PRIVACY POLICY - YOUR PRIVACY RIGHTS
Last Updated Date: April 14, 2026.

We Recently Updated Our Privacy Policy. Updates include:
• Additional data collection and service provider disclosures

Miaplaza California Consumer Privacy Act Notice
This Privacy Policy describes how we handle your personal information, the reasons we do so,
and the rights you have as a California resident regarding your information.

California Communication & Recording Disclosure
For visitors and users in California, please be advised that we use third-party service providers to
facilitate real-time communication and analyze user interactions on our website. These tools,
including chat widgets, video players, online advertising platforms, payment processors, session
replay technologies, and analytical pixels, may function as 'pen registers', ‘wiretapping’, or 'trap
and trace' devices under California law. By using our website and its interactive features (such as
live chat or support forms), you acknowledge and provide your express, prior consent to the
simultaneous interception and recording of your communications and interactions—including
keystrokes, mouse movements, scrolling, and chat text—by Miaplaza and our authorized third-
party service providers. These providers act strictly as an extension of our business to provide
support and improve our services; however, they may process this data in real-time. If you do not
consent to this recording, please disable 'Communication & Experience' cookies in our Privacy
Center or refrain from using our interactive features.

Your privacy at Miaplaza
We take privacy very seriously at Miaplaza and this policy is designed to tell you what
information we collect and how we use it. This policy applies to all Miaplaza services,
Miacademy, MiaPrep, MiaPrep Online High School (MOHS), Always Icecream, and Clever
Dragons, and their respective websites (“Service” or “Services”).

Miaplaza operates several educational websites for children of all ages as well as the WASC
accredited MiaPrep Online High School (MOHS).

Miaplaza’s principal place of business is located at 1425 Stonegate Ct, Gardnerville, NV 89410.
The Data Protection Officer for Miaplaza can be contacted at dataofficer @ mia.school or by
writing to the Data Officer at Miaplaza, Inc., 1259 El Camino Real Unit #1246, Menlo Park, CA
94025.

This policy forms part of our terms of service and explains your rights and responsibilities when
using our services. If you have any questions, please contact us at dataofficer @ mia.school or
+1 (909) 443-1317.

Changes to the privacy policy
We may update this policy from time to time and we will post a notice at the top of the policy if
we do. If we make material changes to this policy that affect the collection and use of your
information, we will notify you if we have your email address. If you have any questions please
contact us at dataofficer @ mia.school.

Information we collect from students
The data collection practices as described herein for students also apply to users aged 12 or
under.

On all Services except MOHS students have the option to provide their birthdate, which allows
customization of their Service experience. The student birthdate is not shared or disclosed
publicly. The option to provide a birthdate is not available to users in the EU.

We collect information about a student’s usage of the Service to help us improve the Service’s
functionality and performance. Information collected from or about a student is not used to
contact or build a profile of the student or used for behavioral advertising.
If the parent / guardian has enabled the Service’s community features, the student may provide
certain information about themselves in their Profile sections including:
• Nickname
• My Status
• About me
• My Hero
• Books I Enjoy
• Favorite Movies
• Most Memorable Vacations

The student can also upload student-generated content, join groups, send friend requests, send
messages to friends, and comment on other people's profiles.

These information postings are pre-moderated by Miaplaza staff for appropriateness and to
prevent the disclosure of personal information.

If community features are not enabled by the parent / guardian, the student can only customize
their MiniMe avatar and add a Nickname. The student cannot visit other students' profiles but
may be able to see the first names and nicknames of other students on certain webpages of the
Service.

We do not condition a student’s participation in an activity on the disclosure of more information
than is reasonably necessary to participate.

Making friends
Students want to make and connect with friends. This is important for building social skills, but
we want it to be in a safer setting than is typical for the Internet.

Students can become friends with other students on the Service by inviting each other to start a
friendship using the Become Friends button on the student’s profile page. Students can search for
friends using a name, nickname, interest, or a user’s unique friendship code.

All user generated content and communication between members, also between friends, is
reviewed by a site moderator (i.e., pre-moderated) before it can be read by the intended
recipients to prevent inappropriate commentary and divulging of personal information.

