Coughlan Companies, LLC dba Capstone (“[b]Capstone[/b]”) is committed to protecting the privacy of children who use our sites and applications. Certain Capstone products, such as PebbleGo, Raintree Online, and PebbleGo Create are offered online via our websites (including pebblego.com and online.raintree.co.uk) or mobile applications for children under 13 (collectively, for the purposes of this Policy, the “[b]Products[/b]”). As such, we aim to provide further privacy protections with respect to Personal Information we may collect from or about children via, or in connection with, the Products. This Children’s Privacy Policy (“[b]Policy[/b]”), which is part of the Capstone Products Privacy Notice, explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 13 in the United States and under the age of 16 in the European Union (“[b]child[/b]” or “[b]children[/b]”). All Capstone Products comply with the U.S. Children’s Online Privacy Protection Act ([b]COPPA[/b]). Capstone’s PebbleGo Create product participates in the iKeepSafe Safe Harbor Program and has been reviewed and certified by the Internet Keep Safe Coalition (iKeepSafe) to meet the requirements of the Children’s Online Privacy Protection Act (COPPA) and related privacy laws. The iKeepSafe Safe Harbor certification helps ensure that Capstone maintains practices and policies that protect children’s personal information in connection with PebbleGo Create. For more information about the certification, please visit [url=https://ikeepsafe.org/certified-products/]https://ikeepsafe.org/certified-products/[/url]. COPPA requires us to inform parents and legal guardians (“[b]parents[/b]”) and teachers, administrators, schools, districts and other educators (“[b]educators[/b]”) about our practices for collecting, using and disclosing personal information from children under the age of 13. It also requires us to obtain verifiable consent from a child’s parent for certain collection, use and disclosure of the child’s personal information. For more information about COPPA and general tips about protecting children’s online privacy, please visit [url=https://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online]OnGuard Online[/url]. Capstone also takes its responsibility to support educators with their obligations under the Family Educational Rights and Privacy Act (“[b]FERPA[/b]”) seriously. The collection, usage, access, and transparency practices described in this Policy reflect Capstone’s commitment to support its customers’ FERPA compliance efforts. Please review the Capstone Product End User License Agreement for more details regarding Capstone’s rights and responsibilities with respect to its customers’ FERPA obligations. We understand and are committed to respecting and protecting children’s privacy online. We urge parents and educators to instruct their children/students to never give out their real names, addresses, phone numbers, or any other information that would allow someone to identify or contact the child. If you believe that your child/student has gained access to a Capstone Product without your consent, or if you have any questions or concerns, please contact us at [url=mailto:privacy@capstonepub.com]privacy@capstonepub.com[/url]. For more information about Capstone Corporate privacy practices, [url=/support/privacy/corporate-privacy-notice]visit here[/url]. @h4 What Children’s Personal Information We Collect This section describes the Personal Information collected from or about children via or in connection with the Products. For the purposes of this Policy, “Personal Information” means any personal information relating to an identified or identifiable individual that is collected online. @h4 PebbleGo (Excluding PebbleGo Create), Capstone Interactive, Capstone Connect Educator Tools, and Raintree (Including Raintree Online and Engage Literacy) * Account and contact information. Account and contact information is collected at the parent or educator level. We do not collect this information from children. From time to time, educators may permit access to data through their Identity and Access Management Solution (e.g. Clever, ClassLink, Google Classroom) in order to utilize single sign-on (SSO) and secure sync rostering. Capstone may have access to student information including district and school enrollment, grade level, first and last name, school ID, and Student Information System ID. * Device and usage information. We may also collect a child-user’s IP address, which may provide general location information such as the zip code, state or country from which a child accessed PebbleGo (excluding PebbleGo Create), Capstone Interactive, Capstone Connect, or Raintree products available at pebblego.com, or online.raintree.co.uk, details regarding how and when a child accessed or used PebbleGo, Capstone Interactive, Capstone Connect, or Raintree products, the frequency and duration of usage, the pages viewed and related pageview activity, and other information about a child’s access of or interaction with PebbleGo, Capstone Interactive, Capstone Connect, or Raintree products. Such information may be used and disclosed by Capstone as described in this Policy. * School or district information. School or district information is collected at the parent or educator level. We do not collect this information from children. * Parental Information. When a parent or legal guardian registers for an account, we may collect contact information such as name or e-mail address. We do not collect this information from children. [b][i]This section does not apply to PebbleGo Create, which is described in more detail below. [/b] [/i] @h5 PebbleGo Create We collect the following categories of Personal Information in connection with use or access of PebbleGo Create via pebblego.com: * [b]Account and contact information.