Privacy Policy

Effective date: 10/8/2020



Wonderschool, Inc. (“Wonderschool,” “we,” “us,” or “our”) knows you care about how your personal information is used and shared, and we take your privacy seriously. This Privacy Policy describes the information we collect, how we use it, and when and with whom we share it. Except as explicitly provided herein, this Privacy Policy applies only to information that we collect and use about you when you access or use our website, mobile application, or other online or mobile service that links to or otherwise presents this Privacy Policy to you. We refer to these products and services collectively as the “Services.” By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways. If you do not agree to this Privacy Policy, please do not access or use the Services.

Remember that your use of the Services is at all times subject to the Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Use.

WILL WONDERSCHOOL EVER CHANGE THIS PRIVACY POLICY?

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to material changes by placing a notice on the Services, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

WHAT INFORMATION DOES WONDERSCHOOL COLLECT?

We obtain information about you through the means discussed below when we provide the Services. Please note that we need certain types of information to provide the Services to you. If you do not provide us with such information, or if you ask us to delete that information, you may no longer be able to access or use certain Services.

INFORMATION YOU PROVIDE TO US

We may collect information that you provide directly to us, such as:
- When you register for the Services;
- When you use the Services, such as when you enroll in childcare programs or offer a program through our Services;
- When you participate in surveys or fill out forms;
- When you subscribe to newsletters;
- When you register for promotions;
- When you transmit user content to us;
- When you request customer support and/or technical assistance; and
- When you otherwise communicate with us or with others through the Services.

The information you provide directly to us may concern you or others and may include, but is not limited to:
- Registration Information: We may collect registration information such as your name, email address, phone number, birthdate, address, social security number, driver’s license number, immunization records, occupation and third-party account credentials (for example, your log-in credentials for Facebook or other third party sites).
- Information Regarding Children: We may collect the name of your child(ren), birth date, and other information regarding your child(ren), including without limitation immunization records.Health Information: We may collect information regarding the health of you or your children. You acknowledge and agree that any such information is provided by you and not a health care professional of any kind. Health information is treated the same as all other personal information.
- Communications: We may collect communications you make on or through the Services, including communications between you and other users of the Services.You are not required to provide us with such information, but certain features of the Services may not be accessible or available, absent the provision of the requested information.

INFORMATION COLLECTED AUTOMATICALLY

Device/Usage Information. We and our third-party service providers, which include ad networks and analytics companies, may use cookies, web beacons, and other tracking technologies to collect information about the computers or devices (including mobile devices) you use to access the Services. As described further below, we may collect and analyze information including but not limited to (a) browser type; (b) ISP or operating system; (c) domain name; (d) access time; (e) referring or exit pages; (f) page views; (g) IP address; (h) unique device identifiers (e.g. IDFA or Android ID); and (i) the type of device that you use. We may also track when and how frequently you access or use the Services, including how you engage with or navigate our website or mobile application. We use this information (including the information collected by our third-party service providers) for analytics (including to determine which portions of the Services are used most frequently and what our users like/do not like), to assist in determining relevant advertising (both on and off the Services), to evaluate the success of our advertising campaigns, and as otherwise described in this Privacy Policy.

Cookies and Other Electronic Technologies. We and our third-party service providers may use cookies, clear GIFs, pixel tags, and other technologies that help us better understand user behavior, personalize preferences, perform research and analytics, and improve the Services. These technologies, for example, may allow us to tailor the Services to your needs, save your password in password-protected areas, track the pages you visit, help us manage content, and compile statistics about usage of our Services. We or our third-party service providers also may use certain of these technologies in emails to our customers to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

We may also use local shared objects (also known as "Flash cookies") to assist in delivering special content, such as video clips or animation. Flash cookies are stored on your device, but they are not managed through your web browser. To learn more about how to manage Flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. If you disable cookies, you may be prevented from taking full advantage of the Services, because the Services may not function properly. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser may not affect flash cookies. As we adopt additional technologies, we may also gather additional information through other methods.

