Effective Date: March 1, 2024

If you reside in the United States, then the personal data provided to, or collected by, our Services is controlled by Collaborative Learning, LLC. 30 N. Gould St. Suite R, Sheridan, WY 82801. If you have any concern about providing information to us or having such information used in any manner permitted in this Privacy Policy, you should not visit our websites, apps or otherwise use our Services.

This Privacy Policy describes the types of information we may collect from you or that you may provide to us when you visit the CLARE.com websites or use our services located at www.passtheare.com (the “Websites”), or a CLARE mobile or desktop application (an “App”) (collectively, the “Services”), and our practices for collecting, using, maintaining, protecting and disclosing such information. This Privacy Policy applies to information we collect: (i) through our Services, and (ii) in text and electronic messages between you and our Services.

By accessing or using our Services, you agree to this Privacy Policy.

IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE OUR SERVICES.

Please read the information below:

We collect several types of information about visitors and/or users of our Services. We may collect this information either directly when you provide it to us or automatically as you navigate through the Websites or App.

(a) We will collect and process your personal data when you register for a Service/create an account, subscribe to a newsletter, submit feedback, enter a contest, fill out a survey, or send us a communication. When ordering products or services on the Websites or App, you may also be asked to provide a credit card number and other payment-related information. Depending upon the activity, some of the information we ask you to provide is required to use the Services (e.g. registering an account) and some is voluntary. If you do not provide data when needed for a particular activity, you will not be able to engage in that activity.

We also collect your Internet Protocol (“IP”) address. We use your IP address to diagnose problems with our servers and/or software, to administer our Services, and to gather demographic information.

(b) We may collect certain information that does not by itself identify a specific individual. Such information tells us about your equipment, browsing actions, and the resources that you access and use through the Services, such as your operating system and browser type. We use analytics and similar services, as explained in our Cookie Policy to help us to deliver a better and more personalized service to users by enabling us to estimate usage patterns, customize our Services according to your individual preferences, and speed up your searches.

(c) When you download our App and use our Services, we automatically collect information on the type of device you use and the operating system version, so we know the best version of the application to provide you. We do not ask you for, access, or track any location-based information from your mobile device at any time while downloading or using our App or Services.

(d) When you contact us for Customer Support we may collect additional information to resolve your issue.

By submitting your personal data, you agree to the transfer, storing and processing of your data within and outside of the country where you reside. We will take reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

We use information held about you in the following ways:

• To present content from our Services in an effective manner for you and for your computer or mobile device

• To provide you with information, products or services that you request from us or which we feel may interest you

• To carry out our obligations arising from any contracts entered into between you and us, including for billing and collection

• If you pay for Services using a credit card, we will transmit your credit card data to the appropriate credit card company and/or credit card payment processing company

• To allow you to participate in interactive features of our Services, when you choose to do so

• To contact you about our Services

• In any other way we may describe when you provide the information or when we prompt you regarding a new use of information about you.

We will share your personal data with third parties only in the ways that are described in this Privacy Policy. We do not sell, trade, rent or disclose your information to others, except as provided herein:

(a) We provide and support some of our Services through contractual arrangements with service providers and other third parties. We and our service providers use your personal data to operate our Websites and to deliver Services. For example, we must release your credit card information to the card-issuing bank to confirm payment for products and services purchased on our Websites; and provide order information to third parties that help us deliver the Services.

(b) We will also disclose personal data in the following circumstances: (i) if it is required by law enforcement or judicial authorities, or to cooperate with a law enforcement investigation; (ii) if we have a good faith belief that we are required or permitted to do so by law or legal process; (iii) to protect our rights, reputation, property or the safety of us or others; (iv) to defend or enforce our rights or your obligations; (v) if mandatory professional standards require the disclosure; (vi) to a third party with your prior consent to do so; or (vii) if we are under a duty to disclose or share your personal data in order to enforce or apply any contracts or agreement that may exist between you and us including this Privacy Policy, our Website Use Policy and our Terms of Service This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

(c) In the event that Collaborative Learning, LLC., decides to sell all or part of its assets or enter into a merger, we reserve the right to include your data, including personal data, among the assets transferred to the acquiring or surviving company.

We offer settings to control and manage the personal data we have about you, including the ability to:

Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).

Amend or Rectify Data: You can edit some of your personal data through your account. You can also ask us to amend your data in certain cases, particularly if it is inaccurate.

Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).

Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

You can learn more about how to make these requests in Sections 6 and 7 of this Privacy Policy provide more information about making these requests. You may also contact us using the contact information in Section 15, and we will consider your request in accordance with applicable laws.

You may change your personal data associated with your account in your “Profile & Settings”

You may also access, request deletion, and correct your personal data by submitting a data request through Customer Support or by writing to us at the addresses at the end of this Privacy Policy.

If your subscription lapses (you stop paying for it), we will retain your personal data for a reasonable period of time in case you choose to re- subscribe.

You may choose to close your account in which case we will delete your information, including your learning history, within 60 days of your request. However, we may retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), comply with contractual obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Service or Website Use Policy or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed. You can close your account by contacting Customer Support.

If you would like to access the information that we have about your use of and access to CLARE Services, please request it by writing to us at the address at the end of this Privacy Policy. You can also ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., your personal data is inaccurate or unlawfully held) by submitting a data request through Customer Support or by writing to us at the address at the end of this Privacy Policy.