[/b] When an account is registered for a child to become a user of PebbleGo Create, we may collect the child’s first and last name, email address, designated username, and password. Educators may permit access to data through their Identity and Access Management Solution (e.g. Clever, ClassLink, Google Classroom) in order to utilize single sign-on (SSO) and secure sync rostering. Capstone may have access to student information including district and school enrollment, grade level, school ID, and Student Information System ID. * [b]Device and usage information.[/b] We also collect a child-user’s IP address, which may provide general location information such as the zip code, state or country from which a child accessed the PebbleGo Create product, details regarding how and when a child accessed or used PebbleGo Create, the frequency and duration of usage, the pages viewed and related pageview activity, and other information about a child’s access of or interaction with PebbleGo Create. * [b]Classroom, school or district information[/b]. We may collect a child’s school address, grade, educator, assignment grades and feedback, and instructional progress and engagement. * [b]Communication information[/b]. We may collect a child’s reactions, comments, and replies to educators’ or other users’ communications when using the Product. * [b]Parental information.[/b] We may collect information concerning a child’s parents or legal guardians, such as name or e-mail address that can be combined with the information described above. This information is collected by Capstone in connection with the creation of a school or district account, as described in more detail below: * Under a PebbleGo Create subscription, only school or district administrators can subscribe to an account. Educator and student accounts are created by syncing the School/District’s roster data with those Identity and Access Management integrations made available via the PebbleGo Create application. We also collect this information when a child uses the features and functionality of PebbleGo Create to engage in educator managed or distributed materials, and to create, share, and post information in PebbleGo Create. Your decision to consent to the provision of a child’s Personal Information is voluntary, but if you choose not to provide any requested information, you or your child may not be able to take advantage of all the features of the Products. We will not require a child to provide more information than is reasonably necessary in order to use the Products. @h5 User Content The PebbleGo Create Product allows users to submit, transmit, share, create, or post information. Such information may include personal information, such as photographs, video or audio files, or recordings of a child’s voice. While this information may be submitted by a user to the Product, Capstone does not specifically collect this information about any user. Further, Capstone does not decide or control how any user-submitted information is used, published, or shared by users. Please note that we have developed an AI-driven question-and-answer knowledge base called “Ask PebbleGo,” which uses a large language model to search our publications for items that may be responsive to certain types of requests. This search capability runs independently and without human interaction. It collects and retains search queries for the purpose of identifying materials that are responsive to the request but does not associate the query with a specific user. @h5 Information that is Automatically Collected In addition to the direct collection in connection with the Products described above, we use technology to automatically collect information from our users, including children, when they access and navigate through the Products and use certain of its features. For more information about the technologies we use and the information collected, see the “Information that is Automatically Collected” section of our General [url=https://www.capstonepub.com/support/privacy/products-privacy-notice]Capstone Products Privacy Notice[/url]. We may combine the information we collect through these technologies with personal information about you or your child that we collect online. For information about our automatic information collection practices, including how you can opt out of certain information collection, see our General [url=https://www.capstonepub.com/support/privacy/products-privacy-notice]Capstone Products Privacy Notice[/url]. @h5 Information Collected from Third Parties In connection with a school, district, or administrator subscription, we may collect information about you or your child from the applicable school, district, or administrator by syncing the School/District’s roster data with the Products utilizing those integrations made available via PebbleGo Create application. @h4 How We Use Children’s Personal Information We use children’s Personal Information we collect from or about your child for the following purposes: * verify if a child is under the age of 13 in the United States and under the age of 16 in the European Union; * verify parental or educational institution consent for the collection and use of a child’s information; * allow children to access their accounts; * allow children to use the Products in accordance with the products’ specifications and documentation; * provide updates about their work or the Products; * track performance in quizzes or other activities; * estimate our audience size and Capstone Product usage patterns; * facilitate the functionality of our websites and mobile applications; * store information about a child’s preferences, allowing us to customize the content according to a child’s individual interests; * to comply with legal and regulatory obligations, respond to lawful subpoenas or governmental requests, as needed; * to maintain, improve, and analyze our Products; * detect, prevent, or investigate suspicious activity