Terms of Service
Thank you for your interest in using the online services operated by the 21st Century Partnership for STEM Education ("21PSTEM"). These Terms of Service ("Terms") govern your use of 21PSTEM’s online services (collectively, the "Services"), including the services which are offered through (i) our website located at www.21PSTEM.org and (ii) www.mathempowerment.org and (iii) www.MathematicalThinking.org and (iv) third-party providers.
1. Our Services
By using the 21PSTEM Services, you agree to be bound by these Terms and to the collection and use of your information as described in our Privacy Policy. 21PSTEM Services include but are not limited to: ME-SBG App, Virtual Math Teams, EnCoMPASS, MathematicalThinking.org, Curriculum App, and PARLO Tracker. If you do not agree to these Terms, you are not permitted to use the 21PSTEM Services.
2. Eligibility and Authority
If you are agreeing to these Terms on behalf of a school, school district, or other educational institution (collectively, a “School”) for the purpose of providing the 21PSTEM Services to students (“Students”), you represent and warrant that you are an authorized representative of the School and you agree to these Terms on the School’s behalf. Otherwise, you are agreeing to these Terms on behalf of yourself. The U.S. Children’s Online Privacy and Protection Act (“COPPA”) requires that online service providers obtain verifiable parental consent before collecting personal information from children under 13. If you are a School providing the Service to children under 13 (whether in the U.S. or elsewhere), you represent and warrant that you have received consent from Parents, or have the authority to provide consent on behalf of parents, for us to collect information from students before allowing children under 13 to access 21PSTEM Services. We recommend that all Schools provide appropriate disclosures to students and parents regarding their use of service providers such as 21PSTEM.
3. Personal Information and Student Data
When 21PSTEM is used by a School for an educational purpose, 21PSTEM may collect or have access to Student Data that is provided by the School or by the Student. “Student Data” is personal information that is directly related to an identifiable Student and may include “educational records” as defined by the Family Educational Rights and Privacy Act (“FERPA”), 20 U.S.C. § 1232(g).
Confidentiality. 21PSTEM agrees to treat Student Data as confidential and not to share it with third parties other than as described in these Terms, and in our Privacy Policy.
Student Data Access. You authorize 21PSTEM to access or collect Student Data for the purpose of providing the Service. In the U.S., 21PSTEM shall collect and process Student Data as a School Official with a legitimate educational interest pursuant to FERPA 34 CFR Part 99.31(a)(1). As between the parties, the School or the Student owns and controls the Student Data. 21PSTEM does not own or control, or license such Student Data, except as to provide the Service and as described in these Terms.
Personal Information and Student Data Consents and Authority. If you are a School User, you represent and warrant that you have provided appropriate disclosures to your School and to parents regarding your sharing such Personal Information with 21PSTEM. Both Parties agree to uphold their obligations under the Family Educational Rights and Privacy Act (“FERPA”), the Protection of Pupil Rights Amendment ("PPRA"), and the Children’s Online Privacy and Protection Act (“COPPA”) and applicable State laws relating to student data privacy. 21PSTEM relies on each School to obtain and provide appropriate consent and disclosures, if necessary, for 21PSTEM to collect any Student Data, including the collection of Student Data directly from students under 13, as permitted under COPPA. You agree to comply with these Terms and all laws and regulations governing the protection of personal information, including children’s information, and the sharing of student education records.
Use of Student Data. By submitting or providing us access to Student Data, you agree that 21PSTEM may use the Student Data solely for the purposes of (i) providing the Service, (ii) improving and developing our Service, (iii) enforcing our rights under these Terms, and (iv) as permitted with the School’s or the User’s consent. 21PSTEM shall not use Student Data to engage in targeted advertising. Any data collected for research purposes will be overseen by an Institutional Review Board (“IRB”) and the collection of your data for approved research purposes will be done as required by an IRB, often including User consent (and assent from Minors with consent from a guardian). Use of Anonymized Student Data. You agree that we may collect and use data derived from Student Data for our own purposes, such as for product development, research analytics, and marketing our Service, provided that such data will be de-identified and/or aggregated to reasonably avoid identification of a specific individual.
