NEELO WEBSITE PRIVACY POLICY

This Privacy Policy describes how Planet 9 Studio, LLC (d.b.a. Neelo) and our subsidiaries and affiliated companies (collectively, “Neelo,” “we,” or “us”) collect, use, disclose, and otherwise process information about you (and your child – if you choose to submit such information) when you use or access our website, https://tryneelo.com, (our “Site”) and when you otherwise interact with us, such as on our parent portal, through our customer support channels, or on social media. We may provide different or additional notices of our privacy practices for certain offerings, in which case those notices will supplement or replace the disclosures in this Privacy Policy. To view our Privacy Policy for the Neelo mobile application, visit https://tryneelo.com/app-privacy-policy.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. If we make material changes, we will provide you with additional notice (such as by adding a statement to the Site or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

Please note that the Site is intended solely for parents and educators and is not intended for children or users under the age of 18. We will not knowingly collect information from our website visitors under the age of 18.

CONTENTS

• Collection of Information
• Use of Information
• Disclosure of Information
• Your Choices
• Contact Us

COLLECTION OF INFORMATION

The information we collect about you depends on how you interact with us. In this section, we describe the categories of information we collect and the sources of this information.

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information directly from you when you sign up for our waitlist, create an account, fill out a form, communicate with us via third-party platforms, sign up for marketing communications from us, request customer support, or otherwise communicate with us. The types of information that we collect directly from you include your name, email address, phone number, device information, prompts submitted to our chat assistant, testimonials you submit about our services, and any other information you choose to provide. We also collect your child’s birth month and birth year, and any other information you choose to provide about your child, including their first name, gender, or photo. If you subscribe to any services or features available through our Site, we work with a third-party payment processor to process your payment information.

Information We Collect Automatically

We automatically collect information about your interactions with us or our Site, including:

• Transactional Information: When you purchase, change, or cancel a subscription, we collect information about the transaction, such as subscription details, purchase price, and the date and time of the transaction.
• Device, Usage, and Activity Information: We collect information about how you access our Site, including data about the device and network you use (such as your hardware model, operating system version, mobile network, unique device identifiers, and browser type). We also collect information about your activity on our Site, including the route by which you access our Site, access dates and times, browsing behavior (such as pages viewed and links clicked).
• Information Collected by Cookies and Similar Tracking Technologies: We use tracking technologies, such as cookies and pixels to collect information about your interactions with the Site and our marketing communications. These technologies help us improve our Site and marketing communications, personalize your experience, and analyze your interactions with us, including to see which areas and features of our Site are popular and count visits. For more information about the cookies and similar tracking technologies we use, and the choices available to you, see the Your Choices sections below.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address or infer that you are looking to subscribe to services or features available through the Site based on your past purchases.

USE OF INFORMATION

We use the information we collect to provide you with access to your account and the parent portal to track your child’s progress on the Neelo App.

We also use the information we collect to:

• Provide, maintain, and improve our products and services;
• Develop new products and services;
• Personalize your experience with us;
• Operate our chat assistant;
• Process and fulfill your orders and facilitate returns and exchanges;
• Send you technical notices, security alerts, support messages, and other transactional or relationship messages;
• Send you marketing communications (see the Your Choices section below for information about how to opt out of these communications at any time);
• Monitor and analyze trends, usage, and activities in connection with our products and services;
• Detect, investigate, respond to, prosecute, and help protect against security incidents and other malicious, deceptive, fraudulent, or illegal activity, and help protect the rights and property of Neelo and others;
• For other business purposes, if used in an aggregated or anonymized manner that does not identify you; and
• Comply with our legal and financial obligations.

DISCLOSURE OF INFORMATION

We disclose personal information as described in this Privacy Policy and in the following ways:

• Vendors and Service Providers. We make personal information available to our vendors, service providers, contractors and consultants who perform services on our behalf, such as companies that assist us with payment processing, fraud prevention, customer service, analytics, and marketing.
• Law Enforcement Authorities and Individuals Involved in Legal Proceedings. We disclose personal information in response to a request for information if we believe that disclosure is in accordance with, or required by, any applicable law, regulation, or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
• To Protect the Rights of Neelo and Others. We may disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Neelo, our users, the public, or others.
• Professional Advisors. We disclose personal information to our legal, educational, financial, insurance, and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• Corporate Transactions. We disclose personal information in connection with, or during negotiations of, certain corporate transactions, including a merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Corporate Affiliates. Personal information is disclosed between and among Neelo and our parents, affiliates, subsidiaries, and other companies under common control and ownership.
• With Your Consent or at Your Direction We make personal information available to third parties when we have your consent or you intentionally direct us to do so.

We also disclose aggregated or de-identified information that cannot reasonably be used to identify you or your child. We maintain and use this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.

YOUR CHOICES

Account Information

You can access, correct, and delete certain information stored within your Neelo account at any time by logging in and navigating to account settings. For any questions relating to your Neelo account information, contact privacy@tryneelo.com.

Cookies and Similar Tracking Technologies

Neelo uses cookies and similar tracking technologies, as described above. You can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect some of the functionality of our Site, such as remembering your preferred settings.

Communications Preferences

You may opt out of receiving promotional emails from Neelo by following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such as those about your account.

CONTACT US

If you have questions about this Privacy Policy, please contact us at privacy@tryneelo.com.