This Privacy Notice ("Privacy Notice") applies to the online services, mobile services, web site and software (collectively, the "Service") made available by Jigsaw Learning, LLC dba TeachTown ("TeachTown," "we," "our," or "us"). The Privacy Notice describes how we collect, use and disclose your personal information when you use our Service or otherwise engage with us.

Our Service is intended to be used for educational purposes by school districts, school boards and individual schools within a district ("Educational Institutions"), individual teachers, interventionists, specialists, data analysts, authorized school administrators, qualified clinicians and other educators ("Educators"), students ("Students"), and, in some cases, their parents or legal guardians ("Parents"). When we provide the Service, we may collect or have access to Student Data (defined below). To learn more about how we process Student Data, please see the "Student Data" section below.

We collect personal information in a variety of ways. Sometimes we collect personal information automatically when you interact with our Service, and sometimes we collect the personal information directly from you. At times, we may collect personal information about you from other sources and third parties.

We collect the following information you provide in connection with our Service:

• Contact and Account Information: We collect personal information such as name, email address, and phone number when you register for our Service, sign up for our mailing list, complete your user profile, or otherwise communicate or interact with us.

• Educational Institution Information: We collect information about Educational Institutions, such as school name, school district, school email address and/or account name and password, message content, teacher or authorized administrator title, and student rosters.

• Student Data: When we provide our Service to Educational Institution, we collect personal information that is directly related to an identifiable Student that is maintained by the Educational Institution or related entity or organization, or by us on behalf of such entity. This Privacy Notice refers to that type of information as "Student Data." Student Data may include "educational records" as defined by the Family Educational Rights and Privacy Act ("FERPA"), 20 U.S.C. § 1232(g). Examples of student data may include a Student's name, date of birth, gender, diagnosis, and developmental information. For more information on how we process and protect Student Data, please see the section on "Student Data" below.

• Information From Parents: We may also collect name and contact information that is provided by a Parent who directly creates an account to access our Service on behalf of a specific Student, or personal information about a Parent that is provided by an Educational Institution.

• Payment and Transaction Information: We collect information such as date and time of your transaction, billing address, amount purchased, order details, whether you used a particular coupon or deal, and payment information, such as a credit/debit card number, when you make a purchase on our Service.

• Comments, Messages and Opinions: When you contact us directly (e.g., by email, phone, mail or by completing an online form), we may record your comments and opinions. We may also record comments and opinions you express when responding to surveys. We use this information to respond to your question or comment, to evaluate and improve our Service and to inform our marketing and advertising activities.

We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages. We may also send you Service-related emails or messages (e.g., user account verification, change or updates to features of the Service, technical and security notices) and communications from or about TeachTown.

Like most digital platforms, we collect certain personal information automatically when you visit and use our Service, including:

• Information We Receive from Third-Party Sites You Connect with Our Service: We may receive personal information about you from third-party platforms, networks, services and/or sites that you connect with our Service and combine that with information we collect through our Service. For example, if you register through or otherwise grant access to a third-party site or service, such as ClassLink or OneRoster, we may collect personal information that is associated with your third-party site account. This information we collect may include, for example, your name and email address, courses, Student rosters, course materials, and Student submissions, including some Student Data. If you create or upload assessments or other academic or educational resources or materials, we collect the content of these materials and metadata you provide about them. The information we receive from these third-party sites is dependent upon that third party's policies and your privacy settings on that third-party site. You should always review and, if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Service

• Information You May Post or Submit on the Service: We collect information about how you use the Service, your actions on the Service, and content you post to the Service or send through messages or other functionalities ("User Content"). Please remember that we may, but have no obligation to, monitor, record, and store User Content in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, or to protect and defend our rights and property. You consent to the recording, storage and disclosure of such communications you send or receive for these purposes.