Third-Party Service Providers. You acknowledge and agree that 21PSTEM may provide access to Student Data to our employees and service providers, which have a legitimate need to access such information in order to provide their services to us. We and our employees, affiliates, service providers, or agents involved in the handling, transmittal, and processing of Student Data will be required to maintain the confidentiality of such data.
Student Data Retention and Deletion Requests. Schools may request that we delete Student Data in our possession at any time by providing such a request in writing, except that 21PSTEM shall not be required to delete content a Student shared to public areas of the Service. We shall respond to the deletion request as soon as possible, but in most instances within 45 days, other than for data stored on backup tapes which shall be deleted in the ordinary course of business. A Parent seeking to modify, correct, or delete personal information in a Student Account that is connected to an active School account will be instructed to contact the School to discuss data deletion or modification. We are not required to delete data that has been derived from Student Data so long as it has been anonymized such that it does not reasonably identify an individual.
Data Breach Notification. We have implemented administrative, physical and technical safeguards designed to secure Personal Information, including Student Data, from unauthorized access, disclosure and use. In the event we have a reasonable, good faith belief that an unauthorized party has gained access to or been disclosed Student Data (a “Security Event”), that we have collected or received through the Service, we will promptly notify the School. If, due to a Security Event which is caused by the acts or omissions of 21PSTEM or its agents, a notification to an individual, organization or government agency is required under applicable privacy laws, the School shall be responsible for the timing, content, and method of any such legally-required notice and compliance with such laws and 21PSTEM shall indemnify the School for costs related to legally-required notifications. With respect to any Security Event which is not caused by the acts or omissions of 21PSTEM or its agents, 21PSTEM shall reasonably cooperate with School’s investigation of the Security Event, as School requests, at School’s reasonable expense. 21PSTEM shall be responsible for the timing, content, cost and method of notice and compliance with such laws as they relate to User accounts that are not associated with a School account.
4. Your Responsibilities
You agree:
(a) that you are responsible for obtaining and maintaining all equipment and services needed for access to and use of the 21PSTEM Services and for paying all charges related thereto; and
(b) not to use the 21PSTEM Services to: (i) violate any third-party rights or any local, state, national, or international law or regulation; (ii) transmit or create any materials that are abusive, harassing, tortious, defamatory, libelous, or invasive of another's privacy; (iii) transmit any material that contains adware, malware, spyware, software viruses, or any other computer code, files, or programs designed to interrupt, destroy, or limit the functionality of any computer software or hardware or telecommunications equipment; (iv) impersonate any person or entity, or otherwise misrepresent your affiliation with a person or entity; or (v) interfere with or disrupt the 21PSTEM Services or servers or networks connected to the 21PSTEM Services, or disobey any requirements, procedures, policies, or regulations of networks connected to the 21PSTEM Services.
5. Personal, Non-Commercial Use Only
You agree to use the 21PSTEM Services only (a) as an end user, for your personal, non-commercial use or (b) as a teacher, for academic use by you and your students in individual classes. 21PSTEM does, pursuant to a separate written agreement, permit certain third parties (y) to integrate with the 21PSTEM Services for commercial use.
6. User Submissions and Generated Materials
21PSTEM does not claim ownership of any materials you submit and create for display or distribution to others through the 21PSTEM Services (“User Submissions and Generated Materials”). As between 21PSTEM and you, you own all rights to your User Submissions and Generated Materials. You grant to 21PSTEM an irrevocable, perpetual, non-exclusive, fully-paid, worldwide license, with the right to sublicense through multiple tiers, to use, distribute, reproduce, modify, adapt, publish, translate, publicly perform, and publicly display or otherwise use your User Submissions and Generated Materials (in whole or in part) in connection with the operation of the Service or the promotion, advertising or marketing thereof, in any format or medium now known or later developed, without compensation or notification to or permission from the user of any kind. You acknowledge and agree that all right and title in the software code and other material used to create or display your User Submissions and Generated Materials is the property of 21PSTEM, and you hereby assign all right and title in such material to 21PSTEM. 21PSTEM hereby grants you a license to such material (a) as an end user, for your personal, non-commercial use or (b) as a teacher, for academic use by you and your students in individual classes. 21PSTEM does not pre-screen User Submissions and Generated Materials and you agree that you are solely responsible for all of your User Submissions and Generated Materials. 21PSTEM is not required to host, display, or distribute any User Submissions and Generated Materials, and may remove at any time or refuse any User Submissions and Generated Materials. 21PSTEM is not responsible for any loss, theft or damage of any kind to any User Submissions and Generated Materials. You represent and warrant that your User Submissions and Generated Materials, and 21PSTEM’s authorized use thereof, do not and will not infringe the rights of any third-party (including, without limitation, intellectual property rights, rights of privacy or publicity, or any other legal or moral rights).
