Privacy Policy
California Addendum

Definitions

Capitalized terms not defined in this Addendum have the meanings given to them in our Privacy Policy. For the purposes of this Addendum, the following additional definitions apply:

• "Business", for the purpose of the CCPA, refers to Red Rover as the legal entity that collects Personal Data and determines the purposes and means of the processing of such Personal Data, or on behalf of which such Personal Data is collected and that alone, or jointly with others, determines the purposes and means of the processing of Personal Data, that falls into the scope of the CCPA.
• "CCPA" means the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020.
• "Consumer", for the purpose of the CCPA, means a natural person who is a California resident. A resident, as defined in Section 17014 of Title 18 of the California Code of Regulations, includes (1) every individual who is in California for other than a temporary or transitory purpose, and (2) every individual who is domiciled in California who is outside California for a temporary or transitory purpose.
• "Sale", for the purpose of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Data to another business or a third party for monetary or other valuable consideration.
• "Sensitive Personal Information" means Personal Data that reveals a consumer's social security number, driver's license number, financial account information, precise geolocation, racial or ethnic origin, religious beliefs, union membership, contents of mail or text messages (where Red Rover is not the intended recipient), genetic data, biometric information, health information, or information about sex life or sexual orientation.
• "Sharing", for the purpose of the CCPA, means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Data to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

CCPA Privacy Notice

This Privacy Notice for California Residents supplements the information contained in our Privacy Policy, and applies solely to all visitors, users, and others who are California Consumers. We have adopted this notice to comply with the CCPA, and any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

Please refer to the "Collecting and Using Your Personal Data" section of our Privacy Policy.

In particular, we have collected the following categories of Personal Data within the last twelve (12) months:

The categories above do not include Sensitive Personal Information as defined under the CCPA. We do not knowingly collect Sensitive Personal Information from website visitors.

Sharing Personal Data

We may disclose your Personal Data to a third party for a business purpose, as described in the "Use of Your Personal Data" section of our Privacy Policy. When we disclose Personal Data for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract. Please be advised that the CCPA prohibits third parties who purchase the Personal Data we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

In the preceding twelve (12) months, Red Rover has disclosed the following categories of Personal Data for a business purpose with service providers it uses:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories (limited to name, address and phone numbers).
• Category F: Internet or other similar network activity.
• Category G: Geolocation data; and
• Category I: Professional or employment-related information.

Your Rights under the CCPA

The CCPA provides Consumers, who are California residents with specific rights regarding their Personal Data. This section describes your CCPA rights and explains how to exercise those rights.

a) Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about its collection and use of your Personal Data over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of Personal Information we have collected about you;
• The categories of sources for Personal Information we have collected about you;
• Our business or commercial purpose for collecting that Personal Data;
• The categories of third parties with whom we have shared that Personal Data;
• The specific pieces of Personal Information it has collected about you (also called a "data portability request");
• If we have sold or disclosed your Personal Data for a business purpose, two separate lists disclosing:
  • Sales, identifying the Personal Data categories that each category of recipient purchased; and
  • Disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained.

b) Deletion Request Rights

You have the right to request that we delete any of your Personal Data that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Data from its records, unless an exception 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 Data, 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.

c) Right to Correction

You have the right to request that we correct any inaccurate Personal Data we maintain about you. Upon receiving and verifying your request, we will use commercially reasonable efforts to correct the inaccurate Personal Data, taking into account the nature of the Personal Data and the purposes of the processing.

d) Right to Limit Use and Disclosure of Sensitive Personal Information

If we collect Sensitive Personal Information (as defined under the CCPA), you have the right to request that we limit its use and disclosure to that which is necessary to perform the services or provide the goods reasonably expected by an average consumer. We do not currently use or disclose Sensitive Personal Information for purposes beyond those permitted under the CCPA.

e) Exercising Your Rights

To exercise the access, data portability, correction, deletion, and other rights described above, please submit a verifiable consumer request to us at: privacy@redroverk12.com, or mail us at Red Rover Technologies Holdings LLC, 559 W. Uwchlan Ave, Suite 200, Exton, PA 19335.

We will confirm receipt of your verifiable consumer request within ten (10) business days of receiving it. We will disclose and deliver the required information free of charge within forty-five (45) days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional forty-five (45) days when reasonably necessary and with prior notice.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Data. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we have collected Personal Data or an authorized representative;
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Data if it cannot verify your identity or authority to make the request and confirm the Personal Data relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use Personal Data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Selling and Sharing Personal Data

We do not sell or share Personal Data, as those terms are defined under the CCPA.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Website

You may manage cookie and tracking preferences on our Website by adjusting your browser settings. For more information, please see the "Usage Data" section of our Privacy Policy.

Mobile Devices

Your mobile Device may give you the ability to manage the collection of certain information. You can adjust your Device settings to control permissions related to location data and other information collected through the Red Rover application. You can also stop the collection of location information from your mobile Device by changing the preferences on your mobile device.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Website does not currently respond to Do Not Track signals.

However, some third party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 16 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below, and include the email address associated with your account.

Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Changes to this California Addendum

We may update this California Addendum from time to time.

The date this California Addendum was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our website and this California Addendum to check for any changes.

Changes to this California Addendum are effective when they are posted on this page.

Privacy Questions

If you have any questions about this California Addendum, you can contact us by email at: privacy@redroverk12.com, or by mail at:

Red Rover Technologies Holdings LLC
559 W. Uwchlan Ave, Suite 200
Exton, PA 19335