• Usage and Device Information:To provide a personalized and high-quality experience for our users, we, and our third-party partners, may use various technologies that automatically record certain technical information from your browser or device when you visit our website, read our e-mails, use our Service, or otherwise engage with us. This information is typically collected through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology (collectively, "Tracking Technologies"). We, and our third-party partners, use these Tracking Technologies to automatically collect usage and device information, such as:

  • Your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account, and other such information.
  • The way you use our Service, including the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the Service, whether you open e-mails or click the links contained in e-mails, whether you access the Service from multiple devices, and other actions you take on the Service.
  • When you access our Service from a mobile device, we may collect unique identification numbers associated with your device, mobile carrier, device type, model and manufacturer, and mobile device operating system brand and model, phone number and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude). We may be able to determine your approximate location by analyzing other information, such as IP address.

We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about our users by monitoring aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns. You can learn more about Google's practices at http://www.google.com/policies/privacy/partners and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

If you would prefer not to accept Tracking Technologies, most browsers will allow you to (i) change your browser settings to notify you when you receive Tracking Technologies, which lets you choose whether or not to accept it; (ii) disable existing Tracking Technologies; or (iii) set your browser to automatically reject Tracking Technologies. Please note that we are unable to respond to "Do Not Track" signals set by your browser at this time.

Please note that not accepting Tracking Technologies may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all Tracking Technologies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. We and our third-party partners may also use Tracking Technologies for advertising purposes. For more information about Tracking Technologies, please see "Third-Party Tracking and Online Advertising" below.

We also obtain personal information from other sources, which we often combine with personal information we collect either automatically or directly from you. We receive the same categories of personal information as described above from the following sources and third parties:

• Social Media Networks: When you interact with our Service through various social media networks, such as when you "Like" us on Facebook or when you follow us or share our content on Facebook, Twitter, LinkedIn, Instagram or other social networks, we may receive some information about you that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review your privacy settings on third-party websites and social media networks and adjust them if they are not aligned with your preferences.
• Service Providers: Our service providers, such as payment processing and marketing partners, collect personal information and may share this information with us in some circumstances.
• Information Provided by Others: From time to time, we may receive information about you from third parties and other users. We may also collect information about you that is publicly available. We may combine this information with the information we collect from you directly.

We use your information for purposes described in this Privacy Notice or as otherwise disclosed to you on our Service or in connection with our Service. Please Note: We do not use Student Data for some of the purposes described below (e.g. marketing). For more information on the limited purposes for which we use Student Data, please see the section on "Student Data" below.

For example, we use your personal information for the following purposes:

• Providing Our Service: We may use your information to process and complete your orders, requests, or transactions, or respond to your customer service requests or feedback. We may also use your information to personalize your experience with us.
• Marketing Communications: From time to time, we may send you periodic promotional or informational communications about new features, updates, products and special offers. We may also use your information to serve you ads about products and special offers about our products or other products or services we think you might find interesting. For more information on your choices about marketing communications, see "Your Choices and Control Over Your Information" and "Third-Party Tracking and Online Advertising" below.
• Transactional Communications: We may communicate with you about your account activities, such as by providing transaction confirmations and alerts. For more information on how we communicate with you, and how to adjust your communications preferences, see "Your Choices and Control Over Your Information" below.
• Product Improvement and Development: We may use your information to maintain, develop, support, and improve our Service and our educational products offerings.
• Security, Compliance with Legal Obligations, or as Otherwise Permitted by Law: We may use information to protect the security and integrity of our business. We may also use information in order to comply with laws, regulations, court orders, or other legal obligations, to enforce our rights or applicable contracts and agreements, to detect, investigate and prevent fraud or unlawful or criminal activity, or for any other reason permitted by law.
• For use in a de-identified manner. We may also use your personal information to generate aggregated or otherwise anonymized data from which any direct and indirect identifiers have been removed or obscured in a way that minimizes the risk of disclosure of the identity of the individual ("De-Identified Information"). We use De-Identified Information for the purposes of development, research and improvement of our Service including through the development and improvement of our models and algorithms. In addition, we may use De-Identified Information for the development and improvement of other educational sites, services and applications or technologies more generally to the extent permitted under applicable law. We may also display aggregate summaries of De-Identified Information publicly or to our customers, such as analytics or reports at the district or school level.

