KAIMERIE™ PRIVACY POLICY

Welcome to Kaimerie

Kaimerie is owned and operated by FOR HER MEDIA LLC, a Texas limited liability company. Kaimerie is a platform of No Average Student, an education brand of FOR HER MEDIA LLC. This Privacy Policy explains what information we collect, how we use it, how we protect it, when we disclose it, and the choices available to users.

1. Information We May Collect

The information collected depends on how Kaimerie is being used and the features enabled for an account.

Account Information

We may collect information such as:

• name;
• username;
• email address;
• grade level;
• school or organization;
• account role;
• parent or guardian information when applicable; and
• authentication and account information.

Student Educational Information

When students participate in Kaimerie, we may collect or maintain:

• lesson progress;
• completed activities;
• assignments;
• responses to educational prompts;
• research topics and projects;
• goals;
• reflections;
• assessments;
• achievements;
• teacher or instructor feedback;
• portfolio materials;
• uploaded educational files; and
• other information created as part of participation in the program.

Technical Information

We may automatically collect limited technical information necessary to operate, secure, and improve the Platform, such as:

• device and browser type;
• IP address;
• login information;
• timestamps;
• system activity;
• error and security logs; and
• information about interaction with Platform features.

We seek to limit collection to information reasonably necessary for legitimate educational, operational, security, and legal purposes.

2. How We Use Information

We may use personal information to:

• create and maintain accounts;
• deliver lessons and educational content;
• save student work;
• track educational progress;
• unlock achievements and program milestones;
• create and maintain student portfolios;
• provide feedback;
• allow authorized teachers, administrators, parents, or guardians to monitor progress;
• personalize authorized educational experiences;
• provide customer and technical support;
• authenticate users;
• maintain Platform security;
• diagnose technical problems;
• improve the functionality and educational effectiveness of Kaimerie;
• comply with contractual and legal obligations; and
• protect the rights, privacy, safety, and security of students and other users.

Student personal information will not be used for targeted advertising based on a student’s activities across unrelated services.

3. Children’s Privacy and COPPA

Kaimerie is designed to serve middle- and high-school students, which means some users may be younger than 13. We take additional measures when collecting personal information from children under 13. When required by the Children’s Online Privacy Protection Act (“COPPA”), Kaimerie will provide appropriate notice and obtain verifiable parental consent before collecting personal information directly from a child under 13.

Where permitted by COPPA, a school or educational organization may provide consent on behalf of a parent for the collection and use of a child’s information when Kaimerie is used solely for an educational purpose authorized by the school and not for an unrelated commercial purpose.

Parents may contact Kaimerie to:

• review personal information collected from their child;
• request correction or deletion where applicable;
• withdraw consent to further collection or use; or
• ask questions about Kaimerie’s information practices.

Withdrawal of consent may affect the child’s ability to continue using features that require the information. Kaimerie does not condition a child’s participation on disclosing more personal information than is reasonably necessary for the applicable educational activity.

4. School-Provided Student Information and FERPA

When Kaimerie provides services to a school or educational institution subject to FERPA, information provided by the institution or maintained by Kaimerie on its behalf may constitute education records protected by FERPA.

Where Kaimerie receives personally identifiable information from education records under the FERPA school-official exception, Kaimerie will:

• use the information only for the educational purposes for which it was disclosed;
• remain subject to the institution’s applicable control regarding use and maintenance of the records as required by FERPA;
• limit access to individuals who require the information to provide authorized services;
• not redisclose the information except as authorized by the institution or permitted by law; and
• maintain appropriate administrative, technical, and organizational safeguards.

Schools remain responsible for determining whether their disclosure and use of Kaimerie satisfies their obligations under FERPA and other applicable education-privacy laws. Institutional customers may also enter into a separate data privacy or services agreement with FOR HER MEDIA LLC.

5. Student Work

Students retain ownership of the original work they create through Kaimerie. Kaimerie may store, process, display, transmit, and reproduce student work only as reasonably necessary to provide the Platform’s educational functions, including assignments, instructor review, progress tracking, and portfolio creation. We do not acquire ownership of a student’s original academic work simply because the student submits or stores it through Kaimerie.

