Privacy Policy

C.H.A.P. PRIVACY POLICY

LAST UPDATED: June 2023

This C.H.A.P. Privacy Policy explains how The C.H.A.P. Foundation Inc. (“CHAP”, “we,” or “us”) collects, uses, discloses, and otherwise processes personal information about you. CHAP is a non-profit organization that strives to prepare students to be calm, humble, and patient while enhancing, enlightening, and enriching their minds, bodies, and life force to be extraordinary. This Privacy Policy applies to information we collect when you access or use our websites, mobile applications, and other online products and services that link to this Privacy Policy (collectively, our “Services”), or when you otherwise interact with us, such as through our customer support channels or on social media.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. If we make material changes, we will provide you with additional notice (such as by adding a statement to the Services or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

CONTENTS

Collection and Use of Information

Analytics

Disclosures of Information

Children’s Privacy Notice

Your Choices

Transfers of Information to the United States and Other Countries

Contact Us

COLLECTION AND USE OF INFORMATION

The information we collect about you depends on how you interact with us or use our Services, and in some cases, you may direct us to use or consent to the use of personal information for additional purposes. In this section, we describe the categories of information we collect and the business purposes for which we use your information.

Categories of Personal Information

Uses of Personal Information

Identifiers--user first name, email, IP address, device ID, username; parent or guardian full name, email, payment card information, IP address, device ID

Customer records-- user first name, email; parent or guardian full name, email, payment card information

· Process your transactions

· Maintain and improve our products and Services

· Personalize the Services;

· Send you technical notices, security alerts, support messages, and other transactional or relationship messages;

· Communicate with you about products, services, and events offered by CHAP and others, and provide news and information we think will interest to you

· Comply with legal obligations

Protected classification characteristics under state or federal law--age [gender, ethnicity]

· Comply with legal obligations

Commercial information--services purchased, purchasing history

Internet or other similar electronic network activity--device ID, IP address, online identifier, mobile network information, browser type, usage data, browsing history, user’s interaction with website or app

· Provide, maintain, and improve our products and Services

· Personalize the Services in order to suggest the appropriate meditations and mindfulness exercise

· Monitor and analyze trends

· Carry out internal operations that are reasonable in the context of your relationship with us

Education information--records maintained by an educational agency, including grades and school reports[PC4]

Inferences--inferences reflecting consumer preferences, characteristics, behavior, attitudes

Sensitive personal information--payment card information, race, ethnicity, health information relating to feelings and moods

· Provide, maintain, and improve our products and Services

· Personalize the Services in order to suggest the appropriate meditations and mindfulness exercise

SOURCES OF INFORMATION

We collect your information when you provide it to us directly or directly from your device when you interact with our Services. We collect certain information such as inferences indirectly from you. For example, we collect information directly from you when you create an account, fill out a form, submit or post content through our Services, make a purchase, request customer support, or otherwise communicate with us. If you make a purchase from us, we work with a third-party payment processor to collect and process your payment information.

Information Collected by Cookies and Similar Tracking Technologies: [PC6] We use tracking technologies, such as cookies, pixels, and SDKs to collect information about your interactions with the Services. These technologies help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. For more information about the cookies and other tracking technologies we use, and the choices available to you, see the Your Choices [link] section below.

INFORMATION WE DERIVE

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address. We may also derive various insights from the information submitted by and about you through our Services.

· Monitor and analyze trends, usage, and activities in connection with our products and Services;

· Target advertisements to you on third-party platforms and websites (for more information and to opt out, see the Your Choices section below);

· Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;

· Detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and help protect the rights and property of CHAP and others;

· Comply with our legal and financial obligations;

· Carry out internal operations that are reasonable in the context of your relationship with us;

· Create de-identified, anonymized, or aggregated information; and

· Carry out any other purpose described to you at the time the information was collected.

ANALYTICS

We engage others to provide analytics, serve advertisements, and perform related services across the web and in mobile apps. These entities may use cookies, web beacons, SDKs, device identifiers, and other technologies to collect information about your use of our Services and other websites and mobile apps, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information is used to analyze and track data, determine the popularity of certain content, and better understand your activity.

DISCLOSURES OF INFORMATION

We disclose the categories of personal information described above in the Collection of and Use of Information section in the following ways:

· We disclose personal information to vendors, service providers, contractors, and consultants that need this information and use this information on our behalf to provide services to us, such as companies that assist us with web hosting, payment processing, fraud prevention, and customer service.

