Thank you for visiting our website www.thesupermeclub.com (our "Website"). The SuperME Club Ltd, and its affiliates (collectively, "Company" or “us” or "we") respect your child’s privacy and are committed to protecting it through our compliance with this policy.

This Website is built for the use and enjoyment of children under the age of thirteen. The US federal Children's Online Privacy Protection Act of 1998 and its rules (collectively, "COPPA") require us to inform parents/legal guardians (as used in this policy, "parents") about our practices for collecting, using, and disclosing personal information from children under the age of 13 ("children"). It also requires us to obtain verifiable consent from a child's parent for certain collection, use, and disclosure of the child's personal information. We also adhere to additional international and US state data protection laws, as outlined below.

This policy describes (a) the types of information we may collect from your child or that your child may provide when they visit our Website; and (b) our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy applies to information we collect on this Website and in email, text, and other electronic messages between you and/or your child and this Website. It is our practice to also follow these same policies and practices for non-digital information supplied by your child and/or you to our Company.

More specifically, this policy notifies parents of:

• The types of information we may collect from children.
• How we use the information we collect.
• Our practices for disclosing that information.
• Our practices for notifying and obtaining parents' consent when we collect personal information from children, including how a parent may
• revoke consent.
• All operators that collect or maintain information from children through this Website.

This Website and our related services may only be accessed and use by your child after we receive “verifiable parental consent” from you as your child’s parent or legal guardian. As part of the process of your granting verifiable parental consent, you have agreed to the terms and parameters of this privacy policy.

Please read this policy carefully to understand our policies and practices regarding your child’s information and how we will treat it. If you do not agree with our policies and practices, your choice is not to grant consent and not to let your child use our Website.

To the extent that teens (i.e., 14 years or older) or adults are granted access to our Website, such teens and adults shall be required to adhere to this privacy policy, excluding the need for obtaining prior verifiable parental consent. No teen or adult shall do anything to undermine the terms of this privacy policy while accessing this Website or any other matters related to the services of this Website.

Description of Parental Rights.
This policy outlines how to exercise your parental rights. Please know that:

• We will not require a child to disclose more information than is reasonably necessary to participate in an activity;
• As a parent you can review your child’s personal information, direct us to delete it, and refuse to allow any further collection or use of your child’s information; and
• As a parent, through our verifiable parental consent process, you will be given the opportunity to agree to the collection and use of your child’s information.
• If you have any questions, instructions, or other concerns, please contact us at privacy@thesupermeclub.com.

Accessing and Correcting Your Child's Personal Information
At any time, you may review the child's personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child's information.
You can review, change, or delete your child's personal information by:

• Logging into your child's account and visiting his or her account profile page.
• Sending us an email at privacy@thesupermeclub.com. If you chose to email us, in order to protect your privacy and security, we shall require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.

Information We Collect About Your Child and How We Collect It
Children can access many parts of the Website and its content and use many of its features without providing us with personal information. However, some content and features require us to collect certain information, including personal information, from them. In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they visit or use the Website.

We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary.

We may collect several types of information from and about users of our Website, including information:

• By which your child may be personally identified, such as name, postal address, email address, telephone number, or any other identifier by which your child may be contacted online or offline] ("personal information");
• That is about your child but individually does not identify your child; and/or
• About your internet connection, the equipment your child uses to access our Website, and usage details.

We may collect this information:

• Directly from your child when your child provides it to us.
• Automatically as your child navigates through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.
• From third parties, for example, our business partners and your child’s school.

Information Your Child Provides to Us.The information we collect on or through our Website may include:

• Information that your child or you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services, or when you or your child reports a problem with our Website. A child must provide us with the following information to register with this website: the child's first and last name, age, grade, classroom designation, and a parent's email address. We also require the child to create a member name and password. We may request additional information from your child, but this information is optional. We specify whether information is required or optional when we request it. In addition, we may also ask, with your additional verifiable parental consent, your child for information when your child enters a contest or promotion sponsored by us.
• Records and copies of your child’s or your correspondence (including email addresses), if one of you contacts us.
• Responses to surveys that we might ask your child or you to complete for research purposes.
• Details of transactions you or your child carries out through our Website and of the fulfillment of your respective orders. You may be required to provide financial information before placing an order through our Website.
• Your child or your search queries on the Website.
• We may enable registered users to communicate with others on or through this Website and/or Service through chat, email, and posting to public areas of the Website and our related services ("Social Features"). The nature of these features allows children to disclose personal information about themselves. We do not monitor or review this content before it is posted, and we do not control the actions of third parties with whom your child shares his or her information. We encourage parents to educate their children about safe internet use and to monitor their children's use of social features.
• Your child or you also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although your child or you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom your child or you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies.As your child or you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your respective equipment, browsing actions, and patterns, including:

• Details of your child or your visits to our Website, including traffic data location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your child or your computer and internet connection, including your child’s or your IP address, operating system, and browser type.

We may combine non-personal information we collect through these technologies with personal information about you or your child that we collect online.

For information about our automatic information collection practices, including how you can opt out of certain information collection, see the "Automatic Information Collection and Tracking" and "Choices About How We Use and Disclose Your Information" the sections below

The information we collect automatically may be only statistical data and may or may not include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your child or your preferences, allowing us to customize our Website according to your child’s or your individual interests.
• Speed up your child or your searches.
• Recognize your child or you when either of you return to our Website.
• The technologies we use for this automatic data collection may include:

Cookies (or browser cookies).A cookie is a small file placed on the hard drive of your computer. Your child or you may refuse to accept browser cookies by activating the appropriate setting on your respective browsers. However, if either of you select this setting you respectively may be unable to access certain parts of our Website. Unless you have adjusted your child or your browser settings so that it will refuse cookies, our system will issue cookies when your child or you direct your respective browser to our Website.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when your child or you go offline, while Session Cookies are deleted as soon as your child or you close your respective web browser. For the record, we use both session and persistent Cookies for the purposes set out below:s

• Type: Session Cookies
• Administered by: Us
• Purpose: These cookies are essential to provide your child and you with services available through the Website and to enable your child and you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these cookies, the services that your child and you have asked for cannot be provided, and we only use these cookies to provide your child and you with those services.

• Type: Persistent Cookies
• Administered by: Us
• Purpose: These cookies allow us to remember choices your child and you make when your child and you use the Website, such as remembering your child’s login details or language preference. The purpose of these cookies is to provide your child and you with a more personal experience and to avoid your child and you having to re-enter your respective preferences every time one of you use the Website.

As of now we do not use any tracking mechanism for cookies on the Website.

Web Beacons. Pages of our Website and/or our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your child or your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your child or your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

In addition, please know that we do not collect personal information automatically, but we may tie this information to personal information about your child or you that we collect from other sources or your child or your provide to us.

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies to collect information about you when you use our website. The information they collect may be associated with your child’s personal information or they may collect information, including personal information, about your child’s online activities over time and across different websites and other online services. They may use this information to provide your child or you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

We may use the personal information we collect from your child to:

• register him or her with the Website and our related services;
• communicate with him or her about activities or features of the Website that may be of interest; or
• track his or her performance in games or other activities.

We use the information we collect automatically through technology (see Automatic Information Collection and Tracking) and other non-personal information we collect to improve our Website and to deliver a better and more personalized experience by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about the child's preferences, allowing us to customize the content according to individual interests.
• Speed up your searches.

We use information that we collect about your child or that your child provides to us, including any personal information:

• To present our Website and its contents to you.
• To provide your child or you with information, products, or services that either of you request from us.
• To fulfill any other purpose for which your child or you provide it.
• To provide your child or you with notices about your account, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• To allow your child or you to participate in interactive features on our Website.
• In any other way we may describe when your child or you provide the information.
• For any other purpose with your verifiable consent.

We may also use your information to contact you about our own, your school’s and other third-parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please [check the relevant box located on the form on which we collect your data (the registration form)/adjust your user preferences in your account profile. For more information, see Choices About How We Use and Disclose Your Information.
We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We do not share, sell, rent, or transfer children's personal information other than as described in this section.
We may disclose aggregated information about many of our users, and unaggregated information that does not identify any individual or device. In addition, we may disclose children's personal information:

• To fulfill the purpose for which your child or you provide it;
• For any other purpose disclosed by us when your child or you provide the information;
• If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.
• To enforce or apply our terms of use and other agreements, including for billing and collection purposes;
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers or others, including to:
• protect the safety of a child;
• protect the safety and security of the Website; or
• enable us to take precautions against liability.
• To law enforcement agencies or for an investigation related to public safety.
• To our subsidiaries and affiliates;
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization; and
• dissolution, or other sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.

We strive to provide you with choices regarding the personal information your child provides to us. We have created mechanisms to provide you with the following control over your child and your information:

• Tracking Technologies and Advertising. You can set your child and/or your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If your child or you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising. The Company does not disclose your information to third-party advertisers.
• Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties' products or services, you can opt-out by at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to opt-out@thesupermeclub.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of legal compliance or other business operational needs.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by emailing us at opt-out@thesupermeclub.com. [For this opt-out to function, you must have your browser set to accept all browser cookies.
• Social Features. The Website offers social features, including[instant messaging, chat, email, posting on message boards, and any other features that may enable children communicate with others on and/or through the Website. We do not control the types of information your child can send or post through them. We encourage parents to educate their children about safety online and to carefully monitor their children's use of social features to ensure they do not disclose their personal information through them.
• We do not control third parties' collection or use of your information to serve interest-based advertising off of our Website. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

The following are all operators that may collect or maintain personal information from children through the Website: [IN A CHART, LIST OF OPERATOR NAMES AND THEIR POSTAL ADDRESSES, TELEPHONE NUMBERS, AND EMAIL ADDRESSES].
OR
A list of all operators that may collect or maintain personal information from children through the Website is available here. Please direct your inquiries about any operator's privacy practices and use of children's information to the operator at its contact information provided above or email us at privacy@thesupermeclub.com.

We have implemented measures designed to secure your child’s and your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. [All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions [and [OTHER INFORMATION]] will be encrypted [using SSL technology].]
The safety and security of your child’s information also depends on you. Where we have given you child and you (or where you have chosen) a password for access to certain parts of our Website, your child and you are responsible for keeping this password confidential. We ask your child nor you share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of any personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

International and US state consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

In the US, if your child is a resident of one of the following states, please know we will do the following:
Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Data portability.
• Opt-out of personal data processing for targeted advertising and sales.
• Colorado, Connecticut, and Virginia also provide their state residents with rights to:
• Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address privacy@thesupermeclub.com. However, please know we do not currently sell data triggering that statute's opt-out requirements.

For children who are residents of New York State, we adhere to the requirements found in the Department of Education’s Parents Bill of Rights for Data Privacy and Security, found at https://www.schools.nyc.gov/school-life/know-your-rights/parents-bill-of-rights-for-data-privacy-and-security, namely:

• Your child’s personal information will not be sold or released for any marketing or other commercial purposes.
• If your child is under age 18:
• You have the right to inspect and review the complete contents of your child’s content found on the Website within forty-five (45) days of our receiving your request and verifying your identity.
• You also have the right to request changes to your child’s information on the Website when you believe such information may be inaccurate, misleading, or violate your child’s privacy.
• You have the right to be notified if a breach or unauthorized release of your child’s personal information occurs.
• You have the right to make complaints about possible breaches and unauthorized disclosures of your child’s personal information and to have such complaints addressed. We will provide you with a response no more than sixty (60) calendar days from when we receive your complaint. If more time is needed, we will provide an explanation to you, along with an approximate date for a response.
• This section is subject to change. Please check back here frequently for updates. If your state is not listed, please note that the Company will be compliant with all applicable state laws.

If your child is a resident of the UK, please know that we follow the UK’s ‘data protection principles’ making sure your child’s information is:

• used fairly, lawfully and transparently;
• used for specified, explicit purposes;
• used in a way that is adequate, relevant and limited to only what is necessary;
• accurate and, where necessary, kept up to date;
• kept for no longer than is necessary; or
• handled in a way that ensures appropriate security, including protection against unlawful or unauthorized processing, access, loss, destruction or damage.

In the case of more sensitive information, we add additional protections. The UK views the following information as being “sensitive information:”

• race;
• ethnic background;
• political opinions;
• religious beliefs;
• trade union membership;
• genetics;
• biometrics (where used for identification);
• health; or
• sex life or orientation.

Under the UK Data Protection Act 2018, you have the right to find out what information the government and other organizations store about your child. These include the right to:

• be informed about how your data is being used;
• access personal data;
• have incorrect data updated;
• have data erased;
• stop or restrict the processing of your data;
• data portability (allowing you to get and reuse your data for different services); or
• object to how your data is processed in certain circumstances.

You also have rights when we use your child’s personal data for:

• automated decision-making processes (without human involvement); or
• profiling, for example to predict your behavior or interests.

If your child is a resident of the EU, please know that we follow the EU’s data protection laws as outlined in the General Data Protection Regulation. On behalf of your child, you have:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.

To make such a request about your child’s particular international or state rights not listed above, please send an email to privacy@thesupermeclub.com.

You can review and change your child’s personal information by logging into the Website and visiting your child’s account profile page.

You may also send us an email at privacy@thesupermeclub.com to request access to, correct or delete any personal information that your child or you have provided to us. We cannot delete your child’s personal information except by also deleting your child’s user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users (e.g., your User Contributions you place in group chats).

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users' personal information, we will notify you, as your child’s parent, by email to your email address specified in your account or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. As your child’s parent, you are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

To ask questions or comment about this privacy policy and our privacy practices, or to register a complaint or concern, please email us at privacy@thesupermeclub.com.