MINERVA PRODUCT AND SERVICES PRIVACY STATEMENT

Effective date: March 31, 2020

The Minerva Project, Inc. (“Minerva”) has developed a learning platform — Minerva Forum (“Forum”) — and educational curriculum to provide online learning experiences (collectively, the “Services”). This Product and Services Privacy Statement (“Privacy Statement”) explains how we collect, use, disclose and otherwise process end-user personal information on behalf of Minerva’s customers in connection with the Services. Minerva is the data processor and Minerva customers are the data controllers with respect to such personal information.

Minerva’s processing of personal information in connection with the Services is governed by this Privacy Statement and the relevant customer or partner agreement (referred to throughout this Privacy Statement as “Customer Agreement”). In the event of any conflict between this Privacy Statement and the Customer Agreement, the Customer Agreement will control to the extent permitted by applicable law. This Privacy Statement applies only to Minerva’s collection, use, disclosure, and otherwise processing of the personal information of Minerva’s customers’ end users. This Privacy Statement does not govern: (i) Minerva’s processing of its customers’ business representatives’ personal information; (ii) Minerva’s customers’ processing of personal information outside of the Services; and (iii) Minerva’s processing of personal information in connection with any other service or product we offer. BECAUSE MINERVA DOES NOT CONTROL THE PRIVACY PRACTICES OF THE RELEVANT CUSTOMER, YOU SHOULD READ AND UNDERSTAND THE RELEVANT CUSTOMER’S PRIVACY POLICY.

This Privacy Statement is not a substitute for any privacy notice that Minerva customers or partners are required to provide to their employees or other end users.

Personal Information Minerva Collects

Information provided to us by end users in connection with their use of the Services.

• Business and personal contact information, such as name, email and mailing addresses, phone numbers, employer, job title, and role;
• Account information, such as username and password set to establish an online account with us;
• Optional profile information such as an avatar photo or a recording of how to pronounce their name;
• Content you choose to upload or screenshare while using the Forum, such as any image, video, comment, audio or other submission along with the metadata associated with the content you upload;
• Learning activity information, such as video recordings of class participation, assignments or other coursework responses, files or documents, poll submissions, chat messages, and instructor feedback; and
• Correspondence, such as information provided in connection with questions, feedback support, or other interaction with us through the Services.

Information we obtain from the relevant customer. For example, the relevant customer may share end users’

• Contact information;
• Professional information; and
• Registration information.

Information about end users’ using the Services. We and certain of our service providers (“Analytics Companies”) may collect information about end users’ using the Services to help analyze how end users interact with the Services. These Analytics Companies may use cookies and other tracking technologies to collect information about end users, including referring/exit pages, device browser type, domain name, date/time stamp for visit and Internet Protocol (“IP”) address. We and our services providers may also collect information about your interactions with emails we send on behalf of our customers.

Tracking & Cookies Data

Cookies are small text files that can be used by websites to make a user’s experience more efficient.

The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. This site uses cookies that provide necessary functionality, features, and third-party services such as Google OAuth. Some cookies are placed by third party services that appear on our pages. Cookies make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

How Minerva Uses Your Information

To facilitate the Services

In general, Minerva uses your information to facilitate the Services, including to:

• Create and maintain your account with us;
• To enable end users to access and use the Services;
• To enable end users to communicate and collaborate with other Services users;
• To provide information about the Services, such as updates or changes to the Services and security alerts;
• To customize the end user’s experience, such as personalizing content or features;
• To respond to inquiries, complaints and requests for support;
• Facilitate the educational curriculum;
• Facilitate communications between end users and the relevant customer.

To support the relevant customer’s operations

• Send end users surveys, offers and other promotional materials on behalf of the relevant customer; and
• Connect end users with educational opportunities in which end users may be interested.

To support our business operations

• Maintain, improve and develop our Services (including to develop new services and products);
• Enforce Minerva’s terms and conditions, rights, safety or property and/or that of you or others;
• Protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; and
• Create anonymous, aggregated or deidentified data by removing from the records any identifiers (e.g., ID numbers, account numbers, names, etc.) that make the information personally identifiable to you. We may use and share this non-personal information for our business purposes.