Information we collect from parents / guardians
To become a member of a Service, a parent must register for both a parent and a student account.

The parent is required to provide the following information:
• Parent’s first and last name, email address, and a password for the parent account. These are
required to fulfill legal requirements for students’ sites and our contractual obligations to you.
• The first name and first initial of the last name of the parent’s student, plus a password for the
student's account. This becomes the student’s login identifier and also how the student is known
by other members on the Site. You may, if you prefer, choose an alternate name as long as the
student can remember it.
• Further, the parent / guardian is required to make a payment through a third-party payment
service. The payment is used to obtain verifiable parental consent and to purchase the
subscription for the use of the Service. We do not store your full credit card information.
• We also collect Service usage information to help us improve the Service’s functionality and
performance.
We do not share or disclose your personal information with third parties for those third parties'
direct marketing purposes.

Registration Using Facebook
Our website offers you the option to register for an account using your Facebook profile. If you
choose this method, Facebook will share certain personal information with us—specifically your
name and email address—to facilitate the creation of your account on our site. We use this
information solely to create and manage your account, provide you with access to our services,
and communicate with you as needed. We do not receive your Facebook password. You can
disconnect your Facebook account from our service at any time by adjusting your account
settings within our site or in your Facebook account. We do not sell or share this registration
information for cross-context behavioral advertising purposes without your consent, and you
may exercise your rights, including the right to opt-out of such sharing, at any time through our
Do Not Sell or Share My Personal Information link.

We use Trustpilot, an independent third-party review platform, to collect feedback from our
customers and display reviews about our products and services. If you make a purchase or
otherwise engage with our services, we share limited personal information with Trustpilot (such
as your name, email address, and transaction details) for the sole purpose of sending you an
invitation to provide a review. Trustpilot will process this information as our service provider and
will contact you via email to invite you to submit a review. Any review you choose to provide is
voluntary and will be published on Trustpilot’s website under the name you select. Published
reviews are visible to the public and may also be displayed on our website or other marketing
channels. Trustpilot may also collect additional personal information directly from you if you
submit a review, in accordance with their own privacy policy. We encourage you to review
Trustpilot’s Privacy Policy here: https://legal.trustpilot.com/for-reviewers/end-user-privacy-
terms.

Advertising service providers used in conjunction with parents / guardians
We work with third-party advertising networks, third party data controllers, and marketing
analytics service providers such as
• Google,
• Meta / Facebook,
• Amplitude Analytics,
• Pinterest,
• Twitter / X,
• iHeart Media,
• Unbounce, and
• TikTok.

These third parties may collect and use information about parents’ / guardians’ visits to and use
of our Service—as well as activity on other websites—in order to:
• Understand ad effectiveness
• Serve you with tailored advertisements and content based on your interests and browsing
behavior across websites

These providers may use tracking technologies such as cookies, scripts, pixels, or device
identifiers. You can opt out of targeted advertising or data “sharing” under applicable federal and
state laws, such as the California CPRA, on our Privacy Preference Center.

Google Enhanced Conversion Tracking used in conjunction with parents /
guardians
We use Google's Enhanced Conversion Tracking feature to improve the accuracy of our ad
campaign measurement and to better understand how our advertising leads to sales or other
desired actions on our website. When you complete a conversion action on our website, such as
making a purchase or filling out a form, we may collect and securely send your data (such as
your email address or name) to Google. Google uses this data to match conversions to Google
accounts that have interacted with our ads. For more information on how Google handles data,
please see https://safety.google/intl/en_us/settings/

You can control your ad preferences and opt out of personalized ads by visiting
https://myadcenter.google.com/home

Analytics service providers used in conjunction with parents / guardians and students

We use analytics service providers and data processors such as Google Analytics, Amplitude
Analytics and OneTrust to help us:
• Understand how you interact with our Service
• Monitor usage patterns and site performance
• Improve our offerings

Google Analytics collects an IP address, OS, Browser, ISP and coarse location information
(country and city). The IP address is used to determine coarse location and then discarded.
Amplitude Analytics collects an IP address, platform, coarse location (region, country, city),
device type, designated market area (DMA), and language.

