Privacy Policy

§1

Introduction

This Privacy Policy explains how XYZ Ventures, LLC ("First Dollar School," "we," "us," or "our") collects, uses, shares, and protects personal information in connection with the website located at www.firstdollarschool.com (the "Site"), our online application and enrollment system, our tuition payment portal, and our student member portal known as "The Stand" (collectively, the "Services").

First Dollar School is an entrepreneurship institution serving young people ages 9 through 22. Because our Services are designed for families with children under the age of 13, we comply with the Children's Online Privacy Protection Act ("COPPA") and treat the privacy of children with particular care. Section 7 of this Policy describes our practices regarding children.

By using the Services, you agree to the practices described in this Policy. If you do not agree, please do not use the Services.

§2

Who This Policy Applies To

This Policy applies to three categories of individuals:

1. Visitors. Anyone who browses the Site.
2. Parents and Legal Guardians ("Parents"). Adults who submit a waitlist, contact, application, or enrollment form, who pay tuition, or who create and manage an account on behalf of a child.
3. Students. Children and young adults ages 9 through 22 who are enrolled in a First Dollar School program and who access The Stand portal under a parent-authorized account.

§3

Information We Collect

3.1 Information You Provide

We collect information that you submit to us directly, including:

1. Contact and Waitlist Information. Parent name, email address, phone number, ZIP code or city, the child's first name and age, and any free-text notes you include.
2. Application Information. Parent and child names, dates of birth, mailing address, email, phone, school or grade level, program track preferences, short-answer essays, uploaded documents, and any references or supporting materials submitted as part of an application.
3. Enrollment and Account Information. Login credentials, account profile details, emergency contacts, photo/media release status, and other information required to complete enrollment.
4. Payment Information. Billing name, billing address, payment method, and transaction history. Card numbers and bank account numbers are submitted directly to our third-party payment processor (e.g., Stripe) and are not stored on our servers.
5. Student Submissions in The Stand. Once enrolled, a student may submit text, images, business plans, pitch materials, sales logs, peer feedback, and similar content as part of program participation.
6. Communications. Records of emails, messages, support requests, and other communications you send to us.

3.2 Information Collected Automatically

When you use the Site, we and our service providers may automatically collect:

1. Device and browser information (browser type, operating system, screen resolution, language).
2. Internet Protocol (IP) address and approximate geographic location derived from it.
3. Pages viewed, links clicked, referring URLs, session duration, and other usage data.
4. Cookies, pixels, web beacons, and similar tracking technologies. See Section 9.

3.3 Information From Third Parties

We may receive information from analytics providers, advertising platforms, payment processors, identity verification services used to obtain verifiable parental consent, and from people who refer you to us.

§4

How We Use Information

We use personal information to:

1. Operate, maintain, and improve the Services.
2. Process applications, enrollments, payments, refunds, scholarships, and financial aid.
3. Communicate with Parents about a child's application, enrollment, attendance, progress, and program logistics.
4. Provide and personalize educational experiences in The Stand, including coursework, milestones, and feedback.
5. Verify parental identity and obtain verifiable parental consent before collecting information from a child under 13.
6. Send marketing communications to Parents about programs, events, and updates. Parents may unsubscribe at any time.
7. Detect, investigate, and prevent fraud, abuse, security incidents, and violations of our Terms of Use.
8. Comply with legal obligations, court orders, and regulatory requirements.
9. Conduct internal research, analytics, and program evaluation, generally using de-identified or aggregated data.

We do not sell personal information, and we do not use student data from The Stand to deliver targeted advertising.

§5

How We Share Information

We share personal information only in the circumstances described below:

1. Service Providers. Vendors that perform services on our behalf, including website hosting, email delivery, customer support tools, analytics, application processing, payment processing (e.g., Stripe), identity verification, electronic signature, video conferencing, classroom and learning management tools, and background-check providers. Service providers are contractually required to use personal information only to perform their services for us and to protect it.
2. Faculty and Program Staff. First Dollar School employees, contractors, mentors, and instructors who require access to student or family information to deliver the program.
3. Affiliates and Successors. Our affiliates and any successor entity in connection with a merger, acquisition, financing, reorganization, or sale of assets.
4. Legal and Safety. Government authorities, regulators, courts, or other parties when we believe disclosure is required by law, necessary to protect the rights, safety, or property of First Dollar School, our students, families, or others, or to enforce our Terms of Use.
5. With Consent. Any other party with your consent or at your direction.

We do not disclose a child's personal information to third parties for the third party's own marketing purposes.

§6

Legal Bases (For Visitors From Jurisdictions That Require Them)

Where applicable law requires a legal basis to process personal information, we rely on: performance of a contract with you; your consent (which you may withdraw at any time); compliance with a legal obligation; and our legitimate interests in operating, securing, and improving the Services, balanced against your rights.

§7

Children's Privacy (COPPA)

This Section governs our collection and use of personal information from children under the age of 13.

7.1 Parent-Submitted Information

A child under 13 cannot create an account, submit a waitlist or application form, or make a purchase on the Site. All such information is provided by a Parent.

