Headsprout is strongly committed to the privacy of customers on our Web Site, and particularly the privacy of children.

We hope this question-and-answer format will assist you in rapidly finding specific Privacy & Security information. Additional information is located below the answers.

If you have additional privacy or security questions or concerns after reading this information, please contact us.

Your Privacy Questions

1. What information does Headsprout collect from me?
2. What information does Headsprout collect from my child?
3. Can I opt-out of providing information?
4. Can I review and modify information I have provided?
5. How does Headsprout protect the information I provide?
6. Does Headsprout sell my information?
7. With whom might Headsprout share my information?
8. Will I get spam (unsolicited emails)?
9. Does Headsprout use cookies?

1. The Children's Online Privacy Protection Act
2. The Children's Internet Protection Act
3. The Family Educational Rights and Privacy Act
4. Our right to make Privacy Policy Amendments
5. Privacy and Security Certifications
6. Registration and Consent
7. Password Protection
8. Contact Us

1. What information does Headsprout collect from me and how does it use it?

Registration Information.
In order for a child to participate in the Headsprout Early Reading (the "Reading Programs"), we permit only parents or a legal guardian of that child to register at Headsprout. During the on-line registration process, we will collect your name, mailing address, email address, phone number and credit card information, including billing address. In order to register your child or children for the Reading Programs, you will be asked to provide your child's first and last name, gender, date of birth and the relationship of the child to you. We call this information "Registration Information."

How Headsprout Uses Registration Information:

• Mailing Address: We may mail storybooks and ancillary program products to you, and to your child in care of you, to the mailing address that you provide.
• Email Address: Your email address will serve as your login username. We will use the email address to send a confirmation email at registration, as well as information and updates to the Reading Programs. We will also send email notifications to you each time your child completes an episode in the Reading Programs and email your child's progress reports to you. We may use the email address as an additional means of communicating with you about the Reading Programs and Headsprout. In addition, if you click on the "opt-in" button during registration (to "opt-in" to receive third-party information), we may use the email address to notify you periodically about third-party information, or third-party promotional and other opportunities.
• Credit Card Information: We will use your credit card information to bill you for each child that you register for the Reading Programs. The prices for the Reading Programs are posted on the Registration Page. If you subsequently register additional children, you may choose to charge the existing credit card or enter another credit card.
• Phone Number: We will use the phone number as an additional means of communicating with you if necessary.
• Child's Name: We will use a child's name to personalize updates about your child's progress in the program. In addition, we may mail program-related material to your child, care of you and at the mailing address that you provide.
• Relationship to Child: We will use this information for demographic profile purposes and to personalize your child's progress reports.
• Child's Date of Birth: We will use a child's age to group Performance Data of children of similar age so we can assess performance by age, and improve the reading program.
• Child's Gender: We will use a child's gender to personalize the Headsprout Reading programs by using the appropriate pronoun for each child.
• Secondary Uses: Headsprout may use Registration Information and other information in the form of aggregate, anonymous statistical information for demographic profiling and targeted advertising.

• Customer's Order and Lesson History: We will maintain a record containing the details of your order and purchase, as well as when lessons are started, stopped, re-started and completed, for client services and operational purposes.

2. What information does Headsprout collect directly from my child?

Performance Data.
Headsprout collects information directly from your child, via the Internet, in the form of the clicks that your child will make when completing an episode of the Reading Programs. We refer to these clicks, and data on when you child starts and stops a lesson, as "Performance Data." We will use Performance Data to (1) measure your child's performance in each episode of the Headsprout Early Reading (the "Reading Programs") and to adapt the Reading Programs to his or her learning needs, (2) analyze your child's Performance Data, and provide you with periodic progress reports about your child's performance in the Reading Program, and (3) improve the Reading Program.

In the event that we ever modify the Reading Program, or any other Headsprout products and services, such that the continued use of the Reading Programs and other Headsprout products and services require the collection of information that is not Performance Data directly from your child, Headsprout will seek your authorization prior to collecting such additional information from your child.

