Onomatamore, LLC Privacy Notice

Last Updated: December 3, 2025

I. Introduction

Onomatamore, LLC ("we," "us," or "our") provides an online spelling bee preparation program for students in grades 1-8 ("Services"). This Privacy Notice ("Notice") describes how we collect, use, share, and disclose information about you in the course of operating our business, including when you:

• Visit our website, http://www.onomatamore.com ("Site");
• Use our online spelling bee preparation program for students in grades 1-8; or
• When you engage with us in other related ways, including sales, marketing or events.

If you do not agree with our policies and practices, please do not use our services. If you still have any questions or concerns, please contact us at support@onomatamore.com.

II. Types of Information We Collect

Onomatamore, LLC collects certain personal information about you and your use of our Services. "Personal information" is defined by local law. Generally speaking, this may include information that identifies, relates to, describes, or can reasonably be linked, directly or indirectly, to a specific natural person. Depending on local law, certain information may be excluded from the definition of "personal information," including anonymous, deidentified, or aggregated information.

a. Information You Provide to Us

The amount and type of personal information we collect about you depends on your interactions with us. For example, we may collect personal information if you register for an account, if you contact us, interact with our chat feature or otherwise communicate with us.

Personal Information. The collection and use of Personal Information may differ based on whether you are School District User or an Individual or Family User. Depending on your interaction with us, we may collect the following categories of personal information:

• School Names
• School District Name and Address
• The Name and Contact Information of the District-Level IT Officer, and the District-Level officer who is authorized to approve the use of third-party software for classroom use. This includes:
  • Full Name
  • Email address
  • Job Title
• Parent or Guardian's First and Last Name
• Parent or Guardian's Email address
• Student First and Last Name
• Student grade level
• Log-in Credentials as assigned by Onomatamore, LLC
• Student Word Module Test Score Data
• Names of School spelling bee winners
• Messaging between School Staff, Parents and Onomatamore, LLC Staff
• One-way messaging from Students to Onomatamore, LLC
• Communication or Messages sent through the chat feature
• Surveys completed by School staff
• User Survey Responses completed by Students to provide feedback on the service
• We do not request, collect, or process sensitive information.

When you provide us with personal information, you agree to provide accurate, complete, and true information. You agree to not use a false or misleading name that you are not authorized to use.

Payment Data. For subscribers on a paid plan, our third-party payment processor, Stripe, may collect data necessary to process your payment. We do not collect, store or use any payment data on our Site. You may learn more about their privacy notice at https://stripe.com/privacy. For districts in the Onomatamore School Enrollment Program ("OSEP") access is provided free of charge for the current school year and no payment data will be collected.

b. Automatically Collected Information

In addition to the information that you voluntarily provide to us, we may automatically collect information that your web browser provides to us. The categories of personal information that we may automatically collect include:

• Site usage while in testing mode, such as how long students take to complete assessments and individual student scores which will be used for auditing and to allow for the creation of a general results scoreboard for each teacher. There is no sharing between schools or students.
• Cookies and other tracking technologies. We and our service providers or third parties engaged on our behalf may use cookies and similar tracking technologies (collectively, "Cookies") to collect information from and store information on your device when you use, access, or otherwise interact with our Site. We may also use third-party cookies on the public-facing Site.

We use Functional Cookies and Performance Cookies to keep you logged into your account, for the website to function properly, and to allow us to count visits and traffic sources. All information collected by these Cookies is aggregated and therefore anonymous. You may set your browser preferences to opt-out of cookies. Note that opting out or blocking functional cookies may impact your use of the Site.

c. Information From Other Sources

We do not collect information from any third-party sources.

III. How We Use and Process the Information We Collect

We process and use your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation, authentication and provide our Services. Information you provide to us allows us to create credentials and enables you to use your account. We may also use your information for authentication, security, and fraud prevention. We may use your information to improve our Services.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with our Services.
• To record and report user test scores. Testing students is integral to our Services and we may process your information to allow teachers to see their students' progress during the spelling bee season.
• As required by law. We may process, use or share your information for other reasons when necessary to comply with local, state or federal laws.

IV. How We May Share the Information We Collect

Generally, we do not share with third-parties information we have collected from our users. We may share information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of any merger, sale of company assets, financing or acquisition of our business to another company.
• As required by law. We may share or transfer your information when required to do so by local, state or federal law; to respond to requests for public and government authorities such as a judicial proceeding, court order or other legal process; to enforce our Terms; to protect our rights, or the privacy, safety or property of you or others; and to investigate, prevent or take action regarding any illegal activities, to verify the authenticity of any transaction, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms or this Notice, or as evidence in legal proceedings.
• Google Analytics. We may share your information with Google Analytics to track and analyze visitor traffic to our homepage and marketing webpages. We do not share information in the student accounts with Google Analytics. You can view Google's privacy policies and learn about opt-out options by visiting: https://policies.google.com/privacy
• Tawk.to. Onomatamore uses a third-party company called tawk.to, Inc. to allow visitors to the site to ask questions and chat with us. This company only collects the information put into the chat and will compile that information into a dashboard which is currently only available to Onomatamore, LLC and its contractors. You can view tawk.to's privacy policies at www.tawk.to/privacy-policy/.

