California Privacy Policy

Special Privacy Notice for California Residents

If you are a California resident, please read the following Privacy Policy (“Policy”).

The purpose of this Policy is to describe how information obtained from California consumers, including visitors to our websites located at www.primroseschools.com, www.primrosecares.com, www.primrosefranchise.com, www.primroseadvantage.com, www.theprimroseadvantage.com, and all individual school sites linked to www.primroseschools.com (collectively, the “Sites”) and franchised Primrose Schools locations (“Locations”), is collected, used, sold, and disclosed. This Policy also explains how you can make requests of Primrose Schools to know about your Personal Information, delete your Personal Information, and opt-out of the sale of your Personal Information. Please note that this Policy applies to information collected by Primrose School Franchising Company LLC and its affiliates, subsidiaries, and independently owned and operated franchised locations (collectively referred to herein as “Primrose Schools,” “we,” “our,” or “us”).

For ease of reference, you may click on any of the following links to jump to one of the sections addressed below:

California’s Shine the Light Law

California’s Consumer Privacy Act

  1. California Residents’ Rights under the California Consumer Privacy Act
  2. Categories of California Consumers’ Personal Information Collected, Sold, or Disclosed
  3. Methods for Submitting CCPA Requests to Primrose Schools
  4. Verification Process
  5. Authorized Agents
  6. Response Timing and Format
  7. Do Not Sell My Personal Information
  8. Financial Incentive Offers
  9. Contact Us for More Information

California’s Shine the Light Law

Subject to certain limits under California Civil Code section 1798.83, California residents may ask Primrose Schools to provide them with (i) a list of certain categories of personal data that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. California residents may make one request per calendar year.

To make this request, you may contact Primrose Schools at the mail or email address listed in the “Contact Us for More Information” section below. In your request, please state that you are a California resident and provide a current California address for our response. Please allow up to thirty (30) days for a response. Primrose Schools reserves its right not to respond to such requests submitted to addresses other than those specified in the “Contact Us for More Information” section below.

CALIFORNIA’S CONSUMER PRIVACY ACT

1. California Residents’ Rights under the California Consumer Privacy Act

If you are a California resident, you have certain rights regarding information that is treated as Personal Information under the California Consumer Privacy Act of 2018, California Civil Code sections 1798.100 et seq. (“CCPA”).

    • The right to know what categories of Personal Information are being collected, sold, or disclosed and the categories of sources of that Personal Information.

You have the right to know what categories of Personal Information we collect, sell, or disclose about you, as well as the categories of third parties who purchased or received your Personal Information and the categories of sources of that Personal Information. These categories are described below in the “Categories of California Consumers’ Personal Information Collected, Sold, or Disclosed” section below. We are also required to provide to you, before or at the point of collection, a general notice about the categories of Personal Information collected by us and how we intend to use the collected Personal Information.

    • The right to access collected Personal Information

You have the right to request that we provide a copy of your Personal Information that we collected, sold, or disclosed in the preceding twelve (12) months. Only you, or someone you legally authorize to act on your behalf, may make a request related to your Personal Information. You may submit a maximum of two requests in a 12-month period.

You must provide sufficient information to enable us to reasonably verify your identity or that of your authorized agent. We will only use the Personal Information provided in your request to verify your identity or that of your authorized agent. Please note that we cannot provide any Personal Information in response to a request if we cannot verify your or your authorized agent’s identity or your authorized agent’s authority to make the request on your behalf and/or if we cannot confirm that the collected Personal Information relates to you.

After receiving and verifying your request, we will provide the following information (depending on your request):

    • The categories of Personal Information collected about you in the preceding twelve (12) months.
    • The sources of that Personal Information by category.
    • The business or commercial purpose(s) for collecting or selling that Personal Information.
    • The categories of third parties with whom we shared that Personal Information.
    • The specific pieces of Personal Information collected about you.

If we sold your Personal Information or disclosed it for a business purpose, we will provide:

    • The categories of Personal Information sold in the previous twelve (12) months and the categories of third parties to whom the Personal Information was sold.
    • The categories of Personal Information disclosed for a business purpose in the previous twelve (12) months and the categories of third parties to whom the Personal Information was disclosed.

See the “Methods for Submitting CCPA Requests to Primrose Schools” section below for information on how you can exercise your right to access collected Personal Information. For more information, see also the “Response Timing and Format” section below.

