Privacy Policy

I. Introduction

This Privacy Statement provides information on how Development Cubed Software, Inc. dba Tassel collects, uses, and protects personal information collected through our websites and though the provision of our products and services from customers and users (collectively, the "Services"). Tassel provides Services related to graduation, commencement ceremonies, and advanced ticketing, and we are committed to the highest standards of protection for personal data at all times. When we refer to "us," "we," "our," or "Tassel" in this Privacy Statement, we are referring to Tassel and its affiliates. We believe that Privacy is a fundamental right for all individuals. Our clients and their users entrust us with the personal information of both employees and parents, and students. On this basis, we take the responsibility attached to this information very seriously. How we collect information and how we use information may differ based on our relationship with you as an individual. We have identified below the different relationships we may have with you, and our respective use of information we collect.

II. Customer Data and FERPA Compliance

Data received from Customers and when a customer's privacy statement/policy governs. If you are an end-user (parent or student) of our customer (a school or school district) and you are using Tassel products and services through our customer (your school or school district), Tassel may receive information about you from such customer. These disclosures are generally made pursuant to FERPA Section 99.31(a) (1), where Tassel is generally designated Provider as an "other school official" with "legitimate educational interests" for the purposes of disclosing to Provider certain student information of its students or another applicable exemption from FERPA. In these cases, your school or school district's privacy statement or privacy notice governs the use of any personal information. Our Privacy Statement does not supersede the terms of any agreements between us and your school or school district (our customer), nor does it affect the terms of any agreement between the student and the student's school or school district.

FERPA Compliance

Tassel, in its role as a vendor to educational agencies and institutions, both public and private entities ("Educational Agencies"), receives disclosures from the Educational Agencies, which include the directory information, personal information, and other data ("Student Data") contained in student records such as Student ID number, full name, email address, degree(s), applicable honors, GPA as well as information directly from students and parents of students such as a photo and personal message. Only information that is needed for Tassel to perform services, which are outsourced to Tassel by the Educational Agencies, is disclosed to Tassel. These disclosures are authorized by the federal Family Educational Rights and Privacy Act (FERPA). Tassel considers Student Data to be strictly confidential and does not use Student Data for any purpose other than improving and providing our products and services to the Educational Agencies or on the Educational Agencies' behalf. Our collection, use, and sharing of Student Data is governed by our contracts with the Educational Agencies, the provisions of FERPA, the Children's Online Privacy Protection Act (COPPA), and other applicable state and federal laws and regulations that relate to the collection and use of personal information of students. If you have questions about reviewing, modifying, or deleting personal information of a student provided by Educational Entities, please contact the relevant Educational Agency(ies) directly.

III. What Information We Collect and How We Use It

The nature of the personal information we collect and how we use it depends on the context in which we collect that personal information. Please see the section below that applies to you. Note that you may fall under multiple categories if you interact with our products, services and website in multiple ways.

A. Customers (Schools and School Districts and their employees)

i. Information We Collect

a. Directly from you. We collect information necessary to provide the educational technology services as directed by you. The information collected from you depends on the specific product and what is needed to integrate with your systems and to set up and maintain accounts. This includes information in the following data categories:

• Account and Student information: The exact elements will depend on the product and what specific information you as a customer provide to us, but often we receive from you FERPA sanctioned directory information, email addresses, student IDs, GPA, degree(s), applicable honors and metadata. See the section entitled "Customer Data and FERPA Compliance" section for further detail.
• User Account Information: We also collect account information from your designated product administrators and users affiliated with Customers including usernames, email addresses and titles to initially set up products and services for you.
• Supplementary Service Information: Depending on your needs as a customer, we may also facilitate financial transactions through a third-party payment platform of students and parents of students in order to provide services. In these instances, Tassel itself will not collect or store any of the financial information.

b. Indirectly from you. We collect device and usage information when you access and use our products and services, including information that your browser or the mobile app sends when you are using it. This data may include your unique device identifier, IP address, your browser type and configuration, the date and time of your use of the product or service and cookie data. Specifically, we and our service providers use cookies and similar technologies such as local storage (HTML5), web beacons, Javascript, and eTags. The purpose of collecting such information is for improvement of our products and services to better meet the needs of our customers and their users. See our cookie policy for further details on our use of cookies.

c. From third parties. We may receive information from affiliates in our Tassel Group of companies and other third parties. For example, we may receive limited personal information from third-party services that integrate with or complement the Tassel products or services that you have opted into in order to provide you with the best possible user experience.

ii. How We Use This Information

We use your information to provide you the features and functionality of the Tassel products and services, as well as to communicate directly with you and allow you to communicate with other Tassel users (i.e., students and families). It is necessary for us to use the information in this manner in order to provide you with the services your school or school district has requested pursuant to its agreement with Tassel. We will use your information to provide you with news and information about new products and services. Any such marketing communications from us may be discontinued at any time. See "Marketing." We may also use de-identified and aggregated information to understand and improve our products and services. We may share general customer contact information with certain Partners as is necessary to offer and provide our products and services to our current and prospective clients. No customer data other than general institution contact information is provided for these purposes. For absolute clarity, we do not provide any student data or personally identifiable information to any Partners for marketing purposes.

iii. How We Share This Information

We share information to provide the Tassel products and services to you and further improve them. Within Tassel, your information will be accessed only by those who have a need to provide the Tassel products and services. We use vendors to help us provide the Tassel products and services to your school or school district. We may also share this information with third-party vendors that are also used by a Customer and at the Customer's direction. Tassel does not provide warranties for third party providers and will cooperate with Customer requests to share data with a third-party provider with the understanding the Customer vetted that third party and only at the instruction of the Customer. Third-party analytics tools may also have access to your personal information to help us understand how the Tassel products and services are being used such as Google Analytics. On the Tassel websites there are links to social media sites, such as Instagram and YouTube, when you click on the icons on Tassel website some web traffic information is shared with those companies.

B. Students, Parents and Other Guests

This section of our Privacy Statement is provided for informational purposes and describes how parent, student and guest personal information is used when Tassel products and services are provided through a school or school district. How that information is used depends on the school or school district, so please consult your institution's privacy statement.

IV. Sharing with Vendors, Partners, and Other Disclosures

i. Vendors

We engage directly with certain third-party companies to help us provide the Tassel products and services to our customers or to you or to perform work on our behalf ("Vendors"). Our vendors are required to abide by our privacy and security instructions and are contractually restricted from using any personal information they access or receive from us for any purposes other than as needed to perform such services. We may use vendors to help us conduct marketing campaigns and disclose customer contact information necessary for those activities.

V. Children's Privacy

We do not knowingly collect any information from children under the age of 16 unless and until the Tassel customer (school or school district) has provided authorization for a student under 16 to use the Tassel products and services and for us to collect personal information from such student. Please contact us at [email protected] if you believe that we have inadvertently collected personal information from a child under 16 without proper consent. This will allow us to delete such information as soon as possible.

VI. Security

Tassel employs a variety of physical, administrative, and technological safeguards that are designed to protect personal information against loss, misuse, and unauthorized access or disclosure. We strive to continuously enhance our technical and operational security measures. Our measures consider the type and sensitivity of the data being collected, used, and stored, and the current state of technology and threats to information. Tassel's security measures include data encryption, firewalls, data use and access limitations for personnel and vendors, and physical access controls to our facilities. Tassel also aligns its privacy and security operations to best practices and relevant international regulations.

VII. Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 allows you to request information on how we disclose personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. You may make one request each year by emailing us at [email protected] or writing to us (see address below in "CONTACT US").

Please see HERE for our privacy notice regarding the California Consumer Protection Act (CCPA).

VIII. Links to Other Sites

Our Tassel websites may provide links to third party websites or resources. The information practices of those websites are not covered by this Privacy Statement or any other policies or terms applicable to the Tassel websites or the Tassel products or services. We recommend that you review any terms of use and privacy policy of any linked third-party website, such as social media links, before providing any information.

IX. Changes to This Privacy Statement

We may update this Privacy Statement and its last updated date to reflect changes to our data governance practices. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.