Echo Array Learning LLC ("Echo Array Learning", "us", "we", or "our") cares about privacy and data security. This Privacy Policy describes the collection, use, and disclosure of personal information collected from the use of the online services, websites and web applications, and software provided on or in connection with www.echoarray.com (collectively, the "Service"). The Policy also tells you about your privacy rights and how applicable laws protect you.

Echo Array Learning is committed to improving students' learning experience and progress. We use personal information to provide and improve the Service. "You" (or "your") means the individual who is accessing or using the Service, or the parent or legal guardian whose child is accessing or using the Service. Your use of the Service is conditioned on your acceptance of this Policy, whether or not you are a registered user of the Service.

1. What Information Do We Collect?

Information You Provide to Us for Creating an Account To access or use the Service, you provide us with certain personally identifiable information (or "Personal Information") for creating an account. Personal information, which can be used to contact or identify you, may include but is not limited to your e-mail address, username and password ("Registration Data"). Usernames are moderated with the aim of preventing you from using any personal information to create an account. Additionally, passwords are encrypted.

When you sign up an individual account, you represent and warrant that you are at least 18 years old. If you are a parent or legal guardian and create a family account to provide the Service to your child, you must ensure that your child is at least 13 years of age, and you are required to use your email address and a username that cannot be used to identify personal information of your child. Echo Array Learning does not collect personal information about your child. Your child's email address may contain school name or other personal identifiable information.

In accordance with the U.S. Children’s Online Privacy Protection Act, Echo Array Learning does not permit children under the age of 13 to create an account, and thus does not knowingly accept, request, or collect personal information from children under 13 years of age. Please contact us at help@echoarray.com if you believe we have inadvertently collected information from a child under 13 years old so that we may delete the information as soon as possible.

In addition, we may also collect your personal information at other times, such as when you submit questions, request information, or give us feedback or suggestion via email, "Contact Us", or by phone, we may ask your name, postal address, phone number, and email address so we can respond or follow up.

Learning and Activity Information During the course of your use of the Service, we may collect information such as the arrays of items you submit through the user interface for computing and graphing as well as your answers to questions provided in the Service ("Learning Data"). We use the information to evaluate your learning effectiveness, study relations between usage pattern and learning progress, and develop new educational and learning services and products. Please note that your Learning Data will not be shared with other users, visitors, or general public. Echo Array Learning does not use or disclose Learning Data for targeted advertising purposes.

Information We Receive Automatically from Your Use of Our Service Like most websites and online services, we may use cookies and similar tracking technologies to automatically collect certain types of usage information about your computer or device when using the Service or visiting echoarray.com. Usage information may include but is not limited to: (1) your Internet Protocol (IP) address, Internet service provider, and information about the browser or type of device you are using; (2) the date and time of your visit, how frequently you access the Service, the pages you view, the links you click, the time you spent on those pages, and other diagnostic data; (3) your zip code and other rough information about your location (e.g., city).

We may use the data collected through tracking technologies to secure and improve our Service, to provide better technical support, and to track the website usage that can help website optimization and marketing.

A cookie is a small file (or blocks of data) a website or web server places on user's computer or other access device by the user’s web browser. Cookies contain the details of your browsing history on that website. We may use cookies to track your browsing activity (including clicking particular buttons, logging in, or recording which pages were visited in the past).

You can set your browser to refuse all cookies or to tell when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our Service. We may use similar tracking technologies (e.g., web beacons, tags, and scripts) to track user activity on the Service.

We may use web beacons (a small image file) on our websites or emails to track the online behaviors of our users, for example, to check whether a user has accessed certain content, count users who have visited those pages, or opened an email.

We may allow third parties to use their own cookies, web beacons, and similar technologies to collect information through the Service to help us with traffic or usage analytics and research. We permit these third parties only to collect cookie information and similar identifiers (non-personal or anonymous information) that cannot directly identify you or your child, as applicable.

2. Use of Your Personal Data

We may use the information we collect for the following purposes:

To Provide and Maintain Our Service We use the information we collect to manage your account and deliver the Service to you. As a registered user, your Registration Data you provide can give you access to different functionalities of the Service. We also need to use your personal information to provide you with support and to respond to inquiries, including to address your concerns and monitor our Service.

To Understand, Improve, and Develop the Service We may aggregate and summarize user information to better understand how users access to and use our Service, monitor the effectiveness of our Service, detect usage patterns, and to diagnose or fix technology problems. We also use the information to do research to support and improve our Service, and to develop new educational and learning products and services. In addition, we may use the information for other internal administrative and auditing purposes.

To Contact You We may use your information to contact you regarding certain activities relating to your use of our Service and any updates or informative communications related to the functionalities of the Service. We may also send e-mail notifications when a user completes an activity, or we may send periodic promotional or informational e-mails to you. However, we do not use Learning Data to send marketing communications.

Note that you may unsubscribe from a Echo Array Learning mailing list of certain communications (e.g., marketing or promotional notifications) at any time by clicking on the ‘unsubscribe’ link in any of such communications to you. After you unsubscribe from such a list, we will not send you further such communications, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.

For Internal Research Purpose We may aggregate user information in a way that does not directly identify you or other individual users. For example, we may use your information to perform statistical analysis, research on your learning progress, and develop new products and services. We may also use your information to monitor the usage of our Service, identify usage trends and learning patterns, determine the effectiveness of your learning experience, and evaluate our promotional campaigns.

To Promote Safety and Security We use information to promote the safety and security of our Service. For example, we may use the information to authenticate users, detect security incidents, protect against malicious, deceptive, fraudulent, illegal, or other harmful activities.

3. Retention of Your Personal Data

We will retain personal information for as long as is necessary to provide the Service to you and for our internal business purposes, which may extend beyond the expiration or termination of your subscription or user account, unless a longer retention period is required or permitted by law. We may retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We may also retain and use information which has been de-identified or aggregated such that it can no longer reasonably identify a particular individual. All retained personal information will remain subject to the terms of this Privacy Policy.

We may retain some usage data (non-personally identifiable or anonymous information) for internal analysis purposes, for example, to strengthen the security or to improve the functionality of our Service.

4. Transfer of Personal Data for International Users

Echo Array Learning's website or Service is hosted in the United States, and your information, including personal data, may be processed by people or transferred to and maintained on computers located in the United States. This means the laws governing the collection, use, and disclosure of personal information in your state, province, country or other governmental jurisdiction may be different from applicable laws in the United States. We make no representation that the Service is operated in accordance with the laws or regulations of any other nations. By accessing and using the Service and providing us with information directly or indirectly, you consent to the transfer of information to the United States in accordance with this Privacy Policy. Echo Array Learning will take all steps reasonably necessary to ensure that your data is processed securely and in accordance with this Policy.

5. Disclosures of Your Personal Data

Echo Array Learning may disclose your personal information as needed to provide our Service and for other purposes with your consent. When we disclose personal information for a business or commercial purpose, we enter a contract that describes the purpose and requires the recipients to keep personal information confidential and not use it for any other purpose except performing the contract. We may also share personal information in the circumstances described below.

Authorized Third-Party Vendors and Service Providers We may share information with our trusted third-party vendors and service providers to help us evaluate, develop and improve the Service, including performing usage analytics, targeted advertising, marketing, or data processing. However, Echo Array Learning will not knowingly use any Learning Data to target advertising or marketing.

Aggregate or De-Identified Information We may share information in an aggregated and/or anonymous form that cannot reasonably be used to identify an individual.

Business Transaction We may share information in connection with a substantial business transaction, such as the sale of the Service, a merger, consolidation, asset sale, or under the unlikely situation of bankruptcy. In such an event, we will make efforts to provide a notice before personal information is transferred and becomes subject to a different privacy policy.

Law Enforcement and Other Legal Requirements Under certain circumstances, Echo Array Learning may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

We may disclose your personal data in the good faith belief that such action is necessary to: (a) satisfy any applicable law, regulation, legal process, or enforceable governmental request; (b) prevent or investigate possible wrongdoing in connection with the Service; (c) detect, prevent or otherwise address fraud, security or technical issues; (d) protect and defend the rights, property or personal safety of Echo Array Learning, its users, or the public; or (e) as required or permitted by applicable laws.

6. Security of Your Personal Data

The security of your personal data is very important to us, and we constantly review our systems and data to ensure the best possible service to our users. However, no method of transmission over the Internet is 100% secure, or no security system is impenetrable. While we try our best to use sensible means to protect your personal data, we cannot guarantee its absolute security.

Security Procedures We have implemented reasonable technical, administrative, and physical procedures to preserve the integrity and security of all personal information we collect and to protect against unauthorized access to such data. These procedures include periodic reviews of our data collection, storage, backup process and procedures, and processing practices. We also restrict access to personal information to Echo Array Learning employees who are necessary to know such information in order to operate, develop, or improve our Service.

