Common use of Sharing of Personal Information Clause in Contracts

Sharing of Personal Information. We do not share your or your Child's personal information other than as follows: • with your school or school district at their request; • with new teachers within a school that already uses Newsela or schools within a district that already uses Newsela; • with third party service providers, consultants, and other service providers who perform services for us and need access to your or your Child's information to do that work in a manner consistent with this Children's Policy (for example, our web hosting provider, third party analytics service providers and purchase processors); • to comply with laws or to respond to lawful requests and legal process; • to protect the rights and property of Newsela, our agents, users, and others including to enforce our agreements, policies, and terms of use; • in an emergency to protect the personal safety of its users or any person; • in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company, in which case the company receiving the personal information would be obligated to follow this Children's Policy. We may create, use, and disclose anonymized and aggregated data for our own purposes by excluding information (such as your Child's name) that makes the data personally identifiable to your Child. The purposes for which we may create, use, and disclose anonymized and aggregated data include, but are not limited to, conducting analysis and generating statistics regarding the use of our Site, App, and/or Services. Additionally, we may share your Child's personal information with new teachers who use the Services in their classrooms when your Child enrolls in such teachers' classes. We may create and use anonymized and/or aggregated data for our own purposes by excluding information (such as your Child's name) that makes the data personally identifiable to you or your student. The purposes for which we may create and use anonymized and/or aggregated data include but are not limited to, conducting analysis and generating statistics regarding the use of our Site, App and/or Services. We will not share your Child's personal information in any way other than in connection with providing the Services, as described in this Children's Policy, or as directed by a teacher or school. We require our third party service providers not to use your Child's personal information other than to provide the services that we have requested. We will not disclose your Child's personal information to any third party for that third party's own marketing purposes. Additionally, we will not knowingly use or disclose your Child's information (whether personal information or otherwise) for behavioral targeting of advertisements to your Child. We do not sell Children's personal information. For clarity, we may make recommendations within or through the Services of features, tools, and content on the Services to students, including Children, based on their demographic information or activities on our Services. For example, we may suggest a text set to a student based on a previous one the student has read or based on the student's age or grade level. INFORMATION CHOICES AND CHANGES Below are some ways you can control the collection and use of your Child's information in connection with the Services. While we and others give you choices described in this policy, there are many ways web browser signals and other similar mechanisms can indicate your choice to disable tracking, and we may not be aware of or honor every mechanism. Information in the Services You may change some of your or your student's personal information stored in the Services by following the directions on the Site or App. You may send requests about your or your student's personal information, including requests to change your or your student's contact preferences and update or correct your or your student's personal information, to our contact information below. In some cases, changes about a student's personal information may have to be executed by the student's school or teacher, and in such situations, we will attempt to assist you and the school or teacher with such efforts. Behavioral Advertising Newsela does not behaviorally target advertising to Children on sites that are directed to Children or where Newsela has actual knowledge that a user is under 13. For more information about Newsela's Behavioral Advertising activities, please see the section in our general Privacy Policy titled "Interest-based or Online Behavioral Advertising". However, if you would like to opt-out of certain mechanisms for tracking on a device or web browser used by your Child, including tracking of online activities over time and across different websites, you can use one or more of the options described above in the "Interest-Based and Behavioral Advertising" section of the general Privacy Policy. If you delete your Child's cookies, use a different browser or device, or buy a new computer, you or your Child will need to renew your opt-out choice.

