SchoolSpeak is a member of the Community Brands family. This Privacy Policy (“Privacy Policy”) is specific to SchoolSpeak and may contain information not included in Community Brands’ statement. This is due to the specific services and software uniquely provided by SchoolSpeak. Please also review the Community Brands Privacy Policy to ensure you are fully informed of our privacy practices. The Community Brands Privacy Policy can be found here: https://www.communitybrands.com/legal/ .

At SchoolSpeak (“SchoolSpeak”, “we”, “us”, “our”, or the “Company”), we are committed to protecting your privacy. This Privacy Policy is intended to give users of the SchoolSpeak services, including teachers, administrators, students, parents, and third party vendors and contractors to whom the applicable school may grant access to perfom services for the school, a full understanding of types of information we collect and is designed to help you understand how we collect, use and safeguard the information you provide to us and to assist you in making informed decisions when using our Services. This Privacy Policy also describes (1) the measures we take to safeguard the information we collect and (2) your rights and privileges concerning our collection, use and disclosure of information about you.

This Privacy Policy applies to the product platform and websites owned and operated by SchoolSpeak, including, but not limited to, www.schoolspeak.com. Throughout this document, this website, all other SchoolSpeak affiliated websites, and affiliates with links to this policy will be collectively referred to as the “Websites”. Services provided by or enabled via the Websites will be referred to as the “Services”.

SchoolSpeak is not responsible for the content or privacy practices of non- SchoolSpeak websites to which this website, or any other SchoolSpeak website, may link. Also, SchoolSpeak is not responsible for the privacy practices of our Clients or users of our Clients’ websites. You should review any additional privacy policy and terms of use agreements before using a Client’s website.

By using our Websites, you consent to the data practices described in this Privacy Policy. If you do not agree with the data practices described in this Privacy Policy, you should not use our Websites.

In addition to the Websites, SchoolSpeak operates a web-based software, as well as a web-based application, used by our Clients to provide access to a website for authorized individuals, including their employees and customers. The use of information collected through this platform is strictly limited to the purpose of meeting our contractual obligations to our Clients and providing the services requested by our Clients, which are defined within our service agreements.

If you are the customer of one of our Clients, you should refer to that Client’s privacy policy for information on how your personal information is collected, used and protected. Any inquires related to your data, how it is processed, and data access, deletion and modification requests should be directed to that Client.

The data SchoolSpeak collects and uses is governed by this Privacy Policy as amended from time to time, not by the Privacy Policy in effect at the time of data collection. This includes data collected from SchoolSpeak Websites, affiliates with links to this Privacy Policy, and services provided by or enabled via these sites. SchoolSpeak may change the Privacy Policy at our sole discretion and will provide notice of changes in the Privacy Policy and on the privacy policy page of our Websites. If, as the result of such changes, you want to alter the ways in which we are allowed to use your personal information, you can do so by following the procedure described in the section entitled “Privacy Rights”.

Please regularly review our Privacy Policy. If you have objections to the Privacy Policy, you should immediately discontinue use of the Websites and the Services enabled by the Websites. This Privacy Policy does not govern privacy practices associated with offline activities, websites other than the Websites, or any products or services not available or enabled via the Websites.

You will be deemed to have been made aware of, and will be subject to, the changes to the Privacy Policy after such notice has been posted with the following exception: if at the time you provide personal information to SchoolSpeak you limit how such information will be used to communicate with you, either by SchoolSpeak or by third parties, SchoolSpeak will not change your preference in this regard without your express consent. However, if SchoolSpeak sells assets (or the assets of a division or subsidiary) to another entity, or SchoolSpeak (or a division or subsidiary) is acquired by or merged with another entity, you agree that SchoolSpeak may provide to such entity customer information that is related to that part of our business that was sold to or merged with the other entity without obtaining your further consent. SchoolSpeak will provide notice of such asset sales, acquisitions, or mergers on its Websites.

SchoolSpeak’s Websites and Services are not designed for users under the age of 16. As such, this Website is not directed at children under the age of 16 nor do we knowingly collect or maintain information from children under the age of 16 on this Website.

A Note to Parents & Children

If you are a child under 16 in the European Union or UK or a child under 13 in the United States, you may access the Service only to the extent that consent is given or authorized by the holder of parental responsibly over you. Please speak with your parent or guardian about this Privacy Policy so you can better understand how we use your personal data. We make reasonable efforts to verify that consent is given or authorized by the holder of parental responsibility over you, and, if we learn or have reason to suspect that we have collected personal data from you without parental consent, we will promptly delete it.

Parental Access

A parent who has already given SchoolSpeak or our client permission to collect, use, and share their Child's personal information can, at any time, do the following: (1) review, correct, or delete the Child's personal information; and/or (2) discontinue further collection, use, or sharing of the Child's personal information. To do so, please contact your child’s school who you provided consent to.