or fraud; * maintain appropriate records for internal administrative purposes; * maintain a safe, secure, and trusted environment for children in our Products; * enforce our terms, policies, and agreements; and/or * allow interaction with an educator or school administrator or other users We use cookies and other similar technologies to personalize a child’s experience, analyze user trends, and improve the Products. If a child can be identified from this information, for example by combination with other pieces of information, then we will treat this information as Personal Information. You can learn more about our use of cookies and other tracking technologies in the “Use of Cookies” section of our general [url=https://www.capstonepub.com/support/privacy/corporate-privacy-notice]Corporate Privacy Notice[/url]. [b]We do not[/b] sell children’s Personal Information or use it for advertising purposes (including targeted advertising). Likewise, we do not collect precise geolocation information relating to children. When we collect Personal Information from a child, we retain that information only so long as reasonably necessary to fulfill the activity request or allow the child to continue to participate in the activity, to ensure the security of our users and our services, or as required by law. If we learn that we have received Personal Information from a child that is inconsistent with this Policy, we will delete the data. If you believe that we have received Personal Information from a child in error, please contact us at [url=mailto:privacy@capstonepub.com]privacy@capstonepub.com[/url] to request deletion of that information. @h4 How We Share Children’s Personal Information We may share or disclose personal information collected from children in a limited number of cases, including the following: * with our service providers and vendors if the personal information is necessary for them to perform a business, professional, or technology support function for us (List of Service Providers and Subprocessors can be found [url=/content/dam/capstonepub/support/ThirdPartySubprocessorsCustomersCapstone2026.pdf]here[/url]); * with third parties or government entities as necessary to comply with the law or to respond to claims or comply with legal process served on Capstone (e.g., a lawful subpoena, warrant, or court order); * with legal advisors, as necessary to enforce or apply our policies, terms, or agreements; * with law enforcement, legal advisors, or other necessary third parties in order to protect and defend our rights or property or that of our customers, employees, visitors, or the public; * in connection with an acquisition, liquidation, divestiture, restructuring, reorganization, dissolution, merger, or sale or transfer of some or all of our assets (including the negotiation of the same), whether as a going concern or as a part of bankruptcy, liquidation, or a similar proceeding, where the information is among the items being transferred; * if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure; and * to any other parties for any purpose we disclose to you before a child’s information is collected or to which a child’s parent otherwise consents. The Products also offer social features, including posting on PebbleGo Create Boards or other communication features that allow and enable children to communicate with others through the Products. We do not control the types of information a child can send or post through them. We encourage parents and educators to educate children about safety online and to carefully monitor their children's use of social features to ensure they do not disclose their personal information through them. @h4 Registration Information With respect to Child Accounts as described below, parents/guardians must complete the registration process for their children. With respect to Student Accounts as described below, educators must complete the registration process for their students. When we receive a request from a child to register for a Child Account or from a district/school or an educator to register a child for a Student Account, we will provide direct notice (the “[b]COPPA Notice[/b]”) to the parent/guardian, administrator, or educator, as applicable, via email in accordance with COPPA to, among other things, notify them of the following: * that, with respect to Child Accounts, we have collected the parent’s online contact information and the child’s name from the child for the purpose of getting the parent’s consent to collect, use or disclose personal information from the child; * that verifiable consent from the parent/administrator/educator is required for the collection, use or disclosure of the child’s personal information; * that the school or district is authorizing the collection and use of children’s personal information on behalf of the parent, limited to functions of the school or district that could otherwise be provided by a school official; * that we will not collect, use or disclose personal information from the child without consent; * what additional personal information we intend to collect from the child and how we may disclose the information to others; * how the parent/administrator/educator can access this Privacy Policy; * the rights of the parent/administrator/educator in providing consent; and * that, with respect to Child Accounts, if the parent does not give consent within a reasonable time, we will delete the parent’s and child’s online contact information from our records; and * that the parent/administrator/educator will be provided with notice of any material change in the collection, use, or disclosure practices to which the parent/administrator/educator has previously consented in order to obtain additional consent when there is a material change. @h5 Child Accounts With respect to Child Accounts, before the collection, use or disclosure of personal