Data Policy

MaKaboom's Privacy Policy

This is the privacy policy ("Privacy Policy") for MaKaboom.school, which is operated by MaKaboom, LLC ("MaKaboom" "we," or "us").

Your privacy is very important to MaKaboom and we are committed to protecting it. We understand that you need to be in control of your personal information. This Privacy Policy explains the manner in which MaKaboom collects personal information from you and the purpose for that collection. This Privacy Policy is designed to ensure that you are aware of how your personal information is being used and to provide you with choices about that use. By visiting MaKaboom.school or submitting your

personal information, you accept the terms described in this Privacy Policy.

MaKaboom.school collects information that identifies you, such as names, telephone numbers, postal addresses, and email addresses ("personal information"), when voluntarily submitted by our visitors and customers. We receive and store any information that you choose to enter through MaKaboom.school, including any submissions that you make or content you provide on or through MaKaboom.school. We do not knowingly collect information from children under the age of 13. Should we learn that a

child

under 13 has provided us with personal information, we will delete that information from our database.

For purposes of this Privacy Policy and MaKaboom.school's Terms of Use, the term "Customer" means any entity, educational institution, school, student (either directly or through the parent or legal guardian if under the age of 18), or individual who has directly purchased a MaKaboom product or service for commercial or personal use. Clients or students of Customers that are entities, educational institutions, or schools must also register with MaKaboom.school and agree to be bound by this

Privacy Policy and the Terms of Use of MaKaboom.school. The term "User" means any entity, educational institution, school, student, end user or individual that has accessed MaKaboom.school.

If you have any questions, concerns or comments regarding this Privacy Policy, you may contact us at the email and address posted at the end of this Privacy Policy. We are committed to addressing your privacy or security questions or concerns.

Personal Information Collected by MaKaboom.school

Any Customer that requests to participate in the MaKaboom products and/or services (the "Services") or any User that accesses MaKaboom.school must register within MaKaboom.school. If the Customer or User is under 18 years of age, a parent or a legal guardian of that Customer and/or User must first register at MaKaboom.school. If a User does not register at MaKaboom.school, the User will not have access to MaKaboom.school's Services. In addition to the personal information, if payment is required for the Services, your credit card information, including your billing address, will be collected. Once you have registered, you may then sign up to be a Customer or to have your clients and/or student(s) be a Customer(s) for the Services. MaKaboom.school requires that all Customers who will receive its Services, either directly or through a parent, entity, school or educational institution of any type must be identified in MaKaboom.school with the following information: the first and last name, gender, current school grade level, and date of birth. We call this information "Registration Information." We will also require a process to verify your consent to the registration and to the collection of your Registration Information. When you participate in the Services, MaKaboom.school will automatically collect information about your patterns of usage, order history, participation in promotions, session data, and other information relating to usage, choices, and preferences,

including that of your student or students. We call this information "Participation History."

How MaKaboom.school will use the information collected from you

Email Address: Your email address may be used to send a confirmation email at registration, as well as information and updates around our Services. For our Customers, your name or other identifier set up at registration will serve as your login username. In addition, for Customers, we will also email your progress information in connection with the Services or your clients' or students' progress information in connection with the Services. For both Users and Customers, we may use the email

address as an additional means of communicating with you about the Services and MaKaboom.school, including notifying you of updates to MaKaboom.school or its related policies.

Name: The Customer's name or the Customer's client or student's name will be used to customize your or your client or student's participation in the Services, as well as to personalize the reports and updates about your progress with the Services or your client or student's progress with the Services. In addition, for our Customers and Users that are individuals or parents or the legal guardian of a student, respectively, MaKaboom.school may send information to you or your student using your

name or, in the case of a student, his/her name, in your care, at the mailing address that you provide.

Phone Number: The User and Customer's phone number will serve as an alternate way of contacting you for the same purposes as the email address. We will never call a Customer under the age of 18 directly.

Credit Card Information: For our Customers and Users that are individuals or parents or legal guardians of a student, respectively, in some cases, with your consent, MaKaboom, our affiliates, subsidiaries or third parties MaKaboom may contract with to provide services on our behalf, including but not limited to: social networking, hosting, web analytics, online behavioral advertising, billing and payment, lead generation, academic, business, career or financial services (collectively "

Business

Partners") may use your credit card information to bill you for each student that you register on MaKaboom.school for the Services.

Date of Birth: If provided, we will use a Customer's age to group Performance Data, as defined below, of Customer of similar age so we can assess performance by age, and improve the Services. Such information will be aggregated with other Users and Customers in an anonymous manner and will not include any information that could be used to identify a specific Customer.

School Grade Level: We will use a Customer's grade level to group Performance Data of Customers of similar grade levels so we can assess performance by grade level, and improve the Services. Such information will be aggregated with other Users and Customers in an anonymous manner and will not include any information that could be used to identify a specific Customer.

Gender: We will use a Customer's gender to personalize the Services' experience. In addition, we will use a Customer's gender to group Performance Data of Customers of the same gender so we can assess performance by gender, and improve the Services.

Mailing Address: A User or Customer's mailing address may be used to allow MaKaboom to mail you various materials and products related to the Services.

Secondary Uses: Registration Information and other information may be used by MaKaboom for demographic profiling and targeted advertising, although, in such cases, the information will be aggregated as ANONYMOUS statistical information. MaKaboom will not sell, trade, or assign any unaggregated, personal information that it collects to third parties outside of MaKaboom, its affiliates and subsidiaries. If MaKaboom shares, sells, trades or assigns any such personal information with a third party,

it will be in accordance with the terms of this Privacy Policy and for the purposes that are discussed below.

Participation History: Participation History will be collected for User and Customer care, development, marketing and other operational and business purposes, including improvements to the Services by MaKaboom.

Other uses that MaKaboom.school may have for the personal information, Registration Information and Participation History collected include:

To respond to your inquiries and provide customer support;

To administer promotions in which the User and Customer have indicated an interest;

For our internal marketing purposes, which include, but are not limited to, sending the User and Customer material about products, services, updates, etc. that we think may be of interest to the User and Customer;

For investigation of information security and information asset protection-related incidents;

To test, correct and improve our content, applications and Services;

To develop new applications, products and services;

To improve MaKaboom.school and Service performance and delivery;

To prevent potentially illegal activities (including illegal downloading of copyrighted materials in accordance with our Copyright Infringement policy included in our Terms of Use);

To investigate suspicious information that denotes illegal activity such as financial aid fraud;

To analyze academic and learning outcomes and preferences of the User and Customer;

To analyze risk and business results;

To obtain payment for services that we provide to the User and Customer;

To maintain business records for reasonable periods;

To enforce our Terms of Use;

To provide to affiliates and subsidiaries in connection with the contemplated or actual reorganization, merger, acquisition, financing, securitization, insuring, sale or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed with such transaction or fulfilling any records or other reporting requirements to such parties. In the event of any actual reorganization, merger or acquisition, such information may be transferred as part

of

the transaction to the acquirer; and/or

As may be required or permitted by legal, regulatory, industry self-regulatory, insurance, audit or security requirements applicable to MaKaboom, our affiliates and subsidiaries.

Information MaKaboom.school collects directly from your student

MaKaboom.school collects information directly from the User or Customer, over the Internet, in the form of the interactions that the User or the Customer makes when participating in the Services. We refer to the data resulting from such participation, which includes but is not limited to data on when the Customer or the Customer's client or student starts and stops a lesson, the responses the Customer or the Customer's client or student makes to questions asked, the timing of the Customer or

the Customer's client or student's responses, the Customer or the Customer's client or student's choice of character and customizations, and the choice of lessons to play as "Performance Data." We will use Performance Data to:

Measure the Customer or the Customer's client or student's performance in the MaKaboom.school Services and to adapt the Services to his or her learning needs;

Analyze the Customer or the Customer's client or student's Performance Data, and provide the Customer or the Customer's client or student with periodic progress reports about the Customer or the Customer's client or student's performance in the Services, and

Improve the Services.

