HOMEROOM PRIVACY POLICY

Effective Date: February 15, 2016

Please read this Privacy Policy carefully. By accessing and using our website, you are acknowledging that you have read and understood this Privacy Policy and agree to be legally bound by it. If you do not agree with the terms of this Privacy Policy, please refrain from using our Site.

This website is owned by Share Ave, Inc. dba Homeroom (“Homeroom”), a company that respects your privacy, and understands the importance of the information you entrust to us. This Privacy Policy describes our practices concerning the information we collect from you when you visit our website and utilize the services we offer.

This policy describes:

(i) The types of information we collect when you use our service;

(ii) How we use, share, and protect that information;

(iii) How long we retain that information; and

(iv) Your rights and options regarding the information we collect.

If you submit a contact form, or register to receive newsletters and any other information available through this site, you will be prompted to click an “I Accept” button linked to this Policy. Clicking “I Accept” further confirms your understanding of and agreement to be bound by this Privacy Policy, together with our Website Terms of Service.

TYPES OF INFORMATION WE MAY GATHER

Information you may provide while visiting our website includes Personally Identifiable Information and Non-Personal information.

What is Personally Identifiable Information?

Personally Identifiable Information (PII) means any information you actively provide to us that can be used to identify you, such as your name name, telephone number, address, etc. We collect PII on this website through forms, such as contact forms and Enrichment Teacher application forms that you may submit when communicating with us.

In addition, when you visit our website, we will record your computer IP address, and may tie it to your specific account. Under ordinary circumstances, an IP address recorded in isolation is not PII under the standard definition of the term. However, it may become PII when it is combined with other information, as in this case.

What is Non Personal Information?

Non-Personal Information is information that does not identify you, and may include statistical information concerning the pages on our website that users visit most frequently.General Information of this nature is collected through a small piece of computer code called a “cookie,” and includes your computer IP address, unique mobile device identifier, browser type, ISP or carrier name, and the URL of the last webpage you visited before visiting our website. This information gives us insights on how our users use our site and our services. We use this information to ensure that our service continues to appeal to our users.

HOW WE USE INFORMATION

How We Use PII

We use PII to interact with you on a personal level and to provide you with the specific information you may request from us through our website. We do not share your PII with any third parties, other than contracted service providers that enable us to communicate with you (i.e., telecommunications and e-mail service providers). You can change your decision to receive any requested materials (opt-out) at any time by clicking on the “unsubscribe” link included in every email.

How We Use Non-Personal Information

We use Non-Personal Information to analyze the effectiveness of our website, and for other internal purposes, and may therefore share this information with third parties for this purpose. Any information we may share will not include Personal Information.

HOW WE SHARE INFORMATION

Except for the circumstances listed below, we will not share PII with anyone other than those employees and contractors who need access to it in order to perform their job functions. Notwithstanding other provisions of this policy, we may disclose your PII to the following types of third parties without your express consent in the following circumstances:

(1) Web Service Providers:We may employ third-party web service providers to perform functions on our behalf, such as maintaining and providing services for our website (including e-mail transmission, web download management, and other communication functions). To secure these services, it may be necessary to share your information with these third parties, but only to the degree necessary to ensure proper delivery of the services we request. These third parties are expressly prohibited to use PII for any other purpose, or to retain such information after the requested services are provided.

(2) Regulators and Court Orders:We may reveal your PII on a case-by-case basis in order to comply with court orders, official investigations, and in similar involuntary circumstances. Unless instructed otherwise, we will make every effort to inform you when we have received a request to disclose your Personal Information in this fashion.

(3) Testimonials:If you provide us with a testimonial that includes PII (i.e., your name and/or company name), you are authorizing to publish, share, and distribute that information for promotional purposes at any time and in any manner that we see fit.

(4) Official Requests:If requested or required by law enforcement authorities, courts, or regulators, we may disclose any information we have collected from you. We also may disclose your information to exercise or protect our legal rights or to defend against legal claims.