OneTrust collects a unique identifier, IP address, device and browser details, and coarse location
(country and state).

These providers may record your interactions with the Service, which can include data entered
into forms and other personal information. These providers process your data only on our
instructions and do not use personal information for their own purposes or disclose it to others.

Analytics service providers used in conjunction with parents / guardians
We use third party service providers such as Freshworks to enable interaction with you on our
website and/or our product. As a data processor acting on our behalf, Freshworks automatically
receives and records certain information of yours like device model, IP address, the type of
browser being used and usage pattern through cookies and browser settings. Freshworks
performs analytics on such data on our behalf which helps us improve our service to you. You
can read about the cookies Freshworks' sets in their cookie policy here:
https://www.freshworks.com/privacy/

We use third-party payment processors such as Stripe and Braintree to handle payment
transactions. When you make a purchase, your payment information (such as your name, billing
address, and payment method details) is collected and processed directly by these providers. We
do not store full credit card numbers or security codes on our servers. These processors are
service providers and are contractually obligated to use your information only to provide
payment processing services to us. You can review their privacy policies here:
• Stripe Privacy Policy: https://stripe.com/privacy
• Braintree Privacy Policy: https://www.paypal.com/us/webapps/mpp/ua/privacy-full

Other third party service providers used in conjunction with parents / guardians and
students
We use third party service providers such as Airtable to process and store the personal
information we collect from parents / guardians (see section above).

We use third party service providers such as Klaviyo and Zapier to communicate with parents /
guardians by email. You can find Klaviyo’s privacy policy here:
https://www.klaviyo.com/legal/privacy/privacy-notice

You can find Zapier’s privacy policy here: https://zapier.com/legal/data-privacy

We use third party service providers such as Cloudflare to help secure and optimize delivery of
our website. Cloudflare acts as a content delivery network (CDN) and security provider. In this
role, Cloudflare processes data such as IP addresses and traffic information to protect our
services against attacks and improve site performance. Cloudflare acts only as our service
provider and does not use this data for its own purposes. You can learn more in Cloudflare’s
privacy policy here: https://www.cloudflare.com/privacypolicy/

We use third party service providers such as Vimeo and YouTube to host embedded videos for
the Services. If a student views an embedded video on our Service, the service provider may
receive certain information automatically, such as the student’s device IP address, device type,
and other technical information necessary to deliver the video. The service provider may also
store certain information on the device used for viewing an embedded video.

We do not permit Vimeo or YouTube to use this information for personalized advertising on our
site, but these service providers may still collect and use data in accordance with their own
privacy policies. Please note that video service providers may be able to show ads and collect
additional information about the student when the student watches our videos directly on the
video service providers website.

You can find Vimeo’s privacy policy here: https://vimeo.com/privacy
YouTube is a service operated by Google and you can find their privacy policy here:
https://policies.google.com/privacy

We use third party service providers such as Churnbuster to send parents reminders about
subscription and payment methods. You can find Churnbuster’s privacy policy here:
https://churnbuster.io/privacy-policy

We use Google Fonts which collects an IP address. Google does not use any information
collected by Google Fonts to create profiles of end users or for targeted advertising.

We provide access to the Desmos Graphing Calculator for students with parental consent. Use of
the graphing calculator does not require active collection of personal information. However,
Desmos will have access to any user generated content created in the graphing calculator.
If you have any questions about our use of third party service providers, contact us at dataofficer
@ mia.school

Information we collect from MiaPrep Online High School (MOHS) families
To comply with legal requirements and to provide the MOHS Service, the parent / guardian
enrolling their student in MOHS is asked to provide their
• First and last name,
• Email address,
• Phone number,
• Household address,
• Government issued ID verification document, and
• Payment method for the enrollment fee and tuition.

MOHS requires identity verification documents during enrollment to verify the identity of
parents / guardians (driver's license, government-issued ID, or passport) and students (certified
birth certificate, government-issued ID, or passport). MOHS uses these documents solely for
enrollment verification, regulatory compliance, and preventing fraudulent applications.

