Children’s Online Privacy Protection Rule (COPPA) Notice

ELLO TECHNOLOGY, INC.

NOTICE REGARDING CHILDREN’S INFORMATION

This notice explains our information collection, disclosure, parental consent practices and parental choice procedures with respect to information provided by children ('Child' or 'Children'), meaning users under the age of 13 in the United States or another age of digital consent under applicable local laws and regulations in other countries. This notice is provided in accordance with the U.S. Children’s Online Privacy Protection Act ('COPPA') and applicable local privacy laws and requirements, and outlines our practices regarding Children’s personal information. For more information about COPPA and general tips about protecting Children’s online privacy, please visit the FTC's Online Privacy and Security page. For more information about our privacy practices generally, see our Privacy Policy at www.ello.com/privacy.

Data Collection:

What data we collect from everyone

Ello Technology, Inc. ('Ello', 'we' or 'us') collects information about Children directly from their parents and guardians ('Parents'), who provide us with their Child’s first name, grade, academic level, home environment, school, activities and interests ('Parent-Supplied Information').

Ello collects information directly from the Child through their interactions with the app, including audio recordings which are turned into session transcripts (’Child-Supplied Information’).

Ello collects ‘App Event Data’ such as time spent in the app, pages or screens viewed, buttons clicked, and other in-app activity (“App Event Data”).

How we use the data we collect for all users

Parent-Supplied Information: Ello uses Parent-Supplied Information in order to provide Parents and their Children with custom-tailored services.

Child-Supplied Information: Ello uses audio recordings to allow the Child to interact with the tutor via conversation, and to assess the Child’s pronunciation and fluency. Ello uses transcripts of sessions to analyze a Child’s academic progress and personalize instruction to each Child. Ello derives Learner Profiles from these transcripts which include Child’s interests and academic progress and contain Personal Information.

App Event Data: Ello uses App Event Data to improve the performance, usability, and educational value of the app for all users, and provide Parents with additional services, such as insights and analytics regarding their Child’s academic progress, app usage patterns, and engagement over time.

We do not use App Event Data to track Children across third-party websites or services, and we do not share this information with third parties for advertising purposes.

How we use the data we collect from users opted into general service improvement

General Service Improvement is an optional setting available during account creation and within the Ello app. It is not required to use the Ello service.

If a Parent enables General Service Improvement, Ello may use the Child's audio recordings and session transcripts to improve our Services for all users. For example, Ello may train speech recognition models or analyze transcripts to understand how the AI Tutor teaches and responds to children.

If a Parent does not enable General Service Improvement, Ello will not use the Child's data for these purposes without obtaining the Parent's express written consent.

How we protect and share the data

We do not share children's personal information with advertising networks, data brokers, or for any marketing purpose.

You have the right to consent to Ello's collection and use of your Child's personal information without consenting to its disclosure to third parties, except where such disclosure is integral to providing the Service. At this time, Ello does not disclose children's personal information to third parties for any non-integral purpose.

We share children's personal information only with the following categories of third parties, each for an integral purpose, and only for the purposes shown:

• Cloud hosting and infrastructure providers: to operate and secure the Service
• AI model providers: to power the AI tutor's conversational and instructional features. We contractually prohibit these providers from using your child's information for their own purposes or to train their general-purpose models.
• Analytics and error-monitoring providers: to maintain reliability and security of the Service
• Legal and regulatory recipients: when required by law or to protect safety

When we delete the data

• Raw audio recordings are deleted 30 days after the session (unless ‘General Service Improvement’ has been selected, which increases retention period to 5 years of inactive subscription)
• Transcripts of Child sessions, and derived Learner Profiles, are deleted after 3 years of an inactive subscription (unless ‘General Service Improvement has been selected, in which case they are retained for 5 years of inactive subscription)
• Parent Supplied Information are deleted after 5 years of an inactive subscription for all users
• App Event Data is anonymized or deleted after 5 years of an inactive subscription for all users

For purposes of this data retention policy, ‘Inactive Subscription’ is defined as an account where there is no active subscription, and there has been no login or meaningful interaction with the account for a continuous period of 24 months.

Note for non-US users

Ello is hosted and operated in the United States. If you use the Service from any other region with laws governing data collection, protection and use that may differ from United States law, you consent to your personal information being transferred outside of those jurisdictions to the United States. The personal information we or our service providers collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe, and certain information may be accessible by persons or companies outside of the United States who provide services for us.

Miscellaneous note

All information pertaining to a Child shall also be treated as part of the Parent’s 'Personal Information' and may be shared as described in the 'Disclosure' section of Ello’s Privacy Policy for business transfers (subject to the limitations of any COPPA notice or Children's Privacy Policy); to vendors and service providers; to comply with legal requirements; and also pursuant to a Parent’s instructions.

AI Service Provider

Ello is an AI Service Provider. The child interacts via conversation with an AI Agent, powered by Ello’s internal models as well as models from companies including but not limited to Anthropic, OpenAI, and Google. The app reminds the Child that they are interacting with AI at a minimum every 3 hours. Each utterance from the AI and from the child is passed through multiple safety systems. These include internal content filters, prompt-level safety instructions, and external moderation provided by upstream model providers. Session transcripts are reviewed for safety and legal purposes. Ello is subject to certain AI service provider legal obligations including but not limited to CA SB 243.

Parental Consent:

Ello obtains verifiable parental consent before collecting, using, or disclosing personal information from your Child. If you sign up for a paid Ello plan, we obtain your consent through Monetary Transaction by requiring a credit card or payment system information. If you sign up for a free Ello plan, we obtain your consent through “Text Plus” two-step text message process. After you indicate consent in the app, we send a confirmation link to the mobile number you provided. When you tap the link, your consent is recorded, and we send a follow-up text confirming that your child's account has been activated.

If you do not consent, then we will not collect, use or disclose any personal information about your Child, and your Child will not be allowed to use features which require personal information. If you are not using our services for any other purposes and do not provide consent within a reasonable time from the date the direct notice was sent to you, we will also delete your online contact information from our records.

Parental Choices and Controls:

At any time, you can refuse to permit us to collect further Personal Information from your Child in association with your account, and can request that we delete from our records the Personal Information we have collected in connection with that account. You also have the right to review Personal Information collected from your child. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service. You can contact Ello to request access to, change, or delete your Child’s personal information by sending an email to us at support@ello.com. A valid request to delete personal information will be accommodated within a reasonable time. In addition to the foregoing, we will exercise commercially reasonable efforts to delete personal information belonging to Children when it is no longer needed for the purpose for which it was collected.

Contact Us: If you have questions or comments about Ello’s data collection practices concerning your Child, please review our Privacy Policy, at www.ello.com/privacy. You can also contact us at: support@ello.com

Last Updated: April 2026