Headsprout may aggregate your child's Performance Data with the Performance Data of other children participating in the Reading Programs for marketing and other business related purposes. Such aggregate information will be anonymous and will not identify your child.

3. Can I opt-out of providing any of the information requested?

Headsprout collects information that is required to ensure the program operates consistently and accurately, or that specifically enhances the effectiveness of the Reading Program. Therefore, all the information we request is mandatory, with the exception of certain marketing information, such as where you heard about Headsprout.

4. Can I review and modify information you collect from me?

You will have the opportunity to review and modify your Registration Information each time you log onto the Headsprout Web Site using your password.

5. How does Headsprout protect my information from loss, misuse or alteration?

Headsprout has security measures in place to protect the loss, misuse or alteration of information under our control. Headsprout uses Secure Sockets Layer (SSL) to encrypt information that you transmit to us over the Internet. Once we receive your transmission, we will store all information on secure servers behind a firewall. As a further security measure, all credit card information will be encrypted.
In addition, only the Headsprout management team and the lead engineers can access the information stored on these servers and in these databases. The Headsprout management team and engineers will continuously review and update the integrity of the Web Site and the security of your personal information.

6. Will Headsprout sell my information to third parties?

Headsprout does not currently sell, trade or assign the information that it collects to third parties, such as mailing houses, market research firms, or advertisers. We, however, may aggregate the information that we collect from users of the Web Site to prepare (1) demographic profiles and (2) performance profiles regarding the progress of children who use the Reading Program. Headsprout may share aggregated information with advertisers, marketing professionals, or potential investors. This aggregated information will be compiled and reported in the form of anonymous group statistics only.

In addition, as Headsprout continues to develop its business, it might sell some or all of its assets. In such transactions, customer information is generally one of the transferred business assets. An acquiring company would be required to protect all information that Headsprout collects from users of the Headsprout Web Site and Reading Programs in accordance with the terms of this Privacy Policy, as amended from time to time.

7. With whom might Headsprout share my information?

Except as provided in this Privacy Policy, Headsprout will not disclose the information that it obtains from you to third parties without your express written permission, or where we believe, in good faith, that the law requires us to disclose the information.

8. Will Headsprout send me unsolicited third-party promotional emails?

No, Headsprout will not send you unsolicited third-party promotional emails. You have the choice to Opt-In to receive third-party email offers and promotions when you register for the program. If you click on the "Opt-In" button, we may occasionally send email messages about third-party offers or promotions that we believe may be of special interest to you. Only Headsprout, or its partners working under confidentiality agreements, may send these direct emails to you. If you do not wish to receive these email announcements, do not choose the "Opt-In" button when registering for your Headsprout account. If you do "Opt-in," you can at any time later "Opt-Out" by changing the option in the Account Management Section to indicate you no longer want to receive such email offers and promotions.

9. Does Headsprout use cookies?

As a standard practice, Headsprout assigns a number to each user of the Web Site to anonymously monitor site traffic patterns, site usage information and complete your web transactions in a secure manner. This random number is stored in a "cookie." A cookie is a small amount of data sent to your browser from our web server and stored on your computer's hard drive, then sent back to the server by your browser each time you access the Web Site. Only Headsprout can access this cookie information and we never store sensitive information such as usernames or passwords in cookies. Cookies enable us to temporarily store information about what pages you visit on the Headsprout Web Site ('Tracking Information'). We use this Tracking Information to manage and administer our Web Site. We also use cookies to store your user ID permanently. Headsprout does not, and cannot, use cookies to retrieve personal information from your computer.

The cookie also allows Headsprout to never log you off the site; each time you return, you never have to log in again. However, if you are using a shared computer such as one at a school, lab or library, be sure to log off after each session. This ensures that no one can then use the same computer to access your account.