We require parental consent in the form of a signed parental consent form before the School will gives access to any student user from whom information will be collected. Parental consent is received by the School, and the School is responsible for providing parent users access to their child's profile so that the parent user may review, modify, or delete any child information contained in the profile by logging into their child's account on the Website. The School is responsible for confirming receipt of valid parental consent forms for each child before allowing the child to access the Website.

Parents always have the right to refuse further collection, use and/or disclosure of the child information by giving notice to the School. Parents also have the option to agree to the collection and use of their child's personal information without agreeing to the disclosure of the information to third parties by notifying the school; however, due to the nature of the Website, if parents do not consent to disclosure, their child will not have access to the Website. In any case, we may provide any collected information to third parties who use it solely to provide support for our internal operations.

Student Users will not be required to disclose more child information than is reasonably necessary to enable the child's participation in the Website features. This child information is not sold to any third parties and is only disclosed to third parties as described in this Privacy Policy.

The clients of SchoolSpeak co-own the information collected on this site as collected for contracted services. SchoolSpeak is the sole owner of information collected on this site outside of those contracted services. We have access to and collect information that you voluntarily give us via email, webform or other direct contact from you. We will use your information to respond to you, regarding the reason you contacted us. We will not sell or rent this information to anyone. We may disclose information to our corporate affiliates and third parties to provide products and services to you or related to products or services you have downloaded from SchoolSpeak. Unless you ask us not to, we may contact you via email in the future to tell you about our services, new products, or changes to this privacy policy or to provide you with informational or educational newsletters.

Do not provide personal information about others unless you are authorized or required to do so by applicable law or contract. Before supplying personal information about others, you and the person about whom you supply the information must review and consent to the Terms of Use and Privacy Policy of the Website. By submitting any personal information about others, you represent and warrant that you are authorized to do so, that you have made the Terms of Use and Privacy Policy available to the person about whom you supply the information, and that you have obtained that person’s written consent to our Terms of Use and Privacy Policy. If applicable law allows you to supply the information without doing the foregoing, you represent and warrant that you have abided by that law and that it allows us to receive and disclose the information under this Privacy Policy without any further action on our part. You agree to indemnify, defend and hold harmless SchoolSpeak, our parents, subsidiaries, officers, directors, employees and agents, sponsors and supporting artists, licensors and suppliers for any failure by you to comply with this paragraph.

Personal Information and Business Information

“Personal Information” as used in this Privacy Policy is information that we directly associate with a specific person or entity, such as name, address, payment information, mobile telephone number, and email address. All registered users shall be given a User ID and password. Users must provide first and last name. User may also provide other personal information such as date of birth, grade student is in, parent’s name and emergency contact information.

The Personal Information you provide will vary based upon the context, and we will not collect your Personal Information unless you make it available. You are not required to provide Personal Information at any time while visiting the Websites; however, you may be required to provide Personal Information to use certain Services. You may provide us with Personal Information by participating in online surveys, subscribing to newsletters and other recurring offerings through the Websites, and in connection with other products, services, features, or requests made available through the Websites.

Users may post text, photos, homework, calendar entries, school events, grades, assignments, and other files or materials to the Website, including to message boards or chat areas. Please note, the school has control over who can post and view user submissions. User submissions may contain Personal Information.

SchoolSpeak collects the Business Information necessary to enable us to respond to your requests for our products and services and to send you information regarding our products and services from time to time. For these purposes, we have defined “Business Information” as any information that identifies or may identify a company or an individual contact at a company or that allows others to contact a company or an individual contact at a company. When you visit our Websites, you may be asked to submit information such as e-mail address, company name, address, phone number, and/or areas of interest. We may also ask you where you heard about our company or products, or for other information that will help us understand more about your needs or help us process your requests for information. Our information collection and use practices are described in more detail below.

Support

We offer certain limited online support services. If you access our online support, email support, live chat, or call us directly, you may be asked to provide information such as school name, email address, and other information to help us determine what the technical issues are and how best to help you resolve them.

Product-Related Information Collection

SchoolSpeak collects certain additional information in connection with your use of our Services. For instance:

• Account Set-Up and Access: Upon subscribing to our services, SchoolSpeak collects Personal Information including contact details and registration details required by schools. This allows us to identify you to authorize your access and use of the services, and to provide you with your relevant account information. .
• Online Product /Account Application: Certain products and services are subject to an application and enrollment process, which may be completed on paper or online. Information requested may include Federal ID number, bank account, credit card and contact information. This information is used to process your enrollment request and, if approved, to set up and administer your account. .
• Web-based Services: Some of our web-based Services collect certain additional information, including IP address, browser, connection speed, domain, referring URL and other environment-related information. This enables us to provide a secure environment for the use of the services, to pre-populate forms and calculate aggregate statistical information about the customers using these services. We use this information to better protect you and to provide a better user experience..

