Privacy Policy

Level Up is a K-8 math learning service, operated by Playful Digits, the company behind Level Up and the data controller for the personal data described in this policy. In the United States, you can reach us by mail at Playful Digits, 14205 N MoPac Expy, Ste 570, PMB 142266, Austin, TX 78728, USA, and by email at moc.htampulevel@ycavirp. Our full operating-entity details are set out under Operator details below.

Our domain is levelupmath.com. The marketing site lives at this domain; the product runs at app.levelupmath.com.

Two different things, one policy. Level Up is two things with very different privacy profiles, and this policy is explicit about which one it is describing at every point.

• The app your child uses (at app.levelupmath.com). This has no advertising, no advertising or social-media tracking pixels, no selling or sharing of data, and no social features. The only analytics that can run here are our own, for fixing bugs, and only if you have given consent (see "The app your child uses: no ads, no tracking pixels" and "Analytics inside the app" below).
• Our adult-facing websites (the public site at levelupmath.com and the parent dashboard at family.levelupmath.com). With your consent, these use ordinary analytics and advertising-measurement tools, described under "Cookies and similar technologies" below.

We never apply the advertising or marketing tools to children, and we never send a child's data to an advertising platform. Wherever a section below talks about pixels, cookies, retargeting, or advertising, it is about the adult-facing websites, and we say so.

This Privacy Policy works alongside our Terms of use and our Data Processing Agreement. The Terms of use sets out the contract you enter when using the Service; this Privacy Policy explains what personal data we handle and how; the Data Processing Agreement covers the formal processing terms and, in Annex A, the canonical list of subprocessors.

For any privacy or data-protection question, write to moc.htampulevel@ycavirp.

The personal data we process falls into five categories.

1. Parent account data. When you create a parent account we collect your full name, email address, an authentication identifier from our authentication provider (Clerk), and any subscription metadata our payment processor (Stripe) returns to us (such as the country of your billing address, a transaction identifier, and the last four digits of the card used). We do not see or store your full card number. We collect contact preferences if you opt into product communications.

2. Child profile data. For each child you register, we collect a first name (or chosen handle), grade level, optional unit-system preference (metric or U.S. customary), and the device/browser information needed to operate and support Linked Devices (browser type and version, operating system, and screen size). We do not collect last names, dates of birth, gender, photos, voice or video recordings, or any contact details from children.

3. Adaptive assessment data. While your child completes the initial assessment and continues to practice, the Service performs adaptive assessment dynamically. We record problem responses, attempts, hint requests, time spent on each item, and the resulting skill placement per topic. The purpose is to identify your child’s current knowledge and the specific gaps to work on next, and to summarize that picture for you in the parent dashboard and the AI-generated report. This is assessment, not behavioral tracking: we look at math skill, not at how your child spends their time, who they communicate with, or what they do outside the Service. The app your child uses carries no advertising trackers of any kind (see the two sections that follow "Children's data" below).

4. Marketing website and parent-dashboard visitor data (adults). When an adult browses our public website or uses the parent dashboard, we may process: usage signals collected by PostHog (analytics consent), advertising-measurement and retargeting signals from the Facebook Pixel, the TikTok Pixel, and Google Ads (click identifiergclid, recorded at signup and sent to Google from our servers so an ad click can be matched to the account it produced), and short-lived technical logs (IP address, user agent, request timestamps) used for security and abuse-prevention. None of these run before you give consent in regions that require it. None of these advertising or measurement tools run in the app your child uses.

5. Billing data. When you pay for a Subscription, Stripe collects and processes your payment instrument directly; we receive a tokenised payment-method reference, the country of your billing address, transaction amounts and timestamps, and renewal status. We retain invoice records as required by Romanian accounting law (see "How long we keep it").

We also do not collect biometric identifiers (such as face, fingerprint, or voiceprints), precise device geolocation, or contact lists, from anyone. Coarse, country-level location is inferred from the network request only to apply the correct privacy rules; we never track a device's precise location.