If we ever need to collect information that is not Performance Data directly from a Customer, MaKaboom.school will seek authorization of a parent or guardian, if the Customer is under the age of 18, prior to collecting such additional information from the Customer. In addition, we may aggregate the Customer or the Customer's client or student's Performance Data with the Performance Data of other Customer participating in the Services for marketing and other business related purposes.

Aggregate

information will be ANONYMOUS and will not identify the Customer or the Customer's client or student or be combined with other information that would allow individual Customers to be identified.

Opting-out of providing the information we request

Because the MaKaboom.school Services are individualized and customized for each Customer, all the information we request from the Customer or the Customer's client or student is required for the Customer or the Customer's client or student to participate in the Services, with the exception of certain information to be used for our marketing purposes to you only. At any time, the Customer or the Customer's client or student may revoke the consent to participate in the MaKaboom.school Services or refuse to allow MaKaboom.school to further use or collect the Customer or the Customer's client or student's personal information. Any ANONYMOUS Performance Data will be retained, but we will no longer use any identifiable information regarding the Customer or the Customer's client or student that has been provided. However, if the Customer or the Customer's client or student does any of the foregoing, the Customer or the Customer's client or student will not be able to participate in the

Services.

Reviewing and changing your information

The User, Customer or the Customer on behalf of its client or student may review and modify your Registration Information at any time by accessing MaKaboom.school using your password.

Consent

In order to use and/or access the Services, the Customer or the Customer's client or student will be asked to submit certain personal information about the Customer or the Customer's client or student and to authorize MaKaboom.school to use that information in a limited number of ways. For our Customers that are individuals or our Users that are a parent or legal guardian of a Customer under the age of 18, we will require you to review and submit a Parental Consent as part of the

registration

process, which will require you to consent to our collection and use of information directly from your child over the Internet as described above.

Password Protection

The Customer or the Customer's client or student will be asked to select a password to access the Services through MaKaboom.school, and this password will be used to allow the Customer or the Customer's client or student to use the Services. The Customer or the Customer's client or student password should be kept confidential. The Customer or the Customer's client or student password will also allow the Customer or the Customer's client or student to review and change the information we collect

about the Customer or the Customer's client or student.

Protecting your information

No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information the User, Customer or the Customer's client or student transmits to us. As such, the User, Customer or the Customer's client or student does so at his/her own risk. MaKaboom.school has multiple security measures in place to protect the loss, misuse or alteration of information under our control.

The Services are hosted in the United States. If the Customer or the Customer's client or student are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that the User, Customer or the Customer's client or student are transferring their personal data to the United States, which does not have the same data protection laws as the EU or other regions; by providing the User, Customer or the Customer's client or

student personal data, the User, Customer or the Customer's client or student consent to the use of their personal data for the uses identified above in accordance with this Privacy Policy and the transfer of the User, Customer or the Customer's client or student personal data to the United States as indicated above.

The User, Customer or the Customer's client or student personal information and third parties

Except as provided in this Privacy Policy, MaKaboom.school WILL NOT disclose the personal information that it obtains from the User, Customer or the Customer's client or student to third parties without the User, Customer or the Customer's client or student express written permission, or where we believe, in good faith, that the law requires us to disclose the information.

MaKaboom.school WILL NOT sell, trade, or assign any unaggregated personal information that it collects to third parties outside of MaKaboom.school. If MaKaboom.school shares, sells, trades or assigns any such personal information with a third party, it will be only be after it obtains the User, Customer or the Customer's client or student express written permission. We, however, may aggregate the information that we collect from Users and Customers to create demographic profiles and performance profiles regarding the progress of Customers or a Customer's clients or students who use the Services. MaKaboom.school 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 such a manner that makes individual Customers or Users unidentifiable. In addition, in order to offer and improve the Services, MaKaboom.school may share Registration

Information about the parents, legal guardians, and school officials that register to participate in the Services, along with such Users or Customers' Participation History, to contractual business partners of MaKaboom.school that are directly involved in the sale, distribution, operation, maintenance, and support of the Services on behalf of MaKaboom.school.

Notwithstanding anything to the contrary, as MaKaboom.school 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 MaKaboom.school collects from Users and Customers and Services in accordance with the terms of this Privacy Policy.

Unsolicited third-party promotional emails

MaKaboom.school will not send the User, Customer or the Customer's client or student unsolicited third-party promotional emails.

Use of cookies

As a standard practice, MaKaboom.school uses "cookies". A cookie is a small amount of data sent to your browser from our web server and stored on your computer, then sent back to the server by your browser each time you access MaKaboom.school. Cookies are used solely for the required operations of MaKaboom.school and our Services. We do not use cookies to collect any personal information, nor do we use them for behavioral advertising, to build a Customer profile unrelated to the use of MaKaboom.school, or for any other reason. Please note that if the User, Customer or the Customer's client or student refuses the MaKaboom.school cookie (by turning cookies off in your browser or by clicking "don't accept" if you have set your browser to warn you before accepting cookies), this may render MaKaboom.school and our Services unusable to the User, Customer or the Customer's client or student. Cookies cannot be used to gather personal information from the User, Customer or the

Customer's client or student computer.

Children's Online Privacy Protection Act

For the parents or legal guardians of Customers or Users that are under the age of 18: Congress has enacted a law called the Children's Online Privacy Protection Act of 1998 (COPPA) that is designed to protect children's privacy during use of the Internet. MaKaboom.school has implemented practices consistent with the guidelines provided by the Federal Trade Commission to date. MaKaboom.school will never knowingly request, obtain, use or disclose personally identifiable information or private content from anyone under the age of 13 without parental consent. You must be the parent or legal guardian to grant such consent. If we receive this parental consent, we may receive personal information from children under the age of 13 listed on your subscription account in order to provide our Services to them. MaKaboom.school DOES NOT SHARE CHILDREN'S PERSONALLY IDENTIFIABLE INFORMATION WITH THIRD PARTIES. If you are a parent or legal guardian of a user under 13 you may, at any time, revoke

your consent to allow your student to use the Services under your subscription, refuse to allow MaKaboom.school to further use or collect your child's personal information, or direct MaKaboom.school to delete all identifiable information regarding your child that you have provided. To do so, please contact our Privacy Officer at the contact information below. However, if you do any of the foregoing, your child will not be able to use the Services.

To the extent that MaKaboom.school collects, uses, or discloses personal information from children under the age of 13, it is done in strict accordance with this Privacy Policy and for the sole purpose of providing Services to the Customer and User.

If you would like more information about COPPA, please go to http://www.ftc.gov/ogc/coppa1.htm.

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" Course - a course that makes certain technology more affordable for eligible schools and libraries. Our Services do not provide

links

to external resources or chat rooms, and do not contain any offensive or inappropriate material. If you would like more information about CIPA, please go to http://www.fcc.gov/cgb/consumerfacts/cipa.html.

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 Course 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. MaKaboom.school is compliant with FERPA by assuring its Customers and Users that:

Any sensitive online information is transmitted over secure channels;

All Customer and User data are stored in ways that are not publicly accessible; and

Security audits are regularly performed to ensure data integrity.

MaKaboom.school does not share information with any third parties that could be used to personally identify Customers or Users. If a Customer that is an entity, educational institution or school requests that a client or student's data be sent to a third party, with parental consent, MaKaboom.school will send the data to the Customer and never directly to the third party.

If you would like more information about FERPA, please go to http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html.

Amendments

MaKaboom.school may amend this Privacy Policy from time to time. We will notify the Customer or the Customer's client or student by email regarding any material changes to our privacy and security practices. Please review all revisions to the Privacy Policy. The User, Customer or the Customer's client or student continued use of MaKaboom.school and the Services after the date MaKaboom.school has emailed such notices will be deemed to be the User, the Customer or the Customer's client or

student's agreement to the changed terms.

Contact Us

If you have any questions about our Privacy Policy and/or your privacy or security measures at MaKaboom.school, please contact our Privacy Officer:

MaKaboom.school

Attn: Privacy Officer

2905 Homestead Rd,

Santa Clara, CA 95051

Or email us at: hongseok@makaboom.com