Privacy Policy

State of Connecticut Rev. 133C579

WWW.ORANGEOWLACADEMY.COM

Version Date: April 25, 2017

GENERAL

Orange Owl Academy (“Company” or “we” or “us” or “our”) respects the privacy of its users (“user” or

“you”) that use our website located at http://www.orangeowlacademy.com, including other media forms,

media channels, mobile website or mobile application related or connected thereto (collectively, the

“Website”). The following Company privacy policy (“Privacy Policy”) is designed to inform you, as a user

of the Website, about the types of information that Company may gather about or collect from you in

connection with your use of the Website. It also is intended to explain the conditions under which

Company uses and discloses that information, and your rights in relation to that information. Changes to

this Privacy Policy are discussed at the end of this document. Each time you use the Website, however,

the current version of this Privacy Policy will apply. Accordingly, each time you use the Website you

should check the date of this Privacy Policy (which appears at the beginning of this document) and review

any changes since the last time you used the Website.

The Website is hosted in the United States of America and is subject to U.S. state and federal law. If you

are accessing our Website from other jurisdictions, please be advised that you are transferring your

personal information to us in the United States, and by using our Website, you consent to that transfer

and use of your personal information in accordance with this Privacy Policy. You also agree to abide by

the applicable laws of applicable states and U.S. federal law concerning your use of the Website and your

agreements with us. Any persons accessing our Website from any jurisdiction with laws or regulations

governing the use of the Internet, including personal data collection, use and disclosure, different from

those of the jurisdictions mentioned above may only use the Website in a manner lawful in their

jurisdiction. If your use of the Website would be unlawful in your jurisdiction, please do not use the

Website.

BY USING OR ACCESSING THE WEBSITE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN

THIS PRIVACY POLICY.

GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION

Users of the Website Generally

“Non-Personally-Identifying Information” is information that, without the aid of additional information,

cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is

information such as a name or email address that, without more, can be directly associated with a specific

person. Like most website operators, Company gathers from users of the Website Non-Personally-

Identifying Information of the sort that Web browsers, depending on their settings, may make available.

That information includes the user’s Internet Protocol (IP) address, operating system, browser type and

the locations of the websites the user views right before arriving at, while navigating and immediately after

leaving the Website. Although such information is not Personally-Identifying Information, it may be

possible for Company to determine from an IP address a user’s Internet service provider and the

geographic location of the visitor’s point of connectivity as well as other statistical usage data. Company

analyzes Non-Personally-Identifying Information gathered from users of the Website to help Company

better understand how the Website is being used. By identifying patterns and trends in usage, Company

is able to better design the Website to improve users’ experiences, both in terms of content and ease of

use. From time to time, Company may also release the Non-Personally-Identifying Information gathered

from Website users in the aggregate, such as by publishing a report on trends in the usage of the

Website.

Web Cookies

A “Web Cookie” is a string of information which assigns you a unique identification that a website stores

on a user’s computer, and that the user’s browser provides to the website each time the user submits a

query to the website. We use cookies on the Website to keep track of services you have used, to record

registration information regarding your login name and password, to record your user preferences, to

keep you logged into the Website and to facilitate purchase procedures. Company also uses Web

Cookies to track the pages that users visit during each Website session, both to help Company improve

users’ experiences and to help Company understand how the Website is being used. As with other Non-

Personally-Identifying Information gathered from users of the Website, Company analyzes and discloses

in aggregated form information gathered using Web Cookies, so as to help Company, its partners and

others better understand how the Website is being used. COMPANY USERS WHO DO NOT WISH TO

HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO

REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT

CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF

WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY

FOR ANY RESULTING LOSS OF FUNCTIONALITY.

Web Beacons

A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user

and allows website operators to check whether a user has viewed a particular web page or an email.

Company may use Web Beacons on the Website and in emails to count users who have visited particular

pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users’

Personally-Identifying Information. They are a technique Company may use to compile aggregated

statistics about Website usage. Web Beacons collect only a limited set of information, including a Web

Cookie number, time and date of a page or email view and a description of the page or email on which

the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective

by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is

tendered, permitting you to accept or decline Web Cookies on an individual basis.

Analytics

We may partner with selected third parties to allow tracking technology on the Website, which will enable

them to collect data about how you interact with the Website and our services over time. This information

may be used to, among other things, analyze and track data, determine the popularity of certain content

and better understand online activity.

