I.Introduction

This Privacy Policy (the “Policy”) describes the type of information that Candue Inc. also d/b/a StudentPOS (the “Company”) gathers from users of the CanDue TM software application (the “App”) and how the Company uses that information. The Policy is part of the Company’s Terms of Use which is available at www.candue.io

We created the App for use by educational institutions, teachers, educational specialists, tutors and parents, educational organizations, (“Educators”) in helping middle school, high school, college and other students (“Students”) to achieve their full potential. This Policy refers Educators and Students collectively as “Users” or “you.”

II.What Information Does the Company Collect?

The Company occasionally collects Personal Information from Users. “Personal Information” means information that can be used to identify an individual.

A.Consent and Modification

By using the App, you consent to the terms of the Policy and to our processing of Personal Information in the manner and for the purposes set forth in the Policy. If you do not agree with the Policy, please do not use the App.

The Company reserves the right, at its sole discretion, to change the Policy at any time, which change will be effective ten (10) days following posting of the revision to the Policy on the App. Your continued use of the App ten (10) days following such posting means you accept those changes.

If the Company makes any change in how we use your Personal Information, the Company will notify you by email (at the e-mail address specified in your account), or by means of a notice on the App prior to the change becoming effective.

B.Information We Collect

The Company collects information in the following ways:

1.Information Users Provide Directly

The Company collects information directly provided by Users as part of using the App, such as information provided as part of setting up an account.

The Company also collects User Content (e.g., scheduling information, reminders, appointments and other academic information ) that Users post on the App, as well as communications between Users and the Company as part of using the App.

2.Information Provided by an Educator on Behalf of a Student

The Company collects information directly provided by Educators on behalf of Students as part of using the App, such as information used to set up accounts or user profiles for Students.

The Company also collects User Content (e.g., scheduling information, reminders, appointments, homework assignments, homework/academic preferences, test preparation information, available homework dates/times and other related information to homework and academics) that an Educator posts on the App in relation to a Student.

3.Cookies

The Company may use cookies and similar technologies, such as web beacons, pixels, and clear gifs and third-party analytics services to collect and analyze information about Users. This may include information about Users’ search preferences, interaction with ads within the App, and location.

4.Log Files

The App automatically records certain log file information, such as IP address, location, mobile carrier, device, and interaction with links in the App.

5.Device Identifiers

The App may access, collect, monitor, store on your device, and/or remotely store one or more device identifiers, which are small data files which uniquely identify it.

Metadata Metadata is technical information associated with User Content, such as how or when User Content was collected. The App collects metadata on User Content.

III.Use of Information

The Company provides the App for the benefit of Educators and Users for educational purposes.

The Company may in its discretion use information from Users to operate and improve the App and to deliver the App. These uses may include providing you with more effective customer service; making the App easier to use by eliminating the need for you to enter the same information repeatedly; performing research and analysis aimed at improving the App; automatically updating the App; diagnosing or fixing problems with the App; and displaying content customized to your interests and preferences.

The Company also uses information from Users to communicate with Users. The Company may send certain mandatory service communications, such as welcome letters, information on technical service issues, and security announcements. The Company may in its discretion also contact Educators to inform them of other products or services available from the Company.

The Company does not use Personal Information for commercial purposes not related to the App, including advertising.

Personal Information collected by the App may be stored and processed as allowed by law in the United States or any other country in which the Company or its affiliates, subsidiaries or agents maintain facilities. By using the App, you consent to any such transfer of information outside of your country. The Company may transfer your Personal Information to affiliated companies for the purpose of storing or processing such information on its behalf. Such information may be transferred to other countries. The Company requires that these parties agree to process such information in compliance with the Policy. In particular, if you provide Personal Information, it may be transferred to and processed on computers in the U.S. and other countries.

The Company may disclose your Personal Information or any information submitted via the App if the Company has a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce any applicable terms of service, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of the Company, our Users, yourself or the public. The Company may be required to disclose Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements

IV.Sharing of Information

The Company will not share your Personal Information except as provided for by this Policy. The Company may share other information as provided by this Policy.

A.Affiliates

The Company may share information collected by the App with businesses that are legally part of the same group as the Company, or that become part of that group (“Affiliates”).