(5) Asset Transfers:In some cases, we may choose to buy or sell assets. In these business transfers, customer information is typically one of the business assets that are transferred. Moreover, if all or substantially all of our business assets were acquired, or in the unlikely event that we go out of business or enter into bankruptcy, customer information (including your PII), would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any assets may continue to be used as set forth in this policy.

HOW WE PROTECT YOUR INFORMATION

We take the security of your information seriously and use appropriate technical and organizational measures to protect PII against unauthorized or unlawful processing and against accidental loss, destruction or damage. Our website and the server(s) upon which it is hosted use a generally accepted standard of technological security for the purpose of protecting all information provided by visitors from unauthorized access, loss, destruction, damage, misuse, loss, or corruption. We also limit access to PII to those employees who reasonably need access to it to deliver our service.

However, because no security system can be 100% effective, we cannot completely guarantee the security of any information we may have collected from or about you. In addition, we have no control over the security of other websites on the Internet that you might visit even when a link may appear to those websites site from our Site. If you share your computer or use a computer that is accessed by the general public, remember to sign off and close your browser window when you have finished your session. If there is a breach of security, then we may either post a notice through the service or attempt to notify you via email so that you can take reasonable protective steps.

HOW LONG WE RETAIN INFORMATION

Unless you request that we delete some or all of the PII you provide to us, we will retain it for as long as we deem necessary to fulfill a business purpose or comply with a legal request. We reserve the right to retain non-personal information for as long as we deem necessary

Notwithstanding the foregoing, we reserve the right to retain any and all General Information we collect from you; provided, however, that we will retain your name and contact information. We may also choose to anonymize certain of the information you provide to us so that it can no longer be attributed to you if we would like to retain it for longer periods of time.

YOUR OPTIONS AND CONTROL

You may limit how we use the PII you provide us with as follows: (i) You may stop receiving emails from us by clicking the “unsubscribe” link at the bottom of the email; and (ii) you may edit or delete some or all of the PII associated with your account (apart from your name and contact information) at any time.

OTHER PRIVACY MATTERS

Underage Users:Although the services we provide are for children, this site is intended for adults over the age of 18. We do not knowingly collect or maintain personal information from children under the age of 18 at our site, unless an adult provides it. In the event a child under the age of 18 submits a question to us at our site and identifies his or her age, we may use the email address of the child for the sole purpose of responding to the question from the child on a one time only basis. However, we will not use the email address of the child for further contact and we will remove the address from our records after we have initially responded.

For Residents of Certain States:California residents are accorded special privacy rights under California Law (California Civil Code Section 1798.83). In addition to the rights set forth in this Privacy Policy, California residents generally have the right to request information from us regarding the manner in which we share certain categories of PII with third parties for their direct marketing purposes. Pursuant to Section 1798.83 of the California Civil Code, Californians may request that a business disclose the the types of personal information the it shares with third parties for direct marketing purposes, and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. Californians may request information about our compliance with this law by sending us a message via the Contact Us link on the Site.

In addition, in compliance with the California Online Privacy Protection Act (CalOPPA) and the Delaware Online Privacy Protection Act (“DOPPA”):

– There is no login requirement to use this site, and all users can visit this site anonymously.

– We do not currently employ any technology that enables us to track your online activities over time and across third-party websites, nor do we plan on doing so in the future. Keep in mind, however, that we have no control over the activities of third parties, and they may employ such technology that tracks your activity on this site. Because we do not employ tracking technology, we offer no response to Do-Not-Track requests transmitted by Web browsers.

External Links:The Website may include links to other websites whose privacy policies we do not control. Once you leave our site, use of any information you provide is governed by the privacy policy of the operator of the site you are visiting. That policy may differ from ours and is not covered within this privacy policy.

Changes to this Privacy Policy:We reserve the right to amend, alter, or otherwise change this Privacy Policy at our sole and absolute discretion. If we make any changes regarding the disclosure of Personal Information to third parties, we will inform Users via a prominent link on our site, and post notice of the new Policy from the privacy link on our Website. Further use of this site following any such change constitutes your agreement to follow and be bound by the amended Privacy Policy.