Account Security To protect your account and personal information, we also require you use a strong password and keep your password secure. For your protection, remember to sign out of all accounts before closing your browser. There is a sign out link on top of the website's navigation bar. After signing out, make sure to close all browser windows. Do not use the "Remember" feature if you are signing in to your account from a computer that other persons may have access to. This is to ensure that others cannot access your personal information. If you have any concerns about the security of your account or the security of our Service, please report your concern to us immediately at support@echoarray.com.

7. Third-Party Service Providers

We may use third-party service providers to collect, store, use, process and transfer information about your activity on our Service in accordance with their Privacy Policies. These service providers may have access to your personal data in connection with the Service we provide to you.

Email Marketing Echo Array Learning may send you e-mail regarding our products and services, or your use of our products and services. Only Echo Array Learning, or its vendors or service providers operating on our behalf, will send you these e-mails. You can choose not to receive these e-mails by clicking the unsubscribe link in any e-mail or by contacting help@echoarray.com. Please note that you are not permitted to unsubscribe or opt-out of non-promotional messages regarding your account, such as account verification, changes or updates to features of the Service, or technical or security notices.

8. Region-Specific Disclosures

The Service is designed for and targeted to United States customers, and is governed by and operated in accordance with the laws of the United States. If you access and use our Service from the European Union, Asia, or any other region of the world where the laws and requirements governing personal data collection, use, or disclosure may be different from applicable laws in the United States, then through your continued use of the Service, you are transferring your data to the United States, and you expressly consent to have your data transferred to and processed in the United States.

CCPA Privacy and Your Rights Under the CCPA

If you are a resident of the state of California, the term "personal information" has the meaning provided by the California Consumer Privacy Act (the "CCPA"), and you are entitled to certain rights with respect to personal information that we have collected under the CCPA.

You Rights Under the CCPA The CCPA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights.

• Right to Know The right to know which categories of personal information we have collected, the categories of data sources, and the purposes for which the personal information is being used.
• Right to Request Deletion The right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
• Right to Opt Out of Personal Information Sales The right to direct us not to sell (as such term is defined by the CCPA) your personal information we have collected about you to third parties. To submit an opt-out request please contact us via email help@echoarray.com.

Exercising Your CCPA Data Protection Rights In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact us via email help@echoarray.com, and provide us with sufficient information that allows us to verify your identity before processing your request. You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you the Service or engage with you in the same manner. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our system, or as permitted by applicable laws.

Do Not Sell Personal Information We do not "sell" personal information to third parties without your consent. You have the right to opt-out of the sale of your personal information. Once we receive and confirm a verifiable request from you, we will stop selling your personal information. However, our third party service providers or partners (e.g., analytics) may use cookies and related technologies to collect your personal information directly from your browser or device, and they may use or sell such information in accordance with their own privacy statements. You can visit www.privacyrights.info to opt out from sales of this type of personal information by some or all of the participating businesses. Please note that any opt out is specific to the browser you use. You may need to opt out on every browser you use.

Minors Under 16 Years of Age We do not knowingly collect personal information of a child under the age of 13. We do not sell the personal information of consumers we actually know to be less than 16 years of age, unless we receive affirmative authorization (the "Right to Opt In") from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.

9. Links to Other Websites and Services

Our Service may contain links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and practices, which are not covered by this Privacy Policy. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We have no control over and assume no responsibility for the content, privacy practices or practices of any third party websites and services. In particular, we encourage parents or legal guardians to monitor your children's Internet usage and instruct them not to provide information on other websites without your permission.

10. Changes to This Privacy Policy

Echo Array Learning may, in its sole discretion, modify or update this Policy from time to time, which will be reflected in the 'Last Updated' date set forth at the beginning of this Policy. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Policy regularly to stay informed about our most current policies and practices.

Non-material changes will be effective immediately upon posting. If we change this Policy in a material manner, we will do our best to notify you of the changes by posting a notice on our website or via email, so you have the opportunity to review the revised policy before you choose to continue using our Service. Your continued use of the Services following the effective date of change constitutes your acceptance of the revised Policy. If you do not agree to any terms in this Policy or to any terms in a future revision of this Policy, do not use or access the Service.

11. Contact Us

If you have any question regarding this Policy statement, you may contact Echo Array Learning LLC, 800 Denow Road, #392 Suite C, Pennington, New Jersey 08534, or email us via help@echoarray.com.

Effective Date: October 28, 2021