California Supplemental Notice

Last updated December 17, 2025

Our Privacy Notice explains how we, PenguinLearn Holdings LLC, doing business as PenguinLearn, collect and use personal data when you use our website and services (collectively, the “Services”). This Supplemental California Privacy Notice (“CA Notice”) applies to California residents who use the Services. This CA Notice does not apply where an exception under the California Consumer Privacy Act (“CCPA”) applies.

Our Personal Data Handling Practices over the Preceding 12 Months

In the last 12 months, we collected the categories of personal data described in the section titled “Your Personal Data” of our Privacy Notice. These categories correspond to the categories of “personal information” defined under the CCPA.

  • Identifiers such as a real name, alias, email address, and account name.
  • Information capable of being associated with you, including payment information related to purchases.
  • Characteristics of protected classifications under California or federal law, including age, sex, gender identity, or disability, where voluntarily provided or required for lawful purposes.
  • Commercial information, including records of services purchased, obtained, or considered.
  • Audio, electronic, visual, or similar information, such as live class audio/video and class recordings.
  • Professional or employment-related information, such as information provided by Teachers for onboarding and participation.
  • Education information, including class participation and learning-related activity.
  • Inferences drawn from the information above to improve platform operations and class experiences.

We collected this personal data as described in our Privacy Notice and used it for the purposes described there, including providing and operating the Services, processing payments, enabling live classes, ensuring safety, preventing fraud, and maintaining platform functionality.

In the last 12 months, we disclosed personal data to the categories of recipients described in the section titled “Sharing Your Data” of our Privacy Notice, such as Teachers, service providers, payment processors, video providers, and background check providers.


California Rights and Choices

If you are a California resident, you have certain rights related to your personal data under the CCPA, subject to applicable exceptions.


Right to Know / Portability

You may request disclosure of certain information about the personal data we collected about you within the past twelve months. Once we verify your request, we will disclose:

  • The categories of personal data we collected about you;
  • The categories of sources from which the personal data was collected;
  • The business or commercial purpose for collecting personal data;
  • The categories of third parties to whom personal data was disclosed; and
  • The specific pieces of personal data collected about you.

Right to Deletion

You may request deletion of your personal data, subject to certain exceptions. If your PenguinLearn account is deleted, you will no longer be able to access the Services and would need to create a new account.


Right to Non-Discrimination

We will not discriminate against you for exercising any rights under the CCPA.


How to Submit a Request

Requests may be submitted by emailing support@penguinlearn.com.


Verifiable Requests

We take reasonable steps to verify your identity before responding to a request.


Authorized Agents

You may designate an authorized agent to make a request on your behalf. Parents or guardians may also make requests on behalf of their minor children.


Responding to Requests

We will confirm receipt of your request and respond within the timeframes required by law.


Other California Privacy Rights

California residents under the age of 18 may request removal of content they have publicly posted by contacting support@penguinlearn.com.

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