Third-Party Products

SchoolSpeak discloses Personal Data that we collect (described above) in accordance with the terms set forth in this section. We share your Personal Data with third parties who provide certain services to us to assist us in meeting business operation needs. These parties are authorized to process your Personal Data, on our behalf and pursuant to our instructions, only as necessary to provide these services to us.

Registrations

To access information (blogs, demos of our products, marketing materials etc.) on the Websites, a user may be required to register with SchoolSpeak. During registration a user is required to give certain information (such as name, email address, job title). This information is used to contact you about the products/services on our site in which you have expressed interest.

Payment

We request information from you on our payment form. To make a payment, you must provide contact information (like name and address) and financial information (like credit card number, expiration date). This information is used for billing purposes and to fill your payment. If we have trouble processing a payment, we'll use this information to contact you.

Surveys and Contests

From time-to-time, our Websites may request information via surveys or contests. Participation in these surveys or contests is completely voluntary and you may choose whether or not to participate and therefore disclose this information. Information requested may include contact information (such as name and shipping address), and demographic information (such as zip code). Contact information will be used to notify winners and award prizes, if applicable. Survey information will be used for purposes of monitoring or improving the use and satisfaction of the Websites.

Cookies

SchoolSpeak may place “cookies” on the browser of your computer. Cookies are small pieces of information that are stored by your browser on your computer’s hard drive. Cookies may enhance the convenience and use of the Website. For example, the information provided through cookies may be used to recognize you as a previous user of the Website (so you do not have to enter your personal information every time), offer personalized information for your use, and otherwise facilitate your experience using the Website. You may choose to decline cookies if your browser permits, but doing so may affect your ability to access or use certain features of the Website.

SchoolSpeak may also utilize web beacons on our Websites. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. The information collected through these automated means may include information that we gather and store about your visit to, and use of, the Websites, such as your IP address, type of browser and operating system used, date and time you access the websites, pages you visit, and, if you linked to the Websites from another website, the address of that website. This data does not include Personal Information and is not treated as Personal Information under this Privacy Policy, but it may include the IP address of your device. We may link an IP address to information that is personally identifiable.

Most web browsers automatically accept cookies, but you can disable this function so that your browser will not accept cookies. Please be aware that disabling this function may impact your use and enjoyment of this Website.

Third-Party Analytics

We may also allow certain third-party analytics service providers to include cookies and web beacons within the pages of the Websites on our behalf and to retain and use the information received from such cookies and web beacons themselves. Third-party service providers that collect this data on our behalf may offer information about their data collection practices, and in some cases, an opt out on their respective websites which you can access here: http://www.google.com/analytics/.

Do Not Track

Currently, various browsers — including Microsoft Edge, Google Chrome, Internet Explorer, Mozilla Firefox, and Apple Safari — offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Web sites’ visited by the user about the user's browser DNT preference setting. We do not currently commit to responding to browsers' DNT signals with respect to the Company's Web sites, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. We take privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

We take precautions to protect your information. When you submit sensitive information via the Websites, your information is protected both online and offline. We use appropriate security measures to protect the security of your data both online and offline. These measures vary based on the sensitivity of the information that we collect, process, store, and the current state of technology. Please note, though, that no website or internet transmission is completely secure, so while we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will never occur.

Email Communication

Each promotional email and text message we send will contain instructions on how to unsubscribe should you decide not to receive future promotional communications. If you choose to opt-out of receiving promotional e-mail or text communications from any SchoolSpeak business unit, we may still periodically communicate with you via mail and telephone. Please allow up to 10 business days to be removed from our promotional communications list.

We send notification emails about the Website and Services from time to time as necessary. Generally, you may not opt-out of these communications, which are not promotional in nature.

We also send newsletters to our users with news of new service offerings and promotions. Should you change your mind about receiving these newsletters, you can unsubscribe by following the directions present in each email we send out.

Most of our communications are intended to:

• inform you of an application status; and
• inform you of payment status;

Third-Party E-Mail Promotions

If you access and/or use any of our Partner’s services from a link on this Website, a SchoolSpeak /Partner co-branded site or by any other means, any information you reveal in connection with such service is submitted to our Partner and is not subject to this Privacy Policy. You should consult the privacy policy of any Partner or third-party site with respect to its treatment of any information that you may reveal through such service.

