SumoMath, LLC Privacy Policy

This Privacy Policy explains how information is collected, used, and

disclosed by SumoMath (“SumoMath,” “we,” “us,” or “our”) in connection

with your use of our website and online services that link to this

you use any Service, you consent to our collection, use, and/or

disclosure of your information as described in this Privacy Policy.

Accordingly, we urge you to read this Privacy Policy in full, as well as

our Terms of Service, and contact us if you have any questions.

We market and sell our products to adults who purchase or otherwise

subscribe to our Services, which can then be used by children at the

direction and under the supervision of these adults. We respect all of

our users’ privacy, but we recognize the need to provide additional

privacy protections with respect to the personal information we collect

from children under 13 pursuant to the United States’ Children’s Online

Privacy Protection Act of 1998 (“COPPA”). Accordingly, our privacy

practices with respect to children under 13 are set forth below in our

Children’s Privacy Policy section.

Please help us protect your children’s privacy by instructing them

never to volunteer their personal information online without your

permission.

1. The Information We Collect and How We Use It

Throughout this Privacy Policy, we use the term “Personal Information”

to describe information that can be used to directly or indirectly

contact or identify you, such as your full name, home or other physical

address, email address, and telephone number. Personal Information

also includes anonymous information that is linked to information that

can be used to directly or indirectly contact or identify you. Personal

Information does not include information that has been made

anonymous or aggregated so that it can no longer be used, whether in

combination with other information or otherwise, to contact or identify

you.

We use the term “Non Personal Information” to describe information

that cannot be used to directly or indirectly contact or identify you and

that is not linked to information that can be used to directly or

indirectly contact or identify you. Non Personal Information includes

passively collected information about your activities on our Services,

such as usage data, to the extent that information is not linked to your

Personal Information.

Account Creation:

Teachers, parents, and other adult visitors 18 or over must create

accounts by registering on the website, activating their account

through the email provided during registration in order to purchase a

subscription to any Service. Only with a subscription will users have

access to any Services. During our online registration and subscription

process, we collect and store your first and last name, email address,

and phone number. For parents registering for a minor under 18 we

collect the student's first and last name, student's birthdate, student's

gender, student grade level, and school name and geolocation. We

also collect the username and password for all users. Currently

payment can only be done with a credit card, so we collect your credit

card number, expiration date, and security code. We transmit this

payment information for processing, and we do not store this

information. You are also responsible for keeping the student

information that you enter accurate, complete and up to date. If you

recognize that student information is inaccurate, incomplete, or

outdated, you are responsible for correcting it.

We will not use the Personal Information collected during the account

creation process for any purposes other than securing verifiable

parental consent; fulfilling requested transactions; sending you order

confirmations and other notifications you request or that are required

by law; providing you with access to the Services, including ensuring

proper licensing and providing necessary copyright permissions; and

providing the customer service, technical support, and sales support

you request.

Teacher Login Credentials

If you are an adult with teacher access to these Services, we collect

the username and password you create during the registration process

or subsequently assigned to you by your school or school district

purchaser each time you login. Any time you request that we reset

your password, and submit your email address as part of that process,

we collect your email address.

We will not use this Personal Information for any purposes other than

verifying your identity and authenticating your login; facilitating your

access to content; and monitoring subscription compliance. If you

personally purchase access to any Service, we may use your user

credentials to provide the customer service, technical support, and

sales support you request.

Student Login Credentials Created by Parent or Guardian

We collect and store the student login credentials that you create

during the registration process. We will not use this Personal

Information for any purpose other than providing you and your

students access to the Services.

Account Activity by Teacher

If you are an adult with teacher access to our Services, you must

complete the teacher registration process prior to the first time you

username and password and we collect that information.

Adults with teacher access to our Services can create an online

classroom by creating a new group and entering a category name,

group title (class name), group description (grade level), school name

and location. All new groups created must be approved by SumoMath prior to

being added to the Service or public view. Once the new group is

approved by SumoMath, the teacher can add members to their classroom by

submitting a classroom roster of student names. After a teacher

provides their class list of student names, SumoMath will return

the login credentials, username and password, for each student in the

class list. Each time including the first time, the teacher creates or

edits their classroom roster form and submits it to SumoMath, SumoMath will add

or remove student names from the teacher’s group. For each new

name added to the class list, SumoMath will create login credentials and

return the credentials to the teacher via email. For each name

removed from the class list, SumoMath will deactivate the account removing

the student’s data from all public view including the teacher's group

and the account will be publicly inaccessible. If any student on the

class list submitted by the teacher is under 13 years of age, the

teacher confirms he/she has the right to consent on the students’

behalf to our collection, use and disclosure of their information as

described in this privacy policy.

If a teacher sends an invitation to an existing user or receives an

invitation from an existing user requesting membership to the

teacher’s online classroom, SumoMath will send a notification to the

registered email of this user requiring consent from the account holder

to share user data with this teacher. Upon receiving the account

holder’s consent, the user can be added as a member of the classroom

once accepted by the classroom teacher or accepted by the user

depending if the request was originated from the teacher or individual

user.

You can access classroom reports that become available as your

students complete assignments in our Services. These classroom

reports show the number of activities completed; each student’s

progress on incomplete activities, and time practiced. If you have

teacher access, you can review student activity on the Services; and

give students assignments.

We will not use any Personal Information we gather about you as you

use the Services for any purposes other than verifying your identity

and authenticating your login; facilitating your access to paid content;

and monitoring subscription compliance. If you have teacher access,

the student information you provide as you use the Services should be

limited to information that is relevant to the legitimate educational

purpose of improving student performance. We will not ask you to

enter, and you are specifically instructed not to enter, information

about students that is not relevant to this legitimate educational

purpose. You are also responsible for keeping the student information

that you enter accurate, complete and up to date. If you recognize

that student information is inaccurate, incomplete, or outdated, you

are responsible for correcting it. For assistance, or if you experience

difficulties making corrections to student information, please contact

us. We will use information about students entered by teacher and

parent users to provide services to your school educational institution.

You may not disclose or otherwise use the student data entered on this

site for any unauthorized purposes.

When you are logged in, we automatically collect Non Personal

Information about your use of the Service to support our internal

operations, including information about how various features of the

Service are used, what you download, and the number, frequency and

length of each session. We do not combine this Non Personal

Information with or link it to any of the Personal Information

mentioned above.

Correspondence With Us

We collect and retain Personal and Non Personal Information from you

when you send us a message or when you send us an email. We use

such information solely to provide the services or support you request.

Location Information

We collect and store information about your school, classroom, or

online group geolocation. Location information is used only to provide

the services or support requested. Location information can not be

used to directly or indirectly identify a user’s location. Location

information can be used to provide teachers with data reports but will

not contain any identifiable personal information.

Automated Information

We automatically receive and record certain technical information from

your browser as you use our Services, including your IP address, to

improve the functionality of our Services. When we collect an IP

address, we combine it with other information submitted by the user’s

browser, such as requests for files from the web server. We compile

this information to create access logs, which we analyze to determine

trends, such as which pages are used the most, which browsers are

most frequently used by visitors to access the site, and which areas of

the world site users are accessing our products from most frequently.

Our access logs do not contain any information which can be uniquely

associated with any particular IP address or Personal Information

about any individual user.

2. How We Share the Information We Collect

We will not share any information collected through our Services with

third parties, except as described below.We do not share Personal

Information with third parties for their own marketing purposes.

1 Personal Information

Service Providers

We may share Personal Information with third-party service providers

only if necessary for them to perform services on our behalf, including

without limitation service providers who provide email services,

process credit card payments, and provide services in support of our

internal operations.

Corporate Affiliates and Corporate Business Transactions

If we enter into a business transition such as a merger, consolidation,

acquisition, sale of assets, joint venture, securities offering,

bankruptcy, reorganization, liquidation, or dissolution, your Personal

Information may be among the assets we transfer. You acknowledge

and consent that such transfers are permitted by this Privacy Policy,

and that any acquirer of ours or that acquirer’s affiliates may continue

to collect and use your Personal Information as set forth in this Privacy

Policy.

Legal Compliance and Security

We reserve the right to disclose Personal Information when required to

do so by applicable law—for example, in response to a court order,

subpoena, legal process, or other claim or inquiry. We also may

disclose Personal Information in response to a law enforcement

agency’s request or where we believe it is necessary to investigate,

prevent, or take action regarding illegal activities, suspected fraud,

situations involving potential threats to the rights, property, or safety

of any person, violations of our Terms of Service, or to verify or

enforce compliance with the policies governing our Services and

applicable laws, or as otherwise required or permitted by law or legal

requirements.

Consent

We may share your Personal Information with a third party if you

consent to the sharing.

2 Non Personal Information

This Privacy Policy does not limit our use of any Non Personal

Information, and we reserve the right to use and disclose such

information to third parties at our discretion. However, in the event

that we wish to release Non Personal Information that identifies a

school or educational institution by name, we will enter into a separate

agreement with a school or school district purchaser to authorize

release and publication.

