COOLMATH PRIVACY POLICY

Coolmath.com, LLC (“Coolmath”, “we”, “us”) values your privacy and understands the importance of keeping your personal information secure. We have written this Privacy Policy (“Policy”) to help you understand how we collect, use, and share information provided by educators participating in the Count Forward Financial Literacy Teacher Pilot Program (“Program”). This Policy does not apply to other Coolmath.com, LLC websites or apps, such as CoolmathGames.com or coolmath4kids.com.

By choosing to participate in the Program, you understand that your information will be handled as described in this Policy. Your participation in the Program, and any dispute over privacy, is subject to this Policy and our Terms and Conditions, including its applicable limitations on damages and the resolution of disputes.

INFORMATION WE COLLECT

When you apply for or participate in the Program via our campaign website or feedback forms, for the purpose of fulfilling its objectives, we may collect:

• Contact Information: Your name, school email address, school name, and city/state;
• Classroom and Demographic Data: Grade levels taught, subject areas, estimated number of students, and teaching format; and
• Feedback and Survey Responses: Your evaluation of game performance, student engagement, and educational value.

At Coolmath we are committed to minimizing the amount of personal information, especially sensitive information, we collect.

We DO NOT ask for or collect information such as your home address, phone number, age, gender, racial or ethnic origin, religious/political affiliation, health information, Social Security Number or other identifying information (e.g., driver's license number, passport number, or state ID), payment information, in accordance with the Terms and Conditions, biometric information or precise geolocation data.

We also DO NOT ask for or collect personal information from your students. Student gameplay on CoolmathGames.com or coolmath4kids.com remains anonymous in accordance with our Terms and Conditions and Privacy Policy applicable to those other Coolmath.com, LLC websites.

We also maintain records of communications with participants, including the nature of the request, name and contact information. If you choose to contact us, please do not provide any sensitive information to us. If you contact us for support we may maintain information you provide as part of that request for support, including your name, contact information and details about your request for support as a part of our management records. We do not combine this information with other types of information for purposes other than responding to your request for support. We do not share this information with third parties, unless necessary to respond to your request for support.

INFORMATION WE COLLECT AUTOMATICALLY

Coolmath will allow participants to play interactive games as part of the Program (“Games”). We automatically collect information about your use of the Games, such as games played, the length of time that you use our Games, and other activities on the Program website.

We also automatically collect or analyze information about your browser and/or device. This information may include: IP address; device identifiers; device name and model; browser name and version; operating system name and version.

HOW WE USE YOUR INFORMATION

We use the information collected for the following explicit purposes:

• Program Management: To evaluate applications, select participants, communicate instructions, and deliver the Reward associated with the Program, in accordance with the Terms and Conditions;
• Research and Improvement: To measure the effectiveness of our educational financial literacy tools and refine our Games;
• Aggregated Reporting: We may share anonymized, aggregated statistics (e.g., "85% of pilot educators reported increased student interest in budgeting") in our promotional or educational impact reports;
• Protecting Rights and Interests: To protect the safety, rights, property, or security of Coolmath.com, LLC the Games, any third party, or the general public or the participants; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity that we consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Policy or our Terms and Conditions;
• Legal Compliance: To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority;
• General Business Operations: Where appropriate for the administration of our general business, accounting, recordkeeping and legal functions. As part of our routine business administration, such as employee training, compliance auditing and similar internal activities; and
• Future Communications (Optional): If you explicitly opt in, we may use your email to send updates about new educational resources and free classroom games.

DATA SHARING AND THIRD PARTIES

We generally process data in the United States. When we share data, we may provide data to companies globally. In each case, we have safeguards in place which allow those transfers to happen in a way that ensures data is handled in accordance with the applicable law.

We do not sell your personal information. Furthermore, we do not share, rent, or disclose your personal information with third parties for their own marketing or advertising purposes.

In general, we may share your information as follows:

• Affiliates: We may disclose the information we collect from you to our affiliates or subsidiaries, including other companies within the Sandbox International Holdings Ltd group of companies; however, if we do so, their use and disclosure of your information will be subject to this Policy;
• Service Providers: We may disclose the information we collect from you to other companies who perform services on our behalf. For example, we may share information with trusted service providers assisting us in executing the Program (e.g., survey platforms, gift card fulfillment partners), strictly under confidentiality and data protection agreements. These service providers are prohibited from retaining, using, or disclosing your information except as necessary to perform services for us;
• Business Transfers: We may disclose your information to another entity in connection with an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer, including during negotiations related to such transactions;
• Protecting Rights and Interests: We may disclose your information to protect the safety, rights, property, or security of Coolmath.com, LLC, the Games, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity which we, in our sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Policy or Terms and Conditions; and
• Legal Compliance: We may disclose your information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; in response to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.

SECURITY

We are committed to maintaining the privacy and integrity of your information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures.

Unfortunately, the transmission of information via the internet is not completely secure. Although we implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted to us; therefore we do not assume any responsibility for any transmission of your information which you do at your own risk.

DATA RETENTION AND YOUR RIGHTS

This section is subject to specific disclosures on privacy rights set forth below. We are committed to facilitating the exercise of your rights granted by the laws of your jurisdiction and to which we are subject, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of future communications. Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority and the right to appeal our decision regarding a data access request. We will do our best to honor your requests subject to any legal and contractual obligations. If you are a resident of California (or another state that has adopted laws substantially similar to the CCPA - California Consumer Privacy Act), you have the right to request:

• The categories of personal information (including sensitive personal information if applicable) we have collected about you;
• The categories of sources from which the personal information is collected;
• The business or commercial purpose of collecting, selling or sharing personal information;
• The categories of third parties with whom we share or sell personal information;
• The categories of personal information about you that we have disclosed for business purposes; and
• The specific pieces of personal information we have collected about you.

Additionally, you have the right:

• to know the length of time we retain your personal information;
• to request deletion of your personal information;
• to request the correction of any inaccurate data;
• to opt out of the sale or sharing of your information (if applicable);
• to limit the use of sensitive personal information (if applicable); and
• to not be discriminated against for exercising any of your CCPA rights.

If you would like to make a request or request we delete or no longer use your information, contact us at privacy@coolmath.com.

CONTACT US

If you have questions about this Policy or wish to exercise your privacy rights, please contact:

POLICY CHANGES

From time to time we may change this Policy. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy of this Policy on our website. Please check our website periodically for updates.