Services and Product Data

SchoolSpeak will not access your Product Data or Services Data except in the following limited circumstances:

• to provide you with technical support, solely at your request and with your permission;
• where the inherent purpose of the product or service requires SchoolSpeak to provide the Product Data or Services Data to a third party on your behalf; and
• unless you opt-out, to utilize Aggregate Information derived from Product Data and Services Data to help us improve our products and services and in developing additional offerings. Aggregate Information is non-identifying information about you that is provided to third parties for analysis. For example, we might inform third parties regarding the number of users of this Website and the activities they conduct while on this Website to better understand user experience. Third-parties who receive aggregate information cannot identify or contact you based on the information they receive.

SchoolSpeak will not provide your Product Data or Services Data to any third-party or permit any third-party to access your Product Data or Services Data, except with your permission or to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order. In addition, if at any time you decide to discontinue your use of the applicable service, your Services Data will be destroyed and removed from all servers according to terms set forth in your Service Agreement, subject to applicable back-up and disaster recovery practices and procedures.

Unless you give us your permission, we don’t share data we collect from you with third parties, except as described below:

Third-party service providers or consultants. We may share data collected from you on the SchoolSpeak Site with third-party service providers or consultants who need access to the data to perform their work on SchoolSpeak’s behalf, such as a website analytics company or our third-party advertising partners. These third-party service providers are limited to only accessing or using this data to provide services to us and must provide reasonable assurances that they will appropriately safeguard the data.

Compliance with Laws. We may disclose your data to a third party if (i) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or government request (including to meet national security or law enforcement requirements), (ii) to enforce our agreements and policies, (iii) to protect the security or integrity of the SchoolSpeak Site or our services and products, (iv) to protect ourselves, our other customers, or the public from harm or illegal activities, or (v) to respond to an emergency which we believe in good faith requires us to disclose data to assist in preventing a death or serious bodily injury. If SchoolSpeak is required by law to disclose any of your data that directly identifies you, then we will use reasonable efforts to provide you with notice of that disclosure requirement, unless we are prohibited from doing so by statute, subpoena or court or administrative order. Further, we object to requests that we do not believe were issued properly.

Affiliates. We may share data collected from you from the SchoolSpeak Site with our affiliates. We all will only use the data as described in this notice. Personal or business information will never be shared with affiliates for marketing purposes.

Business transfers. If we go through a corporate sale, merger, reorganization, dissolution or similar event, data we gather from you through our website may be part of the assets transferred or shared in connection with due diligence for any such transaction. Any acquirer or successor of SchoolSpeak may continue to use the data we collect from you through our Site as described in this notice.

Aggregated or de-identified data. We might also share data collected from you from the SchoolSpeak Site with a third party if that data has been de-identified or aggregated in a way that does not directly identify you.

We do not share your data (including, but not limited to, the personal data of your end users) with third parties for their direct marketing purposes, unless you give us your consent to do so.

We may retain your information for a period of time consistent with the original purpose of collection. For instance, we may retain your information during the time in which you have an account to use our Web sites or Services and for a reasonable period of time afterward. We also may retain your information during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

You may opt out of any future contacts from us at any time. Additionally, if the collection of your personal data was based on your consent, you have the right to revoke that consent at any time. Be aware that by revoking consent, you may lose access to services you previously opted to use.

You may request to review, correct, delete, or otherwise modify any of the personal information that you have previously provided to us through the Company’s Web Site(s) and Services. You can do the following at any time by contacting us via the email address listed below or contacting the school directly:

• See what data we have about you, if any
• Change/correct any data we have about you
• Have us delete any data we have about you
• Express any concern you have about our use of your data

Requests to access, change, or delete your information will be addressed within a reasonable timeframe.

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To request a copy of such information, please contact us as described in the “Questions, Concerns or Complaints” section below, and we will respond within 30 days as required by law.

SchoolSpeak commits to resolve complaints about our collection or use of your personal information. SchoolSpeak takes its users’ privacy concerns seriously.

If you believe that SchoolSpeak has not complied with this Privacy Policy with respect to your personal information, you should first contact us at SchoolSpeak by emailing us at privacy.schoolspeak@communitybrands.com, or by writing to the SchoolSpeak Privacy Office at the following address:

Community Brands
Attn: SchoolSpeak Privacy Office
9620 Executive Center Dr. N #200
St. Petersburg, FL 33702
USA

In your letter, please identify yourself as a SchoolSpeak user and describe in as much detail as possible the ways in which you believe that the Privacy Policy has not been complied with. We will investigate your complaint promptly.

Please note that SchoolSpeak is not responsible for the content or privacy practices of non- SchoolSpeak websites to which this Site or any other SchoolSpeak website may link. Also, SchoolSpeak is not responsible for the privacy practices of its customers or users of its customer websites. You should review the additional privacy policy of the customer site before using the site.

Effective: June 14, 2019.