Age of Majority Declaration

Effective date: November 30, 2025

Last updated: November 20, 2025

Purpose of this Declaration

This Age of Majority Declaration establishes the legal age requirements to use the Speakly Platform as an Account Owner and the responsibilities associated with creating sub-profiles for minors.

1. Age of Majority Requirement for Account Owners

1.1. Minimum Required Age

By creating an account on Speakly as Account Owner, you declare and warrant that:

• You are at least 18 years old or have reached the legal age of majority in your jurisdiction of residence, whichever is greater
• You possess full legal capacity to enter into binding contracts under applicable laws
• You are not subject to any legal restriction that prevents you from accepting these terms

1.2. Age Verification

• During the registration process, you must explicitly check the box "I declare that I am of legal age"
• This declaration constitutes a binding legal representation of your age and capacity
• The "Create account" button remains disabled until you confirm this declaration
• Speakly reserves the right to request documentary age verification at any time

1.3. False Declaration

Falsification of your age or legal capacity constitutes:

• Material breach of the Terms and Conditions of Use
• Cause for immediate cancellation of your account without right to refund
• Possible violation of laws protecting minors

Speakly reserves the right to take legal action against those who falsify their age or legal capacity.

2. Use of the Platform by Minors

2.1. Prohibition of Direct Accounts for Minors

Minors under 18 years old CANNOT create or be Account Owners.

The Speakly Platform does not allow minors to:

• Create main accounts
• Provide payment information
• Accept terms and conditions by themselves
• Manage main account settings

2.2. Sub-profile System for Minors

Minors can use Speakly only through the Multi-Profile System, under the following conditions:

• An adult of legal age (father, mother, or legal guardian) must create and own the main Account
• The Account Owner can create student sub-profiles for minors under their responsibility
• The Account Owner assumes total and exclusive responsibility for the use of the Platform by minors

3. Account Owner Responsibilities Regarding Minors

3.1. Declaration of Relationship and Authorization

By creating a sub-profile for a minor, the Account Owner expressly declares that:

• Is the father, mother, or legal guardian of the minor, or
• Has express and verifiable parental authorization to manage the minor's access to online educational services
• Assumes complete responsibility for all activities performed under said sub-profile

3.2. Verifiable Parental Consent

In accordance with international minor protection regulations, the Account Owner provides verifiable parental consent by:

• Creating a sub-profile for a minor
• Editing personal data: Name, Gender, Age, Avatar (Optional)
• Providing the minor's date of birth (for automatic age calculation)
• Accepting the Terms and Conditions on behalf of the minor
• Authorizing the collection and processing of the minor's data in accordance with the Privacy Policy

3.3. Supervision and Control

The Account Owner commits to:

• Supervise the use of the Platform by the minor
• Regularly review the minor's activities, classes, and academic progress
• Protect access credentials to prevent unauthorized use
• Activate the Parental Control PIN (highly recommended) to restrict unsupervised access
• Immediately notify any inappropriate activity or security concern

3.4. Withdrawal of Consent

The Account Owner can withdraw parental consent at any time by:

• Deleting the minor's sub-profile from account settings
• Direct contact to info@speakly.fun

Upon withdrawal of consent, the sub-profile will be deactivated and the minor's data will be treated in accordance with the Privacy Policy and data retention.

4. Minor Protection Principles

Speakly is designed in line with internationally recognized minor protection principles:

4.1. Applied Principles

We apply the following minor protection principles in our practices:

• Verifiable parental consent: We require consent from the father, mother, or legal guardian for minors to use the platform through sub-profiles
• Data minimization: We collect only information strictly necessary to provide the educational service
• Transparency: We clearly communicate to parents/guardians about our data collection and use practices
• Parental rights: Parents/guardians can review, correct, and delete the minor's data at any time
• No commercialization: We do not sell, commercialize, or share minors' data with third parties for marketing purposes
• Enhanced protection: We implement additional security measures to protect minors' data such as optional PIN activation.
• Parental control: We offer tools for parents/guardians to supervise platform use

4.2. Considerations by Region

We recognize that different regulatory frameworks exist for minor protection in different jurisdictions:

• United States: Parental consent principles for minors under 13 years old
• European Union: Consent of the parental authority holder for minors according to age defined by each member state (typically between 13-16 years)
• China: Parental consent for minors under 14 years old
• Other jurisdictions: We apply appropriate protection principles according to applicable local laws

Commitment: Speakly commits to evolving its practices to comply with applicable legal requirements in the jurisdictions where it operates

5. Data Collected from Minors

5.1. Minimum Necessary Information

For minors' sub-profiles, Speakly collects only information strictly necessary to provide the educational service:

Identification Data:

• Minor's real name or nickname
• Date of birth (for automatic age calculation)
• Avatar or profile picture (optional, provided by the Owner)
• Gender

Academic Data:

• History of classes attended
• Evaluations and academic progress reports
• Teacher feedback
• Language and level preferences

Usage Data:

• Interactions with the educational Platform
• Class attendance and punctuality

5.2. Data NOT Collected

Speakly DOES NOT collect from minors without express parental consent:

• Direct contact information (minor's own email or phone)
• Payment information (always managed by the adult Owner)
• Biometric data
• Sensitive information not related to the educational service

5.3. Use of Minors' Data

Minors' data is used exclusively to:

• Provide personalized language classes
• Generate academic reports and progress feedback
• Communicate with the Account Owner (parent/guardian) about the minor's performance
• Improve the quality of the educational service
• Comply with legal obligations

We NEVER sell, commercialize, or share minors' data with third parties for marketing purposes.

