PRIVACY POLICY

Updated May 9, 2025

1. Introduction

This Privacy Policy (hereafter "Policy") describes the policies of Septerrex Technologies, LLC (hereafter "we", "our", "us") regarding the collection, access, use, and retention of educational and personal information provided to us by our K-12 educational institution customers (hereafter "Customers"). This Policy also describes our practices regarding any and all other data collected through use of our products by authorized account holders affiliated with our Customers ("Users"). By using our products, you, the User and/or Customer, agree to the collection and use of your information in accordance with this Policy.

2. Data We Store

We receive and store Educational Data from our Customers, including but not limited to student information, instructor information, school or school district details, and course information and schedules.

We also store any and all data generated by Users through use of our products.

Collectively, all data we store is hereafter referred to as "Customer Data".

Customer Data is stored in cloud databases located in the United States.

3. Our Commitment to Privacy and Security

We maintain strict safeguards to protect Customer Data in our possession against unauthorized access. Data is encrypted both at rest and in transport, and permission-based access controls prevent unauthorized User access.

Although we implement access restrictions, the system administrators for each of our Customers can provide differing levels of access to other users within their organization. It is the responsibility of each Customer to ensure they do not grant access to individuals or Users who should not have access to sensitive data.

It is the responsibility of our Customers to ensure accounts held by individuals no longer affiliated with their organization are deactivated in order to prevent continued access by that individual to sensitive data. The system administrators for each of our Customers can take such action to deactivate accounts, or Customers may reflect such changes in the Educational Data provided to us.

Despite our precautions, no system can be completely secure, and there is always a risk of unauthorized access. Upon discovery of a data breach, we will take measures to safeguard and prevent further unauthorized access and we will notify the primary contact of all impacted Customers.

4. Retention and Continued Use of Data

We retain Customer Data in order to provide data analysis to our Customers and improve our products and services.

We may use any and all Customer Data, either in original form or de-identified, to train algorithms and models, including but not limited to machine learning or artificial intelligence algorithms and models.

Customer Data related to a specific User or all data relating to a Customer and their Users will be retained for a period of twelve (12) months following account inactivity or the termination or expiration of a license agreement, respectively. After this retention period, the data may be de-identified or deleted in accordance with our internal policies and applicable law. Customers may request a return or export of their data within thirty (30) days following termination of a license agreement, subject to any applicable fees as described in their license agreement.

5. Disclosure of Information

We do not sell Customer Data, nor do we share Customer Data except as described in this Policy.

We engage with various cloud service providers to deliver our products. Our providers do not have ownership or access to any data in our possession which may be stored or utilized via services they provide.

We may use non-personally identifiable data or otherwise de-identified data for consulting purposes or to demonstrate the effectiveness of our products.

Notifications to users through use of our products may contain limited, pertinent personally identifiable information, such as names and email addresses.

No User mobile phone number will be shared with third parties or affiliates for marketing or promotional purposes.

We may disclose Customer Data if:

a) We are required to do so by law or regulation, or

b) To comply with legal processes, such as a court order or subpoena, or

c) In response to valid requests by government agencies or law enforcement, or

d) We believe disclosure is necessary to protect our rights or property, or

e) We believe disclosure is necessary to protect our Users or Customers, including enforcement of contracts or investigation of suspected misuse of our products.

In the event that we are acquired by or merge with a third-party entity, or in the event of our dissolution, liquidation, or reorganization, we reserve the right to transfer Customer Data as part of such merger, acquisition, liquidation, or reorganization. In any case, we would request but cannot guarantee that data security and privacy standards no lesser than our own continue to protect the data in our possession.

6. Compliance

Our services comply with the Family Educational Rights and Privacy Act ("FERPA").

7. Severability

If any provision of this Policy is found to be unenforceable, invalid, or illegal under any current or future law, that provision will be severed from this Policy and the remaining provisions will remain in full force and effect.

8. Changes to this Privacy Policy

We may periodically update this Policy without prior notice to reflect changes in our practices. In the case of material changes to this Policy we will notify the primary contact for each of our Customers.

9. Contact Us

If you have any questions regarding this Policy, please contact us via the contact form available on our public webpage, septerrex.com.