PowerSchool Neverskip is committed to protecting the privacy of its customers/users of its platform, its employees, third-party consultants, vendors, service providers and suppliers. This Privacy Policy sets out how PowerSchool Neverskip may collect and use personal information from individuals in connection with your use of our platforms and any products or services that reference or otherwise are incorporated in this Privacy Policy (collectively “the Services”), or in connection with your employment with PowerSchool Neverskip or products or services that you provide to PowerSchool Neverskip (collectively “you”).

This Privacy Policy is published in compliance with inter alia:

• Section 43A of the Information Technology Act, 2000 (“IT Act”); and
• Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPDI Rules”).

Our Privacy Policy explains: (a) what personal information and sensitive personal data or information (“SPDI”) (for the purposes of this Privacy Policy, personal information and SPDI will be collectively termed as “Personal Information”) we receive from you; (b) how we collect and use that Personal Information; and (c) how we process, share and protect your Personal Information.

Please note that this Privacy Policy does not apply in the following circumstances:

1. Third-Party Sites: The Services may include links or references to websites, services or materials that are not controlled by us. This Privacy Policy does not apply to such third-party sites, which are subject to their own privacy notices.

• Existing Customers and Users: In some cases, we may access or use your Personal Information on behalf of your organization who is our customer. In such cases, we will treat your Personal Information as prescribed in the respective agreements between us and your organization, rather than as described in this Privacy Policy. Please reach out to your organization for more information or if you would like to exercise any of your data subject rights in connection with our use of your Personal Information.

PowerSchool Neverskip is committed to the following aspects on security of your Personal Information:

1. Categories of Personal Information collected from you.

We will only collect information about you in accordance with applicable law. The Personal Information we collect depends on the context of your interactions with us and the choices you make, including your own privacy settings and the specific services you use. Depending on your particular use, we may collect the following categories of information about you:

We collect the following Personal Information:

a. name;

b. postal address;

c. unique personal identifier, online identifier, internet protocol address

d. account name or other similar identifiers;

e. password;

f. physical, physiological and mental health condition;

g. sexual orientation;

h. medical records and history;

i. biometric information

j. email address; and

k. financial information such as bank account details.

Further, we may collect:

1. commercial information (such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
   1. internet or other electronic network activity information (e.g., browsing history, search history, operating system details, URI (Uniform Resource Identifier) addresses, the method utilized to submit the request to the server, the country of origin of the request, and information regarding a consumer’s interaction with an internet website, application, or advertisement (such as time spent on a particular page, details about the path followed within a Service);
   1. any other information that you communicate to us directly during your communications with us; and
   1. inferences drawn from the foregoing.

• We limit how, and with whom, we share your Personal Information.

PowerSchool Neverskip will only share your Personal Information with others for the following purposes:

1. at your request;
2. to process or service a transaction or product authorized or requested by you;
3. when required by law to disclose such information to appropriate authorities;
4. to such third parties that assist us in facilitating the transaction or product authorized or requested by you;
5. to our professional advisers;
6. for employment purposes such as payrolling; and
7. for the purpose of payment to third-party consultants, vendors, service providers and suppliers.

• We establish safeguards to help ensure the security and confidentiality of your information.

PowerSchool Neverskip maintains physical, electronic and procedural safeguards that comply with industry standards to protect your Personal Information. We routinely test our information systems and website to help ensure that unauthorized access does not occur. Some of the security measures adopted by us are:

• We review our Personal Information collection, storage, and processing practices, including physical security measures, to guard against unauthorized access to systems; and
• We restrict access to your Personal Information to our employees who need it to do their job. Employees with access to your Personal information are required to strictly maintain the confidentiality of such information.

If you suspect any unauthorized use of your account, you must immediately notify us by sending an email to the contact details indicated in the contact section. You shall be liable to indemnify us due to any loss suffered by us due to such unauthorized use of your account or password.

Further, we shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond our reasonable control including but not limited to acts of government, computer hacking, unauthorized access to computer data and storage devices, computer crashes, breach of security and encryption, poor quality of internet service, etc.

• We keep your Personal Information for as long as it is necessary to do so to fulfil the purposes for which it was collected as described above.

PowerSchool Neverskip has measures in place such that your SPDI which is in our possession or under our control, is destroyed and/or anonymized as soon as it is reasonable to assume that: (i) the purposes for which your SPDI has been collected have been fulfilled, and (ii) retention is no longer necessary for any other reason.

We may, however, reserve the right to retain and store your Personal Information for our business purposes, whether such Personal Information has been deleted or not. After a period of time, your data may be anonymized and aggregated and then may be held by us as long as necessary, to enable provision of Services or for analytics purposes.

• You rights in relation to your SPDI

You have the right to withdraw your consent at any time in writing in accordance with the terms of this Privacy Policy. You may write to us at [hello@neverskip.com] to access, review, amend or correct your SPDI or withdraw your consent to provide SPDI.

Upon request, we will endeavor to provide you with a complete copy of your Personal Information held or processed by us in a structured, commonly accepted, and machine-readable format. We have provided this as a part of our service to download required information whenever needed by the customer themselves. We will also send you service-related email announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. You do not have an option to opt out of these emails, which are not promotional in nature.

Your Consent:

You provide all Personal Information to us voluntarily or as part of your employment with us. By consenting to this Privacy Policy, you are providing us with your consent to our use, collection, and disclosure of your Personal Information in accordance with this Privacy Policy. You may choose not to provide us with Personal Information, but in the event that you do so, we will be unable to provide you with access to our platform or provide services through our platform.

Changes to our Privacy Policy:

We may update this privacy policy from time to time to comply with applicable laws or to conform to our current business practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Company’s website prior to the change becoming effective. We encourage you to periodically review our Company’s website for the latest information on our privacy practices.

Contact:

If there are any questions regarding this privacy policy, the practices of our website or your dealings with our website or grievances in relation to your SPDI, you may contact our Grievance Officer using the information below:

Name: J Rathakrishnan

Email: rathaji@neverskip.com