7. Activity Sharing
At the time you submit to 21PSTEM an activity you’ve developed using the 21PSTEM Services (an “Activity”), you may elect to make your Activity public. If you do so, then you expressly authorize 21PSTEM to (i) make your Activity available to other School users for use in individual classes with other students, (ii) allow other School users to copy and modify your Activity and use the modified version in individual classes with other students and (iii) modify your Activity and make the modified version available to other School users for use in individual classes with other students. In the case of any such use of your Activity (whether unmodified or modified), you will receive an attribution credit. If you elect to make your Activity public, in no event will 21PSTEM authorize any third-party to sell your Activity to others, nor will 21PSTEM sell your activity itself, without your permission.
8. Copyright Infringement
21PSTEM has a policy of removing User Submissions and Generated Materials that violate copyright law, and, in appropriate circumstances, suspending access to the 21PSTEM Services (or any portion thereof) to any user who uses the 21PSTEM Services in violation of copyright law, and/or terminating the account of any user who uses the 21PSTEM Services in violation of copyright law. If you believe your copyright is being infringed by a user of the 21PSTEM Services, please provide written notice of claims of copyright infringement.
Contact: support@21pstem.org[JB1] , 610-825-5644
9. Feedback
If you choose to provide technical, business or other feedback to 21PSTEM concerning the 21PSTEM Services, 21PSTEM will be free to use such feedback without restriction. You understand and agree that the incorporation by 21PSTEM of your feedback into any of its products or services does not grant you any proprietary rights thereto.
10. Termination and Suspension
Without limiting other remedies, 21PSTEM may terminate or suspend your 21PSTEM Services account without notice if 21PSTEM believes that you have violated these Terms or have engaged in conduct that violates applicable law or is otherwise harmful to the interests of 21PSTEM, any other 21PSTEM Services user, or any third-party. You may discontinue your use of the 21PSTEM Services at any time.
11. Password and Security
You are responsible for maintaining the confidentiality of your 21PSTEM Services password, and you are solely responsible for all activities that occur under your password. You agree to immediately notify 21PSTEM of any unauthorized use of your password or any other breach of security related to the 21PSTEM Services. 21PSTEM may require you to alter your password if 21PSTEM believes that your password is no longer secure.
12. Third-party Services
21PSTEM may integrate with or provide links to certain third-party services (collectively, such third parties, “Linked Partners”). The Linked Partner services made available through the 21PSTEM Services or the integration of such sites and services with the 21PSTEM Services are for your convenience only and do not signify the endorsement by 21PSTEM of such Partner sites or services.
13. Disclaimer and Limitations of Liability
(a) You agree that use of the 21PSTEM Services is at your sole risk. The 21PSTEM Services are provided on an “as is” and “as available” basis. 21PSTEM expressly disclaims all warranties of any kind, whether express or implied, with respect to the 21PSTEM Services and all services provided by any of our partners (whether API partners, linked partners, or otherwise), including, but not limited to, the implied warranties of merchantability, fitness for a particular use or purpose, and non-infringement. You acknowledge that access to data and materials (including, but not limited to, your or others’ user submissions and generated materials) available through the 21PSTEM Services is not guaranteed and that 21PSTEM will not be responsible to you for any loss of data or materials caused by the 21PSTEM Services or their unavailability. You understand and agree that any data, materials, services and/or information downloaded or otherwise obtained through the use of the 21PSTEM Services is done at your own discretion and risk and that you will be solely responsible for any damage arising therefrom.