Aggregated and Non-Personally-Identifying Information

We may share aggregated and Non-Personally Identifying Information we collect under any of the above

circumstances. We may also share it with third parties and our affiliate companies to develop and deliver

targeted advertising on the Website and on websites of third parties. We may combine Non-Personally

Identifying Information we collect with additional Non-Personally Identifying Information collected from

other sources. We also may share aggregated information with third parties, including advisors,

advertisers and investors, for the purpose of conducting general business analysis. For example, we may

tell our advertisers the number of visitors to the Website and the most popular features or services

accessed. This information does not contain any Personally-Identifying Information and may be used to

develop website content and services that we hope you and other users will find of interest and to target

content and advertising.

SOCIAL MEDIA

We may use hyperlinks on the Website which will redirect you to a social network if you click on the

respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s

“tweet” button or the Google+, that particular social network’s plugin will be activated and your browser

will directly connect to that provider’s servers. If you do not use these buttons, none of your data will be

sent to the respective social network’s plugin provider. So for example, when you click on the Facebook’s

“Like” button on the Website, Facebook will receive your IP address, the browser version and screen

resolution, and the operating system of the device you have used to access the Website. Settings

regarding privacy protection can be found on the websites of these social networks and are not within our

control.

COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION

Website Registration

As defined above, Personally-Identifying Information is information that can be directly associated with a

specific person. Company may collect a range of Personally-Identifying Information from and about

Website users. Much of the Personally-Identifying Information collected by Company about users is

information provided by users themselves when (1) registering for our service, (2) logging in with social

network credentials, (3) participating in polls, contests, surveys or other features of our service, or

responding to offers or advertisements, (4) communicating with us, (5) creating a public profile or (6)

signing up to receive newsletters. That information may include each user’s name, address, email

address and telephone number, and, if you transact business with us, financial information such as your

payment method (valid credit card number, type, expiration date or other financial information). We also

may request information about your interests and activities, your gender, age, date of birth, username,

hometown and other demographic or relevant information as determined by Company from time to time.

Users of the Website are under no obligation to provide Company with Personally-Identifying Information

of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website

features.

BY REGISTERING WITH OR USING THE WEBSITE, YOU CONSENT TO THE USE AND

DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS

“COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.

Online Postings

Certain Personally-Identifying Information collected from users may be disclosed as a matter of course as

a result of your use of the Website. We may provide areas on the Website where you can post reviews

and other information relating to your activities on the Website. Such postings are governed by our Terms

of Use. In addition, such postings may appear on other websites or when searches are executed on the

subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable

web pages, that information will be publicly available and can be collected and used by others. For

example, if you post your email address, you may receive unsolicited messages. We cannot control who

reads your posting or what other users may do with the information you voluntarily post, so we encourage

you to exercise discretion and caution with respect to your personal information. USERS ASSUME ALL

RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM THEIR

VOLUNTARY DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION.

Company Communications

We may occasionally use your name and email address to send you notifications regarding new services

offered by the Website that we think you may find valuable. We may also send you service-related

announcements from time to time through the general operation of the service. Generally, you may opt

out of such emails at the time of registration or through your account settings, though we reserve the right

to send you notices about your account, such as service announcements and administrative messages,

even if you opt out of all voluntary email notifications.

Company Disclosures

Company will disclose Personally-Identifying Information under the following circumstances:

• By Law or to Protect Rights. When we believe disclosure is appropriate, we may disclose

Personally-Identifying Information in connection with efforts to investigate, prevent or take other

action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the

rights, property or safety of Company, our users, our employees or others; to comply with

applicable law or cooperate with law enforcement; to enforce our Terms of Use or other

agreements or policies, in response to a subpoena or similar investigative demand, a court order

or a request for cooperation from a law enforcement or other government agency; to establish or

exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such

cases, we may raise or waive any legal objection or right available to us.

• Marketing Communications. Unless users opt-out from receiving Company marketing materials

upon registration, Company may email users about products and services that Company believes

may be of interest to them. If you wish to opt-out of receiving marketing materials from Company,

you may do so by following the unsubscribe link in the email communications, by going to your

account settings (if applicable) or contacting us using the contact information below.

• Third-Party Service Providers. We may share your Personally-Identifying Information, which

may include your name and contact information (including email address) with our authorized

service providers that perform certain services on our behalf. These services may include fulfilling

orders, providing customer service and marketing assistance, performing business and sales

analysis, supporting the Website’s functionality and supporting contests, sweepstakes, surveys

and other features offered through the Website. We may also share your name, contact

information and credit card information with our authorized service providers who process credit

card payments. These service providers may have access to personal information needed to

perform their functions but are not permitted to share or use such information for any other

purpose.

