Hearing Milestones Online Privacy Policy

Hearing Milestones, LLC Privacy Policy

Last Updated: May 11, 2020

Hearing Milestones, LLC ("Company", "we", or "our") is committed to protecting the

privacy of everyone who uses our site or curriculum software program (individually the “Site” and

“Application”, collectively “Services”). This Privacy Policy ("Policy") explains our information

collection, disclosure, and management practices with respect to information collected on children

(generally under the age of 13 in the US, or as determined by applicable local law) (each a "child"

or "children") and other users of our Services. This Policy applies to Company's Site,

www.hearingmilestones.com, along with the Application. Any third parties described below that

process your data may not adhere to this Policy; Company expressly disclaims any and all liability

for unauthorized processing by such third parties.

We do not currently collect personal information or personally identifiable information on

children who use our Services or Application, as the terms ‘personal information’ and ‘personally

identifiable information’ are defined by the Children’s Online Privacy Protection Act (COPPA)

and the Family Educational Rights and Privacy Act (FERPA) respectively. However, out of a

respect for the importance of the Data and an abundance of caution, we have chosen to treat certain

Data in a manner that is more protective than prescribed by applicable law. PLEASE DO NOT




  1. Data We Collect. Together and as defined below, the Account Data, Site Data,

Verification Data, and School Data all comprise "Data". We collect only the Data we

believe is reasonably necessary to provide the Services to our users. For more information

about COPPA, and general tips about protecting children's online privacy, please visit

the FTC's website.

  1. If you sign up for email updates on our Site, we collect your email address. We may

see if you click through those emails.

  1. When you pay on our Site, we require certain financial information (like your bank

account or credit card information) in order to process payments and comply with

applicable law. If you sign up for an account on our Site, we may collect an email,

your name, password, your physical address, and a history of your orders from the

Site (all of the above collectively “Account Data”)

  1. If you are a parent, guardian, or teacher attempting to verify your identity, we may

collect information like identification cards, email address, or photograph

("Verification Data").

  1. When you create an account in the Application, we will ask for a username and

password. When a user completes activities, we will collect their answers and

evaluation scores. The information relating to the user’s identity and activities in

the Application is collectively School Data. Under no circumstances should you

put any personally identifiable information in your login credentials, like first and

last name, birthday, or otherwise. We will not be responsible for any personally

identifiable information placed in your account by you.

  1. When you browse the Site, we track things like IP address, pages you view, and

functions you request like sign-on, identity verification, and general security

functionality, using cookies, pixels, and similar identifiers ("Site Data").

  1. Uses of Data. We use your Data as follows.
  2. Marketing
  3. We do not serve ads in the Services, we do not perform behavioral

advertising on the Services, nor do we retarget visitors to the Site solely

because of their visit to the Site.

  1. If you are of legal age and choose to receive email updates from us by

providing your email address, we may send you updates on the Company,

information on products relevant to you, and other relevant marketing

communications. You can unsubscribe from these emails or via the

unsubscribe link in the email.

  1. We may use Verification Data to validate and provide support to accounts in

compliance with applicable law, including COPPA and FERPA.

  1. If you believe your child is participating in an online activity with

Company that collects their information, and neither you nor the

child's teacher has received an email providing notice or seeking

your consent, please contact jen@hearingmilestones.com. We will

not use any emails provided for parental consent purposes to market

to the parent, unless the parent has expressly opted-in to email

marketing or has separately participated in an activity that allows for

such email contact.

  1. We use Account Data to offer you a better experience on the Site and to improve

our own processes, Services, and the Site.

  1. We use School Data to:
  2. Distinguish users from one another;
  3. help you learn;

iii. provide, maintain, develop, and improve the Application;

  1. personalize your experience on the Application; and
  2. secure the Application through the login process.
  3. We may use any Data to protect against harmful, illegal, offensive, copyrighted,

and other material that might violate our Terms of Use. Company has the right to

reject any content deemed inappropriate or containing personal information, or for

any other reason, at the time of submission, or at any subsequent time, all in

Company's sole discretion.

  1. We use Site Data to better understand how users interact with our Site, to protect

the Site, to make the Site easier to navigate, to measure the popularity of certain

pages, and to improve our business including by offering new products, marketing

the Site, and similar purposes. We also use the Site Data to enable sign on and logout.

  1. Data We Share.
  2. We share all Data collected by the Services with the cloud services provider that

hosts the Services. This service provider is contractually bound to adhere to

confidentiality and security obligations in a way that is consistent with this Policy.

  1. We share your email address with our email managing service, which is also bound

to adhere to confidentiality and security obligations consistent with this Policy.

  1. We share Account Data with our payment processor and Site host.
  2. We share School Data with the account creator, either a Parent or School, or as

mandated by applicable law, such as FERPA.

  1. We may also share Data in connection with or during negotiation of any merger,

financing, acquisition, bankruptcy, dissolution, transaction, or proceeding

involving sale, transfer, divestiture, or disclosure of all or a portion of our business

or assets to another company. Any such transfer will require the receiver to uphold

this Policy.

