Seesaw Indirect Collection Notice

Seesaw Indirect Collection Notice Last Updated: January 18, 2024 Seesaw Learning, Inc ("Seesaw", "we", "us" or "our") collects personal information from lead generation partners and publicly available sources to identify and contact prospective customers.

If you have received an email from Seesaw that links to this notice, we have collected information that identifies or is associated with you (your "personal information"). This notice explains how we use that personal information and your rights with respect to that information.

Please note this Indirect Collection Notice (the "Notice") only describes how we use the personal information we collect from lead generation and publicly available sources, as described further below. If you are in Australia or New Zealand, your personal information will only be collected from publicly available sources or from sources where you have agreed for your information to be collected and used for electronic and other direct marketing to you by entities such as us. It does not cover how we collect and use personal information in other contexts, including from visitors to our website. For more information on how we collect and use personal information in other contexts, please visit our Privacy Policy.

Who is responsible for your personal information Seesaw is the controller (i.e. collector) of the personal information collected as described in this Notice, which means that we determine and are responsible for how your personal information is used.

If you have any questions about how we use your personal information, or if you would like to opt out of receiving any further communication from us, please email us at privacy@seesaw.me or use the “unsubscribe” link contained at the bottom of our email to you.

What personal information do we collect We collect the following personal information: ●

Identifiers, including your name and email address;

●

Professional and employment information, including the name and address of the organization or department you work at and your role at that organization.

How we obtain personal information We collect personal information from our lead generation partners, including A-ZGovBIZ, Sprint Education, and ISC Research (our “Partners”). Our Partners may supplement such information from publicly available sources like Zoominfo, LinkedIn and other social media channels. Our Partners may combine information from several sources, which means that we are not always able to identify the exact source of your personal information.

If you are in Australia or New Zealand, your personal information will only be collected from publicly available sources or from sources where you have agreed for your information to be collected and used for electronic and other direct marketing to you by entities such as us. If you would like to know more about where we obtained your personal information, please contact us by email at privacy@seesaw.me.

431381 13981760.3

1

How we use your personal information We use the personal information we collect to tailor and send you promotional email messages about our products and services.

If you or someone else at the organisation where you work signs up for our services, we will also use your personal information to help us measure the effectiveness of our promotional campaigns.

If you would like to opt out of receiving any further communication from us, please email us at privacy@seesaw.me or use the “unsubscribe” link contained at the bottom of our email to you.

How long we keep your personal information We will normally keep your personal information for the duration of the promotional email campaign that we collected it for, and for two years after that.

How we share your personal information We may disclose your personal information to our service providers, such as data hosting and email distribution providers, who will use the information on our instructions. They may also aggregate and anonymize your information to analyze the performance of and improve their products.

If we sell our business or company, we may share your personal information with the buyer as part of the purchase or takeover process.

If we are required to do so by a court order or in connection with a legal claim or complaint, we may also share your personal information with law enforcement and our professional legal advisors.

Lawful basis If you are in the EEA or UK, the lawful basis we rely on for processing your personal information as described in this notice is that processing is necessary for our legitimate interests, namely the promotion of our products and services and measurement of the effectiveness of our promotional campaigns.

International transfers The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations.

Your personal information will be transferred to recipients in the United States as listed above in the section headed "How we share your personal information". These transfers are made subject to appropriate safeguards to ensure that your personal information is treated in the same way as it would have been in your jurisdiction.

If you are in the EEA or the UK, we ensure that any such transfers of personal information are made to recipients (including Seesaw affiliates) certified under the EU-U.S. Data Privacy Framework or otherwise subject to standard contractual clauses adopted by the European Commission, as approved and adapted for use for transfers of personal information subject to UK data protection laws where applicable.

If you wish to enquire further about the safeguards used, please contact us by email at privacy@seesaw.me.

431381 13981760.3

2

Your Rights In accordance with applicable privacy law, and depending upon the jurisdiction in which you reside, you may have some or all of the following rights in respect of your personal information.

If you are in the EEA or the UK: ●

Right of access. You may have the right to obtain: o

confirmation of whether, and where, we are processing your personal information;

o

information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;

o

information about the categories of recipients with whom we may share your personal information; and

o

a copy of the personal information we hold about you.

●

Right of portability. You may have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.

●

Right to rectification or correction. You may have the right to obtain rectification or correction of any inaccurate or incomplete personal information we hold about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

●

Right to deletion or erasure. You may have the right, in some circumstances, to require us to delete or erase your personal information.

●

Right to restriction. You may have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

●

Right to object. You may have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

If you are in Australia: ●

Right of access. You have the right to access personal information we hold about you.

●

Right to rectification or correction and notification to third parties. You have the right to request the correction of personal information we hold about you. You also have the right to have any correction notified to third parties to whom we have provided your personal information.

●

Right to object. You have the right to object to receiving marketing, and to the disclosure or use of your personal information for marketing.

If you are in New Zealand: 431381 13981760.3

3

●

Right of access. You have the right to obtain confirmation as to whether (or not) we hold information about you, and access to such personal information, where it may be readily retrieved.

●

Right to rectification or correction. You have the right to request the correction of personal information we hold about you.

●

Right to opt-out. You have the right to opt-out of marketing. You can contact us to do so or use the unsubscribe mechanism included in each electronic direct marketing message we send to you.

How to exercise your rights If you would like to exercise any of the above rights, please email us at privacy@seesaw.me.

We may ask you to verify your identity before we process your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request personal information from you, such as your name, email address, and/or phone number. We may decline a request to exercise the above rights if we are unable to confirm your identity. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

Complaints You can contact Seesaw in the first instance at privacy@seesaw.me.

You also have the right to lodge a complaint to your local data protection authority: ●

If you are in the EU, information about how to contact your local data protection authority is available here.

●

If you are in the UK, your local data protection authorities are the UK Information Commissioner's Office.

●

If you are in Australia or New Zealand, your local data protection authorities are the Office of the Australian Information Commissioner (for Australia) and the Office of the Privacy Commissioner (for New Zealand).

Updates to this Notice We may update this Notice from time to time. When we make changes to this Notice, we will change the date at the beginning of this Notice and notify individuals by email and by prominent posting on our website, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

431381 13981760.3

4