OWL Privacy Policy

Last Updated: March 21, 2025

CATS2 Foundation (including current and future affiliates and subsidiaries, “CATS2”, “we”, “our”, or “us”) provides technology solutions including the OWL for Schools software-as-a-service platform, websites (including https://www.owlschools.org/, the “Site”), mobile applications, application programming interfaces, software development kits, and customer support (our “Services”). Our services are provided to K-12 schools and other institutions in the Unites States (our “Customers”), as well as to our Customer’s staff (“you” or “your”). This privacy policy (“Privacy Policy”) describes the data privacy practices of CATS2 when you access our services, as well as any other personal information obtained when you call, email, or otherwise interact with CATS2 in relation to the services. We are committed to protecting the privacy of those who entrust us with their Personal Information. “Personal information” means any information pertaining to an identified or identifiable individual and may include, for example, email addresses and contact details and any similar information provided to us in the course of our business operations. Our users trust and expect that we will protect their Personal Information in accordance with the promises we make. This Privacy Policy includes Personal Information that is collected via email, SMS, telephone, and other means. Personal information that is de-identified or anonymized is not considered Personal Information.
By accessing our Services or otherwise interacting with us, you are accepting the practices described in this Privacy Policy. We recommend that you review this Privacy Policy periodically, as it may be updated from time-to-time. If you do not agree to the policy, please do not use our Services.

1. Information Collection Overview
For the 12-month period prior to the date of this Privacy Policy, we explain here what categories of Personal Information we have collected in the usual course of business from users of the Services, where we got it from, and with whom we have shared it:

1.1 What Categories of Personal Information We Collect
We collect information from your when you access and interact with our Services via any portal, environment or communication tool. Information may be obtained, for example, when you submit information to the Site or mobile application, when it is uploaded to the OWL platform, as well as from emails, calls, or texts you may send us.
Personal Information can include, but is not limited to, the following categories of information:

• User credentials associated with the Services
• If you are affiliated with a Customer, information provided to us by the Customer about you, which may include first and last name, user role assigned, school affiliated with, and contact information (including phone number, and email address).
• Information about your use of the Services.
• Device location information, such as details on your location while using the Services. Precise geolocation information from mobile devices is only collected when you are at the school, and only during an emergency or while actively using the OWL for Schools mobile app.
• User generated content: Content of messages that you send while using the Services, which may include health information
• Mobile information, including Site browsing information such as log information about your use of the Site, the type of browser you use, access times, pages viewed, videos viewed, and your IP address, as well as mobile phone information such as device identifiers and diagnostics, crash and performance data.

1.2 How We Use Information
CATS2 will only use Personal Information to the extent it is necessary to deliver the Services, including

• To enable a private by invitation only link and communicate during an emergency only.
• To help us improve the Services
• To help us respond to your inquiries
• To contact you about important Service updates
• For legal obligation purposes
• To facilitate communication between users of the Services
• To make sure our Services work properly with your device and make sure you can see and use our intended Site on the device you are using, and for analytical purposes.
• To protect the security or integrity of the Services and our business, such as by managing risk exposure, including by identifying potential hackers and other unauthorized users.
• To provide you information based on your location during an emergency, for your safety, to disclose to law enforcement and governmental agencies as necessary, and to ensure no fraudulent submissions are being submitted.
• To personalize content (such as “Hello John Doe”) and to direct personal messages to the right mobile device.

We do not sell any of the information we collect through our Services, and we do not engage in profiling or the behavioral targeting of advertisements.

1.3 How We Share Information
We may share Personal Information with:

• Our affiliates, agents and successors; to the extent relevant, select technical and other service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations).
• Users who are authorized to view this information or to whom such information is communicated or designated
• Our service providers who help us with fraud protection, and third party service providers that perform website analytic services for us.
• School officials, law enforcement and other governmental authorities in accordance with applicable law.

In some jurisdictions, individuals may have the right to withdraw consent from certain uses. If you reside in such jurisdictions, you may have additional rights which are detailed in this Privacy Policy. In all cases, any service providers will be contractually limited in the way they may use Personal Information maintained by CATS2, including requirements that such information be maintained in a confidential and secure manner.
In Connection with Business Transfers: In the event that a division, a product or all of CATS2 is bought, sold or otherwise transferred, or is in the process of a potential transaction, personal information will likely be shared for evaluation purposes and included among the transferred business assets, subject to client contractual requirements and applicable law.
To Comply with Laws: CATS2 may also disclose specific Personal Information when such disclosure appears necessary to comply with applicable law, a subpoena in the course of managing a dispute, governmental inquiry or other litigation process. We may also disclose information to our accountants, auditors, agents, lawyers and other advisors in connection with the enforcement or protection of our legal rights or to protect the interests or safety of our clients, employees or others, in accordance with or as authorized by law.

2. Cookies
Like many websites, we analyze how visitors use our Site through what is known as “cookie” or similar tracking technology. A cookie is a small text file that is placed on your computer when you access the Site and allows us to recognize you each time you visit the Site. We may use cookies to: (1) allow you to use the Site without having to re-enter your user name and password; (2) enhance or personalize your Site usage; (3) monitor the Site usage; (4) manage the Site; and (5) improve the Site and our Services. If you choose, you can set your browser to reject cookies or you can manually delete individual cookies or all of the cookies on your computer by following your browser’s help file directions. However, if your browser is set to reject cookies or you manually delete cookies, you may have some trouble accessing and using some of the pages and features that are currently on our Site, or that we may put on our Site in the future. Note that browser-management tools for cookies are outside of our control and we cannot guarantee their effectiveness.
CATS2 may use Google Analytics to evaluate use of the Site for our internal purposes such as evaluating usages of the Site. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners.
We may combine the information we collect through cookies with other information we have collected from you or information from other sources.