How Minerva Shares Your Information

• At the relevant Customer’s direction. Minerva may share your information with the relevant customer or with other third parties to facilitate the Services. For example, we may share your information with educational institutions or others (such as your colleagues). We may also enable end users to share information when using the Services, for example, by sharing presentations or participating in chats with other end users.
• With third-party or affiliate service providers. Minerva may share your information with third-party or affiliate service providers that perform services for or on behalf of Minerva for the purposes described in this Privacy Statement, including to: provide you with the Services, optimize the performance of the Services, provide technical support, and/or provide other services to Minerva such as payment processing.
• In connection with corporate transactions. Minerva may share some or all of your information in connection with or during negotiation of any merger, financing, acquisition, dissolution, or other transaction involving the sale, transfer, divestiture or disclosure of all or a portion of Minerva’s business or assets. In the event of an insolvency, bankruptcy or receivership, your information may also be transferred as a business asset.
• Other Disclosures. Regardless of any choices you may make regarding your information, Minerva may disclose your information with government, law enforcement officials or private parties if Minerva believes that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on Minerva; (b) protect and defend Minerva’s rights or property, the customer or other users of the Services; (c) comply with a legal investigation; and/or (d) to investigate or assist in preventing any violation or potential violation of law, this Privacy Statement or Minerva’s terms of use.

Age Limitations

Minerva does not knowingly allow use of the Services by anyone younger than 13 years old. We do not direct the Services at children under the age of 13. In the event that we learn that we have collected information on a child under the age of 13 without parental consent, we will take steps to delete that information as soon as reasonably practicable. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact the relevant customer. We encourage parents or guardians with concerns to first contact the relevant customer and then, if necessary, contact us.

Student Privacy

Minerva maintains policies and procedures designed to comply with all applicable requirements of relevant student privacy laws including, without limitation, the Family Educational Rights and Privacy Act (FERPA). FERPA may provide students or their parents with certain rights in their personal information. If you have any questions about FERPA or your rights, please contact us at privacy@minervaproject.com. Minerva will never use any student data to advertise or market to students or their parents. We will not mine student data for any purpose other than those related to providing the Services. Data mining or scanning of user content for the purpose of advertising or marketing to students or their parents is prohibited.

Information Security

Minerva maintains physical, electronic, and procedural safeguards designed to safeguard the security of personal information. Minerva cannot, however, guarantee that any safeguards or security measures will be sufficient to prevent an information security issue.

Information Retention

Minerva retains end users’ information for the periods set out in the Customer Agreement including as appropriate to (a) provide the Services; (b) comply with legal and accounting obligations; (c) resolve disputes; and (d) enforce the terms of the Customer Agreement.

International Data Transfers

Minerva is headquartered in the United States and may have service providers in other countries. Minerva may transfer your information outside of the country in which you reside, including to the United States.

Links to Other Sites or Applications

The Services may contain links to third-party websites or applications. When you click on a link to any other website or location, you will leave the Services and go to another site or application operated by a third party. The third party may collect personal information about you. Minerva’s providing a link to any other website or location is for your convenience and does not signify Minerva’s endorsing such other website or location or its contents. Minerva has no control over, does not review, and is not responsible for these third party websites or their content. Please be aware that this Privacy Statement does not apply to these third party websites or applications.

Your Choices Regarding Your Information

The relevant Minerva customer is the data controller of end users’ personal information. As a data controller, the relevant Minerva customer is responsible for receiving and responding to end users’ requests to exercise any rights afforded to them under applicable data protection law(s). Minerva will assist the relevant customer in responding to such requests as set forth in the applicable customer agreement.

Where Minerva is required by law to collect your information or where Minerva needs your information in order to provide the Services to the relevant customer, if you do not provide this information when requested (or you later ask to remove it), Minerva may not be able to provide you with the Services. Minerva will tell you what information you must provide to use the Services by designating it as required at the time of collection or through other appropriate means.

You may have several choices regarding use of your information on the Services.

• Cookies. If you decide at any time that you no longer wish to accept Cookies from the Services, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the Services. Please consult your browser’s technical information to learn how to exercise this option. If you do not accept Cookies, however, you may not be able to use all or portions of the Services.
• How Minerva Responds to Do Not Track Signals. Some Internet web browsers transmit “do not track” signals to the websites and other online services with which your web browser communicates. There is currently no standard that governs what, if anything, websites should do when they receive these signals. Currently, Minerva does not take action in response to these signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Changes to This Privacy Statement

Minerva reserves the right to modify this Privacy Statement at any time. The Services, laws, regulations and industry standards may evolve which may make changes to this Privacy Statement appropriate. Minerva will post the changes to this page. Minerva encourages you to review the Privacy Statement to stay informed. In accordance with applicable law, Minerva may notify you of any material changes in its collection, use, or disclose of your information by posting a notice on the Services. Any material changes to this Privacy Statement will be effective thirty (30) calendar days following notice of the changes on the Services. These changes will be effective immediately for new users of Services. If you object to any such changes, you must notify Minerva prior to the effective date of such changes that you wish to deactivate your account. Continued use of the Services following the effective date of such changes indicates your agreeing to such changes.

How to Contact Us

If you have any questions or complaints about this Privacy Statement or Minerva’s data processing practices, please contact Minerva by email at: privacy@minervaproject.com or by mail at: