California Privacy Policy

Effective Date: February 2, 2023

This Privacy Notice (“Notice”) is provided pursuant to the California Consumer Privacy Act (“CCPA”) and describes how Primrose School Franchising Company LLC and our affiliated entities (collectively, “Primrose Schools,” “us,” “we,” or “our”) processes Personal Information of California residents who interact with us online and offline, including visitors to our websites located at www.primroseschools.com, www.primrosecares.com, www.primrosefranchise.com, www.primroseadvantage.com, www.theprimroseadvantage.com, all individual school sites linked to www.primroseschools.com, and users of our mobile applications (collectively, the “Services”). This Notice may not encompass all Personal Information collected or processed by individual schools, which are independently owned and operated franchises. This Notice supplements our other privacy policies and notices, including our main Privacy Policy. In the event of a conflict between any other policy, statement, or notice and this Notice, this Notice will prevail as to California consumers.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.

Within the past 12 months, we collected the following categories of Personal Information about California consumers. Note that the Personal Information we collect about you may vary depending on the nature of your interactions with us and may not include all of the examples listed below.

• Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers
• Personal information described in Cal. Civ. Code § 1798.80(e), including name, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, credit card number, debit card number, or other financial information, medical information, or health insurance information
• Characteristics of protected classifications under California or federal law, including age and date of birth, race, ancestry, ethnic origin, sex, gender, gender identity, religion or creed, military or veteran status, medical condition, and disability
• Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
• Internet or other electronic network activity information, including browsing history, search history, and information regarding your interactions with our websites, applications, or advertisements
• Geolocation data, including location data inferred from your device IP address
• Audio, electronic, visual, thermal, olfactory, or similar information, including phone calls and video conferencing
• Professional or employment-related information, including: skills, qualifications, work experience, references, recommendations, and other information included in a resume, CV, application form, or cover letter; answers to behavioral or other screening questions in an application or interview; information contained in any personal webpages or documents you choose to share with us; information relating to professional licenses, training, disciplinary actions, and membership in professional organizations; information relating to membership in civic organizations; citizenship, immigration, visa status, and work authorization information (including information from related documents, such as your passport, driver’s license, or other identification, proof of residence, and proof of authorization to work in the United States, and documents you provide with your US Citizenship and Immigration Services Form I-9); languages spoken; criminal records information including results of background checks
• Non-public education information, including school(s) attended, grades, transcripts, records of attendance, disciplinary records, or other information relating to your secondary and post-secondary education
• Inferences used to create a profile reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
• Sensitive Personal Information. The categories of Personal Information we may collect include the following categories of Sensitive Personal Information:
  • Social security, driver’s license, state identification card, or passport number
  • Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
  • Personal Information that reveals a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership
  • Personal Information collected and analyzed concerning a consumer’s health 

We also collect some Personal Information that does not directly fit within one of the categories defined by the CCPA. For example, we collect the contents of communications you send to us, and may derive the geographic coordinates of a property (latitude/longitude) from address information. 

Generally, we collect the categories of Personal Information described above from the following categories of sources:

• Directly from you
• From our independently owned and operated franchisees
• Automatically when you use our Services
• When you interact with us by phone or through videoconferencing technology
• From service providers that help us to run our business (such as those that host or support the Services, provide analytic, communications, marketing or data storage services, or otherwise perform functions on our behalf)
• From third parties, which may include internet service providers, ad networks, social networks, data brokers, background check vendors, and individuals who may submit Personal Information about you
• Derived from other information we collect
• Government records

Generally, we collect Personal Information about California residents for the following purposes. The specific purposes for which we collect your Personal Information may vary depending on the nature of your relationship with us.

• To provide education and care to Primrose Schools students
• To facilitate your use of our Services 
• To provide our Services to you
• To communicate with you
• To maintain records of enrollment 
• To process your purchases
• To respond to your inquiries and provide customer service
• For marketing, promotions, and advertisements 
• To provide you with tailored recommendations and updates 
• To show you relevant ads while you are browsing the internet or using social media
• To improve our Services, develop new Services, set default options, and provide you with a better experience
• To provide operational, analytical, and other support for our franchisees
• As part of our application process for potential franchisees, and relationship with current franchisees
• To facilitate the process of applying for a job with us. For example, to open and maintain your application records, and assess your eligibility for employment.
• To protect the security of our Services 
• To detect and prevent fraud against you and or/us
• To comply with applicable laws and regulations

We may use Sensitive Personal Information to comply with government reporting requirements and other legal obligations, to manage the security of our property, systems and your account, and to provide reasonable accommodations.

