COPPA Direct Notice to Schools Acting as Agents for Parents With Children Under the Age of 13

Effective Date: 04/01/2025

Under the Children’s Online Privacy Protection Act (COPPA), 15 U.S.C. § 6501 et seq. and implementing regulations, 16 C.F.R. 312, online operators such as SkilRedi Corporation (“SkilRedi,” “we,” “our,” “us”) must provide direct parental notification (“Direct Notice”) and obtain verifiable parental consent before collecting personal information from children under the age of 13 (“Children” “Child”). However, where an educational institution has contracted with an operator to collect personal information from Children for the use and benefit of the school, and for no other commercial purpose, the operator is not required to obtain consent directly from parents under COPPA, and can presume that (1) the school is acting as an agent for parents and (2) the school’s authorization for the collection of Children’s personal information is based upon the school having obtained the parents’ consent. In this case, the operator must provide the school with Direct Notice of its collection, use, and disclosure practices.

By executing a services agreement with SkilRedi, the school provides consent, on behalf of Children’s parents or guardians, to SkilRedi’s collection, use, and disclosure of personal information from and about Children through Services.

This notice serves as SkilRedi’s Direct Notice to educational institutions (“schools,” “you”, “your”) of our information collection use and disclosure practices with respect to Children registered for SkilRedi accounts.

Information We Collect About Children.

Information We Collect Directly. When a Child uses or interacts with our online services, the Child may provide us with personal information. In connection with administering a SkilRedi account, the Child may provide us with:

• First and last name
• Birth date
• Email address
• Username and Password

Information We Collect Automatically. We may automatically collect information about a Child’s use of Services through our servers and in log files, such as the following: domain name; browser type and operating system; web pages viewed; links clicked; the length of time spent on Services; the length of time Services is used; the referring URL; language information; device name and model; operating system type, name, and version; and activities within Services.

We may also collect IP address, or a similar unique identifier from Child users of Services; we use such identifiers solely to support the internal operations of our Services, including to maintain or analyze their functioning; perform network communications; authenticate users or personalize content; and protect the security or integrity of users and Services. We never use unique identifiers to track Child users across third-party apps or websites.

How We Share Information.

We disclose the personal information we collect about Children in the following ways:

• Schools: We will disclose Children’s personal information to the Child’s school upon the request of the school.
• Third-Party Service Providers. We may disclose a Child’s personal information to third-party service providers who perform functions on our behalf and/or on behalf of a school to provide Services.
• Business Transfers. If we are acquired by or merged with another company, if all or a portion of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the personal information we have collected about Children to the other company.
• In Response to Legal Process. We may disclose personal information that we have collected from Children to comply with applicable law, a judicial proceeding, court order, or other legal process.
• To Protect Us and Others. We may disclose personal information that we have collected from Children where we believe it is necessary to investigate, prevent, or act regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or our policies, or as evidence in litigation in which SkilRedi is involved.

SkilRedi does not collect any personal information from or about Children until the school provides its consent by executing a services agreement with SkilRedi. In the rare case that SkilRedi incidentally collects any personal information about Children prior to receiving this consent, it will delete such information if the school does not provide timely consent. After Services implementation, parents can direct SkilRedi to stop collecting personal information from their Children; however, in such cases the Children will not be able to use Services. If SkilRedi receives direction from a parent or guardian to stop collecting and using their Child’s personal information, we will notify the school of the request and disable the Child’s access to Services.

It is your responsibility to ensure Children’s parents receive copies of this Direct Notice and our Children’s Privacy Policy. For a complete explanation of our information practices related to Children’s personal information, please see the SkilRedi COPPA Privacy Policy.

Upon your request, SkilRedi will provide (1) a description of the types of personal information collected, (2) an opportunity to review a Child’s personal information, (3) the right to have a Child’s personal information deleted, and (4) the opportunity to prevent further use or online collection of a Child’s personal information.

You may reach out to contact@skilredi.com if you have any questions about SkilRedi’s COPPA practices.