    • The right to request deletion of Personal Information

With certain exceptions, you have the right to request that we and our service providers delete Personal Information we or our service provider collected or maintained. Once we receive and verify your request, we will delete and instruct any applicable service providers to delete your Personal Information from our records, unless an exception applies.

We and our service providers may deny a verified deletion request if we must maintain your Personal Information to:

    • Complete the transaction or provide a good or service requested by you for which we collected the Personal Information, or otherwise perform a contract between us.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity.
    • Debug to identify and repair errors that impair existing intended functionality of our systems.
    • Exercise a legal right provided for by law, including exercising or ensuring free speech rights.
    • Comply with the California Electronic Communications Privacy Act (California Penal Code sections 1546 to 1546.4).
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest if:
      • the research adheres to all other applicable ethics and privacy laws;
      • deleting the Personal Information is likely to make the research impossible or seriously impair it; and
      • you provided informed consent during the initial data collection.
    • Enable our internal use in a manner that you would reasonably expect based on your relationship with us.
    • Comply with our legal obligations.
    • Otherwise use your Personal Information internally in a lawful manner that is compatible with the context in which you provided the information.

See the “Methods for Submitting CCPA Requests to Primrose Schools” section below for information on how you can exercise your right to delete collected Personal Information.

    • The right to opt-out of the sale of Personal Information

You have the right to opt-out of the “sale” of your Personal Information to other businesses or third parties. The CCPA defines “sell,” “selling, “sale,” and “sold” to include selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means.

Once we receive an opt-out request, we will act upon the request as soon as commercially reasonable, but no later than fifteen (15) days from the date we receive the request. We will also notify all third parties to whom we have sold the Personal Information after receiving the request, but before we are able to comply with the request, that you have exercised your opt-out right and instruct them not to resell the Personal Information.

However, if we have a good-faith, reasonable, and documented belief that the request is fraudulent, we will deny the request and provide you with an explanation of our rationale.

You may elect to opt-in to the sale of Personal Information after opting-out. In the event that a transaction requires the sale of your Personal Information as a condition of completing the transaction, we will inform you of this and provide instructions on how you can opt-in. See the “Do Not Sell My Personal Information” section below for more on how to opt-out of the sale of Personal Information.

    • The rights of California consumers who are less than 16 years of age

Under California law, consumers who are less than 16 years of age must provide affirmative authorization, or a parent or guardian of a consumer less than 13 must provide affirmative authorization, before a business may sell their Personal information. This is referred to as the “right to opt-in.”

We do not have actual knowledge that we sell the Personal Information of California consumers who are less than 16 years of age.

    • The right to be free from discrimination

You have the right to equal service, and we will not discriminate against you if you exercise your rights under the CCPA.

2. Categories of California Consumers’ Personal Information Collected, Sold, or Disclosed

We collect a variety of categories of Personal Information about California consumers, their household, and/or their devices, from both online and offline sources. We will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated, or incompatible purposes without providing advance notice.

In particular, we have collected the following Personal Information in the last twelve (12) months:

    • Identifiers: Examples of these identifiers include, but are not limited to, name, alias, postal address, unique personal identifier, Internet Protocol address, email address, Social Security number, driver’s license number, passport number, or other similar identifiers.
    • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): Examples of this information include, but are not limited to, a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
    • Internet activity information: Examples of these identifiers include, but are not limited to, browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
    • Professional or employment-related information: Examples of this information include, but are not limited to, current or past job history or performance evaluations.
    • Characteristics of protected classifications under California or federal law: Examples of this information include, but are not limited to, age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

We may have obtained the Personal Information listed above from the following sources in the last twelve (12) months:

    • Information you provide directly to us:
      Certain areas and features of our Sites may require registration. For example, to register for the Primrose Newsletter, you must provide your email address. We may also collect Personal Information such as your name, address, phone number, and email address from you in connection with sweepstakes, contests, or other promotions that we may conduct or offer through our Sites.
      We also host blogs and online communities, such as Pointers for Parents, which allow you to post text, photos, videos, and other information online. Please note that all of this information will be available for public viewing, so you should not post any information that is considered confidential and/or that you would prefer to keep private.
    • Independently owned and operated franchisees. For example, we may collect the information listed above when you provide the information to an independently owned and operated Primrose Schools® franchisee to submit a request for more information on Primrose Schools or enroll students at a Primrose Schools location or during the regular course of students’ education and care.
    • Cookies and other tracking technologies: For example, we may automatically collect the following Personal Information or other information about your use of our Sites through cookies, web beacons, and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; device ID; the length of time you visit our Sites; page views; and the referring URL or webpage that led you to our Sites.
    • Third-party marketing vendors. For example, third-party marketing vendors may provide us with Personal Information, such as personal identifiers and/or website usage, when you open a promotional email or click on an online advertisement.

