Privacy Policy

This Privacy Policy (“Policy”) describes how DistrictWON LLC (“DistrictWON”, “Company”, “we”, “our” or “us”) treats information collected or provided in connection with an Authorized User’s (“you” or “your” or “user”) use of UReportNow and all services provided by Company in connection with UReportNow (collectively the “Services”). Please note that your use of the Services constitutes your acceptance of this Policy as set forth below:

WHAT THIS POLICY COVERS

This Policy describes how DistrictWON collects, uses, and discloses personal information through the provision of Services.

This Privacy Policy does not apply to DistrictWON’s handling of: information collected from users of DistrictWON’s company website, which is governed by our Website Privacy Policy.

Unless expressly superseded, this Policy is incorporated into and is subject to the Agreement that governs your use of the Services, including the Terms of Use. .

Our Approach to Student Data Privacy: In the course of providing the Services to our school customers and their Authorized Users, DistrictWON may receive or have access to certain information that directly relates to an identifiable student (as used herein, “Student Data”).

Our receiving and use of Student Data is governed by our Terms of Use and applicable laws which may include the federal Family Educational Rights and Privacy Act of 1974 (“FERPA”), the Children’s Online Privacy Protection Act (“COPPA”), as well as other applicable federal, state, and local privacy laws and regulations (“Applicable Laws”). With respect to any Student Data, DistrictWON’s Terms of Use prohibit any customer and Authorized Users from sending us information for which proper consent has not been obtained. With respect to FERPA, DistrictWON generally expects to receive only “directory information” under Sections 99.3 and 99.37 of FERPA for the purposes of providing Services. With respect to COPPA, the Terms of Use expressly prohibit any use of Services by anyone under the age of 13.

DEFINITIONS

Capitalized terms not defined in this section or above will have the meaning set forth by Applicable Laws.

“Agreement” means the underlying contractual agreement between DistrictWON and the Customer, including but not limited to the Terms of Use.

“Authorized Users” means all authorized users of our Services, including Authorized School Users, parents and legal guardians, and children over the age of 13. “Authorized School Users” means students over the age of 13, educators, and staff using the Services pursuant to an Agreement or with the permission of the School District or State Agency. “School Customer” means the School District or State Agency that is the party to the Agreement to provide the Services to the School Customer’s Authorized School Users. “Original Content” means the output of a Service instance, such as a news article, generated by a Service instance prompted by information supplied by a user. “School District” means a local education agency, school network, independent school, or other regional education system. “State Agency” means the educational agency primarily responsible for the supervision of public elementary and secondary schools in any of the 50 states, the Commonwealth of Puerto Rico, the District of Columbia, or other territories and possessions of the United States, as applicable.

WHAT PERSONAL INFORMATION DO WE COLLECT?

When you access or use our Services, you may choose to provide us with personal information, including Student Data. This information may be provided to us directly (e.g. when an account is created or through communications with us) or through our Services. Student Data. Below is a list of the categories of Student Data that may be collected by DistrictWON or its Services, either directly or through the School Customer’s use of the various features and configurations of the Servicers: Identifier and Enrollment Data, such as name, school, username and password. Why? Our Services require some basic information about any person who may be an Authorized User or the subject of Original Content. This information is provided to us by our School Customers, directly from an Authorized User. Other Data. We may collect the following types of personal information from all other Authorized Users: Contact Information, such as name and email address, as well as school name and school location, whether you are a teacher, administrator, or other authorized person that creates an account or uses our Services or communicates with us. Account Information, such as customer user login and password, for account creation and access purposes. Device and Usage Data. Depending on the Services, we may collect certain information about the device used to connect to our Services, such as device type and model, browser configurations, and persistent identifiers, such as IP addresses and unique device identifiers. We may collect device diagnostic information, such as battery level, usage logs, and error logs, as well as usage, viewing, and technical information (e.g., email open rates), such as the number of requests a device makes, to ensure proper system capacity for all Authorized Users. We may collect IP addresses and use that information to approximate device location to support operation of the Services. To the extent that we collect this information from website visitors who have not signed up for an account, this data is solely used to support operation of the Services and is not linked to Student Data. How? Cookies and Similar Technologies. We collect device and usage data through “cookies,” Web beacons, HTML5 local storage, and other similar technologies, which are used in some of our Services . Why? We use this information to remember returning users and facilitate ease of login, to customize the function and appearance of the Services, and to improve the user experience. This information also helps us track product usage for various purposes, including website optimization, to ensure proper system capacity, troubleshoot and fix errors, provide technical assistance and customer support, provide and monitor the effectiveness of our Services, monitor and address security concerns, and compile analytics for product improvement and other internal purposes. Learn how to opt out of cookies and similar technologies by reading the “What Rights and Choices Do You Have?” section of this Privacy Policy below.