  1. We may disclose School Data if permitted or required by law, for example, in

response to a court order or a subpoena. To the extent permitted by applicable law,

we also may disclose personal information collected from children (i) in response

to a law enforcement or government agency's request; (ii) if we believe disclosure

may prevent the instigation of a crime, facilitate an investigation related to public

safety, or protect the safety of a user of Services; (iii) to protect the security or

integrity of our Services, and other technology, as well as the technology of our

service providers; or (iv) to enable us to take precautions against liability.

  1. We may use and disclose aggregate or anonymized Data for any purpose, except

when prohibited by applicable law. If we are required to treat School Data as

personal information under applicable law, then we may use and disclose such

School Data for all the permissible purposes for which we may use and disclose

personal information under applicable law.

  1. Purposes of Collection and Processing.
  2. We collect Verification Data to satisfy our legitimate interests in verifying the

identities of parents and teachers on the Services, and to contact them with

important updates about the safety and functioning of the Services.

  1. We process the School Data to provide you with the Service(s) you request.
  2. If you sign up for email marketing updates, our collection of your email address

and interactions with our emails is based on your consent.

  1. We place cookies with your consent, if such consent is required by applicable law.
  2. We collect Site Data to fulfill our legitimate interests in:
  3. improving our Site, for example by understanding which parts of the

Application appeal to users and which parts do not;

  1. conducting internal analysis and research;

iii. meeting any applicable law, regulation, legal process or enforceable

governmental request;

  1. enforcing our Terms of Use, including investigation of potential violations;


  1. detecting, preventing, or otherwise addressing fraud, security or technical


  1. Parental Choice. A Parent whose identity we or the School has verified can ask to review

information that the Company maintains about their child. A verified Parent may also

delete or deactivate the child's account, eliminating access to the Services available to from

Company for that child. Deactivating or deleting an account also prevents Company from

collecting or using subsequent personal information from that account. Please contact your

School for assistance in exercising these rights. THE COMPANY DOES NOT







  1. Data Retention. Subject to earlier exercise of your rights under this Policy, we will store

your School Data as long as you have an account on the Services. We may keep your email

as long as you do not revoke your consent to direct marketing. We will store your Site Data

as long as we deem reasonably necessary to provide the Services. If any of the Data is

deemed to be personal information as defined by applicable law, we will only keep a child’s

personal information obtained through his or her school as long as necessary to deliver

services or for School purposes, unless we are required by law to retain it.

  1. Security. We use appropriate technical and organizational means to protect your personal

data. For example, we use SSL to encrypt data in transit and encrypt Data at rest.

Unfortunately, no data transmission over the Internet or data storage system can be

guaranteed to be 100% secure. If you have reason to believe that your interaction with us

is no longer secure (for example, if you feel that the security of any account you might

have with us has been compromised), please immediately notify us of the problem by

contacting us at the address below.

  1. Cookies and Other Technology. “Cookies” are small pieces of information that a website

stores on your computer while you are viewing a website. We may use both session cookies

(which expire once you close your web browser) and persistent cookies (most of which

have an expiration date, based on the purpose of the cookie, at which point they self-delete)

to provide you with a more personal and interactive experience on our Site. We place three

kinds of cookies: essential, advertising, and performance/analytics.

  1. Essential Cookies. These cookies are strictly necessary to provide you with the Site and

services available through our Site and to use some of their features, such as access to

secure areas. Because these cookies are strictly necessary to deliver the Site, you cannot

refuse them without impacting how our Site functions.

  1. Non-Essential Cookies. We use two kinds of non-essential cookies: performance and

advertising. Non-essential performance cookies help us analyze how the Site is are being

accessed and used, enable us to track performance, and secure the Site. For example, we

use those cookies to get insights regarding users and Site performance, such as page speed

or to help us customize our Site and services for you in order to enhance your experience.

Non-essential advertising cookies are used to help us track the effectiveness of our

advertisements. We sometimes use cookies delivered by third parties to track the

performance of our advertisements. For example, these cookies remember which browsers

have visited our Site. The information provided to third parties does not include Personal

Information, but this information may be re-associated with Personal Information after we

receive it. This process helps us manage and track the effectiveness of our marketing


  1. Use. We use generally use cookies and similar technologies as follows:
  2. for “essential” or “functional” purposes, such as to enable various features

of the Site like remembering passwords or staying logged in during your


  1. for social media integration e.g. via third-party social media cookies, when

you share information using a social media sharing button or “like” button

on our Site, or when you engage with our content on or through a social

networking website such as Facebook; and

iii. for analytics purposes, consistent with our legitimate interests in how our

Site is used or performs, how users engage with and navigate through the

Site, what sites users visit before visiting our Site, how often they visit our

Site, whether an email was received or opened, and other similar


If you’d like to remove or disable cookies via your browser, refer to your browser’s


Most advertising networks offer you a way to opt out of interest-based advertising. If you

wish to limit third parties’ collection of information about your use of our Site, you can

opt-out of such at the Digital Advertising Alliance.

  1. Changes to this Policy; Notice

We may amend this Policy at any time by posting the amended version to the Site and

changing the “Last Updated” date above, or by providing such notice or obtaining consent

to changes as may be required by applicable law. Please contact us at the mailing address

or email below with questions about Company's privacy policy, collection, and use


Hearing Milestones, LLC

Attn: Privacy

PO Box 159

Potosi, Wi 53820-9707