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
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
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”).
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.
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):
If we sold your Personal Information or disclosed it for a business purpose, we will provide:
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.
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:
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.
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.
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.
You have the right to equal service, and we will not discriminate against you if you exercise your rights under the CCPA.
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:
We may have obtained the Personal Information listed above from the following sources in the last twelve (12) months:
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:
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:
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:
You have the right to submit a verifiable request to us using the following methods:
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.
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:
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.
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.
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.
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.
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.
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).
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:
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