Privacy Policy

1. Introduction

This privacy policy (the "Policy") applies to DigiXL, Inc., the Workybooks.com website.

As used in this Policy, "personal data" means any information that relates to, describes, could be used to identify an individual, directly or indirectly.

Applicability: This Policy applies to personal data that Workybooks collects, uses, and discloses and which may include: (i) data collected through the Services, (ii) data collected through the process of training Workybooks machine learning algorithms, (iii) data collected through Workybooks websites, and (iv) data collected from third party sources. Third party sources may include, but not be limited to: public databases, commercial data sources, and the public internet. When you make purchases, we use third-party payment processors to collect credit card or other financial information. Workybooks does not store the credit card or payment information you provide, only confirmation that payment was made.

This Policy does not apply to the following information:

• Personal Data about Workybooks employees and candidates, and certain contractors and agents acting in similar roles.

Changes: We may update this Policy from time-to-time to reflect changes in legal, regulatory, operational requirements, our practices, and other factors. Please check this Policy periodically for updates. If any of the changes are unacceptable to you, you should cease interacting with us. When required under applicable law, we will notify you of any changes to this Policy.

Definitions: Through this Policy, You, or Your means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to DigiXL Inc. Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

2. Collecting and Using Your Personal Data

2.1 Types of Data Collected

2.1.1 Personal Data

While interacting with the Services, You may provide certain personally identifiable information that could be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Your user name for the Services
• Text or image prompts you input into the Services, or public chats you maintain on the service
• Your IP address
• Usage Data
• Tracking Technologies and Cookies
• Contact Information
• Organizational Information like your company title
• Your Email
• Cookies
• Other data that you elect to send to Workybooks

2.2 Use of Your Personal Data

Workybooks may use Personal Data for the following purposes:

• To provide, maintain, and improve our Service, including to monitor the usage of our Service.
• To manage Your account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

2.3 Sharing of Your Personal Data

We may share Your personal information in the following situations:

• With Service Providers, Third Party Vendors, Consultants, and other Business Partners: We may share Your personal information with these parties in order to provide services on our behalf, monitor and analyze the use of our services, contact You, and for the reasons stated in the Agreement. Service Providers to monitor and analyze the use of our Service, to contact You.
• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.
• With Law Enforcement: Under certain circumstances, Workybooks may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). To the extent we receive a request from Law Enforcement for Your personal data, we will promptly notify You and provide You with a copy of the request, unless we are legally prohibited from doing so.

With Other Parties in order to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

We use the following third-party services:

• Google Analytics for anonymous usage analytics.
• Tawk.to as a third-party support chatbot.

2.4 Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

2.5 Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

2.6 Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

2.7 Data Breach Notification

In the event of a data breach affecting your personal information, we will:

• Investigate and contain the breach promptly
• Assess the risk to affected individuals
• Notify relevant regulatory authorities as required by applicable law (within 72 hours where required by GDPR)
• Notify affected users without undue delay when the breach is likely to result in a risk to your rights and freedoms
• Notify affected schools within a reasonable timeframe, not to exceed 30 days from discovery, when Student Data is involved
• Provide information about the nature of the breach and steps you can take to protect yourself
• Document the breach and our response

If you believe your data has been compromised, please contact us immediately at support@workybooks.com.

3. Children's Privacy and COPPA Compliance

Workybooks is committed to protecting the privacy of children. Our Service is designed for use by children in grades K-5, and we comply with the Children's Online Privacy Protection Act ("COPPA").

3.1 Information We Collect From Children

We collect only the minimum information necessary to provide our educational services:

• Username (which may be a pseudonym assigned by a teacher or parent)
• Grade level
• Educational content interactions and progress
• Content created within the Service (worksheets, responses)

We do NOT collect from children:

• Email addresses (parent/teacher email is used for account management)
• Physical addresses
• Phone numbers
• Social Security numbers
• Precise geolocation data

3.2 Parental Consent

We obtain verifiable parental consent before collecting personal information from children under 13 through one of the following methods:

• Consent provided by the child's school, acting as the parent's agent under COPPA's school consent exception, for educational use only
• Direct consent from a parent or guardian via email verification with a follow-up confirmation

3.3 Parental Rights

Parents and legal guardians have the right to:

• Review their child's personal information by contacting us at support@workybooks.com
• Request deletion of their child's personal information
• Refuse further collection of their child's information
• Receive a description of the types of information collected

To exercise these rights, contact us at support@workybooks.com with "COPPA Request" in the subject line. We will respond within 30 days.

3.4 Data Retention for Children

We retain children's personal information only for as long as necessary to provide the educational service.

3.5 Teacher and School Use

When Workybooks is used in a school setting, teachers and school administrators may create accounts on behalf of students. In this case, the school is responsible for obtaining appropriate parental consent and acts as the parent's agent for COPPA purposes.

4. Student Data and FERPA Compliance

Workybooks is committed to protecting student education records in compliance with the Family Educational Rights and Privacy Act ("FERPA").

4.1 Definitions

• "Student Data" means personally identifiable information from education records, as defined by FERPA.
• "Education Records" means records directly related to a student and maintained by an educational agency or institution.

