Online,● UNESCO’s guidance for students, teachers and parents on personal data andprivacy protection in online learning.
10.2 At Registration, Novakid obtains the consent of the statutory representative forcollecting the personal data of minors. Novakid asks for the phone number and e-mail of thestatutory representative to make sure that no child Registers on the Website. Novakid does
not collect personal information directly from children at Registration. If we learn that wehave collected personal information directly from a child under 16 without the consent of
their statutory representative, we will take steps to delete such information from our files assoon as possible. If you are aware of anyone under 16 registered on the Website, pleasecontact us at policy@novakidschool.com.
10.3 At any time, you can withdraw your consent of Novakid collecting further personal
information from your child and can request that we delete the personal information we
have collected in connection with you or your child from our records. You can request thedeletion of your data by connecting Novakid via the chat services after you logged in.
Please keep in mind that a request to delete records may lead to termination of yourAccount which disables the accessibility of Online Classes in the future.
10.4 As your and your child’s personal data are processed by the Teachers of Novakid, weconcluded a data processing contract with them in order to prevent fraudulent or
inappropriate activities as well as to regulate the Teacher’s data processing activities during
the providing of our Services. If you think that a Teacher steps over legal and/or ethicallimitations during the data processing or he or she processes your data incorrectly or
unlawfully, please contact us at policy@novakidschool.com.

11. YOU AND YOUR CHILD’S PRIVACY RIGHTS
11.1 Access and Retention:
If you have an account registered on the Website, you can log in to view and update youraccount information. You have the right to obtain confirmation of whether or not we areprocessing personal data relating to you or your child, have communicated to you such dataso that you could verify its accuracy and the lawfulness of the processing and have the data
corrected, amended or deleted where it is inaccurate or processed in violation of the GDPR.
We encourage you to contact us at policy@novakidschool.com with your questions orconcerns, or to request edits to your and your child’s personal information, or to have it
removed from our database. Requests to access, change or remove any personal data you
provided to us will be handled within 30 days.
11.2 Additional Rights for EU Territory:
If you are from the territory of the EU, you may have the right to exercise additional rights
available to you under applicable laws, including:(a) Right of Erasure: In certain circumstances, you may have a broader right toerasure of personal information that we hold about you – for example, if it is nolonger necessary in relation to the purposes for which it was originally collected.
Please note, however, that we may need to retain certain information for record
keeping purposes, to complete transactions or to comply with our legal obligations.
(b) Right to Object to Processing: You may have the right to request Novakid tostop processing your personal information and/or to stop sending you marketing
communications.
(c) Right to Restrict Processing: You may have the right to request that we restrict
processing of your personal information in certain circumstances (for example,
where you believe that the personal information we hold about you is inaccurate or
unlawfully held).

(d) Right to Data Portability: In certain circumstances, you may have the right to beprovided with your personal information in a structured, machine readable andcommonly used format and to request that we transfer the personal information toanother data controller without hindrance.
11.3 Additional Rights for Brazilian individuals
If you are a Brazilian individual, you have the following rights in addition to the rights
described in section 9.1 of this Policy:(a) Right of erasure: If you would exercise this right, we will respond to you
immediately, or if that is not possible, we will send a reply to you to indicate thereasons of fact or law that prevents the immediate adoption of the measure. If we are
not the data processors of the data you requested the erasure of – wheneverpossible – we will indicate who the processing agent is.
(b) Right to be informed: You have the right to obtain information about what typesof processing we carry out on your personal information.
(c) Right of access: If you request the providing of your personal data processed byus, we will grant you access to such data in 15 days of your request, if the data
requested is more than the simplified request version.
(d) Nondiscrimination: We do not process your data for unlawful or abusive
discriminatory purposes. In certain circumstances, you have the right to request areview of our data processing and the supervisory authority (the Brazilian National
Authority for Protection of Data (hereinafter: “ANPD”)) may carry out an audit toverify discriminatory aspects.
(e) Data portability: Your data might be transferred to another service or productsupplier in accordance with the regulations of the ANPD and as subjects tocommercial and industrial secrets.
You also have the right to complain to the ANPD about our collection and use of yourpersonal data. For more information, please contact the ANPD.
11.4 Data protection officer
If you would like to exercise the rights included in this section 9 of this Policy, please contact
our data protection officer (hereinafter “DPO”) at dpo@novakidschool.com or at 548 Market
St 8291, San Francisco, CA 94104, USA. We will consider your request in accordance withapplicable laws. To protect your privacy and security, we may take steps to verify youridentity before complying with the request.
For any complaints that we can’t resolve directly, please contact our European
Representative Weiszbart and Partners Law Firm (address: 1052 Budapest, Kristóf tér 3. III.
flr., Hungary; e-mail address: weiszbartandpartners@gmail.com).

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

12. MODIFICATIONS TO THIS POLICY
If our privacy practices change, we reserve the right to modify this Policy. We will post amodified version at the Website. So please review it regularly.

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

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