SkilRedi COPPA Privacy Policy

Effective Date: 04/01/2025

This COPPA Privacy Policy (“COPPA Policy”) serves as the SkilRedi Corporation (“SkilRedi”, “we”, “our”) online notice under the Children’s Online Privacy Protection Act (“COPPA”) and describes how we collect, use, and disclose the personal information we collect about Children who use our Services that are directed to Children. In this policy, “Child” or “Children” means a user under 13 years old. This COPPA Policy also explains how a parent or guardian (“parent” or “you”) can restrict the collection, use and/or disclosure of your Child’s information and how you can request deletion of your Child’s information.

SkilRedi Services

SkilRedi is a university-incubated information technology startup that works to provide comprehensive training programs to enable individuals to acquire the skills and knowledge needed to pursue careers in advanced technologies. Our learning management system uses virtual and augmented reality and digital twin interfaces to train technicians and elevate workforce skills. This COPPA Policy refers to all of these SkilRedi services collectively as the “Services”.

Under the Children’s Online Privacy Protection Act (COPPA), 15 U.S.C. § 6501 et seq. and implementing regulations, 16 C.F.R. 312, online operators such as SkilRedi must obtain verifiable parental consent before collecting personal information from Children. However, where an educational institution has contracted with an operator to collect personal information from Children for the use and benefit of the school, and for no other commercial purpose, the operator is not required to obtain consent directly from parents under COPPA, and can presume that (1) the school is acting as an agent for parents and (2) the school’s authorization for the collection of Children’s personal information is based upon the school having obtained the parents’ consent.

By executing a services agreement with SkilRedi, the school provides consent, on behalf of Children’s parents or guardians, to SkilRedi’s collection, use, and disclosure of personal information from and about Children through Services.

This COPPA Policy applies to:

• Child users of SkilRedi, a learning management system that schools, including administrators and teacher end users (collectively, “Schools”), use to facilitate learning outcomes.

This COPPA Policy does not apply to:

• Any personal information we collect about non-Child users (e.g., students over 13 years old, teachers, and parents) through our Services or any personal information we collect through other SkilRedi services that are not directed to Children. All such personal information is subject to the SkilRedi Privacy Policy, available here.

Who Operates the Services?

SkilRedi operates the Services and will collect personal information about Children as described in this COPPA Policy. We can be contacted at: contact@skilredi.com.

What Information Do We Collect About Children?

Information We Collect Directly. When a Child uses or interacts with our online services, the Child may provide us with personal information. In connection with administering a SkilRedi account, the Child may provide us with:

• First and last name
• Birth date
• Email address
• Username and Password

Information We Collect Automatically. We may automatically collect information about a Child’s use of Services through our servers and in log files, such as the following: domain name; browser type and operating system; web pages viewed; links clicked; the length of time spent on Services; the length of time Services is used; the referring URL; language information; device name and model; operating system type, name, and version; and activities within Services.

We may also collect IP address, or a similar unique identifier from Child users of Services; we use such identifiers solely to support the internal operations of our Services, including to maintain or analyze their functioning; perform network communications; authenticate users or personalize content; and protect the security or integrity of users and Services. We never use unique identifiers to track Child users across third-party apps or websites.

How Do We Collect Information?

We may collect information about Children directly from Children and/or their schools, as well as automatically through a Child’s use of our Services. We will not require a school or Child to disclose more information than is reasonably necessary to use our Services.

How Do We Use The Information We Collect?

We use personal information about Children to provide the Services. We do not use personal information about Children for our own commercial purposes.

Schools decide how they will use our Services and schools are responsible for ensuring that their collection and use of personal information from Children through the Services complies with applicable laws. If you are a parent and you have questions about your Child’s school’s use of our Services, you should discuss your questions with your Child’s school.

We may use information we collect automatically to analyze trends, administer the Services, track users’ movements around the Services, gather demographic information about our user base, and better tailor our Services to our users’ needs. Except as noted in this COPPA Policy, we do not link this automatically collected data to a Child’s personal information. We use deidentified or aggregated data to improve our Services.

We may use information we collect to notify and communicate with the school or parents about a Child’s use of our Services.

Parents can tell us to stop collecting personal information from their Children; however, in such cases the Children will not be able to use our Services. If you direct us to stop collecting and using your Child’s personal information, we will notify the school of your request and disable your Child’s use of our Services.

How Do We Share Children’s Information?

We do not sell personal information about Children, and there is no means for a Child to make his or her personal information public through our Services (though schools may choose to share a Child’s information and responses with the Child’s classmates or with other teachers). We will disclose the personal information that we collect about Children only as follows:

• We will disclose Children’s personal information to the Child’s Instructor as directed by the Child’s school. Parents may request information about the information we have collected from their Child(ren) by contacting us at contact@skilredi.com.
• Third-Party Service Providers. We may disclose a Child’s personal information to third-party service providers who perform functions on our behalf and/or on behalf of a school to: provide the Child and the Child’s school with the Services that we offer; conduct quality assurance testing; facilitate creation of accounts; provide technical support; and/or provide other services to us. These third-party service providers are permitted to use personal information only to provide the services requested by SkilRedi or the school.
• Business Transfers. If we are acquired by or merged with another company, if all or a portion of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the personal information we have collected about Children to the other company. We will notify all users of any material change in our information practices, as well as any choices users may have regarding their personal information.
• In Response to Legal Process. We may disclose personal information that we have collected from Children to comply with applicable law, a judicial proceeding, court order, or other legal process.
• To Protect Us and Others. We may disclose personal information that we have collected from Children where we believe it is necessary to investigate, prevent, or act regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or our policies including this COPPA Policy, or as evidence in litigation in which SkilRedi is involved.
• Disclosure to Other Third Parties Only with Consent. Beyond the disclosures described in this COPPA Privacy Policy, SkilRedi will disclose a Child’s information to any other third party only at a School’s direction.

Our Use of Cookies

We use cookies and similar technologies to collect personal information about a Child’s use of our Services. “Cookies” are alphanumeric identifiers that we transfer to a computer’s hard drive through a web browser for record-keeping purposes. We may use both session Cookies (which expire once a user closes a web browser) and persistent Cookies (which stay on a computer until a user deletes them). Some Cookies make it easier for a Child to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track a Child’s activities on our Services for operational purposes.

Third-Party Analytics. We may also use third-party analytics tools and technologies, such as Google Analytics, to track and analyze data from our Site or Services. These tools use Cookies and similar technologies to collect information such as how often users visit the Site, what pages they visit, and what other sites they used prior to coming to the Site. We use the data collected by such third-party analytics tools only to help us administer and improve the quality of our Site, Apps, and Services and to analyze Site and Apps usage. These third parties are not permitted to use the information collected on our Services, except to help us conduct and improve our business. Google’s ability to use and share information collected by Google Analytics about a user’s visits to the Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. For more information on Google’s privacy practices, please click here. For information about how to opt out of Google Analytics, please click here.

Third-Party Links

Schools may provide Children with links to third-party educational and learning resources located on third-party websites or apps, through our Services. Any access to and use of such linked websites and apps is not governed by this COPPA Policy, but instead is governed by the privacy policies of those third-party websites and apps. We are not responsible for the information practices of such third-party websites and apps.

Rights to Review, Delete, and Control Our Use of Children’s Personal Information

Parents and Schools can review or have the information collected from their Child(ren) or students(s) deleted. Parents may also refuse to permit further collection or use of such information. To do so, please contact us at: contact@skilredi.com

You will be required to authenticate yourself as the Child’s parent or school to receive information about that Child. Please note that we cannot delete copies of information that a Child’s school has already collected and/or copied, and copies of information that you have deleted may remain in archives for a period of time.

Changes to this COPPA Policy

This COPPA Policy is current as of the effective date set forth above. We may change this COPPA Policy from time to time, so please be sure to check back periodically. If we make any changes to this COPPA Policy that materially affect our practices regarding the personal information we have previously collected from a Child, we will provide your Child’s school with notice of the revised COPPA Policy and request renewed consent in advance of such change becoming effective. The revised COPPA Policy will also be posted and highlighted on our Site.