We may have used, shared, and/or sold the Personal Information described above for one or more of the following business or commercial purposes in the last twelve (12) months:

    • To provide education and care to Primrose Schools students. For example, we may use parent or student personal information for parent communications, student management and assessment, processing tuition payments, or to otherwise provide, review, and improve student education and care.
    • To respond to your inquiries and for other customer service purposes.
    • To tailor the content and information that we may send or display to you, to offer location customization and personalized help and instructions, and to otherwise personalize your experiences while using the Sites.
    • To administer sweepstakes, contests, and other promotions we may conduct from time to time through the Sites.
    • For marketing and promotional purposes. For example, we may use your Personal Information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about information we think may interest you. We also may use the information that we learn about you to assist us in advertising on third-party websites, including for creating audiences and for measurement, reporting, and optimization.
    • To manage the Careers page on the Sites, which is a tool used by Primrose and our franchisees to assist in employee recruiting efforts.
    • To better understand how users access and use our Sites, both on an aggregated and individualized basis, in order to improve our Sites and respond to user desires and preferences, and for other research and analytical purposes.
    • If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
    • We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms and Conditions of Use or this Policy, or as evidence in litigation in which Primrose Schools is involved.
    • We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.

Please note that we may combine information that we collect from you and about you (including automatically-collected information) with information we obtain about you from our affiliates, vendors, and/or other non-affiliated third parties and use such combined information in accordance with this Policy.

We may aggregate and/or de-identify information we collect. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties or affiliates.

We may have shared or sold the following Personal Information to the specified categories of third parties in the last twelve (12) months:

    • Identifiers. Recipients of this information may include: Affiliates and subsidiaries; service providers; Primrose Schools franchisees; applicant tracking vendors; email service providers; website development and hosting services providers; data analytics providers; marketing partners; and payment processors.
    • Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1797.80(e)). Recipients of this information made include: Affiliates and subsidiaries; service providers; Primrose Schools franchisees; applicant tracking vendors; email service providers; website development and hosting services providers; data analytics providers; marketing partners; and payment processors.
    • Internet activity information. Recipients of this information may include: Affiliates and subsidiaries; service providers; Primrose Schools franchisees; data analytics providers; and marketing partners.
    • Professional or employment-related information. Recipients of this information may include: Affiliates and subsidiaries; service providers; Primrose Schools franchisees; and applicant tracking vendors.
    • Characteristics of protected classifications under California or federal law. Recipients of this information may include: Affiliates and subsidiaries; service providers; Primrose Schools franchisees; applicant tracking vendors; email service providers; website development and hosting services providers; data analytics providers; and marketing partners.

We may have disclosed for a business purpose the following Personal Information to the specified categories of third parties in the preceding twelve (12) months:

    • Identifiers. Recipients of this information may include: Affiliates and subsidiaries; service providers; Primrose Schools franchisees; applicant tracking vendors; email service providers; website development and hosting services providers; data analytics providers; marketing partners; and payment processors.
    • Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1797.80(e)). Recipients of this information made include: Affiliates and subsidiaries; service providers; Primrose Schools franchisees; applicant tracking vendors; email service providers; website development and hosting services providers; data analytics providers; marketing partners; and payment processors.
    • Internet activity information. Recipients of this information may include: Affiliates and subsidiaries; service providers; Primrose Schools franchisees; data analytics providers; and marketing partners.
    • Professional or employment-related information. Recipients of this information may include: Affiliates and subsidiaries; service providers; Primrose Schools franchisees; and applicant tracking vendors.
    • Characteristics of protected classifications under California or federal law. Recipients of this information may include: Affiliates and subsidiaries; service providers; Primrose Schools franchisees; applicant tracking vendors; email service providers; website development and hosting services providers; data analytics providers; and marketing partners.

3. Methods for Submitting CCPA Requests to Primrose Schools

You have the right to submit a verifiable request to us using the following methods:

    • Online Request Form. You may submit a request to know by completing the online CCPA Consumer Request to Know Form located here or a request to delete by completing the online CCPA Consumer Request to Delete Form located here.
    • Email. You may submit requests by downloading and completing the CCPA Consumer Request Form and emailing the completed form to privacy@primroseschools.com.
    • Toll-Free Telephone Call. You may submit requests by calling our toll-free CCPA Request Hotline at 1-800-PRIMROSE. A member of our team will process your request and guide you through the verification process.
    • In-school Form. You may complete and submit a Request Form at any of our school locations in California.

See the “Do Not Sell My Personal Information” section below for more on how to submit a request to opt-out of the sale of Personal Information.

4. Verification Process

Once we receive a request to know or to delete, we must verify your identity before we can respond.

You may be required to provide the following information for verification purposes:

    • Your first and last name.
    • Home city, state, and zip code.
    • Your email address.
    • Your telephone number.
    • Any other data point that is reliable for the purpose of verifying identity.

If you submit either a request to know specific pieces of Personal Information collected, or a request to delete sensitive, irreplaceable, or otherwise valuable Personal Information, you (or your authorized agent, if applicable) will be required to provide a signed declaration affirming your identity (or your authorized agent’s identity, if applicable). The declaration is included on the online CCPA Consumer Request to Know Form located here and online CCPA Consumer Request to Delete Form located here.

5. Authorized Agents

An authorized agent is either a natural person or a business entity registered with the California Secretary of State that a consumer has authorized to act on his or her behalf.

You may use an authorized agent to submit a request to know, to delete, or to opt-out. You may make such a designation by providing the agent with written permission to act on your behalf. We will require the authorized agent provide either (1) a power of attorney or (2) proof of your written permission. In addition to proof of your written permission, we may require you to verify your own identity and directly confirm that you provided the agent permission to submit the request.

6. Response Timing and Format

    • Acknowledgement of receipt of request

We will confirm receipt of a request from you within ten (10) days. This confirmation will provide information about how we will process the request, including a description of our verification process and an approximation of when we will send you a substantive response.

    • Substantive Response

We will respond to a verifiable request from you within forty-five (45) days. If we cannot respond in that time, we will notify you in writing that we need an additional forty-five (45) days and explain the reason for the needed additional time. We will deliver the written response by mail or email, at your option.

Any disclosures we provide will cover only the 12-month period preceding our receipt of your verifiable request. If we cannot comply with your request, we will explain why. If you have requested to know specific Personal Information we collected, we will provide that information to you via email.

We do not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why and provide you with a cost estimate before completing the request.

    • Acting upon opt-out requests

We will act upon an opt-out as soon as commercially reasonable, but no later than fifteen (15) days from the date we receive the request.

7. Do Not Sell My Personal Information

You have the right to direct us not to sell your Personal Information and you may exercise this right at any time. Once you opt-out, we will not sell your Personal Information unless you give us authorization to do so. We will not ask you to reauthorize such sales until 12 months have passed since complying with request to opt-out.

If you are a California consumer and wish to opt-out of the sale of your Personal Information, you may submit an opt-out request by clicking on the following link: Do Not Sell My Personal Information. Alternatively, you may submit a request by calling 1-800-PRIMROSE.

8. Financial Incentive Offers

At this time, we do not offer any financial incentives or price or service differences that relate to our collection, retention, or use of your Personal Information. However, if this changes, we will provide a written description of the material terms of the financial incentive or price or service difference to you in a written Notice of Financial Incentive and you will only be enrolled as a participant if you affirmatively opt-in to the program. You may revoke your opt-in consent at any time. The Notice of Financial Incentive will explain the processes for opting-in to participate and revoking your consent (opting-out).

9. Contact Us for More Information

California consumers who have questions or concerns about our privacy policies and practices may contact a trained customer service representative through one of the following methods:

    • Toll-free call: 1-800-PRIMROSE
    • Email: privacy@primroseschools.com
    • Mail:Attention:Privacy
      Primrose School Franchising Company LLC
      3200 Windy Hill Road, Suite 1200E
      Atlanta, Georgia 30339

When contacting our customer service, please include in the communication or have available the information listed under the “Verification Process” section above. If using an authorized agent, please include in the communication or have available proof of authorization.

Last updated on: 05/26/21