4.2 School Official Designation

When Workybooks contracts with a school or school district, we operate as a "school official" under FERPA, meaning:

• We perform services that the school would otherwise perform itself
• We are under the direct control of the school regarding the use of education records
• We use Student Data only for the purposes for which it was disclosed
• We comply with FERPA requirements regarding re-disclosure

4.3 Use of Student Data

We use Student Data solely for the educational purposes specified in our agreement with the school, including:

• Providing and improving educational services
• Tracking student progress and generating reports for teachers and parents
• Personalizing learning experiences

We do NOT use Student Data for:

• Advertising or marketing purposes
• Creating advertising profiles
• Sale to third parties
• Any purpose other than providing the contracted educational service

4.4 Data Security for Student Records

We implement appropriate administrative, physical, and technical safeguards to protect Student Data, including:

• Encryption of data in transit and at rest
• Access controls limiting data access to authorized personnel
• Regular security assessments
• Employee training on data protection

4.5 Parental and Eligible Student Rights

Under FERPA, parents (or eligible students aged 18+) have the right to:

• Inspect and review education records
• Request correction of inaccurate records
• Provide consent before disclosure (except for permitted exceptions)
• File complaints with the U.S. Department of Education

4.6 Third-Party Access

We do not share Student Data with third parties except:

• Service providers who assist in delivering the Service (bound by confidentiality agreements)
• As required by law
• With explicit school or parental consent

We maintain a list of sub-processors that handle Student Data, available upon request.

5. Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

6. Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

7. Supplemental Terms and Conditions for Certain Regions

California

This Statement applies solely to residents of California or individuals whose information has been collected in California. Workybooks has adopted and included this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA"). Any terms used in this Statement that are defined in the CCPA have the same meaning given therein.

SELLING INFORMATION

Workybooks does not sell Your Personal Information, as defined under CCPA. If in the future we do sell your personal information, we will notify you and you may have the right to opt-out of such sale.

YOUR RIGHTS AND CHOICES

The CCPA provides individuals residing in California or whose Personal Information was collected in California with specific rights regarding their Personal information. The below describes your rights and how you may exercise them.

Access to Specific Information and Data Portability Rights

You have the right to request that Workybooks disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once Workybooks receives and confirms your verifiable information access request, Workybooks must disclose to you: (i) the categories of Personal Information we collected about you; (ii) the categories of sources for the Personal Information we collected about you; (iii) our business or commercial purpose for collecting or, if applicable, selling that Personal Information; (iv) the categories of third parties with whom we share that Personal Information; (v) the specific data points or pieces of Personal Information we collected about you. If we disclosed for a business purpose or sold your Personal Information, Workybooks must also provide separate lists that: (x) identify the personal information categories that were sold to each category of recipient in connection with sales of your Personal Information; and (y) identify the personal information categories that were provided to each category of recipient in connection with business purposes disclosures of your Personal Information.

Deletion Request Rights

You have the right to request that Workybooks delete any of your Personal Information that we collected from you and/or retained. Unless subject to a certain limited exception, once Workybooks receives and confirms your verifiable data deletion request, we will delete (and direct our service providers to delete) your personal information from our records. Workybooks will notify you promptly if it determines it must deny your deletion request.

Do Not Sell Opt-Out Rights

You have the right to opt-out of any sales, as defined by the CCPA, of Personal Information by Workybooks. However, Workybooks does not sell your information.

EXERCISING YOUR RIGHTS

To exercise your access, data portability, and deletion or do not sell opt-out rights described above, you may submit a verifiable consumer request by any of the following means: By email to support@workybooks.com.

8. Advertising in Our Apps (KNOVA and Workybooks)

We display advertisements in our mobile apps using Google AdMob. This section explains how advertising works and how we protect children's privacy.

8.1 COPPA Compliance for Advertising

Our apps are designed for children and families. We take children's privacy seriously and comply with the Children's Online Privacy Protection Act (COPPA) in our advertising practices.

For Child Profiles:

• We request only non-personalized ads - no behavioral targeting or tracking
• Ads are tagged for child-directed treatment under COPPA
• Ad content is restricted to G-rated (family-safe) content only
• No personal data is collected or shared for advertising purposes
• We do not allow interest-based advertising for children

For Adult Profiles:

• Adults may receive personalized ads based on their interests
• Ad content is restricted to T-rated (teen-appropriate) or below
• Adults can opt out of personalized advertising through their device settings

8.2 Information Collected by Advertising Partners

For Children (Non-Personalized Ads):

When serving non-personalized ads to children, only the following non-identifying information may be collected:

• Device type and operating system
• General location (country/region level only)
• App usage context (which screen the ad appears on)

No persistent identifiers are used for tracking children.

For Adults (Personalized Ads):

When personalized ads are enabled for adult profiles, the following information may be collected:

• Advertising identifier (IDFA on iOS, GAID on Android)
• Device and browser information
• Interests inferred from app usage and other apps
• Approximate location

8.3 Third-Party Advertising Partner

We use Google AdMob to serve advertisements. Google's privacy policy applies to the collection and use of data for advertising purposes.

Relevant Google Policies:

• Google Privacy Policy
• How Google Uses Data from Apps
• Google AdMob Terms of Service
• Google Families Policy

8.4 Your Choices

Opting Out of Personalized Ads (Adults Only):

On iOS:

1. Open Settings
2. Tap Privacy & Security
3. Tap Apple Advertising
4. Toggle off "Personalized Ads"

On Android:

1. Open Settings
2. Tap Google
3. Tap Ads
4. Toggle on "Opt out of Ads Personalization"

8.5 Advertising Data Retention

• For Children: No advertising-related data is retained or stored
• For Adults: Advertising identifiers may be retained by Google according to their data retention policies

9. Contact Us

If you have any questions about this Policy, or would otherwise like to exercise your rights under this Policy or applicable law, you can contact us at:

• General inquiries: support@workybooks.com
• COPPA/Children's privacy requests: support@workybooks.com (Subject: "COPPA Request")
• FERPA/Student data requests: support@workybooks.com (Subject: "FERPA Request")
• Data Protection Officer (EU/UK): support@workybooks.com