Statement of Compliance

Site License Services

Strivven Media LLC (“Pathful”) is a wholly owned subsidiary of Pathful, Inc. (“Pathful”). Some or all of the Services (as defined below) may be provided by Pathful or Pathful, and in the case they are provided by Pathful, all references to Pathful/Service Provider shall be deemed to include Pathful. Any product references to VirtualJobShadow.com or VJS Junior may be replaced with the updated product names of Pathful Explore and Pathful Junior respectively.

Nepris Inc. (“Nepris”) is also a wholly owned subsidiary of Pathful, Inc. The Privacy Policy and Terms of Service for Nepris are defined separately. Pathful Connect (a service of Nepris), provides software as a service to work alongside services provided by Pathful Media LLC.

This statement is provided by Pathful Media LLC, a North Carolina limited liability company having a mailing address of 750 N Saint Paul St Ste 250 PMB 63880 Dallas, Texas 75201-3206, and an email address of info@Pathful.com, (“Pathful”) in accordance with the requirements of various state and federal laws. The statement is intended to serve both as notice to users of Pathful’s services as well as an addendum to Pathful’s agreements with educational institutions.

I. COPPA

Pathful has reviewed and confirms that its operations and provision of services comply with the U.S. Children’s Online Privacy Protection Act (COPPA). This confirmation of compliance is based on Pathful’s observance of applicable Federal Trade Commission (FTC) operating guidance and interpretation of COPPA’s applicability to vendors with particular reference to the following: https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions (March 2015 revision).

Pathful has posted a clear and comprehensive online privacy policy describing its information practices for personal information collected online from children. This privacy policy is available here: http://www.virtualjobshadow.com/resources/policy/
Pathful does not solicit information from or market products or services to children under 13 through its website or otherwise. To the extent which Pathful’s services cause Pathful to obtain personal information from children, these services are provided in connection with an educational institution which is responsible for providing notice to parents before contracting with Pathful.
Pathful does not share student’s personal information with third parties except as required to deliver its services to students in accordance with its agreements with educational institutions.
To the extent which Pathful has obtained a student’s personal information, the student’s parent, legal guardian, or the eligible student may review and correct the student’s personally identifiable information in the student’s record by logging into Pathful’s platform using the student’s login credentials, which may be provided by the student or administrators associated with the educational agency. Pathful certifies that a student’s records shall not be retained or available to Pathful upon termination of the relationship with the associated educational institution. At that time, all associated student data will be deleted by Pathful.
Pathful maintains the confidentiality, security, and integrity of information it collects from children, including by taking reasonable steps to release such information only to parties capable of maintaining its confidentiality and security and employing of physical, administrative, and technical safeguards based on currently available technology and industry best practices.
Pathful retains personal information collected online from a child for only as long as is necessary to fulfill the purpose for which it was collected and deletes the information using reasonable measures to protect against its unauthorized access or use.

II. FERPA

A. Pathful is willing to enter a binding data sharing agreement with educational institutions. Pathful requires its employees, contractors, and consultants to comply with data privacy requirements through confidentiality agreements.
B. Pathful strictly limits its use of personally identifiable information to the minimum required to provide its services to eligible students through its agreements with educational institutions. Its use of such information is in a manner consistent with the privacy policy available here: http://app.pathful.com/resources/policy/
C. Pathful shares with educational institutions contact information for its Chief Technology Officer, who is responsible data management and maintenance. This contact information is also made available through Pathful’s website.
D. Pathful’s management team defines and maintains privacy and data protection policies.
E. The educational institutions with which Pathful has relationships retain ownership of any personally identifiable information shared with Pathful.
F. Pathful certifies that a student’s personally identifiable information shall not be retained or available to Pathful upon completion of its relationship with educational institutions. At that time, all student data will be deleted by Pathful.
G. Pathful acknowledges that the educational institutions with which it enters into agreements have the right to perform audits of Pathful’s data security practices. Pathful will reasonably cooperate in the conducting of any such audits.
H. Pathful works hard to ensure the security and confidentiality of student data. Pathful’s reasonable efforts include employment of physical, administrative, and technical safeguards based on currently available technology and industry best practices to promote the integrity and security of both its services and student records.
I. In the event of an unauthorized disclosure of student records as held by Pathful, Pathful will notify the affected students by contacting the local educational agency administrators by email with a detailed explanation of the breach and any steps needed or taken to provide a remedy. The local educational agency will then be prepared to disseminate this information to the affected parent, legal guardian, or eligible student.