HOW DO WE USE PERSONAL INFORMATION?

Student Data. DistrictWON uses Student Data for educational purposes, to provide the Services, and to ensure secure and effective operation of our Services, including: • to provide and improve our content generation Services; • to support School Customers’ and Authorized School Users’ activities; • to ensure secure and effective operation of our Services; • for purposes requested or authorized by the School Customer or Authorized School User or as otherwise permitted by Applicable Laws; • for adaptive or personalized learning purposes; • for customer support purposes, to respond to the inquiries and fulfill the requests of our School Customers and their Authorized School Users; • to enforce Services access and security controls; and • to conduct system audits and improve protections against the misuse of our Services, or to detect and prevent fraud and other harmful activities. Other Data. DistrictWON may use Authorized User information for the purposes for which Student Data is used as set forth above. DistrictWON does not use Student Data for marketing purposes, but it may use the personal information of other Authorized Users for marketing in limited circumstances (e.g. to periodically send newsletters and other promotional materials), and as otherwise required or permitted, or as we may notify you at the time of collection. Learn how to opt out of these communications by reading the “What Rights and Choices Do You Have?” section of this Privacy Policy below. We may use aggregate or de-identified data as described in the Aggregate/De-identified Data section below.

TO WHOM DO WE DISCLOSE PERSONAL INFORMATION?

Student Data. We disclose Student Data to third parties only as needed to provide the Services under the Agreement, as directed or permitted by the School Customer or Authorized School User, and as required by law. Such disclosures may include but are not limited to the following: • to other Authorized School Users of the School Customer entitled to access such data in connection with the Services; • to our service providers, subprocessors, or vendors who have a legitimate need to access such data in order to assist us in providing or supporting our Services, such as platform, infrastructure, and application software. We contractually bind such parties to protect our data in a manner consistent with those practices set forth in this Privacy Policy; • to comply with the law, respond to requests in legal or government enforcement proceedings (such as complying with a subpoena), protect our rights in a legal dispute, or seek assistance of law enforcement in the event of a threat to our rights, security, or property or that of our affiliates, customers, Authorized Users, or others; and • in the event we or all or part of our assets are acquired or transferred to another party, including in connection with any bankruptcy or similar proceedings, provided that successor entity will be required to comply with the privacy protections in this Privacy Policy with respect to information collected under this Privacy Policy, or we will provide the School Customer with notice and an opportunity to opt out of the transfer of such data prior to the transfer; and Other Data. DistrictWON discloses Authorized User information for the purposes for which Student Data is used as set forth above. DistrictWON may also disclose Authorized User information as otherwise required or permitted, or as disclosed at the time of collection.

AGGREGATE / DE-IDENTIFIED DATA

We may use de-identified or aggregate data for purposes allowed under FERPA and other Applicable Laws, to research, develop, and improve sites, services, and applications and to demonstrate the effectiveness of the Services. DistrictWON will not attempt to re-identify de-identified data. We may use aggregate information (which is information that has been collected in summary form such that the data cannot be associated with any individual) for analytics and reports. For example, our marketing materials may note the total number of people, including students, served by our Services in the prior year, but that information cannot be used to identify any one person or student. We may also share de-identified or aggregate data with research partners to help us analyze the information for product improvement and development purposes. Records and information are de-identified when all personal information has been removed or obscured, such that the remaining information does not reasonably identify a specific individual. DistrictWON does not disclose de-identified data to its research partners unless that party has agreed in writing not to attempt to re-identify such data.

