Nutrislice, Inc. Nutrislice school menu websites and apps are built for and made available to the general public, including parents, administrators, students and others. With a few exceptions for internal operations, analytics, and back-end site functionality that are noted below, we do not gather personal information about users of our sites, and we do not share the limited amount of information that we do collect with anyone other than the services that are critical for collecting data to monitor or support our internal operations.

A NOTE ABOUT CHILDREN AND COPPA

Under the Children’s Online Privacy Protection Act (“COPPA”), children under the age of 13 receive special protections when it comes to privacy. Nutrislice makes every effort to safeguard the privacy of children and maintain compliance with COPPA. Because our publicfacing websites do not collect any personal information other than passive collection of persistent identifiers for internal operations purposes, we believe our public-facing websites are safe for children and compliant with COPPA.

Some of our mobile apps allow our clients to create and collect surveys that they have created via a back-end interface that is not available to the general public. However, children under 13 are prevented by the respective “app stores”, Google Play and Apple iTunes, and the terms of service of our apps in these stores, from downloading and using any Nutrislice mobile app published by Nutrislice without a parent, guardian or authorized intermediary actually performing or authorizing the installation and supervising the usage. Schools, school districts, or other organizations that supervise children must not utilize Nutrislice survey software with children under 13 unless they take full responsibility for and comply with any applicable requirements of COPPA in order to protect the children’s privacy. This includes not using Nutrislice software to conduct surveys that collect Personal information from children under 13 unless COPPA requirements are met. Under the COPPA guidelines, “COPPA does not preclude schools from acting as intermediaries between operators and parents in the notice and consent process, or from serving as the parent’s agent in the process of collecting personal information online from students in the school context[,]” and “COPPA does not apply where a school has contracted with an operator to collect personal information from students for the use and benefit of the school, and for no other commercial purpose.” See https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions#Schools for more information about Schools and COPPA.

TYPES OF DATA NUTRISLICE OR THIRD PARTIES COLLECT FROM NUTRISLICE SITES AND APPS

A. Persistent identifiers: IP Addresses, Device ID’s, Cookies
In order to support the internal operations of our apps and websites and for no other purpose, Nutrislice and the server-related service providers that we use for the operations of our software may passively collect persistent identifiers, which may include IP addresses, device ID’s, and cookies. We use this data to monitor our software’s usage and performance, and to generate internal analytics and reports regarding the operations of our site. We may use third party service providers to assist us in collection of this data for internal purposes.

B. Google Analytics
We use the Google analytics service to anonymously track the usage of our websites and apps. This includes tracking regional location of users (not using precise GPS data), device and browser types, and tracking what users do on our sites and when. This is primarily for internal operations, but may share this anonymous, aggregated information with our customers (generally school districts). We do not use Google analytics in a way that gathers or utilizes personally identifying information.

C. Surveys created by Third Parties
Nutrislice provides mobile apps and/or web site services that facilitate the creation and conducting of surveys to schools and other thirdparty entities. Nutrislice prohibits usage of survey functionality in Nutrislice Software to collect personal information from anyone for any usage except for internal use by our customers themselves. Additionally, customers are prohibited from collecting any personal information from children under the age of 13 unless the school is (i) operating as an intermediary between parents and Nutrslice in the notice and consent processes required by COPPA, or as an agent for the parent in the process of collecting the personal information; or (ii) the information is gathered for the sole use and benefit of the school and for no commercial purpose, which are permissible uses of survey software under COPPA. Survey creators/conductors are responsible for the content of the surveys they create and conduct through Nutrislice software, including making sure they don’t collect personal information in violation of privacy laws or collect personal information from children under the age of 13 without complying with COPPA.

D. Personal Information for Registered Access to Non-public functionality
For certain non-public areas of our sites, such as those that permit users to create and administer content (including surveys), we may ask registered users to provide standard personal identifying information such as name, username, phone number, email address, etc. Users of these portions of the site must be at least 13 years old.

E. Mobile Polling Functionality and Digital Signage
As an add-on module to its digital signage product, Nutrislice provides “SMS polling”, in which mobile phone users may respond to polls or other questions via SMS. When an individual sends an SMS message to a poll provided by Nutrislice, their phone number will be stored for a time in our database, along with their response. Their phone number will not be shared or made available to any entity other than Nutrislice, for internal purposes only, and to the Nutrislice client that is sponsoring the signage and administering the polls. Nutrislice does not knowingly provide SMS Polling to school audiences where children under the age of 13 are expected participants, and instructs schools not to enable SMS polling for groups where children under 13 are expected to be participants or to gather personal information from any group via SMA Polling.

F. Personal Information Not Collected by Nutrislice
Nutrislice does not collect or store names, usernames, geolocational (GPS) information, addresses, social security numbers, personal photos, video & audio, or other personal information not described above from non-registered users of our public-facing sites and menu apps.

WHAT WE DO WITH COLLECTED DATA

Nutrislice does not use passively collected persistent identifiers including IP addresses, cookies and Device ID’s for any reason other than to support our internal operations. IP address and cookie data may be passed to various third party software service providers that are used by Nutrislice to manage, track, or support internal operations, including Heroku, New Relic, Papertrail, and Google Analytics.

Nutrislice does not share survey data collected by our clients with any third party. Clients using survey functionality are instructed to and agree to maintain strict compliance with COPPA and any other applicable privacy regulations in their usage of Nutrislice software platforms and with their usage and sharing of any personal information that they use Nutrislice software to gather.

For portions of our software that require a user to register an account and provide personal information, we do not share or use any of this personal information other than for internal purposes and to provide you our services.