ESTRELLITA, INC.

PRIVACY POLICY FOR DOWNLOADABLE APPLICATIONS, STUDENT PORTALS AND TEACHER PORTALS

This Privacy Policy ("Policy") is part of Estrellita, Inc.’s (hereafter "ESTRELLITA" or "We", "Us" or "Our") Terms of Use. All the paragraphs in Our Terms of Use and Disclaimer are included in this Policy as if specifically written here.

This Policy explains what information We collect through Our applications, teacher portals and student portals (collectively referenced as "Products"). By using Our Products, you agree to Our Terms of Use, including Our Disclaimer and this Policy. This Policy may be updated as Our organization changes. Updates or changes will be posted here.

Acquisition of Information. We do not acquire any more information about individuals purchasing or accessing Our Products than is required by law or is otherwise necessary to provide Our Products unless you provide it to Us voluntarily. We do not provide your personal information to third parties without your consent.

Personal information, as used in this Policy, means your name, email address, street address, phone numbers, birth date, social security number, credit card information, geolocation information and persistent identifiers that can be used to recognize a user over time and across different sites or online services.

In some instances, you may voluntarily submit personal information to Us. For example, you may provide personal and credit card information. If you opt not to provide Us with personal information, you may be unable to have a purchase order fulfilled.

Personal information of a child under 13 years of age (if received with parental or a guardian’s permission) will be destroyed when no longer needed for the purpose for which it was obtained. Personal information of a child under 13 years of age received without appropriate permissions will be destroyed promptly when We learn of the child’s age.

Sharing Your Information. We will use personally identifiable information you provide to us to send you Products or information if you request it. We also collect information from individuals who contact us through the "Contact Us" portion of our website to respond back to you. We will use your personal information to provide you with additional information, materials and news about Our Products that we believe may be of interest to you or to troubleshoot technical problems if you contact us. You may opt out of such communications by contacting us at info@estrellita.com or by selecting the "unsubscribe" link available in each email we send.

Otherwise, We do not share personally identifiable information with third parties unless (a) you, or your parent or legal guardian in the case of a child lacking majority, authorize such sharing, (b) you are using Our Products for educational purposes through your educational institution and the institution has access to your personal information and use of Our Products for assessment purposes, provided, however, that such institution has written authorization from your parent or guardian or (c) We are compelled to share personal information by an order of a duly-empowered governmental authority (including, but not limited to, a court order) or to comply with laws or regulations. In the circumstances detailed in (c) in this paragraph, your information may be divulged without your consent.

Non-personal Information. Personal information does not include Internet protocol (IP) addresses, Cookies (defined below), device identifiers, URLs for web pages and other technical information. Such information is considered non-personal information. Our Products and websites may collect and store this non-personal information as well as technical, non-personally identifiable information about your device. We use this information to improve our Products, our website performance, information security and for other internal purposes.

Deletion of Personal Information. If you would like to review or delete any personal information you have provided to Us, please contact Us at info@estrellita.com. We may request that you verify your identity prior to sharing information with you.

Access To and Control Over the Use of Your Information. You are able to access, correct and update your personal information. You will be asked for your ID and password so that We may be able to process your changes. We will use reasonable efforts to correct any factual inaccuracies in your information. Failure to update such information, however, will not be considered a breach of this Privacy Policy.

Cookies. We may use "Cookies." Cookies are pieces of information that a website transfers to your computer hard drive to remember that your browser software visited a website. Cookies can identify a particular computer, but not an individual user. Third party entities that We use to provide functionality or through whom you have purchased or downloaded a Product may also use their own Cookies. We do not control use of Cookies by third parties and expressly disclaim responsibility for information collected through them.

Browser Cookies are small data files created by a website and stored on your computer. Cookies enable Us to recognize your browser on return visits and to remember your preferences. You may block Cookies through your browser’s preferences and controls, but doing so may disable some of the features of Our Products or website.

Security of Your Information. It is important that you protect your ID and password to keep your information confidential and to protect your account, if any. Always be sure to log out when you are done using Products. We also take certain steps to keep usernames and passwords confidential. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, We cannot ensure or warrant the security of any information you transmit to Us or that We transmit to you. We disclaim any and all liability for disclosure of any information obtained due to errors in transmission or the unauthorized acts of third parties as more specifically detailed in Our Disclaimer.

Linked Websites. Our Products do not provide links to other websites but may use third-party providers such as Google Play or Apple iTunes in order to provide Products. If a hyperlinked website from Our Products exists, the other website may ask for personal information – for instance, if you are purchasing a Product. We have no control over a third party’s use of any personal information you provide. We urge you to exercise care when providing personal information to anyone. We are not responsible for the privacy policies, content or data handling practices on other websites.

Email Inquiry. If you send an email inquiry to Us, the return email address is used for the answer. We do not use the return email address for any other purpose and do not share it with any third-party.

Acquisition of Children’s Information. Our Products are utilized for education and educational assessments. Some Products are intended for use by children under the age of 13. We do not knowingly collect personally identifiable information from children and we do not include links to any third-party websites or social sharing tools in Products intended for such children. If We learn that We have inadvertently collected personally identifiable information from children, We will promptly delete it unless that information is provided to us by an educational institution or government entity with the written consent of the children’s parents or legal guardians. If you have additional questions regarding Our policy relating to children’s information, please contact us as info@estrellita.com.

Protecting children’s privacy is especially important to Us. It is Our policy to comply with the Children’s Online Privacy Protection Act (COPPA) and all other applicable laws. While individuals under the age of 13 may access and view Our Products, We ask that you carefully monitor your children’s activities on Our Products. We believe that there is no substitute for proper parental supervision. We recommend that children ask a parent or legal guardian for permission before sending personal information to Us, or to anyone else online.

Verifiable consent from a child's parent or legal guardian is required before collecting, using or disclosing personal information from a child under the age of 13 once We know that the individual making contact with Us is under 13. We collect no information about you or your child, other than that detailed in this Privacy Policy unless you choose to provide information to Us. If We need to collect information about a child we know to be under 13 years old, the specific web page will specify exactly what information is being collected. We will only use that information for the child’s access to the Products or for ensuring Products work properly. For e.g., our technicians or a child’s educational institution may see personal information if a user experiences technical difficulties or the child’s educational institution may see such personal information in accessing assessments. We will maintain personal information provided to us for one year (July-July) unless requested by a parent, legal guardian or educational institution to retain that information for a longer period.

If you are an educational institution, you agree that you have written parental or legal guardian permissions signed and on file prior to setting up user accounts for your students and have given public notice of the type of directory information or personal information to be disclosed to Us, giving students and their parents or legal guardians the right to opt-out of such disclosure within a specified time period.

There are several exceptions that permit collection of a child's email address without receiving parental consent in advance:

Personal information about children under 13 years of age may be needed to respond to their communication to Us, such as to receive a publication. Personal information about your child will be destroyed immediately upon completion of its intended purpose once We know the request is not from an adult or if We are informed that no parental or legal guardian permission has been signed.

Public Areas of Internet. Please remember that any information you may disclose in any public areas or the Internet becomes public information. You should exercise caution when deciding to disclose personal information in these public areas.

Hackers. Our Products have security measures that are standard in the industry in place to protect the loss, misuse and alteration of the information under Our control. While We make reasonable efforts to ensure the integrity and security of Our network and systems, We cannot guarantee that Our security measures will prevent third-party "hackers" from illegally obtaining this information.

Contact. If you have any questions regarding Our Products or this Privacy Policy, please contact: Webmaster for the ESTRELLITA Products:

6050 Greenwood Plaza Blvd., #120
Greenwood Village, Colorado 80111
Email: info@estrellita.com
Tel: (303) 779-2610.

Last Updated: June 5, 2015