information from children, we will request verifiable consent from parents. To provide us with verifiable consent, the parent must, among other requirements, * provide or confirm information, including limited, basic, personal information about themselves and their children, as prompted by our registration processes; * agree to abide by our [url=https://www.capstonepub.com/support/legal/product-end-user-license-agreement]Product End User License Agreement[/url] and to ensure that any use of our services by their children does not violate our [url=https://www.capstonepub.com/support/legal/product-end-user-license-agreement]Product End User License Agreement[/url]; * review and edit their child’s username to ensure that no personally identifiable information is present in the child’s username; * review and consent to Capstone’s practices with respect to collecting and using personal information from children under 13 in the United States and under the age of 16 in the European Union; and * print and sign our consent form and return it to us by (1) mailing the signed consent form to Coughlan Companies LLC d/b/a Capstone, ATTN: Data Privacy Administrator, 1710 Roe Crest Drive North Mankato, MN 56003, (2) faxing the signed consent form to 1- 888-262-0705, or (3) scanning and emailing the signed consent form to [url=mailto:privacy@capstonepub.com]privacy@capstonepub.com[/url]. Children may not use PebbleGo Create or other Products until we receive and process this verifiable consent. If we determine that a user is under 13 and we have not received a signed consent form from this child’s parent, we will take steps to delete all or virtually all content posted by the user and take reasonable technical measures to delete all or virtually all stored user information about the user from our records, in compliance with applicable laws. @h5 Student Accounts Where a district/school administrator or an educator registers its students for Student Accounts, we will not obtain verifiable consent directly from parents, but will instead obtain consent from the district/school administrator on the parents’ behalf. In doing so, we presume that the district/school administrator’s or educator’s registration for such accounts and authorization for the collection, use and disclosure of students’ personal information is based upon the district/school administrator or educator having obtained the parents’ consent. In this regard, the district/school administrator or educator will act as the parent’s agent and consent to the collection, use and disclosure of children’s personal information on the parent’s behalf. @h4 Accessing and Correcting a Child’s Personal Information At any time, a parent, educator, school and/or district may review the child’s personal information maintained by us, require us to correct or delete the personal information and/or refuse to permit us from further collecting or using the child’s information. A parent, educator, school and/or district can review, change or delete their child’s personal information by: * Logging into their child’s account and visiting his or her account profile page. * Sending us an email at [url=mailto:privacy@capstonepub.com]privacy@capstonepub.com[/url]. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections. @h4 Additional Steps We Take to Protect Children’s Personal Information When we intend to collect Personal Information from children, we take additional steps to protect children’s privacy, including the following: * In accordance with applicable law, and our practices, we obtain consent from parents/guardians for the collection of Personal Information from their children; * We notify parents or educators , as appropriate, about our information practices with regard to children, including the types of Personal Information we may collect from children, how we may use the Personal Information collected, and whether and with whom we may share that information; * Some of the features on our Products are age-gated so that they are not available for use by children, and we do not knowingly collect Personal Information from children in connection with those features. * We limit our collection of children’s Personal Information to no more than is reasonably necessary to use our Products; and * We give parents access or the ability to request access to Personal Information we have collected from their children and the ability to request that the Personal Information be changed or deleted. @h4 Additional Rights Available Depending on Jurisdiction Depending on the laws of the country or state where a child resides, the parent, guardian, or child may have additional rights with respect to the child’s personal information. For a description of those rights based on jurisdiction, see the [url=/support/privacy/products-privacy-notice]Capstone Products Privacy Policy[/url]. @h4 Operators that Collect or Maintain Information from or about Children Other than Coughlan Companies, LLC, no other operators may collect or maintain personal information from or about children through the Products. All inquiries about our privacy practices and use of children’s information can be directed to the “Contact Us” information below. @h4 Contact Us If you have any questions or suggestions regarding this Policy, please contact us at: Coughlan Companies, LLC dba Capstone Data Privacy Administrator 1710 Roe Crest Drive North Mankato, MN 56003 Email: [url=mailto:privacy@capstonepub.com]privacy@capstonepub.com[/url] Contact number: 888-262-0705 [b]If in the United Kingdom:[/b] Raintree 264 Banbury Road Oxford, OX2 7DY United Kingdom Email: [url=mailto:feedback@raintree.co.uk]feedback@raintree.co.uk [/url] If you believe we have not addressed your concern satisfactorily, you may contact our COPPA Safe Harbor provider at: iKeepSafe Safe Harbor Program Email: [url=mailto:COPPAPrivacy@ikeepsafe.org]COPPAPrivacy@ikeepsafe.org[/url]
