Effective Date: February 25, 2018

PRIVACY POLICY

Levered Learning, Inc. ("Company" or "Levered Learning" or "we" or "our" or "us") respects the privacy of our users. This Privacy Policy ("Policy") describes how we collect, use, and disclose information collected or provided in connection with an end user's use of the Levered Learning platform located at https://app.levered.com (the "Services"). It also describes the choices available to you regarding our use of your personal information and how you can access and update your personal information. The personal and other information that we collect about you is controlled by Levered Learning, P.O. Box 2223, Santa Cruz, CA 95063.

Please note that use of the Services constitutes acceptance of this Policy as set forth below.

IF YOU ARE A PARENT, TEACHER OR SCHOOL ADMINISTRATOR OF A CHILD UNDER THIRTEEN YEARS OLD, PLEASE REVIEW OUR COPPA PRIVACY POLICY CLOSELY, WHICH CONTAINS IMPORTANT INFORMATION FOR PARENTS, TEACHERS AND SCHOOL ADMINISTRATORS ABOUT HOW WE COLLECT, USE AND DISCLOSE THE PERSONAL INFORMATION WE COLLECT FROM CHILDREN UNDER THIRTEEN YEARS OLD.

What Information Do We Collect about You?

We collect both "personal information" and "non-personal information" about you when you use the Services. For purposes of this policy, "non-personal information" is information that we cannot directly associate with a specific person without the aid of additional information. In contrast, "personal information" is information such as name or email address that we can directly associate with a specific person or entity without additional information. When we combine non-personal information with personal information, we treat all of the combined information as personal information.

We may collect personal and non-personal information from end users affiliated with a particular school or other educational institution or organization ("School") who are teachers or other authorized persons (such as teaching assistants, student teachers, or volunteers) ("Teachers") or school administrators ("Administrators") affiliated with such school, students, which may include children under the age of 13 ("Students"), and parents or legal guardians of Students ("Parents", and collectively with Administrators and Teachers, "Adults" or "you" or "your") through the Services as follows:

Information We Collect Directly from Adults:

You can visit the Levered Learning website without submitting any personal information. However, as part of using the Services, you may submit certain information to us. For example, when you register for an account on the Services, we will collect your first and last name, email address, account name, and password and your Student's first and last name, date of birth, grade level and gender. If you are a Parent, we may also collect your mailing address. If you are a Teacher, we may also collect the names of your school and school district. To the extent you decline to share certain information with us, we may not be able to provide some or all of the features and functionalities found on the Services to you or your Student(s).
We may combine personal information collected through the Services with other information that we or third parties collect about you in other contexts-such as our communications with you via email or phone, or your customer service records. We will treat such combined information as personal information and protect it in accordance with this Policy.
The Services may contain certain features and functionalities that can only be accessed upon payments. We do not receive your credit card number or billing information when you make any transaction on or through the Services. Credit card and billing information is collected directly by our payment services provider, Stripe (http://www.stripe.com). Please visit Stripe's website or contract Stripe if you have questions regarding Stripe's privacy practices.
If you choose to provide it, we may collect any feedback, testimonials or comments you provide to us about the Services.

Information We Collect Directly from Students:

To access and use the Services, Students will be required to login to an account created by and affiliated with such Students' Parent or Teacher. A Student's account will be associated with the respective Parent or Teacher's accounts, such that the applicable Adult can view and monitor the Student's progress, as described further below. The Services permit the Student's Parent, Teacher, or Administrator to modify the Student's account name and/or password at their election or the Student's first name or last name associated with the Student's account.
In connection with a Student's use of the Services, we collect the Student's educational progress and performance data generated based on the Student's interaction with the Services (collectively with the Student's name, date of birth, grade level, gender, account name and password, and other automatically collected data described below, the "Student Data").