3. Retention of Personal Information
Personal Information that we collect, access or process will be retained only as long as necessary for the fulfilment of the purposes for which it was collected, unless otherwise provided in agreements between you and CATS2 or as required or authorized by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made de-identified.

4. Opt-Out of Communications
We only send you certain communications relating to the Services we provide, service announcements and administrative messages. We do not offer you the opportunity to opt-out of receiving those communications.

5. Security
CATS2 has implemented a number of security features throughout our Services to prevent the unauthorized release of or access to Personal Information. For example, database information is kept separate from live servers and is firewall protected. Please be advised, however, that although CATS2 has endeavored to create a secure and reliable Site for you, the confidentiality of any communication or material transmitted to or from CATS2 via the Site or e-mail cannot be guaranteed. When disclosing any Personal Information, you should remain mindful of the fact that it is potentially accessible to the public and consequently, may be collected and used by others without your consent. CATS2 has no responsibility or liability for the security of information transmitted via the Internet.

6. Third Party Website
The Site may contain links to third-party websites, such as social media sites like LinkedIn, Facebook, Twitter, Instagram, TikTok and others which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these websites. Accordingly, we recommend that you review the privacy policy posted on any external site before disclosing any Personal Information. Please contact those websites directly if you have any questions about their privacy policies.

7. Children
The Services are not directed to children, nor do we knowingly collect any Personal Information from children under the age of thirteen online without verifiable parental consent. If you believe that a child has provided Personal Information to us, please contact us promptly as described below, and we will endeavor to investigate and delete such information from our systems.

8. Your Privacy Rights
The law in many jurisdictions provides you with the following rights with respect to your Personal Information:

• The right to know what Personal Information we have collected, used, disclosed, and sold about you, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information CATS2 has collected about you.
• The right to obtain a copy of Personal Information we have obtained about you in a portable and, to the extent technically feasible, readily usable format.
• The right to correct inaccurate Personal Information about you, taking into account the nature of the Personal Information and the purposes of the processing.
• The right to request that we delete any Personal Information we have about you.
• The right to opt-out of sale or the sharing of your Personal Information for cross-context behavioral or targeted advertising.
• If we deny your request, the right to appeal our decision. If you are not satisfied with our response, you can contact the applicable privacy regulator, see Section 11, Right to Lodge Complaints.

In addition, and as set forth below, California law requires us to identify, for the 12-month period prior to the date of this Privacy Policy, what information we may have shared with third parties for their own direct advertising purposes. We have not engaged in this activity, but please contact us if you have any questions. For the 12-month period prior to the date of this Privacy Policy, we have not sold or shared any Personal Information about our users. We do not use or disclose sensitive Personal Information, as defined in applicable laws, for any purposes other than those stated herein and permitted by applicable law.
Submitting Requests
If you are a resident of the relevant jurisdictions, you may submit your requests to opt out, correct, delete, and/or to know/obtain Personal Information we have collected about you by contacting us at info@cats2.org.
We will respond to your request in compliance with the requirements of your state’s applicable laws.
Verification of Your Identity
When you exercise these rights and submit a request to us, we will need to verify your identity and may ask for your email address or other information needed for verification. We may also use a third-party verification provider to verify your identity. We will endeavor to honor such requests unless such a request conflicts with certain lawful exemptions under applicable privacy law.
Appeal
You have the right to appeal a decision we have made regarding their requests by emailing us at info@cats2.org.
Non-Discrimination
If you make a request under your state privacy law, we will not discriminate against you in any way. For example, we will not deny you discounts or other benefits or impose penalties on you, or provide you with or suggest that you will receive a different level or quality of benefits or services.
Authorized Agents
You may permit an authorized agent to submit a request to know or to delete your Personal Information. If we receive a request on your behalf, we will ask that person to give us proof that you gave that person written permission to make a request for you. If that person does not provide us with written proof, we will deny their request so that we can protect your Personal Information.
Automated Decision-Making
We generally do not use automated decision-making technology, as that term is defined by applicable privacy laws. If we make use of automated decision-making technology, you will be informed through a separate privacy notice.

9. Visitors from Outside the United States—Cross-Border Transfer
The Site is hosted in the United States. If you are visiting the Site from outside the United States, your information may be transferred to, stored and processed in the United States or other countries in accordance with this Privacy Policy. The data protection and other applicable laws of the United States or other countries may not be as comprehensive as those laws or regulations in your country or may otherwise differ from the data protection or consumer protection laws in your country. Your information may be available to government authorities under lawful orders and law applicable in such jurisdictions. By using the Site and/or providing Personal Information to us, you consent to transfer of your information to our facilities as described in this Privacy Policy.

10. Right to Lodge Complaints
We are transparent about the ways in which we collect and use Personal Information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your Personal Information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or the United States. You may contact the US Federal Trade Commission regarding your concerns. For more information, please see https://www.ftc.gov/faq/consumer-protection/submit-consumer-complaint-ftc.

11. Changes to This Privacy Policy
We may change this Privacy Policy from time to time, including as required to keep current with rules and regulations, new technologies and security standards. When we do, we will let you know by appropriate means such as by posting the revised statement on this page with a new “Last Updated” date. Changes to this Privacy Policy will become effective when posted, unless indicated otherwise.

12. How to Contact Us
If you have questions or concerns about this Privacy Policy or how we collect and use the information of our users or to request a copy of this Privacy Notice in another format, you can contact at info@cats2.org. If we need, or are required, to contact you concerning any event that involves your information, we may do so by email, telephone, or mail.