Wellington Engagement Index Privacy Policy

Introduction

The Wellington Initiative LLC ("Company" or "We") respects your privacy and is committed to protecting it through our compliance with this policy.

With the exception of information of children, this policy describes the types of information we may collect from you or that you may provide when you visit the website, www.weistudent.wellington.org, and wei.wellington.org, and the Wellington Engagement Index features, functionality and software available on or accessible through such websites (collectively, the "Website").

All capitalized terms used but not defined in this policy shall have the same meanings as defined in our Terms of Use available at: wei.wellington.org/Terms.

Without limiting the forgoing, this policy applies to information we collect:

• On or through this Website.

It does not apply to information collected from children or by:

• Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.
• Provided however, the applicable rights set forth in this Policy available to children apply with respect to such children.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you acknowledge this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acknowledgement of those changes, so please check the policy periodically for updates.

All capitalized terms used but not defined in this policy shall have the same meanings as defined in our Terms of Use available at: https://wei.wellington.org/Terms.

Children Under the Age of 13

Our practices for collecting, using, and disclosing personal information from children under the age of 13 ("children") are set forth in our children’s privacy policy available at: witools.org/documents. Children may only access and use the Website as Student Users and not as Administrator Users or Teacher Users. If we learn we have collected or received personal information from children in the capacity as an Administrator User or Teacher User or guest, without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at laughlin@wellington.org.

Certain consumers under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your State’s Privacy Rights section below, for more information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name,
• That is about you but individually does not identify you directly, by way of example such as unique IDs (which may be a number, e-mail address, or other code), grade level integer, gender, race/ethnicity, socio economic variables, class names, teacher IDs; and/or
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies.
• From third parties, for example, our business partners, including your school, teachers, and administrators.

Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you, as an administrator or teacher provide by filling in forms on our Website or otherwise upload directly or indirectly on or to the Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include cookies.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide you with information or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• To allow you to participate in interactive features on our Website, such as the Wellington Engagement Index.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

In addition, anonymized and/or de-identified data may be used for any lawful purpose. These lawful purposes may include, but are not limited to, development of new features for the Software, data research projects and publishing of data research projects, and data benchmarking. Company commits to take reasonable measures to ensure that de-identified data cannot be associated with an individual and to maintaining and using such data without attempting to re-identify the de-identified data.

Disclosure of Your Information

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries, parents, and affiliates to the extent necessary for the purpose collected.
• To contractors, service providers, and other parties we use to support our business.
• To the extent permitted by applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s or our subsidiaries, parents, or affiliates assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company or such entity about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use available at: witools.org/document and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Your State’s Privacy Rights and Additional Disclosures

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. California's “Shine the Light” law (California Civil Code § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to laughlin@wellington.org or write us at: 3650 Reed Road, Columbus, OH 43220.

If you need to access this Policy in an alternative format due to having a disability, please send an email to laughlin@wellington.org or write us at: 3650 Reed Road, Columbus, OH 43220.

The information contained in this section of the Policy applies solely to Website users who meet the definition of the term “consumer” as defined under the California Consumer Privacy Act, as amended, and the then current regulations adopted by the California Attorney General and the California Privacy Protection Agency pursuant thereto (collectively, the “CCPA”) and to other individuals entitled to analogous rights and disclosures under the Personal Information Protection and Electronic Documents Act, S.C. 2000 or applicable state law, including the Colorado Privacy Act, Nevada Revised Statutes Chapter 603A, the Oregon Consumer Privacy Act, the Virginia Consumer Data Protection Act, the New Jersey Data Protection Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, the Children’s Online Privacy Protection Act, the Illinois Biometric Information Privacy Act, the Texas Data Privacy and Security Act, the Montana Consumer Data Privacy Act, the Iowa Consumer Data Protection Act, the Tennessee Information Protection Act, the Indiana Consumer Data Protection Act, the Delaware Personal Data Privacy Act, the Kentucky Consumer Data Protection Act, the Nebraska Data Privacy Act, New Hampshire Senate Bill 255, the Maryland Online Data Privacy Act, the Minnesota Consumer Data Privacy Act, the Rhode Island Data Transparency and Privacy Protection Act, and all other applicable U.S. state and federal privacy laws (collectively, with the CCPA, as applicable “Privacy Laws”) Terms, and correlative terms, defined in the Privacy Laws contained in this section are intended to have the same meaning and effect as set forth in the Privacy Laws. We obtain the categories of personal information listed in the tables below from the following categories of sources: (i) the consumer directly, (ii) indirectly from the consumer, for example, by observing certain interactions with our Website, and (iii) information uploaded or otherwise provided by schools or other customers. We intend to retain each category of personal information for the period necessary for the processing purpose.