Information We Collect Automatically from All Users of the Services:

In connection with the use of the Services, we gather certain non-personal information from each user of the Services, and this information can be associated with such user's user account. This includes usage information, such as information on when, how often and for how long such user uses the Services. We also collect "persistent identifiers," meaning cookies, web beacons, IP addresses, MAC addresses, or unique device identifiers used to collect and track such information as "clicks" and pages viewed when on our website or when using our Services, information about a user's browser software and operating system, the date and time you accessed the Services, and the webpage a user was visiting before navigating to the Services.
"Cookies" are small text files containing a string of alphanumeric characters that are downloaded by a user's web browser or mobile device when such user visits a website. We may use both session cookies and persistent cookies when a user accesses and uses the Services. A session cookie disappears after a user closes his or her browser. A persistent cookie remains after a user closes his or her browser and may be used by his or her browser on subsequent visits to the Services. Persistent cookies can be removed. Please review documentation of a browser used to access the Services to learn the best way to modify cookie settings. Like many websites, the Services do not currently respond to "do not track" browser headers. However, a user can take steps to limit tracking by erasing cookies from his or her computer's hard drive and by setting his or her browser to block all cookies or warn him or her before a cookie is stored.

Information about You That We Collect from Schools

If you are an Administrator, Teacher or Parent, your Student's School may provide us with your name and email address to facilitate your registration for the Services.
If you are an Administrator or Teacher, your School may provide us with additional personal information to assist us in providing the Services to you and your Students.

How Do We Use the Information We Collect from and about You?

We use the information we collect from you and your Students for internal purposes, as follows:

We may use collected information for the purposes for which you or your Students provided the information including, for example, to monitor the Students' educational progress, provide you and your Students with information and reports about Students' performance, create and maintain an account for you or your Student or to respond to a question that you e-mail to us. We also use the collected information as necessary to provide the features and functionality of the Services to you and your Students.
We may also use the collected information to send you administrative notifications or to contact you regarding updates or modifications to the Services or to help troubleshoot problems or alert you to changes in our policies or agreements that may affect your use or your Students' use of the Services.
We may use the collected information to personalize the content that you or your Students see based on personal characteristics or preferences.
We may also analyze collected information relating to you or your Students' use of the Services in order to help us improve the Services.
We may combine personal information collected through the Services with other information that we or third parties collect about you or your Students in other contexts-such as our communications with you via e-mail or phone, or customer service records related to your or your Students' user account. We will treat the combined information as personal information.
We may use non-personal information that we collect for such purposes as: counting and recognizing visitors to the Levered Learning website; analyzing how visitors use the website and the Services; improving the Services and enhancing users' experiences with the Services; creating new products and services or improving our existing Services; enabling additional website analytics and research concerning the website and our Services; and managing our business.

How and with Whom Do We Share Your Information?

We do not share your or your Student's information for marketing purposes, including with any third parties for their own direct marketing purposes. We may share and disclose the information we collect from you and your Students as described in the Policy, as follows:

We will disclose data collected from a Student, including Student Data, to (i) the Student's Parents, Administrators, Teachers or School and (ii) when the Service is used by a School, other Students only as part of an option functionality of the Services that permits Administrators to facilitate conferences with or between multiple Students to discuss particular educational materials provided through the Services. The Student's Administrators, Teachers or School may also share Student Data with other Administrators or Teachers.
We may use third-party vendors, service providers, contractors or agents to assist us in making the Services available or to help us improve the Services. Such third parties may obtain access to the information we collect from you or your Students, including personal information, to assist us in achieving the purposes discussed above in the section entitled "How Do We Use the Information We Collect from and About You."
From time to time, we may report aggregated, anonymous data relating to activity on the Services to third parties or the general public. By way of example only, this may include the provision or publication of reports regarding student engagement with the Services and educational progress. Such aggregated, anonymous data will not contain any personal information of any user of the Services, whether an Adult or a Student.
In the event of a merger, sale of capital stock or assets, reorganization, consolidation or similar transaction involving the Company, the information we possess, including personal information, shall be transferred as a corporate asset to the acquiring entity. We will notify you via email and/or post a prominent notice on our Services of any change in ownership or uses of your or your Students' personal information, as well as any choices you may have regarding your or your Students' personal information.
We will use and disclose your or your Students' information where we, in our sole discretion, believe that the law or legal process (such as a court order, search warrant or subpoena) requires us to do so or in other circumstances where we believe it is necessary to protect the rights, property or physical safety of the Company, our users and/or third parties.
To the extent any Student Data constitutes an Education Record as that term is defined by the Family Education Rights and Privacy Act ("FERPA") and its implementing regulations, we will not disclose Education Records or Student personal information obtained therefrom without prior written consent from a Parent, unless authorized or required by law.