Also during enrollment, the parent / guardian is asked to provide the student’s
• First and last name and preferred name,
• Date of birth,
• Gender,
• Incoming grade level and current schooling arrangements,
• Government issued ID verification document, and
• Academic record.

The parent / guardian further has the option to provide the student’s
• Phone number and email address to permit direct communication between the student and
MOHS, and
• Photo.
Only if the parent / guardian intends to apply for tuition assistance, the following information has
to be provided
• Income information,
• Tax information,
• Government assistance documentation.

These documents are used to verify the applicant’s eligibility for tuition assistance.

MOHS uses third party service providers such as Airtable to process and store the information
we collect.

MOHS uses third party service providers such as Klaviyo and Zapier to communicate with
parents / guardians and MOHS students by email. You can find Klaviyo’s privacy policy here:
https://www.klaviyo.com/legal/privacy/privacy-notice

You can find Zapier’s privacy policy here: https://zapier.com/legal/data-privacy

MOHS uses Google Classroom for classroom and learning management. Google Classroom
includes several Google services such as Google Meet, Docs, Sheets, Slides, YouTube, and
Drive. Enrollment in MOHS includes registration for a Google Classroom account which
requires sharing the following personal information with Google Classroom:
• the student's first and last name. This becomes the student’s Google Classroom email address
which is used to log into Google Classroom and to communicate with other MOHS students and
MOHS staff;
• the student’s course work, classroom activities, and communication;
• the student’s voice as part of voice texting with MOHS staff, if that feature has been enabled by
the parent / guardian.

See the MOHS Student Handbook for more information.

Other information we collect: Cookies, log files and UTM parameters
Our Services use cookies, pixels, and web log files to track site usage and improve your
experience.
• Cookies are small data files stored on your device. We use:
— Session cookies, which are required for secure login and basic functionality. These
expire after you leave the site or close your browser.
— Persistent cookies (if you enable “automatic login”), which let us store your privacy
consent choices and recognize your user account the next time you visit.
— Optional cookies (including those set by third-party analytics and advertising
partners), which help us understand usage, personalize content, and serve relevant
advertisements.
• If your browser does not allow cookies, you may not be able to access all features of our
Services.
• Pixels (also called tracking pixels or web beacons) may be used to support
analytics, advertising, and marketing, as described in other sections of this policy.
• Web log files and information such as entry and exit URLs, IP address,
browser type, and operating system are automatically collected when you access our Services.

This data helps us:
— Diagnose technical issues
— Analyze trends and usage patterns
— Secure our systems
— Improve our Services
• UTM Parameters When you visit our website through a link that includes
UTM parameters (Urchin Tracking Module), we may collect information contained in these
parameters as part of our analytics and marketing activities. UTM parameters are added to the
end of website URLs to help us understand how you found our website or what marketing
campaigns brought you here (for example, “utm_source”, “utm_campaign”, or “utm_medium”).
This information is used solely for internal analysis and to improve our marketing efforts; it is
not used to identify you personally.

Privacy settings in most browsers allow you to prevent your browser from accepting some or all
cookies, notify you when it receives a new cookie, or disable cookies altogether. If your browser
disables all cookies, then information will not be collected or stored via cookies on your device.
Please note that when you opt out of certain cookies, your opt out preferences are recorded by
placing a cookie on your device. Therefore, your browser must be configured to accept cookies
in order for your preferences to take effect. Also, if you delete or clear your cookies, or change
your web browser, you will need to reset your cookie preferences.

You can set your cookie preferences at any time in the Privacy Preference Center and learn more
about your rights regarding the use of your personal information in the sections above. If you
access several Miaplaza Services, you will need to make your election for each Service. Also, if
you clear your cookies on this browser or use another browser or device, you may need to opt
out again for this Service.

For technical reasons we may not be able to remove old cookies when you change your privacy
preferences. Therefore, even If you opt out, you may continue to see advertising, including ads
that may be based on personal information processed before you opted out. We recommend that
you manually clear old cookies from your browser using your browser's cookie management
functions.

Data retention
All user data is retained as long as reasonable to provide the Service to you.
An account is deemed inactive after 1000 days have passed without a payment or a login from
the user. All data is deleted after this date.

If a user requests account deletion, then their profile and associated data is deleted from our
records within 20 business days.

How to update or delete / remove your or your child’s information
You can review the personal information you or your child provided us and update it, or update
the settings for your Service account, at any time by logging in to your account on the Service’s
website and editing the account and profile information. To request data deletion of your account
and information, please send your request to dataofficer @ mia.school and we will take care of it.

If you are a parent / guardian and you wish to request access to review or delete your child’s
information, please contact Miaplaza at dataofficer @ mia.school. Please send your request
using the parental email account that you have used during registration. You will receive a
response to requests sent to us within five business days of our receiving it.
Any deletion requests will be actioned within 20 business days.

If you are the parent / guardian of a child who is using a Miaplaza Service at the direction of
their teacher under a Joint Service school partnering agreement, please contact the appropriate
official at your child’s school to access, review, correct, or delete any of your child’s personal
information in the Miaplaza Service.

If Miaplaza is made aware that a student’s personal information has been collected without prior
consent or under a school agreement, we will take steps to immediately delete the collected
information, or to seek consent.

Information transfer and storage
We transfer Information and Personally Identifiable Information between Europe and the United
States. In addition, such data may be stored on servers located outside your resident jurisdiction,
which may have less stringent privacy practices than your own jurisdiction.

Information collected from and through partner schools / educators
Miaplaza may enter into partnering agreements with schools or similar educational services
providers to offer a Joint Service. In a Joint Service, either Miaplaza obtains parental consent for
the student to participate in the Joint Service or the partner school obtains signed parent /
guardian consent forms prior to the student’s participation in the Joint Service. The partner
school is responsible for ensuring that parents / guardians have been notified in writing of the use
of a Miaplaza Service in the classroom and have been provided access to this privacy policy. The
partner school will also inform parents / guardians that they have the right to opt-out their child
from participation. Parent / guardian requests for review, access, or deletion of your child’s
personal information should be directed to the school.

Any content uploaded that is shared as part of a class at a partner school is retained at the
direction of the school (e.g., for legal compliance reasons such as maintenance of “education
records” under FERPA); to correct or delete this content, please contact the appropriate official at
your child’s school.

Miaplaza deletes personal data in our databases after the expiration of a partner school’s license
agreement. This time period may, however, vary as needed to fulfill the purposes for which the
information was collected. Additionally, an account is deemed inactive after 1000 days have
passed without a payment or a login from the user. All data is deleted after this date.

Partnership with Arizona State University (ASU)
Families enrolling in the ASU Universal Learner Courses (ULC) program through MiaPrep
Online High School (MOHS) should be aware that MOHS will need to provide specific
information to ASU in order to complete enrollment and participate in this program. This
information is limited to:
• The student’s first and last name
• Their MOHS-assigned email address
• The parent / guardian’s phone number
• The student’s date of birth
• The student’s address

Parents / guardians must agree to sharing this personal info, including your name, phone number,
and home address with ASU.

Miaplaza will not provide any other information to ASU without the parent or guardian’s explicit
permission.

Communications with parents / guardians
We will communicate with parents / guardians through email and notices posted on a Service’s
website. These include occasional emails about various features of the Service.

Customized content
Information you provide at registration or in your Account Management section is also used to
customize your experience on the Service. For example, the learning games and teaching videos
that are offered to users depend on the grade range settings chosen by the parent / guardian.

Miaplaza Research
Miaplaza occasionally conducts research with users for internal use only and does not engage a
third party for such activity. We invite parents / guardians to participate via social media. The
parent / guardian will receive an email request and must provide consent for their child’s
participation. Research sessions may collect the following:
• Interaction data (e.g., buttons clicked, time spent on tasks).
• Your child’s first name.
• Your child’s academic progress (e.g., lesson completion, quiz scores).
• Feedback provided via on-screen input options during the session
• Feedback provided verbally (via microphone).
• Video recording of your child and their surroundings (if required).

For questions about your child’s participation in this research or to opt-out of participation,
please contact dataofficer @ mia.school

Complying with law and preventing harmful activities
Miaplaza may process and share personal information if necessary to comply with legal requests,
such as subpoenas or court orders. Miaplaza may share personal information when we believe it
is necessary to comply with the law, to exercise our rights, to protect our interests or property, to
prevent fraud or other illegal activity, to assist law enforcement, or to prevent imminent harm.