3. Changing or Removing Personal Information and Closing

Accounts

Reviewing Your Own Information

If the Personal Information you provided when you created an account

changes, you must promptly notify us of those changes. You have the

right to access, update and correct factual inaccuracies in the Personal

Information that we collect through our Services, subject to certain

exceptions. If you want to access, update, or correct your Personal

Information, simply edit your profile in your account section. To help

protect your privacy and the security of your Personal Information, we

may request information from you to enable us to confirm your

identity and right to access such information, as well as to search for

and provide you with the Personal Information that we maintain. For

information about how to review the Personal Information we collect

from children under 13, please see our Children’s Privacy Policy section

below.

There are instances where applicable law or regulatory requirements

allow or require us to refuse to provide some or all of the Personal

Information that we hold about you. In addition, your Personal

Information may have been destroyed, erased or made anonymous in

accordance with our record retention obligations and practices. In the

event that we cannot provide you with access to your Personal

Information, we will endeavor to inform you of the reasons why,

subject to any legal or regulatory restrictions.

Closing Accounts

If you no longer wish to use our Services, you may close your account

by contacting us or selecting the “close account” option on your

subscription page. Closing an account will deactivate the account

making the account no longer publicly accessible. All data from this

account will be removed from public view or from any public service.

If you close your account, we have no obligation to retain your

information, and we may delete any or all of your information without

liability. However, we may retain information related to you if we

believe it may be necessary to prevent fraud or future abuse, if

required by law, or for legitimate business purposes, such as analysis

of aggregated, Non Personal Information, account recovery, auditing

our records, and enforcing our rights and obligations under our

agreements. We disclaim any liability in relation to the deletion or

retention (subject to the terms of this Privacy Policy) of information or

any obligation not to delete your information.

4. Using the Services Outside the United States

We are based in the United States, and the information we collect is

governed by and operated in accordance with United States law. If

you are using the Services outside the United States, you consent to

having your information and data transferred to the United States.

While users from countries other than the United States may access

certain of our Services, we make no representation that the Services

are operated in accordance with the laws or regulations of, or

governed by, other nations. If you are from any jurisdiction with laws

or regulations governing the use of the Internet, including the

collection, use and disclosure of Personal Information, that are

different from those of the United States, you may only use the

Services in a manner lawful in your jurisdiction.

5. How We Protect Information

We use reasonable technical, administrative, and physical security

measures designed to safeguard and help prevent unauthorized access

to your information, maintain data security, and correctly use the

information we collect. These measures include, but are not limited

to, the use of encryption, physical access controls, information access

controls, and anti-virus and anti-malware software.

Additionally, your account is protected by the password you use to

access your online account, and we urge you to take steps to keep

your username and password safe. Teacher and parent users are

responsible for maintaining the confidentiality of their usernames and

passwords, including student usernames and passwords. If you feel

your password or a password of a student user has been

compromised, you should change it immediately. When you are

finished using our Services, you should log out of your account and

exit your browser. Teacher and parent users are also responsible for

notifying us immediately of any known or suspected unauthorized

use(s) of account, or any known or suspected breach of security,

including loss, theft, or unauthorized disclosure of login credentials.

Any fraudulent, abusive, or otherwise illegal activity on your account

may be reported to appropriate law enforcement agencies by us.

Please be aware that, despite our best efforts, no security measures

are perfect or impenetrable. We cannot guarantee or warrant the

security of any information you disclose or transmit to us on or

through the Services and cannot be responsible for the theft,

destruction, loss or inadvertent disclosure of your information.

6. Links to Other Websites

We may provide links to other websites that we believe may be of

interest to our users. However, we are not responsible for the privacy

practices employed by those websites, nor are we responsible for the

information or content they contain. This Privacy Policy applies solely

to information collected by us through our Services; thus, when you

use a link to navigate to a third-party website, this Privacy Policy is no

longer in effect. We encourage our users to read the privacy policies

of these other websites before proceeding to use them.

7. Contact Us

Teachers, parents, and other adult visitors over 18 with questions or

comments regarding this Privacy Policy may contact us using the

information below:

Email: admin@SumoMath.com

8. Changes to This Privacy Policy

We may periodically make changes to this Privacy Policy, including

changes to keep pace with changing technology and as new or

changed Services are released. We expect most such changes to be

minor. Any non-material changes will take effect immediately upon

posting of an updated Privacy Policy on our Services. You should

periodically check our Privacy Policy for updates. However, there may

be cases where changes to the Privacy Policy may be more significant.

In such cases, we will first provide notice to users who are affected. If

we make changes to this Privacy Policy that may affect our collection

or use of Personal Information from children under 13, we will give

notice and obtain the prior verifiable consent of a parent or legal

guardian. See our Children’s Privacy Policy below for more information

about those practices.