We collect personal information on and through the Website and process that personal information as set forth in this Policy. In particular, our Website collected the following categories of personal information from consumers within the last twelve (12) months:

Use of Personal Information

We may use, or disclose the personal information we collect for purposes that are not materially different from those disclosed in this Policy and for one or more of the purposes set forth below, which may include:

• To fulfill or meet the reason you provided the information.
• To create, maintain, customize, and secure your account.
• To process your requests and prevent fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in Privacy Law.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users, including without limitation consumers, is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose.

We have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

As defined by privacy laws, we do not Sell or Share personal information. We do not have actual knowledge that we Sell or otherwise Share personal information of consumers under 16 years.

In the preceding twelve (12) months, we have Sold or Shared the following categories of personal information to the categories of third parties indicated in the chart below.

However, you or the Purchasing Organization may disclose or otherwise enable the processing of personal information, including without limitation the categories of personal information listed in rows A, C, J, and K of the table above through the use of APIs and otherwise through the Software. You, or the Purchasing Organization, as applicable, are the controllers with respect to such processing.

Sensitive Personal Data

We use and disclose Sensitive Personal Data as set forth in our Wellington Engagement Index Privacy Policy for Children Under the Age of 13 found available at: wei.wellington.org/Privacy , and with respect to Users 13 years of age and over as set forth below.

A User’s name, race, socio economic information, and gender may be Collected and used to provide the Software to the User and the applicable District Admin Users, School Admin Users, Teacher Users, and Purchasing Organizations. This information is Collected and used based on consent provided by the applicable Purchasing Organization for the applicable User, and is used to provide the Software requested.

We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

Right to Revoke Consent for Sensitive Personal Data Processing

You have the right to revoke consent for the processing of your or your Student Users’ Sensitive Personal Data.

You may revoke consent by sending us an email at laughlin@wellington.org

Your Additional Rights and Choices

The Privacy Laws provide consumers with specific rights regarding their personal information. This section describes consumer rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• The specific pieces of personal information we collected about you (also called a data portability request).

Right to Opt-Out of Certain Profiling and Decision Making

You have the right to opt-out of the processing of your personal information for the purpose of profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer, as applicable.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity, we will verify the request and review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete

To exercise your rights to know, opt-out, or delete described above, please submit a request by emailing us at laughlin@wellington.org.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. To designate an authorized agent, submit a request by emailing us at laughlin@wellington.org.

You may also make a request to know or delete on behalf of your child by emailing us at laughlin@wellington.org.

You may only submit a request to know twice within a 12-month period.

Right not to Receive Discriminatory Treatment

You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights conferred by Privacy Laws, including the right not to be retaliated against for the exercise of their rights under Privacy Laws.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email us at laughlin@wellington.org.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out Right

We do not Sell or Share Personal Information and do not use Sensitive Personal Information for purposes other than those authorized by subdivision (a) of Section 1798.121 of the CCPA.

For the avoidance of doubt, Nevada consumers who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A, as amended, may submit a request by emailing us at laughlin@wellington.org.

Changes to Our Privacy Policy

It is our protocol to post any changes we make to the Policy on this page with a notice that the Policy has been updated send to the Purchasing Organization via email. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account and/or through a notice on the Website. The date the Policy was last revised is identified on the first page of this Policy.

Contact Information

To ask questions or comment about this privacy policy or our organization’s designated individual(s), policies and privacy practices, contact The Wellington Initiative LLC at:

laughlin@wellington.org Or

3650 Reed Road Columbus, OH 43220