We share personal information in the ways described below. For more information on how we share Student Data, please see the section on "Student Data" below.

• The Public: When you provide feedback or otherwise post User Content on our Service (e.g., if you post a comment/review), your information (e.g., your first name and comments) may be displayed on our websites or on our social media pages. When you engage with us on social media, we may tag your social media account or the social media account of others (e.g., to give photo credit to another user).
• Third Parties at Your Request: For example, you may have the option to share your activities on the Service with your contacts, such as through email.
• Service Providers: We share personal information with third-party vendors, consultants and other service providers who perform functions or services on our behalf and under our instructions to make our services available to you. For example, this may include vendors and providers who engage in marketing or advertising activities or provide mailing or email services, tax and accounting services, auditing and compliance, fraud prevention, infrastructure provisioning, analytics services, IT services, product fulfillment, and web hosting.
• Business Transaction or Reorganization: We may disclose personal information in the context of a company transaction, such as a merger, sale of company assets or shares, financing, change of control, bankruptcy or other corporate event.
• Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
  • in connection with the establishment, exercise, or defense of legal claims;
  • to comply with laws or to respond to lawful requests and legal process;
  • to protect the rights and property of TeachTown, our agents, customers, and others, including to enforce our agreements, policies, and Terms of Service;
  • to detect, suppress, or prevent fraud;
  • to reduce credit risk and collect debts owed to us;
  • to protect the health and safety of us, our customers, or any person; or
  • as otherwise required by applicable law.
• Otherwise With Your Consent or At Your Direction: In addition to the sharing described in this Privacy Notice, we may share information about you with third parties whenever you consent to or direct such sharing.

We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

We consider Student Data to be confidential and do not use Student Data for any purpose other than to provide the Service on the Educational Institution's behalf, in accordance with any contractual agreements with the Educational Institution.

• As between us and the Educational Institution, Student Data are owned and controlled by the Educational Institution. Our collection, use disclosure of Student Data is our Terms of Service and/or any other agreement with an Educational Institution, and by the provisions of the Family Educational Rights and Privacy Act ("FERPA"), the Children's Online Privacy Protection Act ("COPPA"), and applicable state laws which relate to the collection of Student Data. We collect, maintain, use and share Student Data only for an authorized educational purpose and as described in our Agreement with the Educational Institution, or as directed by the Educational Institution, Educator, or Parent.
• We do not use or disclose Student Data for targeted advertising purposes.
• We do not build a personal profile of a Student other than in furtherance of an educational purpose.
• We maintain a data security program reasonably designed to protect Student Data.
• We will clearly and transparently disclose our data policies and practices to our users.
• We will never sell Student Data unless the sale is part of a corporate transaction, such as a merger, acquisition, bankruptcy, or other sale of assets, in which case we will require the new owner to continue to honor the terms provided in this Privacy Notice or we will provide the Educational Institution with notice and an opportunity to opt-out of the transfer of Student Data by deleting the Student Data before the transfer occurs.
• We will not make any material changes to our Privacy Notice or contractual agreements that relate to the collection or use of Student Data without first giving notice to the Educational Institution and providing a choice before the Student Data are used in a materially different manner than was disclosed when the information was collected.

How We Share and Disclose Student Data: We disclose Student Data solely as needed to provide the Service on behalf of specific Educational Institutions in accordance with our contractual agreements with those Educational Institutions or with the consent of the Educational Institution or Parent. For example, Student Data and teacher account usage data may be disclosed to or accessible by users who are authorized to use the Service on behalf of the Educational Institution. In addition, depending on the manner in which TeachTown is used by the Educational Institution and the terms of the agreement between the Educational Institution and TeachTown, we may provide access to certain Student Data to the Student and/or to the Parent of the Student about whom the records relate, for the purpose of monitoring Student usage and activity and evaluating the effectiveness of the Educational Institution's use of the Service. We also disclose Student Data to our trusted service providers who have a legitimate need to access such information on our behalf, subject to appropriate contractual terms to protect such data.

