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Frog Street Press
Privacy Policy
Last Updated: May 24, 2023

Frog Street Press, LLC, the “Company”, shall provide Client access to its proprietary digital education solution(s) (the “Services”) (Exhibit A). Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use and share your personal information and to assist you in exercising the privacy rights available to you.

The trust you have in Frog Street’s solutions is the foundation of who we are as a company. That trust is why protecting the privacy and security of your personal data is paramount to Frog Street. We want you to know that:

• Frog Street is committed to protecting your personal information;
• Frog Street will not sell any of your personal information to third parties;
• Frog Street will use your data to provide you with superior products and services;
• Frog Street will abide by privacy laws and regulations as applicable; and
• Frog Street will use reasonable security measures to protect your personal information.

We promise to process your personal information in a manner that is always lawful, fair and transparent. We also promise to provide you with choice and control over the use of your personal information in accordance with prevailing laws and obligations.

I. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on whether you visit our websites or become a customer, and the requirements of applicable law.

Information You Provide to Us.

Account Creation: When you create a user account, we collect your name, email, phone number, billing address, shipping address, username, and password.

Your Communications with Us. We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, apply for a job or otherwise communicate with us.

Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

Social Media Content. We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections.

• Registration for Sweepstakes or Contests. We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners.

Information Collected Automatically or From Others.

Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.

In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities.

Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

a) Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
b) Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

Analytics. We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

Information from Other Sources. We may obtain information about you from other sources, such as third party services and organizations to supplement information provided by you. When we collect Personal Information, we will endeavor to minimize the Personal Information collected to only the limited amount of Personal Information we need for our purposes.

II. HOW WE USE YOUR INFORMATION.

We use your information for a variety of business purposes, including to:

Fulfill our contract with you and provide you with our Services, such as:
• Managing your information and accounts;
• Providing access to certain areas, functionalities, and features of our Services;
• Communicating with you about your account, activities on our Services and policy changes;
• Undertaking activities to verify or maintain the quality or safety of a service or device;
• Processing your financial information and other payment methods for products or Services purchased;
• Providing advertising, analytics and marketing services;
• Providing Services on behalf of our customers, such as maintaining or servicing accounts, providing customer service, and verifying customer information;
• Processing applications and transactions; and
• Allowing you to register for events.

Analyze and improve our Services pursuant to our legitimate interests, such as:
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Services and short-term, transient use, such as contextual customization of ads;
• Undertaking research for technological development and demonstration;
• Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
• Improving, upgrading or enhancing our Services or devices or those of our service providers;
• Developing new products and Services;
• Ensuring internal quality control;
• Verifying your identity and preventing fraud;
• Debugging to identify and repair errors that impair existing intended functionality;
• Enforcing our terms and policies; and
• Complying with our legal obligations, protecting your vital interest, or as may be required for the public good.

Provide you with additional content and Services, such as:
• Furnishing you with customized materials about offers, products, and Services that may be of interest, including new content or Services;
• Auditing relating to interactions, transactions and other compliance activities; and
• Other purposes you consent to, are notified of, or are disclosed when you provide personal information.

III. DATA RETENTION.

We store the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

IV. SECURITY OF YOUR INFORMATION.

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to the contact provided by your or your organization.

V. DISCLOSURE OF YOUR INFORMATION

• Except as provided for herein, we will not sell or share Personal Information with third parties for marketing purposes or advertisements unless you give us your consent to do so.
• We may share your Personal Information with certain trusted third-party companies and individuals to perform tasks on our behalf, but strictly for the purpose of carrying out their work for us, for example, to help us provide the website, to enhance the website, to increase the website’s functionality and user friendliness, to provide customer support, to improve your experience on the website, to respond to your inquiries or questions, or to provide you with information regarding our products or services. Unless we tell you differently, these trusted third-party companies do not have any right to use your Personal Information beyond what is necessary to assist us with providing you the best possible service. To the extent we share Personal Information with any third party, we require them to comply with the requirements of a data processor under GDPR.
• We may disclose your Personal Information if Frog Street or substantially all of its assets are acquired by a third party, in which case Personal Information held by Frog Street will be included among the transferred assets.
• We may disclose your Personal Information if Frog Street is required by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that, for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate; and
• We may disclose your Personal Information if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or users.

VI. CHILDREN’S INFORMATION.

The Services may be used by children under 17 (or other age as required by local law) through an Agreement with an educational institution (“Client”). Information in a student’s education record is governed by the Family Educational Rights and Privacy Act. FERPA protects access to and sharing of a student’s education record, which is all information directly related to a student’s education. FERPA’s “school official” exception allows schools to share information with parent volunteers, technology companies, and other vendors but only when these parties use the information for educational purposes directed by the school.

Company qualifies as a “school official” as defined under FERPA with a legitimate interest in the Student Data, and therefore Company is permitted under FERPA to Process Student Data pertaining to Client’s students without Client first obtaining written consent from the parent or guardian of each student. This means that (a) the Services provided by Company to Client, pursuant to this Policy, are institutional services or functions for which Client would otherwise use employees; (b) Company is under the direct control of Client with respect to the use and maintenance of education records; and (c) Company is subject to the requirements of 34 C.F.R. § 99.33 (a), which governs the use and redisclosure of Student Data from education records.
If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

VII. TRANSFER OF DATA.

If this Agreement is terminated or expires for any reason, Company will allow Client access to the Solution(s) for not more than ninety (90) days following such termination or expiration for the sole purpose of transferring Client’s data (including Student Data) from the Solution(s) to Client, provided that Client makes a written request to Company for such transfer within thirty (30) days following termination or expiration of this Agreement.

VIII. DELETION OF DATA.

Company shall delete Client’s confidential data, including Student Data, in a secure manner that prevents its physical reconstruction within ninety (90) days following termination or expiration of this Agreement, provided that Client has not requested the transfer of such data in accordance with Section V.

IX. OTHER PROVISIONS.

CALIFORNIA SHINE THE LIGHT LAW.

The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties.

SUPERVISORY AUTHORITY.

If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

CHANGES TO OUR PRIVACY POLICY.

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

X. CONTACT US ABOUT PRIVACY.

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy or make a privacy-related inquiry, please contact us at:

Frog Street Press, LLC
Attn: Legal Department – Privacy Request
530 S Nolen Drive
Southlake, TX 76092
Phone: 1-800-994-3764
Email: support@frogstreet.com