Under the EU General Data Protection Regulation (GDPR), every kind of processing must have a legal basis. Ours are:

• Performance of a contract (Art. 6(1)(b) GDPR): we process parent account data, child profile data, learning interaction data, and billing data because we need to in order to deliver the Service you asked for.
• Consent (Art. 6(1)(a) and Art. 7 GDPR): we use consent for non-essential cookies and for the analytics tool (PostHog) and marketing tools (Facebook Pixel, TikTok Pixel, Google Ads) where consent is required by local law (notably in the EEA and UK). You can withdraw consent at any time from the cookie settings.
• Legitimate interests (Art. 6(1)(f) GDPR): for security, fraud prevention, abuse mitigation, supply-chain security monitoring, and aggregated product improvement, where the interests of running and protecting the Service do not override your privacy rights.
• Legal obligation (Art. 6(1)(c) GDPR): for accounting record-keeping under Romanian law and for responses to lawful requests from competent authorities.
• Verifiable parental consent: for child profile data and learning interaction data, the parent contracting on the Account provides the consent required by GDPR Art. 8 and, where applicable to U.S. visitors, by COPPA.

Level Up is built around a parent-led signup model: only adults create accounts, and children only access the Service through Linked Devices that you, as parent, set up. This is by design. It lets us collect verifiable parental consent in the simplest possible way, by treating your acceptance of these Terms and your active provision of the child's first name and grade as the act of consent.

How we obtain verifiable parental consent. Only an adult can create an Account. A child never signs up, never enters an email, and reaches the Service only through a Linked Device that you set up from the parent dashboard. You provide the child's first name and grade yourself, and your acceptance of these terms at account creation, together with your active setup of the child, is the verifiable parental consent COPPA requires before any of the child's data is collected.

We minimize children's data aggressively. We do not collect last names, dates of birth, gender, photos, voice or video recordings (we never access a camera or microphone), address, or contact details for children. We do not show advertising to children. We do not sell or rent any children's data. We do not use children's data to build profiles for marketing purposes. The app your child uses contains no Facebook/Meta Pixel, no Google Ads tags, and no third-party advertising or ad-targeting technology of any kind.

Aggregated, anonymised statistics (for example, "75% of 5th graders found this problem easy") are derived from learning interaction data and used to improve the adaptive engine. The aggregation removes anything that could identify an individual child.

For visitors based in the United States, we treat children under thirteen (13) as covered by COPPA. The parent-only signup flow constitutes the verifiable parental consent COPPA requires, and you may review, export, or delete your child's data at any time from the parent dashboard or by contacting moc.htampulevel@ycavirp.

The app your child uses at app.levelupmath.com contains no advertising. It also contains no advertising or social-media tracking technology of any kind: no Facebook/Meta Pixel, no Google Ads tags, and no third-party advertising or ad-targeting scripts. We do not build an advertising or marketing profile of any child, and we never send a child's data or in-app activity to an advertising platform.

The advertising and measurement tools described later under "Cookies and similar technologies" run only on our adult-facing websites, never in the app your child uses.

Within the Service (the app your child uses), Level Up does not:

• sell or rent personal data;
• share personal data with third parties for their own marketing;
• show targeted or personalized advertising;
• allow third-party tracking (advertising or analytics technologies operated by other companies);
• track users across other websites or apps; or
• build behavioral or advertising profiles of any user or child.

The advertising and measurement tools named elsewhere in this policy apply only to our adult-facing websites, never to the Service or to any child.

To find and fix problems in the app your child uses, we can run one first-party analytics tool, PostHog, inside the app. It is off by default and turns on only if you, the parent, have given tracking consent for your child. It never runs during a Level Up support session. When it is on:

• It identifies your child only by an internal, non-identifying reference and grade band. It never uses your child's name.
• It can record a session replay, and we want to be precise about what that is and is not. It is a reconstruction of what happened on your child's own Level Up screen (which buttons were tapped, which screens opened, and the math typed into answer boxes), rebuilt from the app's own activity so we can see where the app confused a child or broke. It is not a video of your child, and it does not use your child's camera, microphone, or the rest of the device. We do not hide the answer fields, because the only thing entered into them is math, which is not personal information.
• It is used only for our own product debugging. It is not advertising, we do not build marketing profiles from it, and we never send it to an advertising platform.