6. How We Disclose Information

We do not sell student personal information. We may disclose information in limited circumstances, including:

Schools and Educational Organizations

Information may be available to the school or organization responsible for the student’s account, including authorized teachers, counselors, instructors, or administrators.

Parents and Guardians

Where appropriate and authorized, parents or legal guardians may receive access to information associated with their child’s account.

Service Providers

We may use service providers that perform functions necessary to operate Kaimerie, such as hosting, storage, authentication, communications, security, and technical infrastructure. We require service providers that receive personal information to use it only for authorized purposes and subject to appropriate privacy, security, and contractual restrictions.

Legal and Safety Requirements

We may disclose information when reasonably necessary to comply with applicable law, legal process, or valid governmental requests, or to protect the safety, rights, and security of Kaimerie, our users, or others. Where education records protected by FERPA are involved, disclosures will also be handled in accordance with applicable FERPA requirements and institutional instructions.

Business Transactions

If FOR HER MEDIA LLC undergoes a merger, acquisition, financing, restructuring, or sale of assets, information may be transferred as part of that transaction, subject to applicable law and protections governing student and children’s information.

7. Advertising

Kaimerie does not sell student personal information for advertising. Kaimerie does not use student personal information to build advertising profiles or serve targeted advertising based on a student’s activity across unrelated websites, applications, or online services.

8. Cookies and Similar Technologies

Kaimerie may use cookies, local storage, and similar technologies when reasonably necessary to:

• keep users signed in;
• remember settings;
• maintain Platform functionality;
• protect accounts;
• detect security threats; and
• understand and improve Platform performance.

We do not use these technologies to create advertising profiles of students.

9. Data Security

Kaimerie uses reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, destruction, or loss. No internet-based system can guarantee absolute security. We therefore continually evaluate safeguards appropriate to the nature of the information maintained by the Platform.

10. Data Retention

We retain personal information only for as long as reasonably necessary to:

• provide Kaimerie;
• maintain a student’s authorized educational record or portfolio;
• fulfill school or organization agreements;
• comply with applicable legal requirements;
• resolve disputes; or
• protect the security and integrity of the Platform.

When information is no longer reasonably necessary, we will delete or deidentify it in accordance with applicable law and contractual obligations. Schools and organizations may have separate requirements governing retention or deletion of student information.

11. Account and Data Deletion

Parents, eligible students, schools, and other authorized account holders may contact Kaimerie regarding correction, access, export, or deletion of personal information. Certain information may need to be retained when required by law, a school agreement, legitimate security requirements, or other applicable obligations. When an institutional relationship ends, student information will be handled in accordance with the applicable agreement and legal requirements.

12. Texas Privacy Rights

Texas residents may have rights regarding their personal data under applicable Texas privacy laws. Depending on the law and circumstances, these rights may include the ability to request:

• access to personal data;
• correction of inaccurate personal data;
• deletion of personal data;
• a portable copy of certain personal data; and
• information about certain data-processing practices.

Some information, including information regulated by federal education or children’s privacy laws, may be subject to different requirements or exemptions. Requests may be submitted using the contact information below. We will authenticate and respond to requests as required by applicable law.

13. No Public Student Profiles by Default

Kaimerie is an educational platform, not a public social-networking service. Student educational records, assignments, achievements, and portfolios are not intended to be publicly available by default. Access to student information is limited according to the account, educational program, and permissions established by Kaimerie and, where applicable, the student’s school or organization.

14. Third-Party Links and Resources

Educational materials may contain links to outside resources. A third-party website or service has its own privacy practices, and this Privacy Policy does not govern information a user independently provides to an unrelated third party. Schools, parents, educators, and students should review the privacy practices of external services before providing personal information.

15. Changes to This Privacy Policy

We may update this Privacy Policy as Kaimerie evolves, new functionality is introduced, or legal requirements change. We will update the effective date when revisions are made. If a change materially affects how children’s or students’ personal information is collected, used, or disclosed, we will provide additional notice or obtain consent when required by law.

16. Contact Information

Questions, privacy requests, or parental requests regarding children’s information may be directed to:

Parents may use this contact information to request review or deletion of personal information collected from a child or to withdraw permission for further collection or use where applicable.