(b) Under no circumstances will 21PSTEM or its officers, employees, directors, shareholders, agents, or licensors be liable under any theory of liability (whether in contract, tort, statutory, or otherwise) for any damages whatsoever, including direct, indirect, incidental, special, consequential or exemplary damages, including but not limited to, damages for loss of money, revenues, profits, goodwill, use, data or other intangible losses (even if such parties were advised of, knew of or should have known of the possibility of such damages), resulting from your (or anyone using your account's) use of the 21PSTEM Services.
(c) If, notwithstanding these Terms, 21PSTEM is found to be liable to you or any third-party in connection with your use of the 21PSTEM Services, the total liability of 21PSTEM and its officers, employees, directors, shareholders, agents, or licensors to you or to any third-party is limited to one hundred U.S. Dollars ($100).
(d) Exclusions and Limitations. Some jurisdictions do not allow the exclusion of certain warranties or the limitation or exclusion of liability for certain damages. Accordingly, some of the above limitations and disclaimers may not apply to you. To the extent that 21PSTEM may not, as a matter of applicable law, disclaim any implied warranty or limit its liabilities, the scope and duration of such warranty and the extent of 21PSTEM’s liability will be the minimum permitted under such applicable law.
14. Indemnification
You agree to indemnify, defend, and hold harmless 21PSTEM and its officers, directors, employees, consultants and agents from and against any and all claims, liabilities, damages, losses, costs, expenses, fees (including reasonable attorneys' fees) that such parties may incur as a result of or arising from your (or anyone using your account's) violation of these Terms. 21PSTEM reserves the right, at its own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, and in such case, you agree to cooperate with 21PSTEM’s defense of such claim.
15. Intellectual Property
“21PSTEM” and certain other of the names, logos, and materials displayed in the 21PSTEM Services, may constitute trademarks, trade names, or service marks (“Marks”) of 21PSTEM or other entities. You are not authorized to use any such Marks. Ownership of all such Marks and the goodwill associated therewith remains with 21PSTEM or those other entities. The content on the 21PSTEM Services (the “Content”), including without limitation, the software, graphs, text and graphics, is protected under United States and international copyright laws, is subject to other intellectual property and proprietary rights and laws, and is owned by 21PSTEM or its licensors. Other than with respect to your own User Submissions and Generated Materials, (a) the Content may not be copied, modified, reproduced, republished, posted, transmitted, sold, offered for sale, or redistributed in any way without the prior written permission of 21PSTEM and its applicable licensors; and (b) you must abide by all copyright notices, information, or restrictions contained in or attached to any Content.
16. Miscellaneous
Entire Agreement. These Terms and our Privacy Policy, together with any additional terms to which you agree when using particular elements of the 21PSTEM Services (e.g., terms relating to the payment of fees for certain 21PSTEM Services), constitute the entire and exclusive and final statement of the agreement between you and 21PSTEM with respect to the subject matter hereof, and govern your use of the 21PSTEM Services, superseding any prior agreements or negotiations between you and 21PSTEM with respect to the subject matter hereof.
Governing Law. These Terms and the relationship between you and 21PSTEM will be governed by the laws of the Commonwealth of Pennsylvania. All lawsuits arising from or relating to these Terms or your use of the 21PSTEM Services will be brought in the Federal or State courts located in Pennsylvania and you hereby irrevocably submit to the exclusive personal jurisdiction of such courts for such purpose.
Additional Terms. The failure of 21PSTEM to exercise or enforce any right or provision of these Terms will not constitute a waiver of such right or provision. If any provision of these Terms is found by a court of competent jurisdiction to be invalid, you nevertheless agree that the court should endeavor to give effect to the intentions of 21PSTEM and you as reflected in the provision, and that the other provisions of these Terms remain in full force and effect. You agree that regardless of any statute or law to the contrary, any claim or cause of action arising out of or related to use of the 21PSTEM Services or these Terms must be filed within one (1) year after such claim or cause of action arose or be forever barred. The section titles in these Terms are for convenience only and have no legal or contractual effect. These Terms will remain in full force and effect notwithstanding any termination of your use of the 21PSTEM Services. If access to the 21PSTEM Services is licensed to the United States government or any agency thereof, then the 21PSTEM Services will be deemed to be “commercial computer software” and “commercial computer software documentation,” pursuant to DFARS Section 227.7202 and FAR Section 12.212, respectively, as applicable. Any use, reproduction, release, performance, display, or disclosure of the 21PSTEM Services and any accompanying documentation by the U.S. Government will be governed solely by these Terms and is prohibited except to the extent expressly permitted by these Terms.
17. Modifications to Terms and Services
(a) Modifications. These Terms may be revised periodically and this will be reflected in the “date last modified” set forth below. Your continued use of the 21PSTEM Services following such update constitutes your agreement to the revised Terms. If you object to any such changes, your sole recourse will be to cease using the 21PSTEM Services. Continued use of the 21PSTEM Services following notice of any such changes will indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes. 21PSTEM reserves the right to modify or discontinue the 21PSTEM Services with or without notice to you.
(b) Date Last Modified. These Terms were last modified on May 21, 2026.
Privacy Policy
21PSTEM, Inc. ("we" or "21PSTEM") is committed to protecting your privacy. This Privacy Policy describes our collection and use of personal information collected from visitors to our website and our mobile application(s) (collectively, our "Service"). "You" or "your" means a visitor or a user (whether logged in or not) of our Service. A note about Student
Data: Our 21PSTEM Service may be used by schools, school districts, or teachers (collectively referred to as "Schools") in a classroom setting. When 21PSTEM contracts with a School to provide the Service to students ("Students"), we may have access to Student Data (defined below). This Privacy Policy is incorporated into and is subject to our Terms of Service, which governs your use of the 21PSTEM Services.
1. Information Collected
(a) Personal Data. You can use the Service without registering for an account or providing any other personal data. If you create an account on the 21PSTEM Services, or communicate with 21PSTEM, you may provide to 21PSTEM certain information by which someone could personally identify you, such as your name, email or unique username (“Personally Identifiable Information”). We also collect information when you save or post content to the Service (“User Content”) and communicate with us. We refer to all of this data collectively as “Personal Data”. We may also collect Personal Data about you from a third-party service. For example, if you login to your 21PSTEM account through an authentication tool, or if you interact with 21PSTEM on social media, we may collect the Personal Data you authorize that third-party service to share.
(b) Usage Data. We automatically collect certain technical usage information when you use the 21PSTEM Services (“Usage Data”). Usage Data includes the information that your web browser or mobile application automatically sends to our servers whenever you visit. The Usage Data collected in our logs may include information such as your web request, Internet Protocol address, operating system, browser type, browser language, referring / exit pages and URLs, platform type, click history, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and whether you opened an email. Typically, this information is collected through log files, web beacons, browser cookies, or other device identifiers that may uniquely identify your browser or device. You may be able to set your web browser to refuse all cookies, and your mobile device to not provide your mobile device identifier. In addition, the 21PSTEM Services may use third-party analytics and bug tracking software (including, without limitation, Google Analytics and Bugsnag) to collect further Usage Data regarding the online usage patterns of our users and bugs in our Services. We may combine Usage Data with Personal Data in a manner that enables us to trace Usage Data to an individual user. Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser at this time. We do not permit third-party advertising networks or other third parties to collect information about your browsing behavior from our website for advertising purposes.
2. Use of Your Information
(a) Use. We use your Personal Data and Usage Data (together, “User Information”) to operate, maintain, and provide to you the features and functionality of the 21PSTEM Services and for related business purposes. We may use your User Information to (i) improve the quality and design of the 21PSTEM Services and to create new features and services by storing, tracking, and analyzing user preferences; (ii) remember information so that you will not have to re-enter it during your visit or the next time you use the 21PSTEM Services; (iii) provide custom, personalized content and information; (iv) monitor aggregate metrics such as total number of visitors, pages viewed, etc.; and (v) diagnose and fix technology problems and otherwise plan for and enhance our Service. 21PSTEM may provide personalized content and information to our users, including teachers, school administration officials, and other users associated with Schools. However, 21PSTEM shall never use Student Data to engage in targeted advertising, nor shall 21PSTEM direct advertising to student users, nor shall 21PSTEM ever use any third-party advertising network on any 21PSTEM Service. As described in the Terms of Service, any data collected for research purposes will be overseen by an IRB and the collection of your data for approved research purposes will be done as required by an IRB.