Effective Date; Changes to This Policy

This Policy is current as of the Effective Date set forth above. We may update this Policy from time to time to reflect changes in the Services or our information processing practices. When we make any changes to our practices under this Policy, we will change the Effective Date. If we make a material change to this Policy, you will be provided with appropriate notice. We may also email you a copy of the revised Policy at your most recently provided email address.

How Do I View, Amend or Delete Information?

A user can log into his or her account and view or amend his or her account information at any time. To delete all data associated with an Adult's account, please e-mail us at support@levered.com. To delete information relating to a Student, the Student's Parent or Administrator may do so by emailing us at support@levered.com. Please note that while changes to a user's profile information are reflected promptly in active user databases, our servers may retain previously provided information for a period of time.

Security

We have implemented commercially reasonable physical, electronic, and procedural safeguards to protect your and your Student's personal information against loss or unauthorized access, use, modification, or deletion. However, no security measures are 100% effective and we cannot guarantee the security of your or your Students' information.

You should take steps to protect against unauthorized access to your or your Students' account password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping his or her log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your or your Students' account via unauthorized password activity. We expressly disclaim any representation or warranty, whether express or implied, with respect to ensuring, guaranteeing or otherwise offering any definitive promise of security in connection with your or your Students' information.

Questions or Comments?

If you have any questions or comments regarding this Policy, please contact us at (831) 288-2018 or at:

Levered Learning, Inc. Attn: Privacy Questions PO Box 2223 Santa Cruz, CA 95063 support@levered.com

COPPA PRIVACY POLICY

This COPPA Privacy Policy ("COPPA Policy") is designed to comply with the Children's Online Privacy Protection Act ("COPPA") and contains important information about how Levered Learning, Inc. ("Company" or "Levered Learning" or "we" or "our" or "us") treats information collected or provided in connection with use of the Levered Learning platform located at https://app.levered.com (the "Services") by children under thirteen years old ("Child" or "Children"). This COPPA Policy also explains how a Child's parents ("Parent") or, in certain situations, a school administrator that is affiliated with the Child's school or school district ("Administrator") can restrict the collection, use and/or disclosure of such Child's information and how such Parent or Administrator can request deletion of such Child's information.

A Child's COPPA Personal Information (as defined below) will be handled only as described in this COPPA Policy. Any information we collect about other users (e.g., students over the age of thirteen, Administrators, Parents, or other adults) will be treated in accordance with the Levered Learning Privacy Policy ("Privacy Policy").

The personal and other information collected from Children by the Services is controlled by Levered Learning, P.O. Box 2223, Santa Cruz, CA 95063.

Notice and Consent

We will make reasonable efforts, taking into account available technology, to ensure that a Parent of a Child receives direct notice of our practices regarding the collection, use, and/or disclosure of COPPA Personal Information collected from the Child, including notice of any material changes to practices to which the Parent previously consented.

Verifiable consent from a Parent is required prior to the collection, use, and/or disclosure of COPPA Personal Information from Children under age 13, including consent to any material change in the collection, use, and/or disclosure practices to which the Parent has previously consented.