DATA PROHIBITIONS, ADVERTISING, ADVERTISING LIMITATIONS

DistrictWON will not: • sell Student Data to third parties; • use or disclose Student Data to inform, influence, or enable targeted advertising to a student based on Student Data or information or data inferred over time from the student’s usage of the Services; • use Student Data to develop a profile of a student for any purpose other than providing the Services to a School Customer or Authorized School User, or as authorized by a parent or legal guardian; • use Student Data for any commercial purpose other than to provide the Services to the School Customer or Authorized School User, or as permitted by Applicable Laws. DistrictWON may, from time to time, provide customized content, advertising, and commercial messages to Authorized Users, provided that such advertisements shall not be based on Student Data. DistrictWON may use de-identified Student Data to recommend educational products or services to School Customers and their Authorized Users (subject to exceptions permitted under applicable law), or to notify such users about new educational product updates, features, or services. EXTERNAL THIRD-PARTY SERVICES This Privacy Policy applies solely to DistrictWON’s Services and practices. DistrictWON School Customers and other Authorized Users may choose to connect or use our Services in conjunction with third-party services and products. Additionally, our sites and Services may contain social media plugins (e.g. like or share buttons) as well as links to third-party websites or services. This Privacy Policy does not address, and DistrictWON is not responsible for, the privacy, information, or other practices of such third parties. Customers should carefully consider which third-party applications to include among the Services and services they provide to students and vet the privacy and data security standards of those providers. Authorized Users may be able to log in to our Services using third-party sign-in services such as Google. These services authenticate your identity and provide you with the option to share certain personal information with us, including your name and email address, to pre-populate our account sign-up form. If you choose to enable a third party to share your third-party account credentials with DistrictWON, we may obtain personal information via that mechanism. You may configure your accounts on these third-party platform services to control what information they share. SECURITY DistrictWON’s servers are hosted, managed, and controlled in the United States and are not intended to subject DistrictWON to the laws or jurisdiction of any jurisdiction other than that of the United States. If you are located outside the United States, you understand and consent to having Student Data collected and maintained by DistrictWON processed in the United States. United States data protection and other relevant laws may not be the same as those in your jurisdiction. This includes the use of cookies and other tracking technologies as described herein. STUDENT DATA We maintain a comprehensive information security program to safeguard Student Data in our possession against loss, theft and unauthorized use, disclosure, or modification. In the event we discover or are notified that Student Data within our possession or control was disclosed to, or acquired by, an unauthorized party, we will investigate the incident, take steps to mitigate the potential impact, and notify the School Customer in accordance with Applicable Laws. OTHER DATA Outside of Student Data, DistrictWON uses commercially reasonable administrative, technical, personnel, and physical measures to safeguard personal information in our possession against loss, theft, and unauthorized use, disclosure or modification. WHAT RIGHTS AND CHOICES DO YOU HAVE? Opt-out of Marketing Communications. If you want to stop receiving promotional materials from us, you can email us at privacy@districtwon.com or follow the unsubscribe instructions at the bottom of each email. Opt-out of Cookies and Similar Tracking Technologies. With respect to cookies, you may be able to reject cookies through your browser or device controls. Note that you have to opt-out of cookies on each browser or device that you use. If you replace, change, or upgrade your browser or device, or delete your cookies, you may need to use these opt-out tools again. Please be aware that disabling cookies may negatively impact your experience as some features may not work properly. To learn more about browser cookies, including how to manage or delete them, check the “Help,” “Tools,” or similar section of your browser. WHAT RIGHTS DO YOU HAVE WITH RESPECT TO STUDENT DATA? Review and Correction. FERPA requires schools to provide parents with access to their children’s education records, and parents may request that the school correct records that they believe to be inaccurate or misleading. If you are a parent or guardian and would like to review, correct, or update your child’s data stored in our Services, contact your School District. DistrictWON will work with your School District to enable your access to and, if applicable, correction of your child’s education records. If you have any questions about whom to contact or other questions about your child’s data, you may contact us using the information provided below. No third-party website tracking. DistrictWON does not track students across third-party websites and does not respond to Do Not Track (DNT) signals. DistrictWON does not permit third-party advertising networks to collect information from or about students using DistrictWON Services for the purpose of serving targeted advertising across websites and over time and we will never use Student Data for targeted advertising. WHAT IS OUR DELETION/RETENTiON POLICY? Upon request, we provide the School Customer the opportunity to review and delete the personal information collected from students. Student Data Retention. We will retain Student Data for the period necessary to fulfill the purposes outlined in this Privacy Policy and our Agreement with the School Customer. We do not knowingly retain Student Data beyond the time period required to support a School Customer’s or Authorized School User’s educational purpose, unless authorized by the School Customer or Authorized School User. Upon request, DistrictWON will return, delete, or destroy Student Data stored by us in accordance with applicable law and customer requirements. We may not be able to delete all data in all circumstances, such as information retained in technical support records, customer service records, back-ups, and similar business records. Unless otherwise notified by our School Customer, we will delete or de-identify Student Data after termination of our Agreement with the School Customer.

