Student Shield Privacy Policy v.1.0

STUDENT SHIELD LLC

[DRAFT] MOBILE APPLICATION PRIVACY POLICY

Effective as of October 22, 2024

This Privacy Policy (the “Privacy Policy”) applies to the Student Shield mobile application (the

“App”), owned and operated by Student Shield LLC (“Student Shield,” “we,” “us,” or “our”).

We have created this Privacy Policy to tell you what information the App collects, how we use

that information, and who we will share that information with, if at all. This Privacy Policy does

not address the privacy practices of any third parties that we do not own, control, or are affiliated

with. Capitalized terms not defined in this Privacy Policy will have the meaning stated in our

Policy and the accompanying Terms of Use. We encourage you to read the Privacy Policy, and to

use the information it contains to help you make informed decisions.

1. Information We Collect or Receive. In the course of operating the App, we will collect

and/or receive the following types of information. You authorize us to collect and/or receive

such information.

(a) Personal Information. We only receive or collect information that identifies you

personally if you choose to provide such personally identifiable information to us via

email or other means. When you sign up to become a user or contact us, you will be

required to provide us with Personal Information about yourself (collectively, the

“Personal Information”). Such Personal Information may include your name, email

address, physical address, and phone number. We do not collect any Personal

Information from you when you use the App unless you provide us with the Personal

Information voluntarily. Personal Information includes any data that identifies, relates

to, or could reasonably be linked to an individual, directly or indirectly.

(b) Third-party Log In. If you sign in through ID.me, you are authorizing us to collect,

store, and use, in accordance with this Privacy Policy, any and all information that you

agreed that ID.me would provide to us through ID.me’s Application Programming

Interface (“API”). Such information may include, without limitation, your first and last

name, username, unique identifier, access token, or email address.

your location. In order to provide these features and functionalities while you are using

your mobile device, we may, with your consent, automatically collect Geolocational

Information from your mobile device or wireless carrier and/or certain third-party

service providers (collectively, “Geolocational Information”). Collection of such

Geolocational Information occurs only when the App is running on your device. You

may decline to allow us to collect such Geolocational Information, in which case we

will not be able to provide certain features or functionalities to you.

Student Shield Privacy Policy v.1.0

(d) Third-Party Analytics. We may use third-party technology providers (e.g., Google

Analytics) to evaluate your use of the App, compile reports on activity, collect

demographic data, analyze performance metrics, and collect and evaluate other

information relating to the App and mobile and Internet usage. These third parties use

cookies and other technologies to help analyze and provide us the data. You consent to

the processing of data about you by these analytics providers in the manner and for the

purposes set out in this Privacy Policy.

(e) Other Information. In addition to the Personal Information and Geolocational

Information, we may automatically collect or receive additional information regarding

you and your use of the App; your interactions with us and information regarding your

computer and mobile devices used to access the App (collectively, the “Other

Information”). Such Other Information may include, without limitation:

(i) From You. Additional information about yourself that you voluntarily provide to

us, such as alert posts or your service preferences.

(ii) From Your Activity. We may collect or receive information regarding:

(A) IP address, which may consist of a static or dynamic IP address and will

sometimes point to a specific identifiable computer or mobile device;

(B) Date and time; and

performance and usage data.

(iii) About Your Mobile Device. We may collect or receive information regarding:

(A) Type of mobile device;

(B) Operating system and version (e.g., iOS, Android, or Windows);

(D) Network type (Wi-Fi, 4G, 5G, LTE).

(iv) From Cookies. We may use both session cookies, which expire once you close the

App, and persistent cookies, which stay on your mobile device until you delete

them and other technologies to help us collect data and to enhance your

experience with the App. Cookies are small text files an app can use to recognize

a repeat visitor to the app. We may use cookies for various purposes, including to:

(A) Type of mobile device;

(B) Personalize your experience;

(D) Measure and optimize the platform’s performance.

If you do not want us to deploy cookies in the App, you can opt out by setting

your mobile device to reject cookies. You can still use the App if you choose to

disable cookies, although your ability to use some of the features may be affected.

Student Shield Privacy Policy v.1.0

2. Information Provided and Administered by Educators. We provide the App exclusively

to and act as a service provider for educational institutions, including but not limited to high

schools, school districts, and boards of education (collectively, the “Educators”) to enable

emergency push notifications to their teachers, students, parents/guardians, responders, and

other relevant stakeholders. A designated administrator for an Educator is confirmed and

assigned via ID.me and is responsible for the student-related Information used with our App

platform. Student accounts and Information will be managed and coordinated by the

Educator and its Administrator; Student Shield has no control or oversight regarding the

Educator’s policies. Educators are acting on behalf of parents/guardians and students to give

Student Shield permission to collect Information described in this Privacy Policy.

As initial information about students is provided from the Educator’s records and may

include unique identifiers that link these records to other records in the Educator’s database.

This may also provide personal information about a student. We are not responsible for the

Educator’s data management or privacy practices.

3. How Information is Used and Shared.

(a) You authorize us to use the Personal Information, Geolocational Information, and the

Other Information (collectively, the “Information”) to:

(i) Provide and improve our App;

(ii) Provide our services;

(iii) Administer promotional programs;

(iv) Solicit your feedback; and

(v) Inform you about our products and services.

(b) We engage third-party companies and individuals to perform functions on our behalf.