Furthermore, we may disclose Student Data in connection with a business transaction or to support our legal rights and obligations, as described in our Privacy Notice under the Section entitled "Our Disclosure of Information."

How We Use De-Identified Student Data: We may generate De-Identified Information from Student Data and use the De-Identified Information for adaptive learning purposes or customized student learning purposes and to recommend content or services relating to Educational Institution purposes or other educational or employment purposes. For more information about how we use De-Identified Information, please refer to the "Our Use of Information" section of this Privacy Notice above.

How We Retain Student Data: We retain Student Data for a period of two years after termination of the contract to continue to provide the Educational Institution access to its records and aggregate reports, after which the Student Data will be deleted and/or de-identified, unless we receive a deletion request prior to that date.

Please note: Educational Institutions are responsible for maintaining current class rosters and removing Student Data which they no longer need for an educational purpose through the Service itself, if applicable, or by submitting a deletion request.

You may request to delete or access Student Data by submitting a request in writing. A user seeking to modify, correct or delete personal information about a Student without the required admin privileges over the Student Data will be instructed to contact the Educational Institution, Educator or Parent (as applicable) with the request.

Questions about Student Data: If you have questions about specific practices relating to Student Data provided to TeachTown by an Educational Institution, please direct your questions to your Educational Institution.

• Updating Account Information and Settings: You may update your account information by visiting your "Account" page . If you are using the Service on behalf of an Educational Institution and wish to close your account, please direct your request to your Educational Institution.
• Controlling Communication Preferences: You can stop receiving promotional email communications from us by clicking on the "unsubscribe link" provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).
• Modifying or Deleting Your Information: If you have any questions about modifying your information, or if you want to remove your name or comments from our Service or publicly displayed content, you can contact us at marketing@teachtown.com. We may not be able to modify or delete your information in all circumstances.

Please note: As indicated above, we do not disclose Student Data for targeted advertising purposes. For more information about our third-party tracking and online advertising in other contexts, please see below.

We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. We permit third-party online advertising networks, social media companies, and other third-party services to collect information about your use of our Service over time so that they may play or display ads on our Service, on other websites, apps, or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We may share a common account identifier (such as an email address or user ID) or hashed data with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

To learn more about interest-based advertising and how you may be able to opt out of some of this advertising, you may wish to visit the Network Advertising Initiative's online resources, at http://www.networkadvertising.org/choices, and/or the DAA's resources at www.aboutads.info/choices. Please note that some advertising opt outs may not be effective unless your browser is set to accept cookies. Furthermore, if you use a different device, change browsers, or delete the opt-out cookies, you may need to perform the opt-out task again.

Google Analytics and Advertising. We use Google Analytics to recognize you and link the devices you use when you visit our site or Service on your browser, log in to your account on our Service, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Service and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site "How Google uses data when you use our partners' sites or apps" located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics' currently available opt outs, including the Google Analytics Browser Ad-On here https: //tools.google.com/dlpage/gaoptout/.

We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Google Ads conversions. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI's online resources at http://www.networkadvertising.org/choices.

Our Service is not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. TeachTown collects and uses Student Data at the direction of and under the control of a School. As such, we rely on each Educational Institution to provide appropriate notice to Parents of the Educational Institution's use of third-party service providers such as TeachTown. In addition, we rely on Educational Institutions, Educators and Parents to obtain and provide appropriate consent and disclosures, if necessary, as permitted under applicable laws. If you are under the age of 13, please do not use our websites or online services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child's parent or guardian to contact us at compliance@teachtown.com to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.

Our Service may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to compliance@teachtown.com. Additionally, TeachTown can be reached by mail at 330 West Cummings Park, Woburn, MA 01801.

We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the "Last Updated" date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify you by email to your registered email address, by prominent posting on this website or our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.