7.2 The Stand Portal

After a Parent has enrolled a child, the Parent may grant the child access to The Stand, our student member portal. Before we collect any personal information from a child under 13 through The Stand, we obtain verifiable parental consent from the enrolling Parent. The consent process is described in the enrollment agreement and confirmed through the Parent's authenticated account.

7.3 Information We Collect From Children

The personal information we may collect from a child under 13 in The Stand is limited to what is reasonably necessary to participate in the program and may include: a first name or username, an avatar, coursework and assignment submissions, business-plan content, sales and milestone records, messages with assigned mentors and peers in moderated channels, and basic device/usage data needed to operate the platform.

We do not condition a child's participation in any activity on the disclosure of more personal information than is reasonably necessary.

7.4 How We Use Children's Information

We use children's information solely to provide the program: deliver coursework and feedback, recognize milestones (such as First Dollar Day), enable moderated peer collaboration, ensure safety, and communicate with the enrolling Parent.

We do not use children's personal information to deliver targeted advertising, build behavioral profiles for marketing, or sell to third parties.

7.5 Parent Rights

The enrolling Parent has the right to:

1. Review the personal information we have collected from the child.
2. Direct us to delete the child's personal information.
3. Refuse to permit further collection or use of the child's personal information, understanding that this may end the child's ability to participate in some or all program activities.
4. Agree to the collection and use of the child's information without consenting to its disclosure to third parties beyond what is necessary to operate the Services.

To exercise these rights, contact us at the address in Section 14. We will respond within a reasonable time and may verify your identity before acting on the request.

7.6 Retention of Children's Information

We retain a child's personal information only for as long as is reasonably necessary to fulfill the purpose for which it was collected, and we delete it using reasonable measures when no longer needed. See Section 10.

§8

Family Educational Records

First Dollar School is a private institution and is not a "school" as defined under the federal Family Educational Rights and Privacy Act ("FERPA"). Even so, we treat student records with comparable care and limit access to authorized personnel with a legitimate program need.

§9

Cookies and Tracking Technologies

We and our service providers use cookies and similar technologies to operate the Site, remember preferences, measure traffic, and improve performance. Categories used include:

1. Strictly necessary cookies that enable core functionality, such as authentication and security.
2. Analytics cookies that help us understand how visitors use the Site (e.g., Google Analytics).
3. Functional cookies that remember preferences such as language.

We do not use cookies to deliver targeted advertising to children, and we do not permit third-party advertising trackers in The Stand.

You can control cookies through your browser settings. Disabling cookies may affect Site functionality. The Site does not currently respond to Do Not Track signals, but it honors Global Privacy Control ("GPC") signals where required by applicable state law.

§10

Data Retention

We retain personal information for as long as needed to provide the Services, comply with legal obligations (including tax and accounting), resolve disputes, and enforce our agreements. Application materials of applicants who do not enroll are typically retained for up to 24 months, after which they are deleted or de-identified unless a longer retention period is required by law. Enrollment, academic, and financial records of enrolled families are retained for the duration of enrollment and for a reasonable period afterward consistent with our recordkeeping obligations.

§11

Security

We use administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit, access controls, vendor due diligence, and incident-response procedures. No system is perfectly secure, and we cannot guarantee the absolute security of information transmitted to or stored on the Services.

§12

Your Privacy Rights

12.1 Rights for All Users

You may contact us at any time to:

1. Access the personal information we hold about you or your child.
2. Correct inaccurate information.
3. Request deletion of personal information.
4. Withdraw a consent you previously provided.
5. Opt out of marketing emails by using the unsubscribe link or contacting us.

We will respond within a reasonable time and may verify your identity before acting on the request.

12.2 State-Specific Rights

Residents of certain U.S. states have additional rights under their state's privacy laws, including California (CCPA/CPRA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), and Maryland (MODPA), among others. Subject to verification and lawful exceptions, you may request to:

1. Know the categories and specific pieces of personal information we have collected.
2. Access a portable copy of your personal information.
3. Correct or delete personal information.
4. Opt out of "sales" or "sharing" of personal information, and out of targeted advertising and certain profiling. We do not sell personal information and do not engage in cross-context behavioral advertising directed at students.
5. Limit the use of sensitive personal information.
6. Appeal a denial of a rights request.

To exercise these rights, contact us at the address in Section 14. We will not discriminate against you for exercising your rights.

12.3 Authorized Agents

You may designate an authorized agent to submit a rights request on your behalf. We may require proof of the agent's authorization and verify your identity directly.

§13

International Users

The Services are operated from the United States. If you access the Services from outside the United States, your information will be transferred to, stored in, and processed in the United States, which may have different data-protection laws than your country.

§14

Contact Us

For any question about this Policy, to exercise a privacy right, or to make a Parent request under COPPA, contact:

XYZ Ventures, LLC
Attn: Privacy Officer, First Dollar School
Email: hello@firstdollarschool.com

§15

Changes to This Policy

We may update this Policy from time to time. When we do, we will revise the "Last Updated" date above. If changes are material, we will provide additional notice (such as by email to Parents or a banner on the Site) before the change takes effect. Your continued use of the Services after the effective date constitutes acceptance of the updated Policy.