Examples may include providing technical assistance, customer service and

administration of the application platform’s services. These other companies will have

access to the Information only as necessary to perform their functions and to the extent

permitted by law.

This Privacy Policy does not address, nor are we responsible for, the privacy practices

of any third party operating any site or service linked to Student Shield. Inclusions of a

third-party name and/or link is in no way an endorsement. Student Shield is not

responsible for the collection, usage, security, retention and disclosure policies and

practices of other organizations.

services, we may analyze certain Information in anonymized and aggregate form to

operate, maintain, manage, and improve the App and/or such products and services.

This aggregate information does not identify you personally. We may share and/or

license this aggregate data to our affiliates, agents, business, and promotional partners,

and other third parties. We may also disclose aggregated user statistics to describe the

App and these products and services to current and prospective business partners and

investors and to other third parties for other lawful purposes. In this Privacy Policy, we

Student Shield Privacy Policy v.1.0

refer to such data as “Anonymized Data” and do not consider it to be Personal

Information.

(d) As we develop our businesses, we might sell or buy businesses or assets. In the event

of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event,

the Information may be part of the transferred assets.

(e) To the extent permitted by law, we may also disclose the Information:

(i) When required by law, court order, or other government or law enforcement

authority or regulatory agency; or

(ii) Whenever we believe that disclosing such Information is necessary or advisable,

for example, to protect the rights, property, or safety of us or others, including

you.

4. Accessing and Modifying Information and Communication Preferences. If you have

provided us any Personal Information, you may access, remove, review, and/or make changes

to the same by contacting us as set forth below. We will use commercially reasonable efforts

to process such requests in a timely manner. You should be aware, however, that it is not

always possible to completely remove or modify information in our databases. You cannot

opt out of receiving transactional emails related to the App (e.g., requests for support).

We may also deliver notifications to your mobile device (e.g., push notifications). You can

disable these notifications by deleting the relevant service or by changing the settings on your

mobile device.

5. How We Protect Your Information. We take commercially reasonable steps to protect the

Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

We cannot guarantee the security of our databases or the databases of the third parties with

which we may share such Information, nor can we guarantee that the Information you supply

will not be intercepted while being transmitted over the Internet. In particular, email sent to

us may not be secure, and you should therefore take special care in deciding what

information you send to us via email.

We will retain Personal Information for the period necessary to fulfill the purposes outlined

in this Privacy Policy unless required by law. Upon expiration of that retention period, we

will securely delete and destroy the Personal Information in a commercially reasonable

manner.

Third party usage, including Educators, of the App may involve Information wholly owned,

administered, and managed by the third party. In those instances, Student Shield is not

responsible for the loss, misuse, and unauthorized access, disclosure, alteration, or

destruction of Information caused by the actions of the third party in its use of the App.

Student Shield Privacy Policy v.1.0

6. App Stores; External Websites. Your app store (e.g., iTunes or Google Play) may collect

certain information in connection with your use of the App, such as Personal Information,

Payment Information, Geolocational Information, and other usage-based data. We have no

control over the collection of such information by a third-party app store, and any such

collection or use will be subject to that third party’s applicable privacy policies.

The App may contain links to third-party websites. We have no control over the privacy

practices or the content of these websites. As such, we are not responsible for the content or

the privacy policies of those third-party websites. You should check the applicable third-

Party Privacy Policy and Terms of Use when visiting any other websites.

7. Students. As Student Shield utilizes information provided by Educators from student

records, it will be protected as required by the Family Educational Rights and Privacy Act

("FERPA") and applicable state laws regarding the privacy of student records or personally

identifiable information (“PII”). We will only disclose education records or provide access in

compliance with FERPA and applicable state laws, and we will require third parties that

contract with us and have access to education records to do the same. Student Shield will not

use PII to target a student for advertising, sell PII or use PII to create profiles about a student

(other than for purposes of the student’s education in a school) when those activities are

prohibited by law. Student Shield will not use, or will seek permission to use, a student’s PII

for purposes unrelated to providing emergency push notifications where required by law to

do so. If any provision of this Privacy Policy conflicts with FERPA or other federal or state

law, Student Shield will comply with the more protective standard for the education records.

8. Children. The App is not directed to children under the age of 13. We adhere to the

Children’s Online Privacy Protection Act (COPPA) and will not knowingly collect Personal

Information from any child under the age of 13. We ask that minors (under the age of 13) not

use the App. If a child under the age of 13 has provided us with Personal Information, a

parent or guardian of that child may contact us and request that such information be deleted

from our records.

9. Legal Basis. We collect and process Personal Information on the legal basis of explicit

consent as outlined in our Privacy Policy, which is necessary to provide you with our

Services, and where applicable, to comply with relevant legal and contractual obligations.

10. Changes to This Privacy Policy. This Privacy Policy is effective as of the date stated at the

top of this Privacy Policy. We may change this Privacy Policy from time to time. Any such

changes will be posted on the App. By accessing the App after we make any such changes to

this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to

the extent permitted by applicable law, our use of the Information is governed by the Privacy

Policy in effect at the time we collect the Information. Please refer back to this Privacy

Policy on a regular basis.

Student Shield Privacy Policy v.1.0

11. How to Contact Us. If you have questions about this Privacy Policy, please email us at

support@studentshieldalerts.com with “Privacy Policy” in the subject line or mail us at the

following address:

Student Shield LLC

Attn: Privacy Policy

1309 Coffeen Avenue, Ste 1200

Sheridan, WY 82801