Learn more about certain rights and practices we describe in this Privacy Policy

Note: Collaborative Learning, LLC., data centers storing personal data are currently located in the US.

CLARE (PASSTHEARE.COM) DELETION PRACTICES

The following are Collaborative Learning, LLC., current practices regarding deletion of consumer account data.

· If your CLARE subscription lapses (you stop paying for it), we will keep your personal data for up to two years after the subscription term ends (subject to some exceptions set forth in the Collaborative Learning, LLC. Privacy Policy and potential sunsetting of passtheare.com described below). If you decide to re-subscribe during this period your data is retained, you may be able to pick up where you left off and see your learning course viewing history (subject to potential sunsetting of CLARE described below).

· If you choose to close your CLARE account (which is different than ending a subscription), we will delete your personal data after cancellation (subject to some exceptions set forth in the passtheare.com Privacy Policy), usually within sixty days.

· If (and when) we sunset passtheare.com, we plan to delete your learning history and other data for your privacy, and you will no longer have access to your learning history and other data once deleted. However, during the sunset process, your data may be retained beyond the standard periods to extend your access prior to deletion.

You can access some of the information that we collect about you. For example, by logging into your account, you can access information regarding recent orders from the Websites; certain personal data we maintain about you; your communication preferences; and your payment settings.

You can ask us for a copy of your personal data in machine readable format by submitting a data request by writing to us at the address at the end of this Privacy Policy, and we will consider your request in accordance with applicable laws.

With respect to your communications preferences, you can unsubscribe from our blog by selecting “unsubscribe” at the bottom of any blog post you receive. If your email address has changed and you would like to continue to receive newsletters, you will need to access your account, update your email address information in your account, and sign-up again for the newsletter.

Occasionally we may send out emails concerning website disruptions.

You also have choices with respect to cookies, as described in our Cookie Policy. By modifying your browser preferences, you may be able to choose to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies some parts of our Websites may not work properly in your case.

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to deliver the Services you have requested) and “legitimate interests.”

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.

Learn more about certain rights and practices we describe in this Privacy Policy

Note: Collaborative Learning, LLC., data centers storing personal data are currently located in the US.

CLARE (PASSTHEARE.COM) DELETION PRACTICES

The following are Collaborative Learning, LLC., current practices regarding deletion of consumer account data.

• If your CLARE subscription lapses (you stop paying for it), we will keep your personal data for up to two years after the subscription term ends (subject to some exceptions set forth in the Collaborative Learning, LLC. Privacy Policy and potential sunsetting of passtheare.com described below). If you decide to re-subscribe during this period your data is retained, you may be able to pick up where you left off and see your learning course viewing history (subject to potential sunsetting of CLARE described below).

• If you choose to close your CLARE account (which is different than ending a subscription), we will delete your personal data after cancellation (subject to some exceptions set forth in the passtheare.com Privacy Policy), usually within sixty days.

• If (and when) we sunset passtheare.com, we plan to delete your learning history and other data for your privacy, and you will no longer have access to your learning history and other data once deleted. However, during the sunset process, your data may be retained beyond the standard periods to extend your access prior to deletion.

For certain services, we collect information under the direction of our clients (e.g., an entity that subscribes to the Services for use by the entity’s personnel). In this respect, we act as a data processor under applicable laws. We will retain and use this personal data as necessary to comply with our legal obligations, resolve disputes, and fulfill our obligations under those

agreements with the data controllers. In these cases, the data controller will have its own privacy policy that applies to your data, including personal data. We encourage you to read their privacy policies to learn more about their data practices.

Access by you to your account is available through a password and/or unique username selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone, that you change your password often using a combination of letters and numbers, and that you ensure you use a secure web browser. We cannot be held accountable for activity that results from your own neglect to safeguard the secrecy of your password and username. If you share a computer with anyone, you should always log out of your account after you are finished in order to prevent access to your information from subsequent users of that computer.

Please notify Customer Support as soon as possible if your username or password is compromised.

Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal data, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this Website cannot be guaranteed and we shall have no liability to you or any third party for loss, misuse, disclosure or alteration of such information; and (c) any such information and data may be viewed or tampered with in transit by a third party.

In the unlikely event that we believe that the security of your personal data in our control may have been compromised, we will try to notify you. To the extent you have provided us with your email address, we may notify you by email and you agree to our use of email as a means of such notification. If you prefer for us to use another method to notify you in this situation, please contact Customer Support with the alternative contact information you wish to be used.

When you use our Websites we may use cookies and other technologies in order to facilitate and customize your use of our Services. Learn more about your choices regarding the use of these technologies and about our response to “do not track” signals in our Cookie Policy.

We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the App, the events that occur within the App, aggregated usage, performance data, and where the App was downloaded from. We do not link the information we store within the analytics software to any personal data you submit within the App.

We currently do not share personal data with third parties for their direct marketing purposes without your permission.

It is our policy to post any changes we make to our Privacy Policy on this page (with a notice that the Privacy Policy has been updated on the Websites). The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Websites and this Privacy Policy to check for any changes.

Your continued use of the Services after such modifications will constitute your agreement to the updated terms of the modified Privacy Policy.

If you have questions or complaints regarding this Privacy Policy, please first contact Customer Support online. You can also reach us by physical mail at the addresses below.

Collaborative Learning, LLC.

Attn: Legal Dept. (Privacy Policy and User Agreement)

30 N. Gould St. Suite R

Sheridan, WY 82801

800-211-4345