This may include sharing information with other companies, lawyers, agents, or government
agencies.

Links out
We may include links to third parties from a Service’s website. We are not responsible for these
companies and because we have a link does not mean we endorse them. Your use of our Services
may be subject to the terms and conditions, terms of service and privacy policies of other
services that we do not control such as mobile app stores, mobile software platforms or payment
processors. Please be sure to check their privacy policies if you decide to visit them.

Security
We follow generally accepted industry standards to protect the personal information submitted to
us, both during transmission and once we receive it. No method of transmission over the Internet,
or method of electronic storage, is 100% secure, however. Therefore, while we strive to use
commercially acceptable means to protect your personal information, we cannot guarantee its
absolute security.

If you have any questions about security on our Site, please contact us at
dataofficer @ mia.school.

Company contact information
If you have questions or comments about this privacy policy, please contact us at +1 (909) 443-
1317 or via email to dataofficer @ mia.school, or by mail at 1259 El Camino Real Unit #1246,
Menlo Park, CA 94025.

INFORMATION FOR USERS IN THE EUROPEAN UNION (GDPR
NOTICE)
Personal Data We Collect
We collect and process the following categories of personal data:
• Account information: Name, email address, password, and other registration details
• Student information: First name, first initial of last name or alias, and password
• Profile information: (if community features are enabled) User-generated content, nicknames,
profile text, etc.
• Payment information: Processed by a third-party provider; we do not store full payment details
• Usage data: IP address, device information, browser type, pages visited, entry/exit URLs, and
cookies
• Optional data: Date of birth (if provided), communication preferences
We collect this information either directly from you (e.g., when you fill out a registration form),
automatically (e.g., via cookies or log files), or from third-party service providers as described in
this policy.
How We Use Your Personal Data
We process your personal data for the following purposes:
• To provide and operate our Services
• To manage user accounts and authenticate logins
• To enable parental controls and consent management
• To process payments and provide customer support
• To analyze, improve, and secure our Services (using analytics and security tools)
• To communicate with you (service updates, support, etc.)
• For marketing and advertising purposes (with your consent, where required)
• To comply with legal obligations
Legal Bases for Processing
We rely on one or more of the following legal bases under the GDPR:
• Performance of a contract: Processing necessary to provide the Services you request
• Consent: For optional processing activities, such as certain cookies or marketing
• Legal obligation: To comply with applicable law
• Legitimate interests: For activities such as analytics, security, or service improvement, provided
these interests are not overridden by your rights
You can withdraw your consent at any time where we rely on your consent.
Data Sharing and Transfers
We may share your data with trusted third-party service providers who help us operate the
Service (e.g., payment processors, analytics providers, cloud hosting).
If we transfer your data outside the European Economic Area (EEA), we use safeguards such as
Standard Contractual Clauses to protect your information.
How Long We Keep Your Data
We retain your personal data only as long as necessary to fulfill the purposes described above or
as required by law.
You may request deletion of your data at any time (see “Your Rights” below).
Your Rights under the GDPR
If you are located in the European Union, you have the following rights regarding your personal
data:
• Right of access: You can request a copy of your personal data we hold
• Right to rectification: You can ask us to correct inaccurate or incomplete data
• Right to erasure: You can ask us to delete your personal data, subject to certain exceptions
• Right to restrict processing: You can request we limit how we use your data
• Right to data portability: You can request your data in a portable format
• Right to object: You can object to processing based on legitimate interests or for direct
marketing
• Right to withdraw consent: Where processing is based on your consent, you may withdraw it at
any time
• Right to lodge a complaint: You may lodge a complaint with your local data protection
authority
To exercise any of these rights, please contact us at dataofficer @ mia.school. We will respond to
your request as required by law.
How to contact us if you are in the European Union
If you have questions about how we use your information or to exercise your rights, you can
contact us at dataofficer @ mia.school or at Miaplaza Germany GmbH, Kollwitzstraße 76, 10435
Berlin, Germany.