Sharing of Personal Information. We do not share your or your Childstudent's personal information other than except as follows: • with your school or school district at their request; • with new teachers within a school that already uses Newsela or schools within a district that already uses Newsela; • with third party service providers, consultants, and other service providers who perform services for us and need access to your or your Childstudent's information to do that work in a manner consistent with this Children's Policy (for example, our web hosting provider, third party analytics service providers providers, advertising services providers, and purchase processors. Note: Newsela never directs targeted advertising at Children. See: “Interest-Based or Online Behavioral Advertising,” below.); • to comply with laws or to respond to lawful requests and legal process; • to protect the rights and property of Newsela, our agents, users, and others including to enforce our agreements, policies, and terms of use; • in an emergency to protect the personal safety of its our users or any person; • in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture divestiture, or disclosure of all or a portion of our business or assets to another company, in which case the company receiving the personal information would be obligated to follow this Children's Policy. We may create, use, and disclose anonymized and aggregated data for our own purposes by excluding information (such as your Child's name) that makes the data personally identifiable to your Child. The purposes for which we may create, use, and disclose anonymized and aggregated data include, but are not limited to, conducting analysis and generating statistics regarding the use of our Site, App, and/or Services. Additionally, we may share your Childor your student's personal information with new teachers who use the Services in their classrooms when you or your Child enrolls student, as applicable, enroll in such teachers' classes, and we may share teacher personal information with other teachers within a school using the Services. We may create and use anonymized and/or aggregated data for our own purposes by excluding information (such as your Childor your student's name) that makes the data personally identifiable to you or your student. The purposes for which we may create and use anonymized and/or aggregated data include but are not limited to, conducting analysis and generating statistics regarding the use of our Site, App App, and/or Services. We will not share your Childor your student's personal information in any way other than in connection with providing the Services, as described in this Children's Policy, or as directed by a teacher teacher, parent/legal guardian or school, or upon obtaining your consent. We require our third party service providers not to use your Childor your student's personal information other than to provide the services that we have requested. We will not disclose your Childor your student's personal information to any third party for that third party's own marketing purposes. Additionally, we will not knowingly use or disclose your Child's student information (whether personal information or otherwise) for behavioral targeting of advertisements to your Childsuch students. We do not sell Children's student personal information. For clarity, we may make recommendations within or through the Services of features, tools, and content on the Services to students, including Children, students based on their demographic information or activities on our Services. For example, we may suggest a text set to a student based on a previous one the student has read or based on the student's age or grade level. INFORMATION CHOICES AND CHANGES Below are some ways you can control the collection and use of your Child's information in connection with the Services. While we and others give you choices described in this policy, there are many ways web browser signals and other similar mechanisms can indicate your choice to disable tracking, and we may not be aware of or honor every mechanism. Information in the Services You may change some of your or your student's personal information stored in the Services by following the directions on the Site or App. You may send requests about your or your student's personal information, including requests to change your or your student's contact preferences and update or correct your or your student's personal information, to our contact information below. In some cases, changes about a student's personal information may have to be executed by the student's school or teacher, and in such situations, we will attempt to assist you and the school or teacher with such efforts. Behavioral Advertising Newsela does not behaviorally target advertising to Children on sites that are directed to Children or where Newsela has actual knowledge that a user is under 13. For more information about Newsela's Behavioral Advertising activities, please see the section in our general Privacy Policy titled "Interest-based or Online Behavioral Advertising". However, if you would like to opt-out of certain mechanisms for tracking on a device or web browser used by your Child, including tracking of online activities over time and across different websites, you can use one or more of the options described above in the "Interest-Based and Behavioral Advertising" section of the general Privacy Policy. If you delete your Child's cookies, use a different browser or device, or buy a new computer, you or your Child will need to renew your opt-out choice.our

Sharing of Personal Information. We do not share your or your Childstudent's personal information other than except as follows: • with your school or school district at their request; • with new teachers within a school that already uses Newsela or schools within a district that already uses Newselaunderstand your and your students' preferences and to enhance your and your students' experience and enjoyment using our Site, App and Services; • with third party service providers, consultants, and other service providers who perform services for us and need access to your or your Childstudent's information to do that work in a manner consistent with this Children's Policy (for example, our web hosting provider, third party analytics service providers and purchase processors); • to comply with laws or to respond to lawful requests and legal process; • to protect the rights and property of NewselaReadTheory, our agents, users, and others including to enforce our agreements, policies, and terms of use; • in an emergency to protect the personal safety of its users or any person; • in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company, in which case the company receiving the personal information would be obligated to follow this Children's Policy. We may create, use, and disclose anonymized and aggregated data for our own purposes by excluding information (such as your Child's name) that makes the data personally identifiable to your Child. The purposes for which we may create, use, and disclose anonymized and aggregated data include, but are not limited to, conducting analysis and generating statistics regarding the use of our Site, App, and/or Services. Additionally, we may share your Childor your student's personal information with new teachers who use the Services in their classrooms when you or your Child enrolls student, as applicable, enroll in such teachers' classes, and we may share teacher personal information with other teachers within a school using the Services. We may create and use anonymized and/or aggregated data for our own purposes by excluding information (such as your Childor your student's name) that makes the data personally identifiable to you or your student. The purposes for which we may create and use anonymized and/or aggregated data include but are not limited to, conducting analysis and generating statistics regarding the use of our Site, App and/or Services. We will not share your Childor your student's personal information in any way other than in connection with providing the Services, as described in this Children's Policy, or as directed by a teacher teacher, parent/legal guardian or school, or upon obtaining your consent. We require our third party service providers not to use your Childor your student's personal information other than to provide the services that we have requested. We will not disclose your Childor your student's personal information to any third party for that third party's own marketing purposes. Additionally, we will not knowingly use or disclose your Child's student information (whether personal information or otherwise) for behavioral targeting of advertisements to your Childsuch students. We do not sell Children's student personal information. For clarityE XHIBIT “C” DEFINITIONS De-Identifiable Information (DII): De-Identification refers to the process by which the Vendor removes or obscures any Personally Identifiable Information (“PII”) from student records in a way that removes or minimizes the risk of disclosure of the identity of the individual and information about them. The Provider’s specific steps to de-identify the data will depend on the circumstances, we may make recommendations within or through the Services of featuresbut should be appropriate to protect students. Some potential disclosure limitation methods are blurring, toolsmasking, and perturbation. De-identification should ensure that any information when put together cannot indirectly identify the student, not only from the viewpoint of the public, but also from the vantage of those who are familiar with the individual. NIST 800-63-3: Draft National Institute of Standards and Technology (“NIST”) Special Publication 800-63-3 Digital Authentication Guideline. Personally Identifiable Information (PII): The terms “Personally Identifiable Information” or “PII” shall include, but are not limited to, student data, metadata, and user or pupil-generated content on obtained by reason of the Services to use of Provider’s software, website, service, or app, including mobile apps, whether gathered by Provider or provided by LEA or its users, students, including Childrenor students’ parents/guardians. PII includes, based on their demographic information or activities on our Services. For examplewithout limitation, we may suggest a text set to a student based on a previous one at least the student has read or based on following: First Name Home Address Last Name Subject Telephone Number Email Address Discipline Records Test Results Special Education Data Juvenile Dependency Records Grades Evaluations Criminal Records Medical Records Health Records Social Security Number Biometric Information Disabilities Socioeconomic Information Food Purchases Political Affiliations Religious Information Text Messages Documents Student Identifiers Search Activity Photos Voice Recordings Videos Date of Birth Grade Classes Place of birth Social Media Address Unique pupil identifier Credit card account number, insurance account number, and financial services account number Name of the student's age parents or grade level. INFORMATION CHOICES AND CHANGES Below are some ways you can control the collection and use of your Child's information in connection with the Services. While we and others give you choices described in this policy, there are many ways web browser signals and other similar mechanisms can indicate your choice to disable tracking, and we may not be aware of or honor every mechanism. Information in the Services You may change some of your or your student's personal information stored in the Services by following the directions on the Site or App. You may send requests about your or your student's personal information, including requests to change your or your student's contact preferences and update or correct your or your student's personal information, to our contact information below. In some cases, changes about a student's personal information may have to be executed