CHILDREN UNDER 13

We do not knowingly collect information from children under 13 and the Services are intended for individuals over the age of 13. If you are a parent and believe that your child under the age of 13 has used the Services and provided personally identifiable information to us through the Services, please contact us at support@districtwon.com and we will work to delete that Services account and any such personally identifiable information.

UPDATES TO THIS POLICY

We may change this Privacy Policy in the future. For example, we may update it to comply with new laws or regulations, to conform to industry best practices, or to reflect changes in our product offerings. When these changes do not reflect material changes in our practices with respect to use and/or disclosure of Authorized Users’ personal information, including Student Data, such changes to the Privacy Policy will become effective when we post the revised Privacy Policy on our website. In the event there are material changes in our practices that would result in Authorized Users’ personal information being used in a materially different manner than was disclosed when the information was collected, with respect to Student Data, we will notify the School Customer, and with respect to other information, we will notify you via email and provide an opportunity to opt-out before such changes take effect.

CONTACT US

If you have questions about this Privacy Policy, please contact us at: Email: privacy@districtwon.com Mail: DistrictWON LLC 19071 Old Detroit Rd., #200, Rocky River, OH 44116 Attn: Counsel

APPENDIX – SUPPLEMENTAL DISCLOSURES Disclosures

Notice for U.S. Customers (other than California customers)—Additional U.S. State Privacy Law Rights You have the following rights, where provided under applicable state law, regarding your personal information (each of which is subject to various exceptions and limitations): Access. You have the right to request, up to two times every 12 months, that we disclose to you the categories of personal information collected about you; the categories of sources from which the personal information is collected; the categories of personal information sold or shared; the business or commercial purpose for collecting, selling, or sharing the personal information; the categories of third parties with whom personal information was shared; and the specific pieces of personal information collected about you. Correction. You have the right to request that we correct inaccurate personal information collected from you, subject to certain exceptions allowed under applicable law. Deletion. You have the right to request that we delete the personal information that we maintain about you, subject to certain exceptions. Even after the deletion of your account, some personal information may remain on our servers, such as in technical support logs, server caches, data backups, or email conversations. These will be automatically deleted after a reasonable amount of time, unless we are legally required to retain information for longer, or unless there is a legitimate business reason (e.g. security and fraud prevention or financial record-keeping). We are not required to delete any information which has been aggregated or de-identified in accordance with the relevant section above. No Discrimination. You have the right not to be discriminated against for exercising these rights. Appeals. You have a right to appeal decisions concerning your ability to exercise your consumer rights. Submission of Requests. You may exercise the above rights by emailing us at privacy@districtwon.com. Note that we may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. Authorized Agent. You may designate an authorized agent to make a request on your behalf. When submitting the request, please ensure the authorized agent identifies himself/herself/itself as an authorized agent and can show written permission from you to represent you. We may contact you directly to confirm that you have authorized the agent to act on your behalf and confirm your identity. Verification. Whether you submit a request directly on your own behalf, or through an authorized agent, we will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us.