Bethesda Country Day School

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Updated 11/2/2020

This Privacy Notice for California Residents supplements the information contained in our website Privacy and Cookie Notice and applies solely to those visitors to our Sites, students and parents of our schools, employees, and others who reside in the State of California (“Consumers” or “you”). The purpose of this notice is to provide you with a comprehensive description of (i) our online and offline practices regarding the collection, use, disclosure, and sale of Personal Information and (ii) your rights regarding the Personal Information we collect. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.

1. COLLECTION, USE, AND DISCLOSURE OF PERSONAL INFORMATION
Spring Education Group, Inc. and its subsidiaries (“Spring Education Group,” “we,” or “us”) collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household (“Personal Information”). We collect the categories of Personal Information specified below online and/or offline. We may use, share, or disclose these categories of Personal Information for one or more of the indicated business or commercial purposes. Nothing in this section limits our ability to use or disclose information as described in the Privacy and Cookie Notice or other materials provided to you, such as a Parent/Student Handbook (e.g., transcripts, record requests) or an Employee Handbook (e.g., employment verifications, benefits elections).

a. Categories of Personal Information Collected
In the past 12 months, we have collected the following categories of Personal Information:

• Identification Information, such as name, mailing address, email address, phone number, a copy of your government-issued identification, and your account information and password;
• Sensitive Information, such as your driver’s license number, insurance policy number, education, employment information, financial information, medical or health insurance information, age, race, ethnicity, physical or mental disability status, gender, or veteran or military status;
• Commercial Information, such as information about products or services purchased, used, or considered;
• Internet Activity Information, such as Traffic Data (as described in the Privacy and Cookie Notice) and other information automatically collected when you use the Site;
• Geolocation Information, such as physical location when you use the Site;
• Professional/Employment Information, such as current or past job history; and
• Education Information, such as education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

b. Sources of Personal Information
We collect the Personal Information described above from the following sources:

• Directly from you, such as your communications with us, registering to use our parent portals, enrolling your child, completing forms or submitting an inquiry;
• Indirectly from you, such as Traffic Data collected automatically from your use of the Site or Education Information from activities inherent to enrolling and attending school; and
• Third parties, such as partners we contract with to provide targeted online advertisements based on Traffic Data or educational and applicant/employee service providers using Personal Information on our behalf and only for the contracted business purpose.

c. Purpose of Personal Information Collection and Disclosure
We may use or disclose the Personal Information we collect about you for one or more of the following purposes:

• to provide you with our services, communicate with you, ensure that your child is receiving safe and appropriate care, and comply with licensing regulations and other legal requirements;
• for our direct marketing efforts, including when we send you marketing communications about our services that may be of interest to you, respond to your inquiries, and send you promotional messages, advertising, surveys, and other information that may be of interest to you;
• to create and maintain a trusted and safe educational environment (e.g., to detect and prevent fraud, abuse, or security incidents, conduct security investigations and risk assessments, enforce our policies, or comply with our legal obligations and licensing requirements);
• to evaluate your job application or employment-related activities (e.g., time cards for payroll);
• to maintain and improve the security and functionality of the Site by processing the Personal Information (e.g., Traffic Data) we collect automatically from your use of the Site to personalize your user experience, ensure that our web pages appear and function properly, improve the Site, programs, products, services, advertising, and content, and perform other functions; and
• for other purposes as permitted by law, such as notifying you about changes to the Site, protecting our rights and property, complying with a law, regulation, legal process or court order, or fulfilling any other purpose with your consent.

d. Disclosure and Sale of Personal Information
In the preceding 12 months, we have disclosed each of the categories of Personal Information described above for one or more of the business purposes described above to service providers and other vendors; parent entities, affiliates, and subsidiaries; medical providers; and enforcement, regulatory and other governmental agencies.

We do not make your Personal Information available for purchase or otherwise share your information with third parties in exchange for monetary compensation. Certain sharing of your information, however, may be considered a “sale” under the CCPA’s broad definition. In particular, in the last 12 months, if you have visited our Site, we may have shared your Commercial Information, Internet Activity Information, and/or Geolocation Information with advertising partners and social media platforms to match and serve our targeted advertisements on third-party websites. You can find additional information about how you can control cookies here.

We do not knowingly “sell” the Personal Information of consumers under the age of 16.

2. CALIFORNIA PRIVACY RIGHTS
To the extent provided for by law and subject to applicable exceptions, you may have the following privacy rights in relation to the Personal Information we collect:

• The right to request that we disclose what Personal Information we collect, use, disclose, and sell;
• The right to request access to the specific pieces of Personal Information we have collected about you;
• The right to request deletion of your Personal Information;
• The right to opt-out of the “sale” of Personal Information; and
• The right to be free from discrimination for the exercise of your privacy rights.

Additionally, subject to certain limits under California Civil Code § 1798.83, you may ask us to provide you with: (1) a list of certain categories of Personal Information that we have disclosed to certain types of third parties for their direct marketing purposes during the immediately preceding calendar year; and (2) the identity of the third parties that received certain Personal Information from us for their direct marketing purposes during that calendar year.

Exercising Your Rights: To submit a request, please complete our online request form, call 877-322-2861, or email us at privacy@springedugroup.com.

Verification: In order to protect your Personal Information from unauthorized access or deletion, we may require you to verify you are the person about whom we collected Personal Information, such as by logging in to your account before making a request. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information for verification. If we cannot verify your identity, we will not provide or delete your Personal Information.

Authorized Agents: You may use an authorized agent to submit a request on your behalf. If you do so, we may require the agent to provide their name, email address, phone number, and written permission from you that includes your contact information. We may contact you using the information provided and verify your identity directly with us and confirm that you have provided the agent permission to submit the request.

3. CONTACT FOR MORE INFORMATION

If you have any questions or concerns about our privacy policies and practices or would like to receive a copy of this notice in an alternative format, please do not hesitate to contact us at privacy@springedugroup.com.

4. CHANGES TO THIS PRIVACY NOTICE
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update the notice’s effective date.