EFFECTIVE: December 11, 2023

Welcome to the Sharpen family! Please read this Privacy Statement carefully as it explains how Sharpen collects, processes, uses, and shares your information when you use our Services, including but not limited to those available at www.sharpen.com. Unless otherwise defined in this Privacy Statement, terms used in this Privacy Statement have the same meanings as terms defined in our Terms of Service. In order to use Sharpen’s Services, you must first agree to the Terms of Service and the Privacy Statement. If you do not agree with our Terms of Service or our Privacy Statement or any other policy, then do not use our Services.

1. Information Collected by Sharpen

Your privacy is very important to us. Below, we define each type of information that is collected when you use our Services.

Personal information: any information that can be used to identify an individual, either alone or in combination with other information, including but not limited to name, address, date of birth, and audio or visual information such as recorded voice or recorded video.

De-identified information: information that has been stripped of any personal identifiable information such that an individual cannot reasonably be identified.

Aggregate information: de-identified information that has been combined with information from multiple users and analyzed such that a specific individual cannot reasonably be identified.

Account information: information collected during account creation or when purchasing the Services, including but not limited to name, address, phone number, email, credit card information, user name, or user password.

Self-reported information: information about you or your family that you submitted into forms, surveys, or other Services’ features, including but not limited to family history or a child’s name, age, sex, grade level, and observed or recorded skills or behaviors.

Genetic information: information about your or your family’s genome sequences, i.e., the A, T, C, and G bases in specific locations of your or your family’s DNA that is derived from swab samples that you submitted to Sharpen.

Customer service information: any information that you provided when contacting our Customer Service or when corresponding with Sharpen about our Services.

Website behavior information: information on how you, account members, or your devices use our Services that is collected by us or service partners using cookies or similar technologies, including but not limited to pages visited, internet protocol address, user response time, device information, or browser information. For more information, please see our Cookie Policy.

Third-party information: information about a third party that is provided by you when you refer a person to Sharpen or when you choose to share your Sharpen data and results with another person, including but not limited to, name and email address. By your providing this information to any third parties, you confirm that the third parties have given you consent for Sharpen to contact them.

Third party-provided information: information that is provided by a third party when you use a third-party service in connection with our Services, including but not limited to posting on social media or signing up for our Services. Please review carefully third parties’ terms of service and privacy statements as Sharpen does not control their information practices.

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2. Use of Information Collected by Sharpen

Sharpen will use the collected information described in section 1 in a manner consistent with this Privacy Statement for the following activities:

Operate and provide our Services, including but not limited to creating user accounts, purchasing Services, processing payments, enabling the use of our website and applications, delivering assessment results and learning solutions, or maintaining the integrity and security of our Services.

Communicate with our customers, including but not limited to providing customer support, sending notices about policy or security changes, requesting customer feedback, sharing information about our Services, or providing information about other offers.

Analyze and improve our Services, including but not limited to enhancing customer experience, running quality control checks, optimizing or developing new Services or Services’ features, training our employees or contractors, measuring how customers use or interact with our Services, or providing personalized content or relevant marketing.

Comply with applicable laws, including but not limited to enforcing our Terms of Service, answering legal or regulatory requests, protecting our proprietary rights/intellectual property, or investigating any suspected or actual breach of security or unlawful or prohibited use of our Services.

Conduct research intended for publication in scientific, peer-reviewed journals. Participation in Sharpen research program is optional. If you choose to participate by completing our Research Consent, you agree to let Sharpen researchers use your self-reported and genetic information for research purpose. Research studies are overseen by an independent ethics review board and are performed exclusively on de-identified and/or aggregate information.

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3. Sharing of Information Collected by Sharpen

Sharpen will never share your individual personal information with third parties, other than as set forth below, without your explicit consent. Unless requested by you or agreed to in a separate agreement, we will not share your information with an insurance company, an employer, or a school attempting to obtain information about an insured person, an employee, or a student. Sharing of the information we collect may occur in a manner consistent with this Privacy Statement under the following circumstances:

When requested by you. You may direct Sharpen to share your information, including your personal and self-reported information, with family members, friends, or other third parties who may or may not use our Services. You should be thoughtful about your sharing choices. Once you have chosen to share your information, the receiving party or parties may also use or share your information. When sharing personal information outside of our Services, including but not limited to social media or third-party services that may or may not connect to our Services, you agree to do so at your own risk. Please always review third parties’ terms of service and privacy statements as their information practices may differ from Sharpen’s. Sharpen will have no liability or responsibility for any consequences resulting from your decision to release or share personal information with others.

When required by law. Sharpen will not share your information with law enforcement or other authorities unless, in the judgment of our legal counsel, it is required by law, legal process, litigation, or requests from governmental authorities. We also may preserve and disclose your information if we believe it is necessary under applicable law to enforce our Terms of Service and other policies, to protect the integrity and security of our Services, to protect the rights, safety, and property of Sharpen, its employees, its users, or its contractors, or to comply with a valid legal or regulatory process. If we are compelled to disclose your personal information, we will use our best efforts, unless prohibited by law, to provide you with prior notice.

Research purpose. Sharpen is constantly innovating to provide the best possible experience for its users and to develop new Services or Service features. Sharpen researchers also use de-identified information to study potential links between genetic markers, learning skills, learning traits, and/or other learning characteristics. The output of this research could lead to a better understanding of learning problems and/or help improve early detection and intervention. If data are published or shared with qualified research collaborators, only summaries of research results or pooled data that do not identify any research participant will be shared. Examples of aggregate information are average or percentage values such as: “85% of the study participants completed the assessment with an average score of 0.52”. If needed, Sharpen may also contact you directly about the study and obtain additional approval from an independent ethic review board.

Service providers. Sharpen uses the services of other companies to help us provide our Services to you, including but not limited to order processing and shipping, customer service, sample processing, data storage, web hosting, or analytics and advertising. Our service providers are subject to contractual obligations governing data security and confidentiality consistent with this Privacy Statement and applicable laws. We have implemented and are maintaining processes and procedures that protect your personal information. For more information, see section 6 below.

Business transaction. If Sharpen is involved in a prospective or actual merger, acquisition, bankruptcy, reorganization, or sale of all or a portion of its assets, we will likely share or transfer your personal information with the other party or parties involved. This Privacy Statement will apply to your personal information as transferred to the new entity.

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4. Your Privacy Controls

Sharpen values the trust you put into us when sharing personal information about you and your family. You have the right to fully access, review, modify, or delete your personal and self-reported information using the methods described below.

Access, modify, or copy your information. You can access and modify or update your personal information at any time by logging in your user account at sharpen.com. From this account, you may copy your information or download any assessment report or educational material made available to you by Sharpen. If you lose access to your personal Sharpen account, we will require that you submit additional information to verify your identity before you can regain access to your information.

Communication preferences. You may opt out from receiving promotional communications sent by Sharpen from time to time by clicking “unsubscribe” at the bottom of the promotional messages or by changing your preferences in your account settings. Please note that if you unsubscribe, you will still receive important messages related to our Services, such as reminders to complete specific assessments or notices about policy or security changes.

Research participation. You may opt out the Sharpen research program at any time by contacting our Privacy and Human Protection administrator at php@sharpen.com. Any information included in ongoing or completed research studies at the time of withdrawal cannot be deleted; however, your information will not be included in any future research project. Withdrawing from a research program will not affect your access to Sharpen Services.

Sample storage. You may opt out the Sharpen sample storage service at any time by contacting our Privacy and Human Protection administrator at php@sharpen.com. You understand that this decision cannot be reversed. Once the residual sample is securely destroyed, Sharpen will have no means to perform additional DNA analyses, unless new swab samples are collected.

Delete information or account. You may request that we delete specific information or all the information associated with your personal Sharpen account by contacting our Customer Service at support@sharpen.com. If you decide to close your account, Sharpen will only retain limited information as reasonably necessary to fulfill your request and comply with legal, regulatory, or accounting obligations. You understand that this decision cannot be reversed. Once your request is confirmed, you will no longer be able to access your information. You also understand that Sharpen will not have the ability, nor obligation to delete any information that you have shared with any third parties, either through or outside of our Services.

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5. Children Privacy

Sharpen is committed to protecting the privacy of your child and all children. Our Services are not designed for or intended to attract children under the age of 18. You must be an adult over the age of 18 to create a Sharpen account and accept the Terms of Service and Privacy Statement. In addition, you must be a parent or a legally authorized representative to collect swab samples from a child and to submit to Sharpen any information about your child. Sharpen will not intentionally collect online any personal information directly from children under the age of 13 without prior consent from their parent or legal representative. If you think that we have collected personal information directly from a child under the age of 13 without appropriate consent, please contact us as described below in section 7 and we will take commercially reasonable efforts to delete such data from our system. Parents and legally authorized representatives assume full responsibility in ensuring that their children use our Services in a manner consistent with our Terms of Service and Privacy Statement.

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6. Information Security

Sharpen uses industry-leading security technologies and practices to prevent unauthorized access to your personal Sharpen account or unauthorized disclosure of your information. All swabs and DNA samples are de-identified when they are received, processed, and stored in our laboratory. To further protect your identity, your personal information and your raw genetic data are stored in distinct databases that have restricted access to minimum essential personnel. All your information is encrypted when it is stored and being transmitted between secure servers. We periodically review and maintain our security practices and take what we believe to be commercially reasonable steps to make it difficult for potential hackers to gain access to your information. Security technology evolves and we cannot safeguard your information or assure that your information will not be improperly obtained by third parties without your help. We encourage you to not share the username and password for your personal Sharpen account, to sign out from your Sharpen account after each session, and to be mindful with whom you share your personal information.

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7. Miscellaneous

Third-Party Policies. This Privacy Statement applies only the information collected by Sharpen. Our Services may provide links or integrations with third-parties organizations that are not affiliated with Sharpen. We do not review or endorse and are not responsible for the privacy practices of these third parties. We encourage you to read the Privacy Statements for each and every website that you visit or use.

Change to this Privacy Statement. We reserve the right to modify this Privacy Statement from time to time in our sole discretion. If we modify this Privacy Statement, we will make a new copy available on our website and notify you by posting a notice on our website or sending a message to the email address associated with your account. You are responsible for the reading of any such modification. If a change is unacceptable to you, you may stop using our Services. Your continued use of the Services will be treated as acceptance of the updated Privacy Statement.

Contact information. If you have a question, complaint, or inquiry about this Privacy Statement, please contact Sharpen’s Privacy and Human Protection administrator by email to php@sharpen.com or by mail to the address below.

Sharpen.com, Inc.

ATTN: Privacy and Human Protection Administrator

33 Bradford Street, Office 30

Concord, MA 01742