III. CALIFORNIA AB 1584

Pathful has reviewed and confirms that its operations and provision of services comply with California Assembly Bill 1584, codified as California Education Code Section 49073.1. Specifically, with respect to any software services provided by Pathful through a contract with a local educational agency:

A. Pupil records continue to be the property of and under the control of the local educational agency.
B. Pupils are able to retain possession and control of their own pupil-generated content and transfer pupil-generated content to their personal accounts. Specifically, content generated by a pupil through Pathful’s services is created and edited in Pathful’s platform and may be exported as a Word or PDF document and saved to the pupil’s computing device.
C. Any information in pupil records will not be used by Pathful except for the exclusive purpose of providing Pathful’s services as described and authorized by contracts between Pathful and the local educational agency.
D. To the extent which Pathful has obtained a pupil’s personally identifiable information, the pupil’s parent, legal guardian, or the eligible pupil may review and correct the pupil’s personally identifiable information in the pupil’s record by logging into Pathful’s platform using the pupil’s login credentials, which may be provided by the pupil or administrators associated with the local educational agency.
E. Pathful works hard to ensure the security and confidentiality of pupil records. Pathful’s reasonable efforts include employment of physical, administrative, and technical safeguards based on currently available technology and industry best practices to promote the integrity and security of both its services and pupil records.
F. In the event of an unauthorized disclosure of a pupil’s records as held by Pathful, Strviven will notify the affected pupil by contacting the local educational agency administrators by email with a detailed explanation of the breach and any steps needed or taken to provide a remedy. The local educational agency will then be prepared to disseminate this information to the affected parent, legal guardian, or eligible pupil.
G. Pathful certifies that a pupil’s records shall not be retained or available to Pathful upon completion of the relationship with the local educational agency. At that time, all pupil data will be deleted by Pathful.

IV. CALIFORNIA SB 1177

Pathful has reviewed and confirms that its operations and provision of services comply with California Senate Bill 1177, codified as 8 Cal. Bus. & Prof. Code Sec. 22584 et seq. Specifically, with respect to any software services provided by Pathful through a contract with a local educational agency:

A. Pathful shall not knowingly engage in any of the following activities:
- Engage in targeted advertising through its services or target advertising on any other site, service, or application when the targeting of the advertising is based upon any information, including covered information and persistent unique identifiers, that Pathful has acquired because of a pupil’s use of Pathful’s services provided in connection with the local educational agency.
- Use information, including persistent unique identifiers, created or gathered through Pathful’s services to amass a profile about a K–12 student except in furtherance of K–12 school purposes.
- Sell a student’s information, including covered information. This prohibition does not apply to the purchase, merger, or other type of acquisition of Pathful by another entity, provided that Pathful or successor entity continues to be subject to the provisions of this section with respect to previously acquired student information.
- Disclose covered information unless the disclosure is made:
  - A. In furtherance of the K–12 purpose of Pathful’s services, provided the recipient of the covered information disclosed pursuant to this subparagraph:
    - i. Shall not further disclose the information unless done to allow or improve operability and functionality within that student’s classroom or school; and
    - ii. Is legally required to as described below;
  - B. To ensure legal and regulatory compliance;
  - C. To respond to or participate in judicial process;
  - D. To protect the safety of users or others or security of the site; Or
  - E. To a service provider, provided Pathful contractually:
    - i. prohibits the service provider from using any covered information for any purpose other than providing the contracted service to, or on behalf of, the operator,
    - ii. prohibits the service provider from disclosing any covered information provided by the operator with subsequent third parties, and
    - iii. requires the service provider to implement and maintain reasonable security procedures and practices as provided below.
B. Pathful shall:
- Implement and maintain reasonable security procedures and practices appropriate to the nature of the covered information, and protect that information from unauthorized access, destruction, use, modification, or disclosure.
- Delete a student’s covered information if the school or district requests deletion of data under the control of the school or district.
C. Notwithstanding section A(4) above, it is acknowledged that Pathful may disclose covered information of a student, as long as sections A(1-3) are not violated, under the following circumstances:
- If other provisions of federal or state law require Pathful to disclose the information and Pathful complies with the requirements of federal and state law in protecting and disclosing that information.
- For legitimate research purposes:
  - as required by state or federal law and subject to the restrictions under applicable state and federal law or
  - as allowed by state or federal law and under the direction of a school, school district, or state department of education, if no covered information is used for any purpose in furtherance of advertising or to amass a profile on the student for purposes other than K–12 school purposes.
- To a state or local educational agency, including schools and school districts, for K–12 school purposes, as permitted by state or federal law.
D. Pathful is not prohibited from using deidentified student covered information as follows:
- Within Pathful’s site, service, or application or other sites, services, or applications owned by Pathful to improve educational products.
- To demonstrate the effectiveness of Pathful’s products or services, including in its marketing.
- In aggregated form for the development and improvement of educational sites, services, or applications.

V. CALIFORNIA AB 1442

Pathful has reviewed and confirms that its operations and provision of services comply with California Assembly Bill 1442, codified as California Education Code Section 49073.6, in its entirety. This bill is not applicable to Pathful’s services generally or its relationship with any educational institution since Pathful does not collect student information through social media and has not been asked to perform such a service by an educational institution.