Your continued use of the Services after the effective date of the

agree to the revised Privacy Policy, please refrain from using the

Services.

CHILDREN’S PRIVACY POLICY

SumoMath (“SumoMath,” “we,” “us,” or “our”) recognizes the need to

provide additional privacy protections with respect to the Personal

Information we collect from children under 13 (“child” or “children”) on

our Services. This Children’s Privacy Policy explains our information

collection, use, disclosure, and parental consent practices with respect

to the Personal Information we collect from children, and it is a part of

and uses terms that are defined in our general Privacy Policy set forth

above.

This Children’s Privacy Policy will control over any conflicting provisions

in our general Privacy Policy. All references to the terms “parent” or

“parental” shall include legal guardians.

1. The Personal Information We Collect from Children, How We

Use It, And How and When We Seek Parental Consent

We market and sell our products to adults who purchase or otherwise

subscribe to our Services, which can then be used by children at the

direction and under the supervision of these adults. Our Services offer

online learning tools that children may access and that may collect

Personal Information from children, as defined by COPPA. We identify

below potential instances of such collection and describe how and

when we will provide parental notice and seek prior verifiable parental

consent.

We do not knowingly collect, use, disclose or store any Personal

Information from children unless we have obtained prior verifiable

parental consent. In any instance where we collect Personal

Information from a child, we will not collect more Personal information

than is reasonably necessary for the child to participate in the Service,

and we will retain that information according to our general Privacy

Policy set forth above. In the event that we discover that we have

inadvertently collected information from a child in a manner

inconsistent with COPPA’s requirements, we will delete that information

and attempt to notify the child’s parent. If you believe that we might

have collected Personal Information from your child without consent,

please contact us.

Account Creation and Student Login Credentials

As described in our general Privacy Policy set forth above, we do not

allow children to purchase or otherwise subscribe to any Service: Our

account creation feature is intended strictly for adult teacher or parent

use, and we take measures to make this apparent in order to prevent

children from submitting Personal Information to our Service in this

manner.

An adult teacher or parent purchaser of any Service may open an

account for a child by adding them to a class roster or creating the

child’s student login credentials during the registration process. We

collect student user credentials each time a child logs in to the

Service. We will not use this information for any purposes other than

authenticating the student’s login and facilitating student access to the

Service. Our staff is not authorized to disclose student login

information; information regarding student login credentials is strictly

controlled by the teacher or parent.

Correspondence With Us

As described in our general Privacy Policy set forth above, we collect

and retain Personal and Non Personal Information from users who

choose to send us an email. Children are not permitted to

communicate with us directly using these means.

Automated Information

We automatically receive and record certain technical information from

a child’s browser, including the child’s IP address, for internal purposes

only. We compile this information to create access logs, which we

analyze to determine trends, such as which areas of the world site

users are accessing our products from most frequently. Our access

logs do not contain any information which can be uniquely associated

with any particular IP address or Personal Information about any

individual user.

Student Account Activity

Additional educational information is collected as the child progresses

through the Service, such as amount of time logged in, number of

quizzes taken and passed, and number of levels passed. This

information allows the Service to adapt to the child and inform the

teacher on the child’s progress.

Consent—Parents

For parent purchasers, in the event we wish to collect the Personal

Information outlined above from a child, we provide parental notice

and seek verifiable parental consent via the email address provided

during account creation. In our email to parents, we provide a link to

our Privacy Policy describing what Personal Information we collect from

children, how we collect it, how we use it, how we disclose it, how the

parent can consent to collection of such information, and your parental

rights over such information. This email contains an activation link

you must acknowledge by clicking on it. The registered parent can

revoke consent to our collection of Personal Information by contacting

SumoMath through email or via our website. Revoking consent may result in

lose of access to Services as outlined in this Privacy Policy and the

Terms of Services Agreement.

Consent—Teachers As Agents of Parents

Adults with teacher access to our Services must create a classroom

roster and provide student first name and last name before students

can access the Services. After a teacher provides their class list of

student names, SumoMath will return login credentials, username

and password, for each student in the class list. If any student on the

class list is under 13 years of age, the teacher confirms he/she has the

right to consent on the students’ behalf to our collection, use and

disclosure of their information as described in this privacy policy.

Consent—Schools As Agents of Parents

Where a school or school district contracts with us to offer the Services

solely for the benefit of their students and for the school system and

for no other commercial purpose, the school or school district may

consent to the collection of children’s Personal Information on parents’

behalf.We encourage schools and school districts using our Services to

notify parents that our Services are being used in their schools.