V. How Long We Keep Your Information

We will only keep your personal information for as long as it is necessary for the purposes set out in this Notice, unless a longer retention period is required or permitted by law. In no instance will we keep your personal information for longer than the period of time in which you have a user account with us. When we have no ongoing legitimate business need to process your information, we will either delete or anonymize such information, or if this is not possible, we will securely store your personal information and isolate it from any further processing until deletion is possible.

VI. How We Keep Your Information Safe

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have an operational need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We strive to protect your information by working toward General Data Protection Regulation (GDPR) compliance and have put in place procedures and a data breach reporting policy to deal with any suspected personal data breach. We will notify you and any applicable regulator of a breach where we are legally required to do so. However, no data transmission over the internet or information storage technology can be guaranteed 100% secure. We cannot promise that your use of our Services will be completely safe. We encourage you to use caution when using the internet.

VII. Your Privacy Rights

Onomatamore is intended for use in the United States only. Based on the applicable laws of your state or territory of residence in the United States, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information or the right to limit use of, opt out, or require prior consent to process sensitive personal information. These rights may be limited in some circumstances by applicable law. To submit a request to exercise your rights, and if applicable, to appeal a denial of any of your rights please contact us at support@onomatamore.com.

VIII. Supplemental Jurisdiction Rights

The laws where you reside may give you certain additional rights with respect to your personal information. These rights only apply to the extent that both you and Onomatamore, LLC are subject to such laws. For users in the following jurisdictions, please see the relevant information below.

• California. You may have certain additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020.
• Other US Jurisdictions. The laws of your state of residency may afford you certain rights with respect to the collection, use and disclosure of your personal information.
• Foreign Jurisdictions. Our Services are not intended for use outside of the United States.

IX. Do Not Track Disclosures

We follow the standards explained in this Privacy Notice and implement "Do Not Track" requests or similar web browser settings.

X. Children's Online Privacy Protection Act ("COPPA") Notice

Our Services are designed to be used by Children, but all accounts must be registered by a parent or legal guardian ("Parent" or "Parents") or a School District acting with the verifiable consent of a Parent. Each School District is responsible for obtaining verifiable Parent consent prior to registering a student and providing a copy of such consent to us upon request.

COPPA requires us to inform parents and legal guardians about our practices for collecting, using, and disclosing personal data from children under the age of 13. This notice provides additional details regarding our practices on our Services.

• We only collect the minimal amount of information necessary for children to use our Services. Specifically, we collect; name, grade, log-in credentials and other account related information as necessary to facilitate educational activities and recognize achievements.
• The Site does not require children to disclose more information than is reasonably necessary to participate in its activities.
• The information collected from children is solely for authorized educational purposes, including enabling login access and tracking progress.
• The site does not use children's personal information for any external commercial purposes, including marketing or advertising. The site will make users aware of the opportunity to subscribe to our Services during the spelling bee offseason and, in the future, subscribe to other content we develop outside of the school program content.
• We may use the non-personally identifiable data we collect to improve the Services and to deliver a better and more personal experience.
• We retain information in a form which permits identification of a child for as long as necessary to provide the Services in which the child is participating, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements.
• We may disclose de-identified, aggregated information about many of our users, and data that does not identify any individual or device.
• In addition, we may disclose children's information (i) to third parties we use to provide or support our Services; (ii) if we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request; (iii) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our company, our customers or others, including to protect the safety of a child, protect the safety and security of the Services; or enable us to take precautions against liability; or (iv) to law enforcement agencies or for an investigation related to public safety.

At any time, and upon providing proper identification, parents may access and review their child's personal information maintained by us, request that we update or delete such information, and/or refuse further collection or use of their child's information. Parents may contact Onomatamore, LLC at support@onomatamore.com.

XI. Additional Information

We follow all requirements under the Federal Educational Rights and Privacy Act ("FERPA") and are treated as a "School Official" under FERPA.

If your District is a subscriber to the National Data Privacy Agreement (NDPA), Onomatamore, LLC is willing to agree to the standard terms of the most recent version of the National Data Privacy Agreement relevant to your jurisdiction. Onomatamore will not negotiate outside of the standard terms.

In the event that a Student NDPA is signed by Onomatamore, LLC and the terms are in conflict with this Notice, the language of the NDPA shall control.

XII. Changes to This Privacy Notice

We may modify this Notice from time to time, in our sole discretion. When any such updates are made, we shall revise the "Effective Date" above and post the new Notice version. We recommend that you review the Privacy Notice each time you visit and/or use the Services in order to stay informed of our ongoing practices.

XIII. How to Contact Us

If you have questions or comments about this notice, you may contact us using the following information: