California AB-1584 Compliance Statement

This Statement describes the policies and procedures employed by Suntex International Inc./First In Math to ensure compliance with the requirements set forth in Section 49073.1 of the California Education Code (the “Code”). For the purposes of this Statement, “System” shall mean the bundle of services provided by Suntex International Inc./First In Math via its websites and/or mobile applications, and “Authorized User” shall mean any employee of a School District that is authorized to access and utilize the System regarding such employment.

Ownership of Pupil Records
All Pupil Records provided to Suntex International Inc./First In Math, or to which Suntex International Inc./First In Math has been granted access, are and shall remain the sole property of the School District or educational agency (collectively, “School District”) that provided or granted access to such records.

Pupil-Generated Content
The Suntex International Inc./First In Math system does not collect or store any Pupil-Generated content. In the event the System is updated to incorporate such a feature, Suntex International Inc./First In Math shall amend this Statement to describe how pupils may retain possession and control of pupil-generated content.

Third Party Access and Use
Suntex International Inc./First In Math prohibits all third parties from accessing or utilizing any Pupil Record for any purpose other than those required by or permitted by the contract for First In Math’s services.

Parent and Pupil Review Procedures
The System enables any Authorized User to permit parents, legal guardians, and eligible pupils to review personally identifiable information contained in Pupil Records, and to correct erroneous information, in accordance with procedures established by the School District.

Security and Confidentiality of Pupil Records
Suntex International Inc./First In Math is committed to maintaining the security and confidentiality of Pupil Records. It has designated a Data Protection Officer (DPO), who is responsible for: (a) ensuring that Suntex International Inc./First In Math servers are protected against unauthorized access to the greatest degree possible; (b) limiting employee access to Pupil Records to whatever extent is required for them to perform their job functions; and (c) training employees in data security procedures to further ensure compliance with company data security policies.

Unauthorized Disclosure
In the event any Pupil Records are inadvertently disclosed via outside data breach or for any other reason, the DPO shall notify the School District that owns such records immediately upon the discovery of such inadvertent disclosure. The School District may in turn utilize the System to notify affected parents, legal guardians, eligible pupils via posts within the System, emails, or in such other manner as the School District deems appropriate.

Post-Contract Data Deletion
Suntex International Inc./First In Math hereby certifies that, upon the termination of a service contract with a School District, it shall isolate and permanently delete all Pupil Records belonging to such School District that may remain on the System, unless the School District or applicable regulations require the retention of such data, in which case the records shall be deleted upon the expiration of the retention period. Prior to deleting any Data Records, Suntex International Inc./First In Math shall first ensure that the School District has downloaded backups of the same.

FERPA Compliance
Suntex International Inc./First In Math offers School Districts utilizing the System the means to comply with their obligations under the Federal Educational Rights and Privacy Act (20 USC §1232(g)), by enabling Authorized Users to inspect and review Pupil Records and to correct any inaccuracies therein as described in Section 4 of this Statement.

Prohibition Against Targeted Advertising
Suntex International Inc./First In Math strictly prohibits the use of any personally identifiable information included in a Pupil Record to direct targeted advertising for any product or service. In furtherance of this prohibition, Suntex International Inc./First In Math does not sell, trade, or rent any element of personally identifiable information to any third party.

Additional privacy information is included in the Suntex International Inc./First In Math online Privacy Policy.