Effective Date: November 12, 2021

Welcome to Sunshine Concept Development Classes (“Sunshine Concept Development Classes,” “we,” “us,” or “our”)!  Your child’s online privacy and safety are very important to us.  This Children’s Privacy describes our practices involving the online collection, use, and disclosure of personal information from children in connection with the Sunshine Concept Development Classes online educational service (the “Sunshine Concept Development Classes Site”) accessed through our website at https://www.sunshinecenter.in
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Sunshine Concept Development Classes will handle personal information collected from children as described in this Children’s Privacy Policy.  Please note, however, that some portions of the Sunshine Concept Development Classes site—such as the sign-up pages, direct notice to parents, and credit card payment pages—as well as the separate general-audience Sunshine website and mobile application, are directed to parents of children and other adults.  Any personal information we collect from other users through these non-child-directed Sunshine services and pages will be treated in accordance with the general-audience Sunshine Privacy Policy, which can be accessed here: https://www.sunshinecenter.in

Sunshine Concept Development Classes are committed to compliance with privacy laws.  As discussed below, we obtain consent from a parent or legal guardian where required by applicable law before collecting, using, and/or disclosing personal information from a child through the use of the Sunshine Concept Development Classes Site.  We take children’s privacy seriously, and we encourage parents to take an active role in protecting their children’s privacy and online experience at all times.  Sunshine Concept Development Classes can be contacted at:

Sunshine Concept Development Classes.
​303, Silver Square, Datattray Road
Santacruz (West), Mumbai – 400 054
Contact Ashima: +91 91670 16604

What Information Do We Collect from Children?
We collect personal information from children when they use the Sunshine Concept Development Classes Site and are enrolled in our courses.
For a child to access and use the Sunshine Concept Development Classes Site, a parent or legal guardian must log the child into a sub-account created and maintained through the account of the parent or legal guardian.  Prior to logging a child into the SunshineKids site, the parent or legal guardian is required to provide the child’s first name, age, and English language proficiency level.  Upon creation of the sub-account, the parent or legal guardian also must consent to the collection of personal information from the child.
After a parent logs a child into the child’s sub-account, we (and in some cases our service providers) collect personal information from the child both directly and automatically.  More specifically: 

• Tutoring activity data including: 
  • the child’s progress and performance data generated based on the child’s interaction with the Sunshine Concept Development Classes Site.
  • video records of the child’s sessions with tutors, as well as messages between the child and the tutor. Sunshine Concept Development Classes captures this so that Sunshine administrators can review and communicate with the child about his or her English learning progress.
• A Sunshine Concept Development Classes user ID, which is an internal number that we use to track information associated with the account and the child’s activity.
• Persistent identifiers, including cookies, IP addresses, MAC addresses, and data associated with web beacons, which we use to provide and improve Sunshine Concept Development Classes, for error logging, for analytics, and to collect usage information and information about the child’s browser, software and operating system, device type, and similar information. Like many websites, the Sunshine Concept Development Classes Site does not currently respond to “do not track” browser headers.  However, you can take steps to limit cookie tracking by erasing cookies from the child’s computer or other device and by setting the child’s browser to block all cookies or warn the child before a cookie is stored.  However, if you choose to block or delete cookies, certain features of the Sunshine Concept Development Classes Site may not operate correctly.

We will not ask for more personal information from children than is reasonably necessary for children to participate in the Sunshine Concept Development Classes Site.  Further, although children interact directly with tutors, we do not allow children to have the option or ability to make personal information more publicly available through the Sunshine Concept Development Classes Site.

How Do We Use the Information We Collect from Children? 
We use the information we collect from children, as follows:
·      For the purposes for which the child provided the information, including, for example, to monitor the child’s educational progress, to provide parents and legal guardians with information and reports about the child’s performance, and to create and maintain the sub-account for the child.  We also use the collected information as necessary to provide the features and functionality of the Sunshine Concept Development Classes Site to children.
·      To personalize the content that children see based on personal characteristics or preferences.
·      To analyze and draw insights based on your child’s use of the Sunshine Concept Development Classes Site.  We use this information for a range of internal purposes, such as error logging, security, helping us improve the Sunshine Concept Development Classes Site, and developing new products and services. 
·      We may combine children’s personal information collected through the Sunshine Concept Development Classes Site with other information that we or third parties collect about children in other contexts—such as our communications with parents or legal guardians via email or phone, or customer service records related to a child’s user account.

How and with Whom Do We Share Information from Children?
Sunshine Concept Development Classes does not sell children’s personal information, and we do not share or disclose children’s personal information for marketing purposes, including to third parties for their own direct marketing purposes.  Moreover, as noted above, children do not have the option or ability to make personal information publicly available through the Sunshine Concept Development Classes Site. 
Sunshine Concept Development Classes may share or otherwise disclose the personal information that we collect from children as described below. 

• With Parents or Legal Guardians.  A child’s account will be associated with the parent or legal guardian’s account, such that the parent or legal guardian can view and monitor his or her child’s progress.  A parent or legal guardian can also access video recordings of his or her child’s lesson with tutors.   
• Tutors.  As part of the Sunshine Concept Development Classes Site, children can schedule and take lessons with tutors through video chat sessions.  When a child engages in a video chat session with a tutor, the tutor will receive the child’s first name and any other personal information your child shares. The tutor, through his or her own tutor account, will be able to review the child’s learning progress and offer feedback.  Children also can communicate directly with tutors outside a video chat session on the Sunshine Concept Development Classes Site, such as through direct messages.
• Service Providers. We may use third-party service providers, contractors or agents to assist us in making the Sunshine Concept Development Classes Site available or to help us improve the Sunshine Concept Development Classes Site.  For example, we use a service provider to provide the video connection for the children’s tutoring sessions, and we use database hosting and data storage providers.  Such service providers may collect data themselves or obtain access to the personal information we collect from children to assist us in achieving the purposes discussed above in the section entitled “How Do We Use the Information We Collect from Children.”  
• Aggregated and De-Identified Information.  We may report aggregated, anonymous data relating to activity on the Sunshine Concept Development Classes Site to third parties or the general public. By way of example only, this may include the provision of reports regarding child engagement with the Sunshine Concept Development Classes Site and/or English-learning progress for such purposes as educational research, to evaluate the educational benefit of using the Sunshine Concept Development Classes Site, to improve the Sunshine Concept Development Classes Site, or to show the efficacy and usage when marketing the Sunshine Concept Development Classes Site.  Such aggregated, anonymous data will not contain any children’s personal information, including persistent identifiers. 
• Business Transfers.  In the event of a merger, sale of capital stock or assets, reorganisation, capital investment, consolidation, or similar transaction (or the due diligence in contemplation thereof) involving Sunshine Concept Development Classes, the information we possess, including personal information collected from children, shall be transferred as a corporate asset to the acquiring entity.  We will notify parents or legal guardians via email and/or post a prominent notice on the Sunshine Concept Development Classes Site of any change in ownership or uses of children’s personal information, as well as any choices available to the parent or legal guardian regarding the children’s personal information.
• Legal.  We will use and disclose children’s personal information where we, in good faith, believe that the law or legal process (such as a court order, search warrant, or subpoena) requires us to do so or in other circumstances where we believe it is necessary to protect the rights, property, or personal safety of Sunshine Concept Development Classes, our users, and/or third parties.

We may share aggregated, de-identified data relating to activity on the Sunshine Concept Development Classes Site with third parties or the general public. By way of example only, this may include the provision of reports regarding child engagement with the Sunshine Concept Development Classes Site and/or English learning progress for such purposes as educational research, to evaluate the educational benefit of using the Sunshine Concept Development Classes Site, to improve the Sunshine Concept Development Classes Site, or to show the efficacy and usage when marketing the Sunshine Concept Development Classes Site. Such aggregated, de-identified data will not contain personal information collected from children.

Parental Rights to Review, Delete, and Control Their Child’s Personal Information
When a child’s account is first opened, we obtain consent from a parent or legal guardian to the collection, use, and disclosure of personal information from children as described in this Children’s Privacy Policy.  We also encourage parents or legal guardians to log in to their child’s account to view the child’s activities and progress.  Parents or legal guardians may also contact Sunshine Concept Development Classes to review the type of information collected from children or to change their consent to the collection, use, and sharing of their child’s personal information.  Parents or legal guardians may also ask us at any time to stop collecting personal information from their child and request that we delete any information we have already collected.  However, such requests may result in termination of the child’s access to and use of the Sunshine Concept Development Classes Site.

To contact us about these parental rights,
please send us an email at ashima@sunshinecenter.in

or contact us at:
Sunshine Concept Development Classes.
​303, Silver Square, Datattray Road
Santacruz (West), Mumbai – 400 054

In any correspondence, please include the parent or legal guardian’s email address and the child’s name.  To protect children’s privacy and security, we will take reasonable steps to verify a parent or legal guardian’s identity before granting access to any children’s personal information.

Data Retention
Absent a request to delete data, we will retain personal information collected online from a child for as long as there is a subscription maintained for the child, and for a period of two years after the child’s account becomes inactive.  We retain this information after a subscription ends because when users reinstate their lapsed subscriptions, they generally want to resume lessons rather than losing their progress and starting over.  Nonetheless, after two years of inactivity, all personal information collected from a child will be automatically deleted from our active servers. 

Personal information collected from children may remain in our backup servers for a reasonable period from the date of any deletion request, after which it will be deleted and cannot be restored.  As discussed above, a parent may request to delete personal information collected from his or her child at any time during the period of the subscription or after the subscription ends. 

In the event we discover that we have collected information from a child in a manner inconsistent with legal requirements, we will either delete the information or seek parent or guardian consent for that collection.

Effective Date and Changes to this Policy
This Privacy Policy is current as of the Effective Date set forth above. We may update this Privacy Policy from time to time to reflect changes in the Sunshine Concept Development Classes Site or our information processing practices.  When we make any changes to our practices under this Privacy Policy, we will change the Effective Date.  If we make a material change to this Privacy Policy, we will make reasonable efforts, taking into account available technology, to ensure that a parent receives direct notice of the changes to our practices.

​Questions or Comments 
For questions or comments regarding this Policy,

please contact us at:
Sunshine Concept Development Classes.
​303, Silver Square, Datattray Road
Santacruz (West), Mumbai – 400 054
Contact Ashima: +91 91670 16604