We provide the schools and school districts using our Services with the

notices required under COPPA, including a description of the Personal

Information we collect from children, how we collect it, how we use it,

how we disclose it, how the school or school district can consent to

collection of such information, and all other rights over such

information.

2. How We Share Personal Information Collected From

Children

We do not provide any child’s Personal Information to third parties—we

use this information for internal purposes only.

3. Parental and School Access and Control Over Personal

Information Collected From Children

At any time, parents or schools operating as the agent of parents can

request to review any Personal Information collected about a child

and/or request that there be no further collection or use of a child’s

Personal Information. Parents or Adults with teacher access may

request no further data collection or use of a child’s Personal

Information by a parent revoking parental consent to our collection of

Personal Information by contacting SumoMath through email or via our

website, or by a teacher removing children from their classroom

roster. Parents with children on a teacher’s classroom roster may also

request removing their child from a classroom roster by contacting the

teacher associated with their child and requesting classroom roster

removal. For each name removed from the teacher’s class list, SumoMath

will deactivate the account removing the student’s data from all public

view including the teacher's group and the account will be publicly

inaccessible. When a parent has given direct parental consent for a

child to join a group and share personal data, sharing consent can be

revoked simply by leaving the group. We take steps to confirm that

anyone requesting Personal Information about a child is in fact the

child’s parent or authorized school agent. Please keep in mind that a

request to deactivate a child’s account and remove all Personal

Information about a child from public view or a request that there be

no further collection or use of their child’s Personal Information may

lead to the termination of an account, membership or other service.

4. How We Protect Children’s Personal Information

The technical, administrative, and physical security measures we

employ to safeguard and help prevent unauthorized access to all

information we collect through our Services is described in our general

5. Contact Us—Questions About the Children’s Privacy Policy

If you have questions or comments regarding this Children’s Privacy

Policy, you may contact us using the information below:

email: admin@SumoMath.com

Student Data Security and Confidentiality Statement

Purposes of Data Entry: Student data entered on this site should be

limited to information that is relevant to the legitimate educational

purpose of improving student performance. We will not ask you to

enter, and you are instructed not to enter, data about students that is

not relevant to this legitimate educational purpose.

Use, Disclosure, and Storage: We will use the student data to

provide the services to you or your school educational institution. You

may not disclose or otherwise use the student data entered on this site

for any unauthorized purposes.

We will only disclose student data to authorized employees or

representatives of the school educational institution, and will not

knowingly disclose the student data to any third person without

express written authorization.

We may also use aggregated data in our research, product

development, and marketing. That aggregated, non-personally

identifiable data (e.g., summary or statistical data) may be shared

with third parties. However, we do not use personally identifiable

student data to market any products or services directly to students or

their parents.

In the event that SumoMath wishes, from time to time, to release

aggregated data that identifies your school or school educational

institution by name, SumoMath will enter into a separate agreement with

your school to authorize release and publication.

Data Quality: You are responsible for keeping the student data that

you enter accurate, complete and up-to-date. If you recognize that

student data is inaccurate, incomplete, or out-of-date, you are

responsible for correcting it directly in the Data Management System.

For assistance, or if you experience difficulties making corrections to

student data, please Contact Us immediately.

Security Safeguards: We are committed to protecting student data

against unauthorized access, destruction, use, modification or

disclosure. Protecting student data requires efforts from us and from

you. We will implement reasonable and appropriate safeguards when

collecting student data from you and when storing that student data in

our database and you will observe our security safeguards and

exercise reasonable caution when using this site.

Specific institutional and technological security safeguards include:

1 Only RLM employees who are authorized to handle student data

are able to access the Data Management System.

2 Only school educational institution employees and

representatives that the educational institution authorizes as

school officials are permitted access to the education institution’s

data within our. This means: a teacher will only be able to see

data for his/her class; a Principal, Coach, or other authorized

School User will be able to view all data at a given school; an

authorized educational institution-level employee, such as an

Instructional Coordinator or Superintendent, will be able to see

all data across the educational institution.

3 Each authorized school official is given a Username and Password

valid only for the duration of the license. You must safeguard

your Username and Password, and not permit any unauthorized

access to student data entered or kept in the SumoMath system.

4 Upon written request by the educational institution, SumoMath will de-

activate any student account for educational institutions who no

longer participate in a SumoMath program. Deactivating a student

account renders the account publicly inaccessible and removes all

student data associated with the account from public view.

5 SumoMath uses industry standard server and network hardware and

software to ensure that data is protected from unauthorized

access or disclosure.

When you use this site, you consent to our privacy practices and agree

to accept the responsibilities outlined in this statement.