· We disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

· We disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of CHAP, our users, the public, or others.

· We disclose personal information to our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

· We disclose personal information in connection with, or during negotiations of certain corporate transactions, including the merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

· Personal information is disclosed between and among CHAP and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.

· With your consent or at your direction.

· We also disclose aggregated or de-identified information that cannot reasonably be used to identify you.

CHILDREN’S PRIVACY NOTICE

Because our mission is to improve mindfulness in kids, we offer our Services to kids, including those under 13 years old (“Kids”), and collect certain personal information from them. This notice is intended to inform parents and legal guardians (collectively, “Parents”) about our privacy practices with respect to Kids’ personal information, including how we collect personal information relating to Kids through our Services, why we collect it, how we disclose it, and what we do with it. We obtain verifiable consent from Parents before collecting personal information from Kids as required by applicable law.

Collection and Use of Information from Kids

We collect the following information from Kids and use it for the purposes indicated below with the required parental consent. We will not condition a Kid’s participation in any of our Services on the disclosure of more personal information than is reasonably necessary to participate in that Service.

Personal Information Collected from Kids

Uses of Personal Information

Identifiers--first name, email, IP address, device ID, username

· Provide, maintain, and improve our products and Services

· Personalize the Services

Protected classification characteristics under state or federal law--age

· Comply with legal obligations

Internet or other similar electronic network activity--device ID, IP address, online identifier, mobile network information, browser type, usage data, browsing history, user’s interaction with website or app

· Provide, maintain, and improve our products and Services

· Personalize the Services in order to suggest the appropriate meditations and mindfulness exercise

· Maintain the security and integrity of our Services

Inferences--inferences reflecting consumer preferences, characteristics, behavior, attitudes

· Provide, maintain, and improve our products and Services

· Personalize the Services in order to suggest the appropriate meditations and mindfulness exercise

Sensitive personal information--health information relating to feelings and moods

· Provide, maintain, and improve our products and Services

· Personalize the Services in order to suggest the appropriate meditations and mindfulness exercise

Disclosure of Kids’ Personal Information

· We disclose Kids’ Personal Information to service providers to the extent necessary to provide our Services.

· We do not sell, rent, or lease Kids’ Personal Information.

· Our Services do not enable Kids to make their personal information publicly available.

· We disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet law enforcement requirements or protect the safety of the Kid.

· We disclose personal information to our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

· We disclose personal information in connection with, or during negotiations of certain corporate transactions, including the merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

Our Practice for Notifying and Obtaining Parents’ Consent When Collecting Personal Information from Kids, including How Parents Can Revoke Consent

CHAP collects Parents’ names and online contact information directly from the Parent and if a Kid tries to register for our Services, from the Kid, in order to obtain the Parent’s consent. Parental consent is required for the collection, use, or disclosure of Kids’ personal information, and CHAP will not collect, use, or disclose any personal information from a Kid if the parent does not provide such consent.

We provide notice of our privacy practices to and collect verifiable consent from Parents through a variety of means depending on the context and purpose for which we collect personal information from Kids. In some instances, we will provide notice through our Website or an email and obtain consent from a parent at an email address or phone number that is not provided by a Kid. In other situations, we may collect consent by engaging in a monetary transaction with a Parent or by obtaining written signed consent from a Parent. A Parent can review a Kid’s personal information, direct us to delete it, and refuse to allow any further collection or use of a Kid’s information. To exercise any of these rights, please contact us help@chap.care. The Parent must provide us with enough information to verify the identity and locate their Kid’s account.

All Operators [PC9] that Collect or Maintain Information from Kids Through the Services

The C.H.A.P. Foundation Inc.

8 The Green STE A Dover, DE 19901

help@chap.care

YOUR CHOICES

ACCOUNT INFORMATION

You may update and correct certain account information at any time by emailing us at help@chap.care. If you wish to delete your account, please email us at help@chap.care, but note that we may retain certain information as required by law or for our legitimate business purposes.

COOKIES

Depending on where you are located, most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

CHAP is headquartered in the United States and we have operations and vendors in the United States and other countries. Therefore, we and those that perform work for us may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. Where required by law, we provide adequate protection for the transfer of personal data in accordance with applicable law.

CONTACT US

If you have any questions about this Privacy Policy, please contact us by email at help@chap.care or by certified mail addressed to 8 The Green STE A Dover, DE 19901.