COPPA Policy

Last Updated: January 18, 2021

Synthesis School, Inc. (“Synthesis,” “we,” “our” or “us”) values the privacy of children and of all of our students. This COPPA Policy (“COPPA Policy”) is designed to comply with the Children’s Online Privacy Protection Act and its rules (as amended, “COPPA”). COPPA requires us to inform parents and legal guardians (as used in this policy, collectively, “parents”) about our practices for collecting, using, and disclosing personal information from or about children under the age of 13 (collectively, “children”). It also requires us to obtain verifiable consent from a child’s parent for the collection, use, and disclosure of the child’s personal information.

Synthesis provides an on-line school based on team games and simulations designed to develop complex problem solving and communication skills with the goal of producing innovative kids (the “Synthesis School”).

This policy notifies parents of:
-The types of information we may collect from or about children.
- How we use the information we collect.
- Our practices for disclosing that information.
- How he or she can access and correct his or her child’s personal data and information

This policy only applies to children under the age of 13 and supplements our general privacy policy located at www.synthesis.is/privacy. Our general privacy policy only applies to minors 13 and over and adults. All capitalized terms not defined in this policy shall have the meaning given to them in the general privacy policy.

Capitalized terms that are not defined in this COPPA policy shall have the meaning given to them in our general privacy policy or our Terms of Service. 

Except as specifically provided in this COPPA Policy, we do not collect any personal information directly from children, only from their parents. 

Data and other Information We Collect from or about Children
To apply for admission to the Synthesis School, a parent must provide the child’s first and last name, his or her date of birth and a video recording of the child’s response to the application question.

We may record the classes that a child attends at the Synthesis School. We will only use these recordings for quality control and to improve the Synthesis School and to ensure compliance with our Terms of Service, including responding to any alleged Prohibited Behavior (as defined in the Terms of Service (e.g., bullying, harassment, etc.)). 

We do not collect more personal information about a child than is reasonably necessary to apply for admission to the Synthesis School and for the child to participate in the Synthesis School.

Automatic Information Collection and Tracking
We use technology to automatically collect information from our users, including children, when they access and navigate through the Site and the Synthesis School and use certain of its features. The information we collect through these technologies may include:
- One or more persistent identifiers, such as the IP address, that can be used to recognize a user over time and across different websites and online services
- Browser information, including what browser a child is using. 
- Actions while visiting the Site or participating in the Synthesis School, including log-in time and when a child clicks the log-in link that we sent.

We do not combine non-personal 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 “Choices About How We Use and Disclose Your Data” sections of our general Privacy.   

How We Use Your Child’s Data or other Information
We use the personal information we collect about your child to: 
- decide whether to admit your child to the Synthesis School;
- enable your child to participate in the Synthesis School;
- provide the Synthesis School;
- maintain a record of the levels that your child has completed;
- understand how students access and use the Synthesis School; and
- improve our Site, the Synthesis School and the other Synthesis School Services.

Our Practices for Disclosing Children’s Information
We do not share, sell, rent, or transfer children’s personal data or other information other than as described in this section.

We may disclose anonymized or aggregated data and other information about our users, including children. In addition, we may disclose children’s personal data and other information:
- If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Synthesis, our customers or others, including to:
           - protect the safety of a child;
           - protect the safety and security of Synthesis or the Synthesis School; or            - enable us to take precautions against liability.
- To law enforcement agencies or for an investigation related to public safety.

In addition, if Synthesis is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Synthesis’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the personal data and other information we have collected or maintain to the buyer or other successor.

Social Features
We enable minors that are enrolled in the Synthesis School to communicate with each other through the chat feature on Zoom during class (“Social Features”). The nature of these features allows children to disclose personal information about themselves. We do not control the types of information that your child can send or post through them. We do monitor information after it has been posted but we do not control the actions of other students with whom your child shares his or her information. We encourage parents to educate their children about safe internet use and to monitor their children’s use of the Social Feature to ensure they do not disclose their personal information through them. 

Accessing and Correcting Your Child’s Personal Data and Information
You may review your child’s personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from using the child’s information at any time. 

You can review, change, or delete your child’s personal data or information by sending us an email at admin@synthesis.is. 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. We will use commercially reasonable efforts to respond to your request within thirty (30) days.

Changes to This COPPA Policy
It is our policy to post any changes we make to this COPPA policy on this page with a notice that the COPPA policy has been updated on the home pages of the Site for at least 30 days. If we intend to make a material change in the collection, use, or disclosure practices with respect to a child’s previously-collected personal data or other information to which a parent has previously consented, we will contact this parent by email to obtain his or her consent. The date the privacy policy was last updated is identified above. You are responsible for ensuring that we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting the Site and this COPPA policy to check for any changes.  Your use, and/or continued use after our efforts to contact you, of the Site, the Synthesis School or any of the other Synthesis School Services, means that you agree to be bound by such changes.

Survival
The policies indicated in this COPPA policy will remain effective, even if the Terms and the other agreements between us are terminated and you are no longer using the Site, the Synthesis School or any of the other Synthesis School Services.

Contact Information
To ask questions or comment about this COPPA policy and our privacy practices or need to reach us for any other reason, you may contact us by e-mail at admin@synthesis.is or by mail at Synthesis School, Inc., 8605 Santa Monica Blvd, PMB 68274, West Hollywood, California 90069.

© 2021 Synthesis School, Inc.