Location Information. When you use the Services, we may collect general location information (such as general location inferred from an IP address). If you authorize us, we may also collect precise geolocation information, which we may use to, for example, provide you with childcare options near you.

INFORMATION COLLECTED FROM THIRD PARTIES

We may collect information about you or others through third parties. For example, to the extent permitted by law, if you seek to offer childcare through our Services, we may ask for and collect supplemental information from third parties, such as information to verify your identity or information for other fraud or safety protection purposes.We may collect information about you or others through non-affiliated third parties. For example, you may be able to access the Services through a social networking account, such as Facebook. If you access the Services through your Facebook account, you may allow us to have access to certain information in your Facebook profile. This may include your name, profile picture, gender, networks, user IDs, list of friends, location, date of birth, email address, photos, videos, people you follow and/or who follow you, and/or your posts or "likes." Social networking sites, such as Facebook, have their own policies for handling your information. For a description of how these sites may use and disclose your information, including any information you make public, please consult the sites' privacy policies. We have no control over how any third-party site uses or discloses the personal information it collects about you.

We may combine information that we collect from you through the Services with information that we obtain from such third parties and information derived from other products or services we provide.

HOW DOES WONDERSCHOOL USE INFORMATION ABOUT YOU?

We use your information for business and commercial purposes, such as:
- To provide you with the Services, including to help you locate childcare, to help a third party company support you in locating childcare,to provide a platform through which you may offer childcare, or to support a third party in supporting you to start, operate, or grow your childcare;
- To respond to your questions or inquiries, including to provide customer support and troubleshooting assistance;
- To communicate with you, including to send you emails about products and services that may interest you;
- To manage and remember your preferences and personalize the Services;To analyze and improve the Services or any other products and services we provide;
- To administer surveys, sweepstakes, promotions, or contests;
- To verify your identity;
- To comply with our legal obligations or as permitted by law;
- To protect the safety and/or integrity of our users, employees, third parties, members of the public, and/or our Services;
- To prevent fraud and enforce our legal terms; and
- To administer and troubleshoot the Services.

We may combine information that we collect from you through the Services with information that we obtain from affiliated and nonaffiliated third parties, and information derived from any other products or services we provide.We may aggregate and/or de-identify information collected through the Services. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes and may also share such data with any third parties at our discretion.

HOW DOES WONDERSCHOOL SHARE INFORMATION ABOUT YOU?

We may share or disclose information in the following ways:
- Affiliates. We may share your information with any of our affiliates.
- Consent/At Your Direction. We may disclose your information to nonaffiliated third parties based on your consent to do so. Such consent includes the disclosure of your information (a) in order to facilitate inquiries or registrations for childcare programs, including sharing your profile information that is publicly available; (b) when we have your permission; or (c) as described in this Privacy Policy, the Terms of Use, or any other legal terms governing your use of the Services.
- Business Partners. We may disclose certain business-related information of those who offer programs through our Services. For example, to promote enrollment in these programs, we may provide to our business partners information regarding program enrollment and program locations.
- Service Providers: We provide access to or share your information with select third parties who perform services on our behalf. They provide a variety of services to us, including data storage, analytics, billing, marketing, product content and features, customer service, data storage, security, fraud prevention, and legal services.
- Protection of Wonderschool and Others: We may share or disclose certain information if we believe in good faith that doing so is necessary or appropriate to (i) protect or defend the rights, safety, or property of Wonderschool or third parties, including to defend or enforce our Privacy Policy, our Terms of Use, or any other contractual arrangement or (ii) respond to your requests for customer service; and/or (iii) protect the rights, property or personal safety of Wonderschool, its agents and affiliates, its employees, users and/or the public.
- Legal Requirements: We may share or disclose certain information if we believe in good faith that doing so is necessary or appropriate to comply with any law enforcement, legal, or regulatory process, such as to respond to a warrant, subpoena, court order, or other applicable laws and regulations.
- Business Transfer: We may share or disclose certain information, in connection with or during negotiations of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Aggregate/Anonymous Information: From time to time, we may share aggregate/anonymous information about use of the Services, such as by creating reports on usage trends. The sharing of such data is unrestricted.