When an Administrator, teacher or other authorized persons (such as teaching assistants, student teachers or volunteers) ("Teachers") or school or other academic institution with which the Administrator or Teacher is affiliated ("School") uses our Services in the classroom or an educational setting, and solely for the benefit of their Students and for the School, such as to sign Children up for the Services, assign activities to Children within the Service, and to track their progress, the Administrator or School may provide consent to the collection and use of COPPA Personal Information from and about Children on behalf of a Parent as permitted under COPPA, including consent to any material change in the collection, use, and/or disclosure practices to which the Administrator or School has previously consented. In such circumstances, we provide the Administrator and School with notices regarding our privacy practices. Administrators and Schools are responsible for providing Parents with notice about how COPPA Personal Information from their Children is collected and used by us.

What Information Do We Collect from Children?

We collect COPPA Personal Information from Children when Children use the Services. For purposes of this COPPA Policy, COPPA Personal Information is information that we can directly associate with a specific Child without additional information, including, for example, first and last name, a home or other physical address including street name and name of a city or town, online contact information, a screen or user name that functions as online contact information, a telephone number, a social security number, a persistent identifier that can be used to recognize a user over time and across different websites or online services, a photograph, video or audio file where such file contains a Child's image or voice, geolocation information sufficient to identify street name and name of a city or town, or information concerning the Child or Parents of that Child that the operator of a website collects online from the Child and combines with an identifier described above. When we combine non-COPPA Personal Information with COPPA Personal Information, we treat all of the combined information as COPPA Personal Information.

We may collect data from Children through the Services as described below. We will not require a Child to provide more information than is reasonably necessary to use our Services.

Information Collected Directly from Children:

To access and use the Services, a Child will be required to login to an account created by and affiliated with such Child's Parent or Teacher.
In connection with a Child's use of the Services, we collect the Child's educational progress and performance data generated based on the Child's interaction with the Services (collectively with the Child's name, date of birth, grade level, gender, account name and password that may be provided by the Child, Parent, Administrator or Teacher, and other automatically collected data described below, the "Child's Data").

Information Collected Automatically from Children:

In connection with the use of the Services, we gather certain information from a Child, and this information can be associated with such Child's user account. This includes usage information, such as information on when, how often and for how long the Child uses the Services. We also collect persistent identifiers, meaning cookies, web beacons, IP addresses, MAC addresses, or other unique identifiers used to collect and track such information as the Child's "clicks" and pages viewed when using the Services, information about the Child's browser software and operating system, the date and time the Child accessed the Services, or the webpage the Child was visiting before navigating to the Services.
"Cookies" are small text files containing a string of alphanumeric characters that are downloaded by a user's web browser or mobile device when such user visits a website. We may use both session cookies and persistent cookies when a Child accesses and uses the Services. A session cookie disappears after a Child closes his or her browser. A persistent cookie remains after a Child closes his or her browser and may be used by his or her browser on subsequent visits to the Services. Persistent cookies can be removed. Please review documentation of a browser used to access the Services to learn the best way to modify cookie settings. Like many websites, the Services do not currently respond to "do not track" browser headers. However, a Parent, Administrator or Teacher can take steps to limit tracking by erasing cookies from a Child's computer's hard drive and by setting the Child's browser to block all cookies or warn the Child before a cookie is stored.

How Do We Use the Information We Collect from Children?

We use the information we collect from Children for internal purposes, as follows:

We may use a Child's name or online contact information of the Child or the Child's Parent to provide notice to the Parent and obtain parental consent.
We may use collected information for the purposes for which a Child provided the information including, for example, to monitor the Child's educational progress, provide Parents, Teachers or Administrators with information and reports about the Child's performance or to create and maintain an account for the Child. We also use the collected information as necessary to provide the features and functionality of the Services to the Child.
We may use the collected information, including persistent identifier information, to personalize the content that a Child sees based on personal characteristics or preferences.
We may also analyze collected information relating to a Child's use of the Services, including persistent identifier information, in order to help us improve the Services.
We may combine COPPA Personal Information collected through the Services with other information that we or third parties collect about a Child in other contexts-such as our communications with a Parent or Administrator via e-mail or phone, or customer service records related to a Child, Parent, Administrator or Teacher's user account.

How and with Whom Do We Share Information from Children?

