COPYRIGHT 2018, FULL MEASURE EDUCATION FME PRIVACY POLICY

The following privacy policy applies to personal data collected at www.fullmeasureed.com and data collected through the provision of Full Measure Education products or services (collectively, the “Services”). Full Measure Education Inc. and its affiliates (collectively “Full Measure Education”) are committed to protecting the privacy of its users. Because Full Measure Education gathers certain types of information about the users of the Services, we believe you should fully understand the terms and conditions surrounding the use of the information we collect. The following discloses our information gathering and dissemination practices for the Services. If you are using any of the Services through an educational or other institution that is a customer of Full Measure Education, this policy does not supersede the terms of any agreements between Full Measure Education and any other party, nor does it affect the terms of any agreement between any user of the Services, their educational institution or any third party. Please make sure that you read the terms of any privacy policies that you enter into with parties other than Full Measure Education, including your educational institution, as those policies may also explain how your personal information is used by them. Please review the following statement to understand how the information you provide to Full Measure Education through the Services will be treated.

1. Information Full Measure Education collects

When you register to use the service, we will request certain personal information, including, but not limited to, contact information, such as your name, city and state, and e-­mail address as well as demographic information such as your age, gender and interests. This information better enables us to provide you with content relevant to your interests and provides us with aggregate data that Full Measure Education uses to improve the Services. We may also ask you for information about your system or how you use Full Measure Education products and services, and we will collect information through your use of the Service, including your actions taken on the Service and your communications with others through the Service. Please see Section 5, below, for information on how to access or update this information and see Section 7 for information on how we collect and use Student Data. Full Measure Education gathers information about all users collectively, such as what areas users visit most frequently and what services users access most often. Full Measure Education automatically logs IP addresses, session sources, and other data which tracks users’ access to the Services. We analyze these logs for sales and marketing purposes as well as system performance monitoring. These logs are analyzed for the aggregate trends they reveal about our customers and how the customers use the Services. We may also collect analytics data to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. These tools collect information sent by your browser or mobile device that assists us in analyzing and improving the Services.. When you access our Services by or through a mobile device, we may receive or collect and store unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google Ad ID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device.

2. Purposes of data collection

Full Measure Education requests information to operate, maintain and provide to you the features and functionality of the Services and to communicate directly with you, as well as for purposes such as the provision of customer service and support, billing, network management, customer surveys, sales management, support, newsletter subscriptions, user group memberships, registration and sponsorship, offers of related services, and other exchanges of information.

3. What Full Measure Education does with the information it collects

Full Measure Education may make forums, message boards, and/or news groups available in certain areas of the Services. Please remember that any information that is disclosed in these areas becomes public information, and you should exercise caution when deciding to disclose your personal information. The personal information you supply to Full Measure Education will not be given, sold, rented, loaned, or otherwise disclosed to any third parties outside of Full Measure Education and its agents, except when we have your permission or under special circumstances, such as when we believe in good faith that disclosure is reasonably necessary to (i) comply with legal process, (ii) enforce the Terms of Use, (iii) respond to claims that any content provided by using the Services violates the rights of third parties, or (iv) protect the rights, property, or personal safety of Full Measure Education, its users, or the public. Full Measure Education may use aggregated personal information to determine the demographic composition of our user base and to distribute statistics and general marketplace information about Full Measure Education. This aggregate information does not identify specific users. Certain non­personal information regarding users is recorded by the standard operation of the Internet servers hosting the Services. This information is primarily used to provide users of the Services with an enhanced online experience. Full Measure Education may disclose aggregated user statistics in order to describe the Services to prospective partners and for other lawful purposes. Also, please be aware that advertisers or Web sites that are linked to the Services may collect personally identifiable information about you. The information practices of those Web sites linked to the Services are not covered by this Privacy Policy and Full Measure Education is not responsible for the privacy practices or the content of such Web sites. Full Measure Education may share personal information other than Student Data, as defined below, with other parties in connection with any company transaction, such as a merger, sale of all or a portion of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy or related or similar proceedings. Full Measure Education’s transfer of Student Data to a third party in the event of a company transaction is governed by our agreements with our educational institutions and applicable law.

4. User options — opt­‐out

Individual end users of Full Measure Education software should contact their educational institution for questions about access to the personal information collected by that institution.

5. Access to your information

Full Measure Education offers users the ability to correct or change the information collected during registration. Users may change this information at any time and as often as necessary by choosing the “edit personal information” option or other similar functionality offered in the Services. To access or change your personal information, log in to your account through the Services. For data not available through such an account, please contact us at the address listed below.

6. Security

Full Measure Education maintains reasonable administrative, technical and physical procedures to protect information stored in our servers, which are located in the United States. Security safeguards may include but are not limited to data encryption, firewalls, data use and access limitations, and physical access controls to buildings.

7. Student data collected during the course of providing services to educational institutions

Full Measure Education provides Services to schools and other educational institutions to improve student learning outcomes. Through the provision of these Services, Full Measure Education collects personally identifiable information from or about students (“Student Data”). We consider such Student Data to be strictly confidential and do not use such data for any purpose other than improving and providing our Services to the school or on the school’s behalf. Our collection, use and sharing of Student Data is governed by our contracts with the educational institutions, in the U.S. by the provisions of the Family Educational Rights and Privacy Act (FERPA) and applicable state laws, and by other state, federal, and international laws as applicable, but not by the provisions contained in this Privacy Policy. If you have any questions about reviewing, modifying, or deleting personal information of a student, please contact your educational institution directly.

8. Children’s privacy

Full Measure Education does not knowingly collect any information from children under the age of 13 unless and until a school or educational institution has provided appropriate consent and authorization for a student under 13 to use the Services and for Full Measure Education to collect information from such student.

9. Full Measure Education privacy policy statement changes

If Full Measure Education changes this privacy statement, we will post those changes so that you will always know what information we gather, how we might use that information, and whether we will disclose it to anyone. By using the Services, you signify your assent to the Full Measure Education Privacy Policy. If you do not agree to this policy, please do not use the Services. Your continued use of the Services following the posting of changes to these terms will mean you accept those changes. Notwithstanding the foregoing, however, with respect to Student Data, as discussed in Section 7, above, our data privacy practices are governed by our agreements with educational institutions and applicable law. Accordingly, any changes in our data handling practices involving Student Data would have to be in accordance with our agreements with educational institutions and applicable law.

10. GDPR

FME Takes Privacy Seriously.  The EU General Data Protection Regulation (GDPR) is the most significant piece of European privacy legislation in two decades. It replaces the 1995 EU Data Protection Directive (European Directive 95/46/EC), strengthening the rights that EU individuals have over their data, and creating a uniform data protection law across Europe.  The FME cloud platform is committed to compliance with applicable GDPR regulations as a data processor. We are fully committed to enable, and assist in any way, our clients, the data controllers, with complete control of their private data, in order for them to meet their GDPR obligations. Full Measure Education’s full statement of compliance with GDPR can be seen here.

11. Contact Full Measure Education

If you have any questions about this privacy policy, the information that we collect from you, or the Services, please contact us at legal@fullmeasureed.com or write to:

Legal Department

Full Measure Education Inc. 1111 19th Street, N.W.

Suite 1120

Washington, D.C 20036

In the event that you are concerned about how data you have provided Full Measure Education through the Services has been used, please contact us at one of the addresses listed above. Full Measure Education takes all concerns about privacy and use of data seriously, and shall endeavor to reply to you within five business days to commence its investigation of your concerns. This policy was updated in May, 2018.