6. Parental Control PIN (Highly Recommended)

6.1. Protection Functionality

Speakly offers an optional Parental Control PIN that allows the Account Owner to:

• Restrict unsupervised access to sensitive functions
• Protect payment information and billing
• Control changes in account settings and sub-profiles
• Prevent accidental deletion of sub-profiles or data

6.2. Recommended Activation

We recommend activating the Parental Control PIN when:

• Managing sub-profiles of minors under 13 years old
• The device is shared by multiple family members
• Additional supervision of Platform use is required

6.3. Owner Responsibility

Activation and management of the Parental Control PIN is the exclusive responsibility of the Account Owner. Speakly is not responsible for:

• Unsupervised use when the PIN is not activated
• Disclosure of the PIN to minors or third parties
• Loss or forgetting of the PIN (requires account recovery process)

7. Class Recordings and Minor Privacy Protection

7.1. Automatic Recording for Educational Purposes

ALL CLASSES ARE AUTOMATICALLY RECORDED on the ClassIn platform for exclusively educational purposes.

By creating a sub-profile for a minor, the Account Owner expressly consents on behalf of the minor that:

• Classes will be automatically recorded
• The minor and Owner can access recordings to review content
• Recordings are kept for 3 months and then automatically deleted
• Access is limited to the student, teacher, and authorized academic team of Speakly

7.2. Special Protection for Minors

For minors' sub-profiles, we implement additional protections:

• Absolute prohibition of downloading, capturing, or redistributing recordings
• No promotional use without explicit and separate parental consent
• Mandatory anonymization if promotional use is authorized (covered faces, identifiable data removed)
• Right of immediate revocation of promotional consent

7.3. Promotional Consent for Minors (Completely Optional)

Use of minors' class recordings for marketing purposes requires explicit, separate, and verifiable parental consent.

This consent:

• Is completely OPTIONAL and VOLUNTARY
• Does NOT affect access to educational services
• Can be revoked at any time without justification
• Must be granted by the father/mother/legal guardian, never by the minor
• Requires separate form with independent checkbox (NOT pre-checked)

Guaranteed protections if consent is granted:

• Total anonymization (covered/pixelated faces, no identifiable data)
• Only brief fragments demonstrating pedagogical methodology
• Right to request immediate removal of published material

8. Jurisdictions with Special Restrictions

8.1. Legal Age by Jurisdiction

We recognize that the age of majority varies by jurisdiction:

Important note: Regardless of the digital consent age in your jurisdiction, only those over 18 years old can be Account Owners on Speakly. Minors can use the Platform only through sub-profiles managed by adults.

8.2. Jurisdictional Compliance

If you reside in a jurisdiction with additional minor protection requirements, you agree to:

• Comply with all applicable local laws
• Obtain any additional authorization or consent required
• Notify Speakly if you are aware of special requirements in your region

9. Rights of Parents and Guardians

As Account Owner responsible for a minor's sub-profile, you have the right to:

• Access all personal information of the minor stored on Speakly
• Review class history, evaluations, and feedback
• Correct inaccurate information of the minor
• Delete the sub-profile and request data deletion (subject to legal retention obligations)
• Withdraw consent at any time
• Object to data processing in specific circumstances

To exercise these rights, contact: info@speakly.fun

10. Consequences of Non-Compliance

10.1. Falsification of Age or Legal Capacity

If it is determined that a user has falsified their age, legal capacity, or relationship with a minor:

• Immediate cancellation of the account without prior notice
• No right to refund of payments made
• Report to authorities if applicable
• Legal actions for damages caused

10.2. Unauthorized Use by Minors

If a minor accesses the Platform without adequate supervision or creates a main account by falsifying their age:

• The Account Owner (if exists) is responsible for all consequences
• Speakly may cancel the account and deny future service
• No refunds will be made for services used before detection

11. Modifications to This Declaration

11.1. Right to Modify

Speakly reserves the right to modify this Age of Majority Declaration to:

• Comply with new legal regulations
• Improve minor protection
• Adapt policies to new functionalities

11.2. Notification of Changes

Material changes will be notified by:

• Email to the Account Owner
• Prominent notification on the Platform
• Update of the "Last updated" date on this document

11.3. Validity of Changes

Changes take effect:

• Immediately for new users
• 30 days after notification for existing users

By continuing to use Speakly after entry into force, you accept the modified Declaration.

12. Contact for Minor Protection Matters

If you have questions, concerns, or need to report a problem related to minor protection on Speakly, contact immediately:

Email: info@speakly.fun

Subject: "Minor Protection - [Brief Description]"

Our Legal and Compliance team will review your inquiry with maximum priority and respond within 72 business hours.

Acceptance of This Declaration

By checking the box "I declare that I am of legal age" during registration on Speakly, you confirm that:

• You have read and understood this Age of Majority Declaration in its entirety
• You meet the minimum age requirement (18 years or age of majority in your jurisdiction)
• You possess legal capacity to accept binding terms
• If you create sub-profiles for minors, you are father/mother/legal guardian or have express parental authorization
• You assume total responsibility for Platform use by minors under your account
• You understand the minor protection principles applied by Speakly

This Declaration is an integral part of the Speakly Terms and Conditions of Use.

Effective date: November 30, 2025

Version: 1.0