by the student's school or teacher, and in such situations, we will attempt to assist you and the school or teacher with such efforts. Behavioral Advertising Newsela does not behaviorally target advertising to Children on sites that are directed to Children or where Newsela has actual knowledge that a user is under 13. For more information about Newsela's Behavioral Advertising activities, please see the section in our general Privacy Policy titled "Interest-based or Online Behavioral Advertising". However, if you would like to opt-out of certain mechanisms for tracking on a device or web browser used by your Child, including tracking of online activities over time and across different websites, you can use one or more of the options described above in the "Interest-Based and Behavioral Advertising" section of the general Privacy Policy. If you delete your Child's cookies, use a different browser or device, or buy a new computer, you or your Child will need to renew your opt-out choice.family members General Categories:

Sharing of Personal Information. We do not share your or your Child's personal information other than as follows: • with your school or school district at their request; • with new teachers within a school that already uses Newsela or schools within a district that already uses Newsela; • with third party service providers, consultants, and other service providers who perform services for us and need access to your or your Child's information to do that work in a manner consistent with this Children's Policy (for example, our web hosting provider, third party analytics service providers and purchase processors); • to comply with laws or to respond to lawful requests and legal process; • to protect the rights and property of Newsela, our agents, users, and others including to enforce our agreements, policies, and terms of use; • in an emergency to protect the personal safety of its users or any person; • in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company, in which case the company receiving the personal information would be obligated to follow this Children's Policy. We may create, use, and disclose anonymized and aggregated data for our own purposes by excluding information (such as your Child's name) that makes the data personally identifiable to your Child. The purposes for which we may create, use, and disclose anonymized and aggregated data include, but are not limited to, conducting analysis and generating statistics regarding the use of our Site, App, and/or Services. Additionally, we may share your Child's personal information with new teachers who use the Services in their classrooms when your Child enrolls in such teachers' classes. We may create and use anonymized and/or aggregated data for our own purposes by excluding information (such as your Child's name) that makes the data personally identifiable to you or your student. The purposes for which we may create and use anonymized and/or aggregated data include but are not limited to, conducting analysis and generating statistics regarding the use of our Site, App and/or Services. We will not share your Child's personal information in any way other than in connection with providing the Services, as described in this Children's Policy, or as directed by a teacher or school. We require our third party service providers not to use your Child's personal information other than to provide the services that we have requested. We will not disclose your Child's personal information to any third party for that third party's own marketing purposes. Additionally, we will not knowingly use or disclose your Child's information (whether personal information or otherwise) for behavioral targeting of advertisements to your Child. We do not sell Children's personal information. For clarity, we may make recommendations within or through the Services of features, tools, and content on the Services to students, including Children, based on their demographic information or activities on our Services. For example, we may suggest a text set to a student based on a previous one the student has read or based on the student's age or grade level. INFORMATION CHOICES AND CHANGES Below are some ways you can control the collection and use of your Child's information in connection with the Services. While we and others give you choices described in this policy, there are many ways web browser signals and other similar mechanisms can indicate your choice to disable tracking, and we may not be aware of or honor every mechanism. Information in the Services You may change some of your or your student's personal information stored in the Services by following the directions on the Site or App. You may send requests about your or your student's personal information, including requests to change your or your student's contact preferences and update or correct your or your student's personal information, to our contact information below. In some cases, changes about a student's personal information may have to be executed by the student's school or teacher, and in such situations, we will attempt to assist you and the school or teacher with such efforts. Behavioral Advertising Newsela does not behaviorally target advertising to Children on sites that are directed to Children or where Newsela has actual knowledge that a user is under 13. For more information about NewselaXxxxxxx's Behavioral Advertising activities, please see the section in our general Privacy Policy titled "Interest-based or Online Behavioral Advertising". However, if you would like to opt-out of certain mechanisms for tracking on a device or web browser used by your Child, including tracking of online activities over time and across different websites, you can use one or more of the options described above in the "Interest-Based and Behavioral Advertising" section of the general Privacy Policy. If you delete your Child's cookies, use a different browser or device, or buy a new computer, you or your Child will need to renew your opt-out choice.