(b) Communications Preferences. We will not use your email address or other Personally Identifiable Information to send you marketing messages unless you provide your consent, or as part of a specific program or feature for which you will have the ability to opt-out. You can always opt-out of receiving promotional email from us by clicking on the “unsubscribe” feature at the bottom of each email or by adjusting your email subscription preferences in your settings. We may, however, use your email address without further consent for non-marketing or administrative purposes, such as notifying you of important 21PSTEM Services changes or for customer service purposes.
(c) Retention of Data. Personal and Usage data may be retained indefinitely by 21PSTEM. If you would like your personal information removed, or if you want to remove your name or comments from our website or publicly displayed content, you can contact us directly at support@21pstem.org. We may not be able to modify or delete your information in all circumstances.
3. Disclosure of Your Information
(a) Your Publication. You may, by using applicable sections of the 21PSTEM Services, share your User Information, including Personally Identifiable Information and other content that you create or post to others accessing the 21PSTEM Services.
(b) Service Providers. We share User Information with our trusted third-party service providers and other individuals who perform services on our behalf, for example, providing customer service support, hosting services, analytics and other services we utilize to help us provide our Service or conduct our business. These service providers access and use User Information only to provide services to 21PSTEM under reasonable confidentiality terms.
(c) Other Required Sharing. We may share User Information: (i) if required to do so by law, or in the good-faith belief that such action is in compliance with state and federal laws (including, without limitation, copyright laws) or in response to a court order, subpoena, legal process or search warrant, or (ii) if we believe, in good faith, such action is appropriate or necessary to enforce our Terms of Service, to exercise our legal rights, to take precautions against liability, to investigate and defend ourselves against any claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the 21PSTEM Services, and to protect the rights, property, or personal safety of 21PSTEM, Education Providers, our users or third parties.
(d) Sharing of Student Work. In some instances, Student Data, including, for example, student's response to a prompt, (collectively, "Student Work") may be visible to other students in the same classroom. A teacher or school administration official will be able to monitor any such Student Work and will be able to hide it at their discretion, for example if said Student Work is in violation of a school's policies or the teacher's desired classroom culture.
4. Your Choices
You may decline to submit Personally Identifiable Information through the 21PSTEM Services, in which case 21PSTEM or your School may not be able to provide certain 21PSTEM Services to you. You may update or correct your name, email address, or password at any time by visiting your “Account Settings” link. You may also delete your account altogether there. With respect to User Information provided by your School, please reach out to your School to request removal or updates of such information. If you have any questions about reviewing, modifying, or deleting your information, or if you want to remove your name or comments from our website or publicly displayed content, you can contact us directly at support@21pstem.org. We may not be able to modify or delete your information in all circumstances.
5. Data Security
We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Service. Access to information is limited (through user/password credentials or room access code and, in some cases, two factor authentication) to those employees who require it to perform their job functions. We use industry standard SSL (secure socket layer technology) encryption to transfer personal information. Other security safeguards include but are not limited to data encryption, firewalls, physical access controls to buildings and files, and employee training. You can help protect against unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your account.
6. Children’s Privacy
Our Service is not directed to children under 13, unless and until a School has provided consent and authorization for a student under 13 to use the Service and for 21PSTEM to collect information from such student. If you believe that we have inadvertently collected Personal Data from a child under 13 years of age without parental consent, then please alert us at support@21pstem.org and we will promptly delete the child's Personal Data from our systems.
7. For Our International Users
By using this Service, you consent to the transfer of your personal information to the United States and to the processing of your personal information in the United States in accordance with this Privacy Policy. You understand that your personal information will be subject to the laws of the United States, which may be different from those of your country of residence.
8. Contact Us
Please feel free to contact us with any questions or comments about this Privacy Policy, your personal information, your consent, or your opt-in or opt-out choices as follows:
21PSTEM
230 Sugartown Road, Suite 100
Wayne, PA 19087
Email: support@21pstem.org
Phone: 610-825-5644
9. Changes and Updates
(a) Updates. This Privacy Policy may be revised periodically and this will be reflected in the “date last modified” set forth below. Your continued use of the 21PSTEM Services following such update constitutes your agreement to the revised Privacy Policy.
(b) Last Modified. This Privacy Policy was last modified May 21, 2026
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