B.Third Party Service Providers

The Company may use contractors to collect, use, analyze and otherwise process information on its behalf. The Company requires such suppliers to handle information in a manner consistent with the Policy.

The Company may occasionally hire other companies to provide limited services on its behalf, such as providing customer support, hosting websites, processing transactions, or performing statistical analysis of its services and well as other services. Those companies will be permitted to obtain only the Personal Information they need to deliver the service. They will be required to maintain the confidentiality of the information and will be prohibited from using it for any other purpose.

C.Anonymous Information

The Company may use Anonymous Information (as defined below) or disclose it to third party service providers, to provide and improve the App. "Anonymous Information" means information which does not enable identification of an individual User, such as aggregated information about use of the App.

V.Review, Deletion and Retention

The Company allows Educators and Students to review Personal Information collected from Students and, upon request, to delete such Personal Information. An Educator or Student seeking to review personal information should contact info@candue.io. It is the Company’s policy to verify the identity of an Educator or Student making a request to review or delete Personal Information.

It is the Company’s policy to retain Personal Information regarding Students for nine (9) months at the end of active use or end of subscription and to delete such information thereafter. Company has the option to delete information earlier at its discretion.

VI.Other Information

A.Business Transitions

If the Company is acquired by or merged with a third party entity, or if it is subject to a bankruptcy or any comparable event, the Company reserves the right to transfer or assign Personal Information in connection therewith.

B.Security, Confidentiality and Integrity of Personal Information

The security of your Personal Information is important to us. The Company follows generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect Personal Information. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while the Company strives to use commercially reasonable means to protect Personal Information, the Company cannot guarantee its absolute security or confidentiality. If you have any questions about security, you can contact the Company at info@candue.io.

Please be aware that certain Personal Information and other information provided by you in connection with your use of the App may be stored on your device (even if that information is not collected by the Company). You are solely responsible for maintaining the security of your device from unauthorized access.

C.International Users

The Company and its servers are located in the United States and are subject to the applicable local and national laws. Those who choose to access the App do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. Users who choose to access or use the App consent to the use and disclosure of information in accordance with this Policy and subject to such laws. The Company may limit the App’s availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion. The Company does not represent or warrant that the App, or any part thereof, is appropriate or available for use in any other jurisdiction.

D.Children’s Privacy

The App is marketed towards Educators for use by Students. The Company does not collect Personal Information from Students less than 13 years of age without verifiable parental consent, including consent by another applicable Educator in compliance with FTC guidance on COPPA consent by schools and teachers. If the Company learns that Personal Information of persons less than 13 years of age has been collected without verifiable parental consent, the Company will take the appropriate steps to delete this information. To make such a request, please contact the Company info@candue.io

E.California Online Privacy Protection Act

Pursuant to the California Online Privacy Protection Act, the Company discloses to disclose how it responds to "Do Not Track Signals"; and whether third parties collect personally identifiable information about users when they use online services.

The Company honors "do not track" signals and does not track, use cookies, or use advertising when a “do not track” mechanism is in place.

The Company does not authorize the collection of personally identifiable information from our users for third party use through advertising technologies.

California Civil Code Section 1798.83 also permits customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for direct marketing purposes. To make such a request, please send an email to info@candue.io. Please note that the Company is only required to respond to one request per customer each year.

F.SOPIPA

The Company operates in compliance with the Student Online Personal Information Protection Act, applicable to Students in California. As noted in this Policy, the Company does not (1) engage in targeted advertising directed to Students, (2) amass profiles on Students for the purpose of advertising, or (3) make unauthorized disclosures of a Student’s Personal Information. As noted above, the Company does (1) maintain reasonable security procedures to protect Students’ Personal Information from unauthorized disclosure and (2) facilitate the review and deletion of Students’ Personal Information upon appropriately verified request.

G.FERPA

CanDue will comply with FERPA, 20 U.S.C. s. 1232g, to the extent it receives and maintain education records as defined therein.

H.Contact Information

If you have questions about this Policy, please contact info@candue.io.

I.Effective Date

The effective date of this Policy is January 16, 2018.