• Business Transfers; Bankruptcy. Company reserves the right to transfer all Personally-

Identifying Information in its possession to a successor organization in the event of a merger,

acquisition, bankruptcy or other sale of all or a portion of Company’s assets. Other than to the

extent ordered by a bankruptcy or other court, the use and disclosure of all transferred

Personally-Identifying Information will be subject to this Privacy Policy, or to a new privacy policy

if you are given notice of that new privacy policy and are given an opportunity to affirmatively optout

of it. Personally-Identifying Information submitted or collected after a transfer, however, may

be subject to a new privacy policy adopted by the successor organization.

Changing Personally-Identifying Information; Account Termination

You may at any time review or change your Personally-Identifying Information by going to your account

settings (if applicable) or contacting us using the contact information below. Upon your request, we will

deactivate or delete your account and contact information from our active databases. Such information

will be deactivated or deleted as soon as practicable based on your account activity and accordance with

our deactivation policy and applicable law. To make this request, either go to your account settings (if

applicable) or contact us as provided below. We will retain in our files some Personally-Identifying

Information to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce our

expect that all your Personally-Identifying Information will be completely removed from our databases in

response to your requests. Additionally, we keep a history of changed information to investigate

suspected fraud with your account.

General Use

Company uses the Personally-Identifying Information in the file we maintain about you, and other

information we obtain from your current and past activities on the Website (1) to deliver the products and

services that you have requested; (2) to manage your account and provide you with customer support; (3)

to communicate with you by email, postal mail, telephone and/or mobile devices about products or

services that may be of interest to you either from us, our affiliate companies or other third parties; (4) to

develop and display content and advertising tailored to your interests on the Website and other sites; (5)

to resolve disputes and troubleshoot problems; (6) to measure consumer interest in our services; (7) to

inform you of updates; (8) to customize your experience; (9) to detect and protect us against error, fraud

and other criminal activity; (10) to enforce our Terms of Use; and (11) to do as otherwise described to you

at the time of collection. At times, we may look across multiple users to identify problems. In particular, we

may examine your Personally-Identifying Information to identify users using multiple user IDs or aliases.

We may compare and review your Personally-Identifying Information for accuracy and to detect errors

and omissions. We may use financial information or payment method to process payment for any

purchases made on the Website, enroll you in the discount, rebate, and other programs in which you

elect to participate, to protect against or identify possible fraudulent transactions and otherwise as needed

to manage our business.

COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY

Company contractually prohibits its contractors, affiliates, vendors and suppliers from disclosing

Personally-Identifying Information received from Company, other than in accordance with this Privacy

Policy. However, third parties are under no obligation to comply with this Privacy Policy with respect to

Personally-Identifying Information that users provide directly to those third parties, or that those third

parties collect for themselves. These third parties include advertisers, providers of games, utilities,

widgets and a variety of other third-party applications accessible through the Website. Company neither

owns nor controls the third-party websites and applications accessible through the Website. Thus, this

them. Before visiting a third party, or using a third-party application, whether by means of a link on the

Website, directly through the Website or otherwise, and before providing any Personally-Identifying

Information to any such third party, users should inform themselves of the privacy policies and practices

(if any) of the third party responsible for that website or application, and should take those steps

necessary to, in those users’ discretion, protect their privacy.

SECURITY

We take the security of your Personally-Identifying Information seriously and use reasonable electronic,

personnel and physical measures to protect it from loss, theft, alteration or misuse. However, please be

advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that

only authorized persons will view your information. We are not responsible for third-party circumvention of

any privacy settings or security measures.

We are dedicated to protect all information on the Website as is necessary. However, you are responsible

for maintaining the confidentiality of your Personally-Identifying Information by keeping your password

confidential. You should change your password immediately if you believe someone has gained

unauthorized access to it or your account. If you lose control of your account, you should notify us

immediately.

Company may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to

Company’s Privacy Policy will be reflected on this page and the date new versions are posted will be

stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all

information that we have about you and your account. Users should regularly check this page for any

changes to this Privacy Policy. Company will always post new versions of the Privacy Policy on the

Website. However, Company may, as determined in its discretion, decide to notify users of changes

made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain

and update their contact information.

