CATCHON, INC.

PRIVACY POLICY

Welcome! We are excited that you are considering the services of CatchOn, Inc. (“CatchOn”). CatchOn provides immediately actionable data analytics to schools, school districts, and other educational institutions. As such, CatchOn is committed to ensuring that the information of your organization and your students and staff is secure, and both your and your users’ privacy is protected. Please read this document in its entirety to understand our privacy policy. If you have any questions, please feel free to contact us at info@catchon.com.

Core Privacy and Security Principles

 

Data Ownership: CatchOn considers and acknowledges all data that CatchOn may gather from an institution or the devices it owns and manages is the property of the customer institution. CatchOn’s customers have complete and unequivocal rights to their data and how they wish their data to be utilized.

Non-Disclosure to Third Parties: CatchOn does not sell, provide, or disclose any information about student and staff utilization of content, resources, or devices to any third parties. CatchOn is a trusted steward of education and student data. Data received from our customers is used solely for purposes of providing CatchOn services.

Security: CatchOn uses significant security measures to protect the privacy of student data. These security protections include, but are not limited to, de-identification of certain personally identifiable student information through the use of irreversible one-way hash, encryption of all data at rest, and encryption of all data in transit.

Student Information

 

As part of its services, CatchOn collects data related to the education of students. Any personally identifiable information we receive is maintained in encrypted form in secure environments compliant with multiple industry standards and not shared with any third parties, other than individuals and entities specifically authorized by the student’s subscribing school or similar institution.

CatchOn’s utilization information and data analytics platform (“Platform”) is not intended for the use of or to be accessed by minors under the age of 13. We instruct our subscribing schools or similar institutions to not allow children under the age of 13 to register for Platform access or disclose personal information to us.

Additionally, we acknowledge that our users, schools and districts are subject to the Family Educational Rights and Privacy Act (20 U.S.C. 12332(g)) (FERPA), which law and supporting regulations generally address certain obligations of an educational agency or institution that receives federal funds regarding disclosure of personally identifiable information in education records. CatchOn has been authorized by the subscribing school or similar institution as a “school official” under FERPA and has a legitimate educational interest in personally identifiable information from education records because We: (1) provide a service or function for which the users, schools and districts would otherwise use employees; (2) is under the direct control of the users, schools and districts with respect to the use and maintenance of education records; and (3) is subject to the requirements of FERPA governing the use and redisclosure of personally identifiable information from education records.

Information We Collect

 

We may collect the following types of information:

Utilization information: The CatchOn agent may gather some or all of the following information: user ID and email domain of the user as provided by the institution’s Mobile Device Management system, the URL the device visited, the date and time the visit occurred, the hardware ID of the device, the local IP address, and the device hostname. The username and/or user ID is deidentified on the agent using a one-way hash before transmission and then the data payload is sent via TLS to the Platform.

Information you provide: When the subscribing school or similar institution signs up for CatchOn, we ask you for some basic personal information. This includes personally identifying information such as your name and school organization information. When you use the Platform, you may provide additional personal information at your sole discretion, including subject interests and grade level interests.

Cookies: Currently, software agents on school-owned and/or -managed devices do not use “cookies” to identify users. However, the CatchOn website, like most websites and on-line applications, does employ “cookies.” In the future (and without further notice or approval) we may send one or more cookies to your computer or mobile device. We only would use cookies to improve the quality of our Platform, including for storing user preferences improving search results, and tracking user trends, such as how people use our Platform.

Automatically Collected Information:

    • Log information: When you access the Platform via a browser, application or other device, our servers automatically record certain information. These server logs may include information such as your web request, your interaction with a Platform, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser or your account. When you use the Platform using your smartphone or other mobile device, we collect information regarding device type, operating system, IP address and device ID. As you interact with the Platform, we obtain information regarding your interactions, such as time of day and date, how long you spend on different pages and the like. If you or your subscribing school or similar institution have installed our extensions to your browser, we may automatically record certain information while the extension is activated, such as your username, the website you visit, and the amount of time spent on each site.
    • User communications: When you send communications to us or to other users through the Platform, we may retain those communications to process your inquiries, respond to your requests and improve our Platforms. We may use your email address to communicate with you about our Platform, including service-related notices. You acknowledge that these service-related notices are necessary for the provision of the Platform and you may not opt out of such service-related notices.

How We Use Information

 

CatchOn uses the information we collect to provide immediately actionable intelligence and data analytics to school districts and similar institutions in order to improve ROI and educational outcomes.

We also use information you provide and information we automatically collect to administer the Platform and to allow you and other users to use the Platform. You understand that certain information that you post to the Platform may be shared through the Platform and will be accessible to the other users. Likewise, you may be able to view information of other users.

At no time will we sell data to advertisers or other third parties for payment. We may also use your non-personally identifiable information, including as aggregated with other users’ information, to analyze use of our Platform, including obtaining demographic information on our users and their subscribing schools or similar institutions generally. We do not retain student personal information for longer than necessary to deliver services or for school purposes.

We may disclose your information if we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or other governmental or law enforcement request, (b) enforce our Terms of Use, including investigation of potential violations, (c) detect, prevent, or otherwise address fraud, security or technical issues, (d) protect against or mitigate harm to the rights, property or safety of our company, the Platform, its users or the public as required or permitted by law, and (e) in order to respond or report on reports of abuse or misuse of the Platform.

Changes to This Privacy Policy

 

Please note that this Privacy Policy may change from time to time. We will post any changes on our website and, if the changes are significant, we may provide a more prominent notice (including email notification of changes).

Other Important Information

 

Corporate Events
If our company becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, CatchOn will require that the acquiring entity carry out the terms of this Privacy Policy. In the event of a bankruptcy, insolvency, reorganization, receivership or assignment for the benefit of creditors, CatchOn will require that the acquiring entity carry out the terms of this Privacy Policy.

Information Security
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures. However, we cannot guarantee its absolute security or that unauthorized persons will not access or use your personal information for improper purposes. In the event of a breach of security affecting personal information on our servers, we will take such notification and other steps as may be required under applicable law. We ask that you do not ever send us or post any highly sensitive information on the Platform, such as social security numbers, personal health information, Driver’s License numbers and the like. We will not be liable for the use or disclosure of any such information if posted through the Platform.

Third Party Sites
This Privacy Policy applies to our Platform and our websites only. We do not exercise control over any other sites that may be linked to or accessed through the Platform or our website, including our Partners. We have no responsibility for the privacy practices of other web sites, including the web sites of our Partners. You should review the policies of any third-party sites before providing personal information to these sites.

Social Media Sites
We may have pages or other presence on various social networking sites or services, such as Facebook, Twitter and the like. Any information you post or provide through such sites and services will be subject to the policies of those sites and services.

Security
We use industry best practice security technology to protect against access, loss, misuse, or alteration of user information. All data resides in SOC 2-compliant data centers in the United States. If you are accessing this Platform from another jurisdiction, you hereby consent to the transfer and processing of your information in the United States.