In addition to the purposes described above, we may use and disclose any category of Personal Information or Sensitive Personal Information we collect to respond to law enforcement requests, or as otherwise required or authorized by applicable law, court order, or governmental regulations; to protect our rights and interests and those of others (including our franchisees); to resolve any disputes; to enforce our policies; and to evaluate or conduct a merger, sale, or other acquisition of some or all of our assets. We also reserve the right to use Personal Information we collect for any other purpose identified in an applicable privacy notice, click-through agreement, or other agreement between you and us, or otherwise with your consent.
We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

We keep the categories of Personal Information described above for as long as is necessary or permitted for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply: 

• Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;  
• Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected; 
• The Personal Information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or 
• We are otherwise required or permitted to keep your Personal Information by applicable laws or regulations.

Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention practices, please contact us using the contact details below.

Disclosures for a Business or Commercial Purpose

We disclose Personal Information to our service providers and contractors for business purposes as follows:

Personal Information:

• Processing your purchases of or requests for products or services
• Performing services (including processing, maintaining, or collecting Personal Information) on our behalf (e.g., fulfilling and delivering orders, processing payments, supporting our promotions, and providing communications, technical, analytical, web hosting, cloud hosting and application support, support for our job application process or vendor management, or other services on our behalf)
• Auditing related to ad impressions
• Ensuring security and integrity of Personal Information
• Debugging to identify and repair errors that impair existing intended functionality
• Short-term, transient use, including, but not limited to, non-personalized advertising 
• Providing advertising and marketing services (except for cross-context behavioral advertising)
• Undertaking activities to verify or maintain the quality or safety of our Services
• To comply with applicable laws and regulations
• Detecting or protecting against malicious, deceptive, fraudulent or illegal activity

Sensitive Personal Information:

• To register children for Primrose Schools’ services
• To assess your eligibility for employment
• To comply with applicable laws and regulations
• To manage the security of our property and systems
• To protect the security of our Services and your account
• To detect and prevent fraud against you and/or us
• To provide accommodations
• To promote safety for Primrose students

Sales and Sharing of Personal Information

Although we do not sell Personal Information in exchange for money, some of the ways in which we share Personal Information for advertising or to our franchisees may be considered “sales” or “sharing” under California law.

Listed below are the categories of Personal Information we share for purposes of cross-context behavioral advertising or otherwise “sell,” as that term is defined under California law. We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.

Category of Personal Information:

• Identifiers
• Personal Information described in Cal. Civ. Code § 1798.80(e)
• Characteristics of protected classifications
• Commercial information
• Internet or other electronic network activity information
• Geolocation Data
• Professional or employment-related information
• Inferences

Categories of Third Parties to which Information was Sold or Shared:

• Advertising companies
• Social networks
• Franchisees

Purposes for Selling/Sharing:

• For marketing, advertising, certain types of analytics or similar purposes
• For certain registration or activities
• To show you relevant ads while you browse the internet or use social media
• To provide operational, analytical, and other support for our franchisees

If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. Please note that, if you submit a request to know, request to delete, or request to correct, you will be asked to provide 2-3 pieces of Personal Information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using the webforms or toll-free number listed below.

Right to Know. You have the right to know what Personal Information we have collected about you, which includes: 

1. The categories of Personal Information we have collected about you, including 
   1. The categories of sources from which the Personal Information was collected
   2. Our business or commercial purposes for collecting, selling, or sharing Personal Information
   3. The categories of recipients to which we disclose Personal Information
   4. The categories of Personal Information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of Personal Information
   5. The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information
2. The specific pieces of Personal Information we have collected about you.

To submit a request to know, please click here or call us at 1-800-774-6763.

Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions. Where we use deidentification to satisfy a deletion request, we commit to maintaining and using the information in deidentified form and will not attempt to reidentify the information. To submit a request to delete, please click here or call us at 1-800-774-6763. 

Right to Correct Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information. To submit a request to correct, please click here or call us at 1-800-774-6763.

Right to Opt Out of Sales and Sharing of Personal Information. You have the right to opt out of the sale of your Personal Information, and to request that we do not share your Personal Information for cross-context behavioral advertising. To opt out of the sale or sharing of Personal Information, please click here or call us at 1-800-774-6763.

Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.

If you have questions about our privacy practices, please contact us as follows:

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