You can turn this on or off at any time from your child's Settings in the parent dashboard (open the child, then Settings → Permissions). It starts off when you add a child, and switching it off stops the analytics.

So our team can catch display bugs and review any problem a child flags as wrong, the app sometimes captures a picture of the question area of the screen (the problem and the answer area, nothing else) and sends it to us. This picture is drawn from the Level Up page the app has already rendered; it is a snapshot of our own content, and it is never a capture of your child, your child's device, other apps, the camera, or the microphone.

These snapshots are captured when your child submits an answer (so a reviewer can confirm the problem displayed correctly) and when your child flags a problem. They are stored on our own systems, used only to review and improve our content, and kept and deleted under the same rules as the rest of your child's learning data.

Level Up has no chat, no messaging, no comments, no forums, no friend lists, and no public profiles. There is no way for one user to contact, see, or interact with another. Children cannot post content, and nothing a child does is visible to any other user. There is no user-generated content to moderate, because there is no channel that would create it. The only messages a child can send go privately to our team (for example, flagging a problem that looks wrong).

All communication about the account and your child's learning goes to you, the parent, never to your child. We do not collect any way to reach a child in the first place (no email address, phone number, or mailing address for children), so we do not and cannot email, text, call, or send push notifications to them. If we notice a problem, have a question, or need to reach anyone, we contact the parent.

There is one narrow exception, and it lives only inside the app. When your child flags a problem, we may show a short, predefined status note about that report: that we fixed it, that it was working correctly, or that we passed the idea along. These three status notes are optional.

When you or your child reports a problem, our team may also write one short note addressed to your child about that problem. We email you the exact note, the report, and the available question context first. The note appears in your child's app only after you approve that text, unless you have chosen to show notes automatically for that child. Sent note text cannot be edited. Approval links work for 30 days; an unapproved note expires after that time. You can use the links to approve or hide the note during those 30 days.

Automatic display is off by default and is a separate choice for each child. If you turn it on, we still email you a copy of every note before it becomes available in the app, with a link to hide it. You can return to approving each future note from any note email while its links are valid, or at any time in Settings, Notifications. Your child cannot reply to a note; the only way for a child to contact our team remains reporting a problem. We never email, text, call, or send push notifications to a child.

After your child completes the initial assessment, we produce an AI-written narrative report and share it with you in the parent dashboard. The narrative is generated by a third-party large-language-model service, currently Anthropic Claude Opus, operated by Anthropic, PBC. We may also use Anthropic Claude or OpenAI GPT models from time to time to support limited adaptive features (for example, generating practice item variants for our content team to review).

What we send. The prompt we send to the model is a pre-computed brief derived from your child's assessment activity: skill placement, foundation analysis, prerequisite mapping, and time-on-task summaries. We do not send your name, your child's last name, photos, voice, or any contact information. We do not send raw item-bank internals.

What we receive. The model returns a narrative summary, which our adaptive engine validates against an allow-list before saving it to the report we show you. The report is stored in our database and is regenerable; only the final saved output is exposed to the parent dashboard.

Legal basis. Performance of a contract (Art. 6(1)(b) GDPR), because the report is part of the Free Assessment we promise to deliver. Aggregated improvement of the adaptive engine relies on our legitimate interest (Art. 6(1)(f) GDPR).

Model training. Our AI subprocessors are contractually prohibited from using your or your child's data to train their general-purpose models. Inputs and outputs are retained by the subprocessor only as long as necessary to provide the inference service and meet the subprocessor's safety obligations (typically up to thirty (30) days).

Your rights. You can request a copy of the report and the underlying brief, or ask for it to be corrected or deleted, by writing to moc.htampulevel@ycavirp. AI is integral to how Level Up assesses and teaches, so we cannot meaningfully run the Service without AI processing your child's assessment data; if AI is not acceptable to you, please close the account. See "Your rights under GDPR" and "Automated decision-making" below.

Playful Digits SRL is the merchant of record for every subscription purchased through Level Up. We issue your invoice and are the counterparty to the Subscription. Stripe Payments Europe, Ltd. ("Stripe") processes the payment on our behalf, including the secure handling of card details, the customer portal you can use to manage billing, and 3-D Secure / SCA where required.

Playful Digits SRL is not currently registered as a VAT payer in Romania, and no VAT is added to the price you pay. If our revenue crosses the threshold that requires VAT registration, we will update this policy and the Terms of use in advance of any change.

Stripe is a subprocessor for the limited purpose of payment processing. We never receive your full card number; we receive only a tokenised payment-method reference, basic transaction metadata (amount, currency, status), and the country of your billing address. Stripe's privacy practices are governed by Stripe's own privacy policy. We have a written data-processing agreement with Stripe and rely on the EU Standard Contractual Clauses where Stripe processes data outside the EEA.

We keep personal data only for as long as we need it. The defaults are:

• Active accounts: parent and child data is retained while the account is active. It moves with the account: if you cancel the subscription but keep the account open, the data stays so you can resume.
• Account closure or child profile deletion: when you close the account, or when you delete a child profile, the corresponding data is removed from our live systems within thirty (30) days.
• Backups: we keep encrypted, daily backups of the production databases for up to thirty (30) days for disaster recovery only. After that window, backups are rotated out and the data is permanently unrecoverable. Records marked for deletion are re-deleted automatically if a backup is ever restored.
• AI subprocessor inputs and outputs: prompts and completions are retained by our AI subprocessors for up to thirty (30) days for safety review and abuse prevention, then deleted in line with their contractual commitments.
• Billing and accounting records: invoices and supporting accounting records are kept for the period required by Romanian law, currently ten (10) years for accounting documentation.
• Administrative audit logs: who did what in our admin tools, retained for security and audit purposes, for up to twenty-four (24) months.
• Marketing analytics: site-visitor analytics events are retained for up to twenty-four (24) months in PostHog, then aggregated or deleted.
• In-app product analytics: where you have enabled it, the PostHog debugging events described under "Analytics inside the app" follow the same retention as our other analytics events (up to twenty-four (24) months), then are aggregated or deleted.
• Question-area screenshots: retained only as long as needed for content review, and deleted with your child's other learning data when you delete the child profile or close the account.

You can ask us to delete your data sooner, subject to legal-retention obligations. See "Your rights under GDPR" below.

There are two ways to have data removed, depending on how much you want to delete:

• Delete a single child: open that child's settings in the parent dashboard and delete the profile. This removes the child and all of their learning data and leaves the rest of your account intact.
• Close the whole account: write to moc.htampulevel@ycavirp from the email address on the Account and ask us to delete it. We confirm the request and then permanently remove the account.

When we delete an account, we remove:

• the parent account and your Level Up sign-in credentials;
• every child profile on the account; and
• all of their learning data, including assessment responses, the resulting reports, and progress.

Deleted data is removed from our live systems within thirty (30) days and rolls out of our encrypted backups within a further thirty (30) days, after which it is permanently unrecoverable. The single exception is billing and accounting records (invoices), which Romanian law requires us to keep for ten (10) years. See How long we keep it for the full retention schedule and Your rights under GDPR for the related access, correction, and portability rights.

We engage a small, carefully chosen set of third parties to help us run Level Up. The core production database and APIs are hosted within the EU (Hetzner in Helsinki); product analytics live in PostHog's EU Cloud (Frankfurt); subscription billing is contracted through Stripe Payments Europe in Ireland. The remaining subprocessors (CDN and security, parent authentication, error tracking, AI services, transactional email, web fonts) are mostly U.S.-based and are engaged only where an EU-resident equivalent does not exist or would materially degrade the Service.

The full, authoritative list, including each subprocessor's name, processing purpose, location, and the transfer mechanism applied, is maintained in Annex A of our Data Processing Agreement. Each subprocessor is engaged under a written data-processing agreement, and we will tell you in advance when we add or replace one.

Where a subprocessor is located in the United States or another country outside the EEA, we rely on the European Commission's Standard Contractual Clauses (SCCs) and, where applicable, on adequacy decisions, to safeguard the transfer.

The core of our infrastructure runs in the European Union: the production databases and APIs are hosted by Hetzner in Helsinki (Finland), product analytics are processed by PostHog's EU Cloud (Frankfurt), Stripe Payments Europe is contracted from Ireland, and most of our team works from within the EU. We deliberately minimize transfers to non-EU jurisdictions.

Some unavoidable transfers do occur, to Cloudflare (CDN, hosting, security), Clerk (authentication), Stripe (payment processing, where the data leaves the EEA for global card-network operations), Sentry (error tracking), Meta (Facebook Pixel and retargeting audiences, consent-gated), Anthropic and OpenAI (AI services), Resend (transactional email), and Google (Google Ads, consent-gated, plus Google Fonts for the public website). These transfers are protected by the European Commission's 2021 Standard Contractual Clauses, supplemented by the technical and organizational measures described in our DPA. Where the destination jurisdiction is the United States, we have reviewed the recipient's commitments under the EU–U.S. Data Privacy Framework (DPF) and its successor frameworks, and rely on them where they provide an additional safeguard.

You can request a copy of the safeguards in place by writing to moc.htampulevel@ycavirp.

We share personal data in three narrow situations and otherwise we do not.

• With our subprocessors, listed above, only as necessary to deliver the Service and only under contract.
• To comply with the law, such as to respond to a lawful request from a competent authority. Where we can, we will challenge requests we believe to be disproportionate and notify you unless prohibited by law.
• In a business transition, such as a merger, acquisition, or sale of substantially all our assets, in which case the acquiring entity will be bound by equivalent privacy commitments. We will notify you in advance.

We do not sell personal data. We do not rent mailing lists. We do not share children's data with marketing platforms. We do not allow our AI subprocessors to train their general-purpose models on your data. The advertising-platform relationships described in this policy (Meta and Google) exist only to measure and improve our advertising to adults on our public websites; they run only for adult visitors who have given marketing consent, and they are never applied to children, to the app your child uses, or to any child's in-app activity.

We apply the technical and organizational measures appropriate to the risk: encryption in transit (TLS 1.2+) and at rest, access controls based on the principle of least privilege, multi-factor authentication on all administrative access, audit logging of administrative actions, isolation of production and non-production environments, regular dependency scanning and supply-chain hardening (including a 72-hour quarantine on newly published dependencies), periodic credential rotation, and incident-response procedures designed to notify affected users within seventy-two (72) hours of becoming aware of a personal data breach (GDPR Art. 33).

No system is perfectly secure. If we discover a security incident that affects your data, we will notify you and the supervisory authority as required by law and tell you what we are doing about it.

As a data subject you have the following rights under the GDPR:

• Access (Art. 15): to a copy of the personal data we hold about you and the children on your account.
• Rectification (Art. 16): to correct inaccurate or incomplete data.
• Erasure / right to be forgotten (Art. 17): to request deletion of personal data when it is no longer needed for the purposes for which it was collected.
• Restriction of processing (Art. 18): to ask us to limit how we use your data while a dispute is being resolved.
• Portability (Art. 20): to receive your data in a structured, commonly used, machine-readable format and have it transmitted to another controller where technically feasible.
• Objection (Art. 21): to object to processing based on legitimate interests, including profiling.
• Withdraw consent (Art. 7): at any time, where processing is based on consent. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
• Not be subject to a decision based solely on automated processing (Art. 22), where the decision produces legal or similarly significant effects (see "Automated decision-making" below).
• Lodge a complaint with your supervisory authority (see Contact below).

To exercise any of these rights, write to moc.htampulevel@ycavirp. We will respond within one (1) calendar month, unless the request is complex, in which case we may extend the deadline by up to two further months and tell you why. Most requests are answered the same week.

Where the request concerns a child's data, the parent or legal guardian on the Account makes the request on the child's behalf.