Other Privacy-related Information

1. Children's Online Privacy Protection Act

Congress has enacted a law called the Children's Online Privacy Protection Act of 1998 (COPPA) which is designed to protect children's privacy during use of the Internet. Headsprout has implemented the following practices, which are consistent with the guidelines provided by the Federal Trade Commission to date. Headsprout will continually monitor developments in this area and update our practices. If you would like more information about COPPA, please go to http://www.ftc.gov/bcp/conline/edcams/kidzprivacy/.

2. The Children's Internet Protection Act

The Children's Internet Protection Act (CIPA) is a federal law enacted by Congress in December 2000 to address concerns about access to offensive content over the Internet on school and library computers. CIPA imposes certain types of requirements on any school or library that receives funding support for Internet access or internal connections from the E-rate program - a program that makes certain technology more affordable for eligible schools and libraries. In early 2001, the Federal Communications Commission (FCC) issued rules implementing CIPA. Headsprout's reading programs are self contained and do not provide links to external resources or chat rooms. Moreover, Headsprout's reading programs do not contain any offensive or inappropriate mattter. As a result, any school or library that uses Headsprout will be fully compliant with CIPA. If you would like more information about CIPA, please go to http://www.fcc.gov/cgb/consumerfacts/cipa.html.

3. The Family Educational Rights and Privacy Act

The Family Educational Rights and Privacy Act (FERPA) is a Federal law that protects the privacy of student education records. The law applies to all schools that receive funds under an applicable program of the U.S. Department of Education.

FERPA gives parents certain rights with respect to their children's education records. These rights transfer to the student when he or she reaches the age of 18 or attends a school beyond the high school level.

Headsprout is fully compliant with FERPA. Specifically:

• Any sensitive online information is transmitted over secure, encrypted channels via SSL as well as other layers of encryption.
• All student data are stored on secure servers utilizing encryption and firewall technology and are not publically accessible.
• All student performance data is stored in a non-identifiable format.
• Security audits are continuously performed to ensure data integrity.
• Headsprout does not share student information with any third parties. If a school requests that student data should be sent to a third party, Headsprout sends the data to the school and never directly to the third party.

4. Amendments

Headsprout may amend this Privacy Policy from time to time. We will notify you by email regarding any material changes to our privacy and security practices. Please review all revisions to the Privacy Policy. Your continued use of the Web Site and the Reading Programs after the date Headsprout has emailed such notices will be deemed to be your agreement to the changed terms.

5. BBBOnLine and TRUSTe Certification

Headsprout is applying for certification from TRUSTe, and BBBOnline, which are independent, non-profit organizations that seek to build users' trust and confidence in the Internet by promoting the use of fair information practices. These organizations will review Headsprout's internal practices with respect to the collection and use of data from our site to ensure that this Privacy Policy accurately reflects our practices. Once they are satisfied that Headsprout's practices conform to this Privacy Policy, they will certify the Headsprout Web Site. You can learn more about BBBOnline and TRUSTe by visiting their web sites at http://www.bbbonline.org and http://www.truste.org/.

6. Registration and Consent

Although users are able to access some areas of the Web Site without registering, a parent or legal guardian must register and activate a Headsprout account in order for a child to use the Reading Program. You will be asked to submit certain personal information about your child and you as described in this Privacy Policy, and to authorize Headsprout to use that information in a limited number of ways. By providing your credit card number, and reviewing and submitting the Parental Consent as part of the registration process, you will have consented to Headsprout's collection and use of certain information directly from your child over the Internet as described in: What information does Headsprout collect directly from my child?

7. Password Protection

During registration, you will be asked to select a password to access your account. Please keep your password confidential and do not share it with anyone else. You must use your password each time you log on to the Headsprout Web Site and to unlock each episode of the Reading Program. In addition, you will need to use your password to review and change information about your child and you.

8. Contact Us

If you have any questions about your privacy or security measures at Headsprout, please contact our Director of Privacy:

Jeff Bilger
Director of Privacy
Headsprout
127 Broadway Ave E.
Suite #200
Seattle, WA 98102
(206) 329-3660

Or email us at:privacy@headsprout.com