CHILDREN

The Children's Online Privacy Protection Act ("COPPA") protects the online privacy of children under 13

years of age. We do not knowingly collect or maintain Personally-Identifying Information from anyone

under the age of 13, unless or except as permitted by law. Any person who provides Personally-

Identifying Information through the Website represents to us that he or she is 13 years of age or older. If

we learn that Personally-Identifying Information has been collected from a user under 13 years of age on

or through the Website, then we will take the appropriate steps to cause this information to be deleted. If

you are the parent or legal guardian of a child under 13 who has become a member of the Website or has

otherwise transferred Personally-Identifying Information to the Website, please contact Company using

our contact information below to have that child's account terminated and information deleted.

CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who

are California residents to request and obtain from us, once a year and free of charge, information about

the Personally-Identifying Information (if any) we disclosed to third parties for direct marketing purposes in

the preceding calendar year. If applicable, this information would include a list of the categories of the

Personally-Identifying Information that was shared and the names and addresses of all third parties with

which we shared Personally-Identifying Information in the immediately preceding calendar year. If you are

a California resident and would like to make such a request, please submit your request in writing to our

privacy officer as listed below.

DO-NOT-TRACK POLICY

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or

setting you can activate to signal your privacy preference not to have data about your online browsing

activities monitored and collected. Because there is not yet a common understanding of how to interpret

the DNT signal, the Website currently does not respond to DNT browser signals or mechanisms.

CONTACT

If you have any questions regarding our Privacy Policy, please contact our Privacy Officer at:

Orange Owl Academy

Attn: Privacy Officer

__________

__________, __________ __________

Email: [email protected]

Phone: __________

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GENERAL INSTRUCTION

WHAT IS A PRIVACY POLICY?

A Privacy Policy is a document or statement that

describes how a company gathers, uses,

manages, and releases the information of

customers or visitors to its website. By accessing

the company’s website, users accept to have to

having their information collected and disclosed

in accordance with the company’s Privacy Policy.

WHAT SHOULD BE INCLUDED?

A simple Privacy Policy will identify the following

basic elements:

• Company: The name of the company that

owns the website collecting information

from its users.

• Website: The URL address of the

company’s website that the user will be

browsing and accessing.

• User’s Information: A description of the

type of information that the website collects

and discloses.

• Collection, Use, and Disclosure: What

information the company will collect , how

they will collect and use the information,

and when and to whom they will disclose

the information.

WHEN IS IT NEEDED?

While there is no federal law in the United States

requiring that websites establish a Privacy Policy,

many states and most other countries do require

a website that collects and stores any personal

information from its users to have one.

In the United States, the Federal Trade

Commission (FTC) regulates laws and policies

regarding the privacy practices of businesses and

the protection of their customers’ personal

information. The FTC also helps to enforce

federal laws concerning the privacy of customers’

information, including the following:

• Fair Credit Reporting Act (FCRA), which

limits how companies can obtain and use a

customer’s credit and background reports.

• Gramm-Leach-Bliley Act, which requires

financial institutions to clearly explain their

　 information sharing practices and also

restricts the sharing and use of specific

financial information.

• Health Insurance Portability and

Accountability Act (HIPAA) created a

“Privacy Rule” that establishes a national

set of standards of how health care service

providers can use an individual’s protected

health information.

• Children’s Online Privacy Protection Act

(COPPA), requires websites that target

and/or collect information from children

under the age of 13 to post a Privacy Policy

that complies with the COPPA

requirements, and also implements certain

parental notice and consent requirements.

Even if your company or website is not in a

jurisdiction that requires a privacy policy, the

reach of your website may subject it to the laws

of other states and countries. For example,

California, has enacted the California Online

Privacy Protection Act of 2003 (CALOPPA) which

requires any website collecting personal

information to have a Privacy Policy posted on its

website that is easily accessible to its users.

Even if your website is not run from California,

CALOPPA applies to any website that collects

personal information from a California resident.

Therefore it is likely that your website will be

subject to the CALOPPA regulations.

The European Union has more established laws

regarding privacy protection, including the Data

Protection Directive (95/46/EC) and the E-Privacy

Directive (2002/58/EC). These directives state

that personal information of European Union

residents can only be transferred to countries

outside of the European Union that have policies

with an adequate level of protection.

Therefore, if you are a website that gathers,

stores, or uses personal information and data

from clients and users, you should have a Privacy

Policy for your website. You also need to make

sure that you adhere to the promises and

disclosures set forth in that policy.

OTHER NAMES

A Privacy Policy may also be called:

Privacy Statement, Internet Privacy Policy,

Website Privacy Policy, Privacy Notice, Privacy

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