Your controls, in one place. From the parent dashboard you can: delete a child's profile and all of their learning data; close the whole account; and turn the in-app analytics consent for each child on or off (open the child, then Settings → Permissions). On our websites you can change or withdraw cookie consent at any time, and we honor the Global Privacy Control signal. For anything else, to access, correct, export, or delete data, write to moc.htampulevel@ycavirp and we will take care of it.

The California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA) and the comparable comprehensive privacy laws now in force in other US states (currently Colorado, Connecticut, Texas, Virginia, Utah, Oregon, Montana, Iowa, Delaware, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, and Rhode Island, along with any other US state whose comprehensive privacy law is in effect) give residents of those states a set of consumer rights over personal information.

You have the right to:

• Know what personal information we collect about you, the categories of sources, the purposes for collection, and the categories of third parties with whom we share it. This policy is that disclosure; if you want a record specific to your account, write to moc.htampulevel@ycavirp.
• Delete personal information we have collected from you, subject to limited exceptions (security, fraud prevention, internal uses reasonably aligned with your expectations).
• Correct inaccurate personal information.
• Opt out of "sale" or "sharing" of your personal information for cross-context behavioral advertising. We do not sell personal information in the traditional sense, but loading the Facebook Pixel and sending events to Meta's Conversions API can fall within the broad CCPA definition of "sharing." To opt out, click the Do Not Sell or Share My Personal Information link in the footer and reject the marketing category, or use the cookie settings directly.
• Limit use of sensitive personal information. Level Up does not use sensitive personal information beyond what is necessary to provide the Service.
• Non-discrimination for exercising any of these rights. We do not charge a different price, provide a lower level of service, or otherwise penalize people who opt out.

Global Privacy Control (GPC). We honor the GPC signal as a valid opt-out preference signal. If your browser sends GPC (either via the Sec-GPC: 1 HTTP header or the navigator.globalPrivacyControl JavaScript property), we treat it as an automatic opt-out: no banner, no advertising cookies, no analytics, no Conversions API fires. This applies regardless of any prior cookie choice and regardless of which state you are in.

California: Limited Data Use on Meta events. When we detect you are visiting from California (via Cloudflare's geolocation of the request), we additionally enable Meta's Limited Data Use (LDU) mode on both the Facebook Pixel and the matching server-side Conversions API events. LDU instructs Meta to process those events under CCPA restrictions. This is in addition to the opt-out controls above, not a substitute for them.

To exercise any of these rights, write to moc.htampulevel@ycavirp. We will respond within 45 days (or 90 days if your request is complex, in which case we will tell you up front). Authorized agents may submit a request on your behalf with appropriate written authorization. We may need to verify your identity before responding to protect against fraudulent requests; we will only use the information you provide for verification to process the request.

Beyond COPPA (which we follow for children under 13, using the verifiable parental consent described above), a growing number of US state laws protect the data of minors. We apply the same posture to every minor, wherever they live:

• we treat a minor's personal data as sensitive and process it only to deliver the Service you asked for;
• we do not sell minors' data, show them targeted or personalized advertising, or build advertising or behavioral profiles of them;
• we do not use manipulative or "dark pattern" design to push a child into sharing more data; and
• for teenagers (13–17), we process only what is strictly necessary to provide the Service.

This meets, among others, the New York Child Data Protection Act and the children's and minors' provisions of the California, Colorado, Connecticut, Delaware, Oregon, New Jersey, Minnesota, and Maryland privacy laws. Maryland applies its minor protections to anyone we knew or should reasonably have known is under 18; our practices meet that standard everywhere.

Level Up is bought and managed by parents for use at home. It is not designed, marketed, or sold for use by schools or school districts, and we have no contracts with schools. Laws that govern student data held by schools and their vendors (such as FERPA and state student-privacy laws like California's SOPIPA) therefore do not apply to us.

GDPR Article 22 gives data subjects the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects. Level Up does not make such decisions.

The AI-generated report described above is informational. It summarizes your child's assessment results in narrative form, is reviewed by our adaptive engine against an allow-list before it reaches your dashboard, and is provided to you (the parent) so that you can make your own choices about how to use it. The report does not by itself produce any legal effect, alter your child's educational status, gate access to any third party, or otherwise change your or your child's situation outside of the Service.

