Keens Academy — Children’s Privacy Notice and Verifiable Parental Consent

Operator: Counter Culture US, Inc., a Delaware corporation, doing business as Keens Academy (“Keens Academy,” “Keens,” “we,” “us,” or “our”)

Address: 2035 Sunset Lake Road, Suite B-2, Newark, Delaware, United States

Contact: [email protected]

This Children’s Privacy Notice explains how Keens Academy collects, uses, discloses, and retains personal information from children under 13 in the United States. For learners elsewhere, Keens Academy applies the parental-consent age required by applicable local law where appropriate.

In this Notice, “Child” means a learner who must use the parental-consent process, and “Parent” includes a parent or legal guardian with authority to consent for the Child.

This Notice supplements the Keens Academy Privacy Policy. It does not replace the separate Parent or Legal Guardian Safety Consent for physical participation.

1. When This Notice Applies

This Notice applies before Keens Academy collects personal information directly from a Child when verifiable parental consent is required. The Parent should read this Notice, review the general Privacy Policy, and complete the consent section before the Child creates or activates a child account, appears on camera, records, uploads an assessment, or otherwise provides covered personal information.

Keens Academy does not condition a Child’s participation on providing more personal information than is reasonably necessary for the requested activity.

2. Information We May Collect from or About a Child

Depending on the features selected, we may collect:

A. Child and Account Information

• name, display name, username, account identifier, age or date of birth, country or region, language, and time zone;
• email or login information when appropriate for the child’s age and product design;
• parent name, email, telephone number, relationship, authority, and verification information;
• enrollment, subscription, class, and support records; and
• account security and authentication information.

B. Learning and Assessment Information

• training interests, goals, preferences, skill level, class history, attendance, practice records, and completion status;
• video, audio, images, thumbnails, captions, transcripts, and metadata submitted for an assessment;
• assessment responses, scores, levels, instructor or automated observations, feedback, recommendations, and progress history; and
• communications with instructors or support personnel.

C. Device and Usage Information

• IP address, device and browser type, operating system, language, settings, and approximate location derived from IP;
• device, application, cookie, or session identifiers;
• login time, session activity, pages and features used, errors, security signals, and upload diagnostics; and
• information needed to prevent fraud, abuse, or unauthorized access.

3. How We Collect the Information

We may collect information:

• directly from the Parent;
• directly from the Child after parental consent;
• automatically from the Child’s device while using the Services;
• from an instructor, authorized organization, or support interaction; and
• from a service provider acting for Keens Academy, such as hosting, authentication, payment, communications, video processing, or identity verification.

The camera is intended to remain off by default unless the Child and Parent choose a feature that reasonably requires video or audio. Available non-camera learning and practice features may be used without submitting an assessment recording.

4. Why We Use the Information

We may use the Child’s personal information to:

1. Create, authenticate, and administer the Child’s account.
2. Confirm age, eligibility, parental authority, and consent.
3. Provide classes, practice tools, assessments, evaluation, feedback, progress tracking, and training plans.
4. Communicate with the Child and Parent about the Services.
5. Provide technical support and resolve account or safety issues.
6. Schedule and administer classes and assessments.
7. Protect the Child, other users, and the Services from fraud, abuse, unauthorized access, or harmful conduct.
8. Maintain service reliability using aggregated or de-identified information where reasonably possible.
9. Comply with law and maintain required consent and compliance records.

We will not materially expand these purposes without additional notice and new parental consent when required.

5. Special Rules for Assessment Video and Audio

Assessment recordings are collected only when the Parent and Child choose a feature that requires them. Keens Academy may use a submitted recording only for evaluation, feedback, instructional support, progress tracking, safety or integrity review, and operation of the requested assessment service.

Assessment recordings will not be used for:

• advertising or paid promotion;
• public social-media posting;
• testimonials or public case studies;
• sale or licensing to data brokers;
• targeted advertising; or
• training general-purpose, promotional, or unrelated AI models,

unless Keens provides separate notice and obtains a separate, valid authorization required for the new purpose. Optional marketing permission is handled only through the separate Media and Marketing Consent and is not required for the Child to use the core Services.

6. Who May Receive the Child’s Information

We may disclose the Child’s information only as reasonably necessary to:

• authorized instructors, reviewers, employees, and contractors supporting instruction, assessment, safety, security, or administration;
• service providers for hosting, storage, authentication, communications, payments, support, analytics, security, video processing, transcription, or parent verification;
• a sponsoring organization authorized by the Parent, if applicable;
• law enforcement, regulators, courts, or others when required by law or necessary to protect a person from serious harm; or
• a successor in a corporate transaction, subject to applicable legal protections.

Service providers must process the information only for authorized services to Keens Academy under applicable contract and law. Keens Academy does not sell a Child’s personal information and does not use or disclose it for targeted or cross-context behavioral advertising.