We may share and disclose the information we collect from Children as described below. We do not share or disclose Children's information for marketing purposes, including to third parties for their own direct marketing purposes. Children do not have the option or ability to make COPPA Personal Information publicly available through the Services.

A Child's account will be associated with the respective Administrator, Teacher or Parent's account, such that the Administrator, Teacher or Parent can view and monitor the Child's progress (as described further below). The Services permit the Child's Parent, Teacher or Administrator to modify the Child's account name and/or password at their election or such Child's first name or last name associated with such Child's account.
We will disclose data collected from a Child, including the Child's Data, to (i) the Child's Parents, Administrators or Teachers and (ii) when the Services is used by a School, other students, including other Children, only as part of an optional functionality of the Services that permits Teachers to facilitate conferences with or between multiple students, including Children, to discuss particular educational materials provided through the Services. The Child's Administrators or Teachers may also share the Child's Data with other Administrators or Teachers.
We may use third-party vendors, service providers, contractors or agents to assist us in making the Services available or to help us improve the Services. Such third parties may obtain access to the information we collect from Children, including COPPA Personal Information, to assist us in achieving the purposes discussed above in the section entitled "How Do We Use the Information We Collect from Children."
We may report aggregated, anonymous data relating to activity on the Services to third parties or the general public. By way of example only, this may include the provision or publication of reports regarding student engagement with the Services and educational progress. Such aggregated, anonymous data will not contain any COPPA Personal Information of any Child.
In the event of a merger, sale of capital stock or assets, reorganization, consolidation or similar transaction involving Company, the information we possess, including COPPA Personal Information of a Child, shall be transferred as a corporate asset to the acquiring entity. We will notify Parents or Administrators via email and/or post a prominent notice on our Services of any change in ownership or uses of Children's COPPA Personal Information, as well as any choices Parents or Administrators may have regarding Children's COPPA Personal Information.
We will use and disclose Children's information where we, in good faith, believe that the law or legal process (such as a court order, search warrant or subpoena) requires us to do so or in other circumstances where we believe it is necessary to protect the rights, property, or personal safety of the Company, our users and/or third parties.
To the extent any Child Data constitutes an Education Record as that term is defined by the Family Education Rights and Privacy Act ("FERPA") and its implementing regulations, we will not disclose Education Records or personal information obtained therefrom without prior written consent from a Parent, unless authorized or required by law.

Choices and Controls

Upon request, we can provide Parents, or Administrators and Schools in certain circumstances, with a description of the specific types or categories of COPPA Personal Information collected from their Child. At any time, Parents, or Administrators and Schools in certain circumstances, can request that we stop collecting, using, and/or disclosing COPPA Personal Information from a Child and can request that we delete the COPPA Personal Information in our records that we previously collected from the Child. Such requests may result in termination of any service provided to the Child. We will take reasonable steps to verify the Parent, Administrator or School's identify before granting access to any COPPA Personal Information.

Such requests can be made by emailing us at support@levered.com. Please note that while changes to a Child's profile information are reflected promptly in active user databases, our servers may retain previously provided information.

We will retain COPPA Personal Information collected online from a child for only as long as is reasonably necessary to fulfill the purpose for which the information was collected.

In the event we discover that we have collected information from a Child in a manner inconsistent with COPPA's requirements, we will either delete the information or immediately seek the Parent, Administrator, or School's consent for that collection.

Effective Date; Changes to this COPPA Policy

This COPPA Policy is current as of the Effective Date set forth above. We may update this COPPA Policy from time to time to reflect changes in the Services or our information processing practices. When we make any changes to our practices under this COPA Policy, we will change the Effective Date. If we make a material change to this COPPA Policy, we will make reasonable efforts, taking into account available technology, to ensure that a Parent or, where permitted, an Administrator or School, receives direct notice of the changes to our practices.

Questions or Comments

If you have any questions or comments regarding this COPPA Policy, please contact us at (831) 288-2018 or at:

Levered Learning, Inc.
Attn: Privacy Questions
PO Box 2223
Santa Cruz, CA 95063
support@levered.com