AI processing is integral to the adaptive assessment and the report; we cannot meaningfully run the Service without it. If AI processing is not acceptable to you, please close the account by writing to moc.htampulevel@ycavirp.

We use a small number of cookies and browser-storage mechanisms. We group them into three categories:

• Necessary: required for the Service to function: session tokens, consent state, security and load-balancing cookies. These run by default and you cannot opt out without breaking the Service.
• Analytics (consent-gated): PostHog EU Cloud (Frankfurt) records how you use our adult-facing websites and the parent dashboard (clicks, scrolls, page navigations, and a session replay, a reconstruction of on-screen activity, not a camera or microphone recording, that can include what you type into forms, with password fields masked and sign-in screens excluded) so we can see where the page helps and where it confuses. Sessions use a per-browser identifier; if you sign up, they can be linked to your account so we can debug issues you actually hit. Loaded only after you accept the analytics category.
• Marketing (consent-gated): three tools, used together to measure how our ads perform and to show follow-up ads to people who visited the site but did not sign up, or who signed up but did not finish the assessment (retargeting). The Meta (Facebook) Pixel and the TikTok Pixel handle the Meta and TikTok ad ecosystems directly. For Google Ads we record the click identifier (gclid) that Google adds to the link you arrived on, and if you create an account our servers tell Google that the click led to a signup. Loaded only after you accept the marketing category.

You can review and change your choices at any time using the cookie settings button (available from the footer of every page).

Regions where we require explicit consent before loading anything optional. The cookie banner appears, and no analytics or marketing cookies are loaded until you give explicit consent, for visitors in: the European Economic Area (all EU member states plus Iceland, Liechtenstein, and Norway), the United Kingdom, Switzerland, Canada (in particular to comply with Quebec's Law 25), and Brazil (LGPD). For visitors in other countries, including the United States, we default to loading analytics and marketing cookies, and you can opt out at any time via the cookie settings or the "Do Not Sell or Share My Personal Information" footer link (see Your rights under US state privacy laws).

Global Privacy Control. If your browser sends the Global Privacy Control signal (Sec-GPC: 1 or navigator.globalPrivacyControl === true), we treat it as an opt-out: no banner is shown, no analytics or marketing cookies are loaded, and no server-side Conversions API events are fired, regardless of which region you are in.

We sometimes invite parents to a beta or early-access cohort through a form on this site. The form collects your name, email, and the first name and grade of each child you would like to add. We use that information to:

• contact you about the beta and the steps to join;
• select cohorts that match the curriculum work we are testing (for example, by grade level);
• send a small number of follow-up emails about the beta.

Beta-form submissions are stored separately from the main product database. The legal basis is consent (Art. 6(1)(a) GDPR), which you give by submitting the form. You can withdraw consent and ask us to delete the submission at any time by writing to moc.htampulevel@ycavirp.

Level Up and this policy are operated by Playful Digits SRL, a Romanian limited liability company (registration CUI 50092060) with its registered office at Bogdan Voda 14, Bucharest 010936, Romania. Playful Digits SRL is the data controller for the personal data described in this policy. For postal mail, including from the United States, write to us at Playful Digits SRL, 14205 N MoPac Expy, Ste 570, PMB 142266, Austin, TX 78728, USA.

We have assessed our processing activities against the criteria in GDPR Article 37 and have not appointed a formal Data Protection Officer (DPO) because our processing does not meet the thresholds set out in that article. We have instead designated a privacy point of contact, reachable at moc.htampulevel@ycavirp, who is responsible for handling data-protection matters and for liaising with supervisory authorities.

Our lead supervisory authority is the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP, dataprotection.ro). Any individual may also lodge a complaint with the supervisory authority in the EU member state where they live or work.

We update this policy when our practices change. The date at the top of the document shows when it was last updated. Where a change materially affects your rights or our processing, we will notify you in advance, for example by email or through a prominent notice on the site.