Pinnacle Charter School (“Pinnacle,” “we,” “us,” or “our”) is committed to protecting the privacy of the families, students, staff, and website visitors we serve, while using data responsibly to improve our programs, communications, and outreach to current and prospective Pinnacle families. This Statement explains what information we collect through our website, online forms, email communications, and advertising activities; how we use that information to improve our services and reach more families; and the choices and rights available to you.

This Statement covers:

• Pinnacle's public website(s)
• Online inquiry, enrollment-interest, volunteer, and contact forms
• Email and text communications you opt into
• Pinnacle's social media pages and the advertising campaigns we run on Meta (Facebook/Instagram) and Google (Search, Display, YouTube)

This Statement does not cover the education records of enrolled students, which are protected separately under the Family Educational Rights and Privacy Act (FERPA) and the Colorado Student Data Transparency and Security Act (C.R.S. § 22-16-101 et seq.). Those records are addressed in Pinnacle's Student Data Privacy Policy and Annual FERPA Notice, available through the school's main office, and are never used for advertising or marketing audience-building.

3.1 Information You Provide Directly

• Name, email address, phone number, and mailing address
• Information submitted through enrollment-interest, contact, or volunteer forms
• Newsletter or email sign-up preferences, including language preference (English/Spanish)
• Messages, comments, or other communications you send us

3.2 Information Collected Automatically

• IP address, browser and device type, pages viewed, time on site, and referring website, collected through website analytics tools (such as Google Analytics)
• Cookies and similar tracking technologies

3.3 Information From Advertising Partners

• Pixel- or tag-based interaction data from Meta and Google when you view or click our ads, or visit our website
• Aggregate or demographic audience insights provided by Google's and Meta's advertising platforms

We do not collect Social Security numbers, financial account numbers, or health information through our website or marketing tools, and we do not knowingly use marketing or advertising tools to gather sensitive categories of information — such as health, financial, racial or ethnic origin, religious belief, or government identification information — as those categories are defined under the Colorado Privacy Act.

• Operate, maintain, and improve Pinnacle's website and online services
• Respond to inquiries and provide requested information about enrollment, programs, and events
• Send newsletters, announcements, and bilingual (English/Spanish) communications you have opted into
• Build and improve marketing campaigns, including identifying and reaching families likely to be interested in Pinnacle through audience-building, similar/look-alike audiences, and remarketing to past website visitors
• Measure and improve the performance of our outreach, such as which pages, ads, or messages are most effective at reaching families
• Comply with legal obligations and protect the safety and integrity of our school community

Pinnacle does not sell personal information, as that term is defined under Colorado law, and does not share data with advertising platforms for any purpose unrelated to the educational marketing and communications purposes described in this Statement.

5.1 Tools We Use

To advertise Pinnacle's programs and measure how families find and use our website, we may use:

• Google Ads (including remarketing and similar-audience features) and Google Analytics
• Meta Pixel and/or Conversions API on Facebook and Instagram

5.2 How These Tools Work

When you visit our website or interact with our ads, Google and/or Meta may place cookies or use similar identifiers on your device. These technologies allow Pinnacle to show ads about our programs to people who have previously visited our site or shown interest (remarketing/retargeting), measure which ads and webpages lead to inquiries or enrollment interest, and build broader audiences of people who share characteristics with our current families so we can reach more prospective families efficiently.

5.3 Our Commitments When Using These Tools

In line with Google's and Meta's advertiser terms, Pinnacle:

• Will not knowingly send Google or Meta any data we know or have reason to believe is from or about a child under 13
• Will not use these tools to build or target audiences based on health, financial, racial or ethnic, religious, sexual orientation, or other sensitive categories

5.1 Tools We Use

To advertise Pinnacle's programs and measure how families find and use our website, we may use:

• Google Ads (including remarketing and similar-audience features) and Google Analytics
• Meta Pixel and/or Conversions API on Facebook and Instagram

5.2 How These Tools Work

When you visit our website or interact with our ads, Google and/or Meta may place cookies or use similar identifiers on your device. These technologies allow Pinnacle to show ads about our programs to people who have previously visited our site or shown interest (remarketing/retargeting), measure which ads and webpages lead to inquiries or enrollment interest, and build broader audiences of people who share characteristics with our current families so we can reach more prospective families efficiently.

5.3 Our Commitments When Using These Tools

In line with Google's and Meta's advertiser terms, Pinnacle:

• Will not knowingly send Google or Meta any data we know or have reason to believe is from or about a child under 13
• Will not use these tools to build or target audiences based on health, financial, racial or ethnic, religious, sexual orientation, or other sensitive categories
• Hashes or otherwise protects contact information, such as email addresses, before it is used to match audiences, where applicable
• Does not sell, rent, or transfer any custom audience we build to other organizations or advertisers
• Maintains this published Statement disclosing our use of remarketing and similar-audience features, as required by Google's advertiser policies
• Will configure consent or disclosure banners as needed for visitors located in jurisdictions, such as the European Economic Area, that require additional consent before cookies are set

6.1 Ad Personalization Opt-Outs

• Google: manage or opt out of ad personalization at Google's Ad Settings (adssettings.google.com)
• Meta: manage ad preferences in Facebook or Instagram Settings under “Ads”
• Industry-wide: opt out of interest-based advertising through the Network Advertising Initiative (optout.networkadvertising.org) or the Digital Advertising Alliance (optout.aboutads.info)
• Browser-level: many browsers let you enable a Global Privacy Control (GPC) signal, which Colorado law requires Pinnacle to honor as a universal request to opt out of targeted advertising

6.2 Your Rights Under Colorado Law

If you are a Colorado resident, the Colorado Privacy Act gives you the right to:

• Confirm whether we process your personal data, and access it
• Correct inaccurate personal data
• Delete personal data
• Opt out of the use of your personal data for targeted advertising or certain profiling
• Receive a portable copy of your data
• Appeal a decision if we deny your request

To exercise these rights, contact us using the information in Section 14. We will respond within the timeframes required by law and may need to verify your identity before completing certain requests.

Pinnacle's website and marketing communications are directed to parents, guardians, and the general public — not to children. In line with the Children's Online Privacy Protection Act (COPPA) and Colorado's children's online privacy protections (SB 24-041):

• We do not knowingly collect personal information directly from children under 13 through our website's marketing or contact forms
• We use reasonable care to avoid practices that could create a heightened risk of harm to minors, and we do not use manipulative design (“dark patterns”) to obtain data or consent from minors
• Our enrollment marketing audiences are built around parent, guardian, and household-level interest signals — not around data we know to be from a minor student
• A parent or guardian who believes their child's information was inadvertently submitted to us may contact us to have it reviewed and deleted

Separate from this marketing-focused Statement, the education records of Pinnacle's enrolled students are protected under FERPA and the Colorado Student Data Transparency and Security Act. Those records are never used for advertising, marketing audience-building, or shared with Google, Meta, or any other advertising platform. Questions about student education records should be directed to the school's main office under Pinnacle's Student Data Privacy Policy and Annual FERPA Notice.

Pinnacle maintains administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or destruction, including:

• Restricting access to marketing and contact data to staff who need it to perform their job duties
• Using encrypted connections (HTTPS/TLS) on our website and online forms
• Requiring strong, unique credentials and, where available, multi-factor authentication for staff accounts on our website, email, CRM, and advertising platforms
• Vetting third-party vendors and service providers for their own security and privacy commitments before sharing data with them
• Limiting the data sent to advertising platforms to the minimum necessary, and never sending sensitive categories of information
• Training staff who manage marketing and communications on safe, lawful data handling
• Maintaining a process to detect, respond to, and provide legally required notice of any data security incident, consistent with Colorado's data breach notification law

Pinnacle works with carefully selected vendors to operate its website and marketing programs, which may include website hosting and content-management providers, email and CRM platforms, social media and advertising platforms (Meta and Google), and analytics providers. These providers may process personal information on Pinnacle's behalf solely to provide services to the school, and are not permitted to use it for their own independent purposes beyond what their own terms allow. Pinnacle does not sell personal information to data brokers or other third parties.