The Child’s assessment recording is not public by default and is not shown to other learners unless the Parent separately authorizes a specific use or the feature clearly requires an authorized group setting.

7. International Processing

Counter Culture US, Inc. is based in the United States. The Child’s information may be processed in the United States or another country where authorized service providers or personnel operate. Privacy laws may differ from those where the Child lives. Where required, Keens Academy will use appropriate safeguards for international transfers.

8. Retention and Deletion

Unless a different period is required or justified and disclosed, our operating defaults are:

• Incomplete or unsubmitted temporary uploads: up to 30 days.
• Submitted assessment video and audio: during active enrollment and up to 12 months after the account’s last activity, unless the Parent requests earlier deletion or separately authorizes a selected Progress Archive.
• Selected Progress Archive recordings: for the stated opt-in period while the option remains active, subject to withdrawal and deletion rights.
• Scores, instructor feedback, levels, training plans, and progress history: while the account is active and up to 3 years after the last activity, unless earlier deletion is required or requested.
• Ordinary support and account records: as needed for the Services and generally up to 3 years after account closure or last interaction.
• Security logs: generally up to 12 months unless a longer period is needed for an incident.
• Consent, withdrawal, transaction, safety, and legal-compliance records: as long as required by law or reasonably necessary to demonstrate compliance and protect legal rights.

We will retain a Child’s information only as long as reasonably necessary for the disclosed purpose. A valid deletion request may shorten these periods unless retention is required by law, necessary for security, or needed to establish, exercise, or defend legal claims. Deleted information may remain in access-restricted backups for up to 90 days before being overwritten or securely deleted.

9. Parent Rights and Controls

A Parent may contact [email protected] to:

• review personal information collected from the Child;
• request correction of inaccurate information;
• request deletion of the Child’s account or personal information;
• refuse further collection or use of the Child’s information;
• withdraw consent for future processing;
• ask who has received the Child’s information; or
• request a copy of this Notice and the consent record.

We may verify the requesting adult’s identity and authority before disclosing, changing, or deleting information. Withdrawing consent may disable a feature that genuinely requires the information, but it will not affect access to available features that do not require it.

10. Security

We use reasonable safeguards appropriate to children’s information, including access controls, authentication, encryption in transit where appropriate, logging, vendor restrictions, staff confidentiality, backup protection, and incident-response procedures. No system is completely secure. Parents should protect account credentials and promptly report suspected unauthorized access.

11. How We Verify Parental Consent

Before collecting covered personal information, Keens Academy will use one or more methods reasonably designed to confirm that consent is given by the Child’s Parent or legal guardian. Depending on the information and legal requirements, this may include:

• a signed consent form returned electronically;
• verified account or payment information used only for confirmation where appropriate;
• identity-document or knowledge-based verification through an authorized provider;
• a staffed telephone or video confirmation;
• an email-plus method permitted for internal-only uses, together with a confirming step; or
• another method permitted by applicable law.

Keens Academy will collect only the verification information reasonably necessary for the method used, protect it, and delete or restrict it when no longer needed, except for limited evidence necessary to document consent.

12. Direct Notice to Parent

By presenting this form, Keens Academy is asking for permission to collect and use the Child’s information as described above and in the Privacy Policy. Consent is voluntary. If consent is not provided, Keens Academy will not activate features that require the Child’s personal information. Camera-off or limited alternatives may remain available where reasonably possible.

13. Verifiable Parental Consent

Child’s Full Legal Name:

Child’s Date of Birth: _

Child’s Country/Region of Residence: _

Child’s Account Email or ID, if any:

Parent / Legal Guardian Full Legal Name: ___

Relationship to Child: _

Parent / Guardian Email:

Parent / Guardian Telephone: _

Parent / Guardian Country/Region: __

☐ I confirm that I am the Child’s parent or legal guardian and have authority to provide this consent.

☐ I have read the Keens Academy Privacy Policy and this Children’s Privacy Notice.

☐ I authorize Keens Academy to collect, use, and disclose the Child’s account, learning, device, usage, and support information as described for operation of the Services.

☐ I authorize the Child to use optional assessment features that collect video or audio solely for evaluation, feedback, instructional support, progress tracking, safety or integrity review, and operation of the requested assessment service.

☐ I understand that marketing and promotional use is not included and requires a separate optional consent.

☐ I understand that I may review or delete the Child’s information, refuse further collection, or withdraw consent by contacting [email protected].

Verification Method Used:

Verification Reference / Evidence ID: _

Electronic Signature / Typed Full Legal Name:

Date and Time: __

Notice and Consent Version: 1.0

14. Contact

Counter Culture US, Inc. d/b/a Keens Academy

2035 Sunset Lake Road, Suite B-2

Newark, Delaware, United States

Email: [email protected]