ONLINE ANALYTICS AND TAILORED ADVERTISING

ANALYTICS
We may use third-party web analytics services on the Services, such as those of Google Analytics. These service providers use the sort of technology described in the “Information we collect automatically” section above to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We may also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on.

TAILORED ADVERTISING
Third parties whose products or services are accessible or marketed via the Services may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (a) inform, optimize, and serve marketing content based on past visits to our websites and other sites and (b) report how our marketing content impressions, other uses of marketing services, and interactions with these marketing impressions and marketing services are related to visits to our websites. We also allow other third parties (e.g., ad networks and ad servers such as Google Analytics) to serve tailored marketing to you and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technologies, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of targeted advertising as described below. You may receive tailored advertising on your computer through a web browser. Cookies may be associated with de-identified data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may share with a service provider in hashed, non-human-readable form.

If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored marketing, you may visit the Network Advertising Initiative's (“NAI”) Consumer Opt-Out Link and/or the Digital Advertising Alliance's (“DAA”) Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertising content even if you opt out of tailored advertising. In that case, the advertising content will just not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI's and DAA's websites, accessible by the above links.

When using a mobile application, you may also receive tailored in-application advertising content. Each operating system--iOS for Apple devices, Android for Android devices, and Windows for Microsoft devices--provides its own instructions on how to prevent the delivery of tailored in-application marketing content. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertising. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.

HOW DOES WONDERSCHOOL PROTECT INFORMATION ABOUT YOU?

We implement technical, administrative, and physical safeguards to protect the information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free, so we cannot guarantee complete security. Your Wonderschool Account is protected by a password for your privacy and security. Among other things, you must prevent unauthorized access to your Wonderschool Account and information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

CHILDREN'S PRIVACY
While we may collect information about children under 13 from their parents, guardians, and/or caregivers, the Services themselves are not designed for minors under the age of 18. As noted in the Terms of Use, we do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at [email protected].

THIRD-PARTY LINKS
The Services may contain links to third-party websites or services. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third parties.

WHAT CHOICES DO I HAVE?

- Disclosure of Information. You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.
- Account Information. You may access your Wonderschool Account to access and, in some cases, edit or remove certain information. This may include your (1) name and password; (2) email address; (3) phone number; and (4) other user profile information. The information you can view, update, and remove may change as the Services change. Some of the information in your Wonderschool Account such as your location, phone number, address, email address and user profile information, may be visible to other user with whom you have confirmed bookings. If you have any questions about viewing or updating information we have on file about you, please contact us at [email protected].
- Marketing Communications. You can unsubscribe from marketing emails by following the directions in those emails.
- Cookies & Analytics: You can opt out of certain cookie-related and analytics processing by following the instructions in this Privacy Policy.
- California Residents: Please click here to view details on rights for California residents.

Please note, however, that certain information may be exempt from such requests in some circumstances, which may include needing to continue processing your information for our legitimate interests or to comply with a legal obligation. We may request that you provide us with information necessary to confirm your identity before responding to your request.

CALIFORNIA DO-NOT-TRACK DISCLOSURE
Wonderschool is committed to providing you with meaningful choices about the information collected on our Services for third party purposes. That is why we have provided links (above) to the NAI “Consumer Opt-Out” link, the DAA opt-out link, and a Google opt-out link. However, Wonderschool does not currently recognize or respond to browser-initiated Do-Not-Track signals, as the Internet industry is currently still working on Do-Not-Track standards, implementations and solutions.

CONSENT TO TRANSFER
Our computer systems are currently based in the United States, so your personal information will be processed by us in the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using the Services, you agree to this Privacy Policy and you consent to the transfer of all such information to the United States, which may not offer a level of protection equivalent to that required in the European Union or certain other countries, and to the processing of that information as described in this Privacy Policy.

WHAT IF I HAVE QUESTIONS ABOUT THIS POLICY?
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to [email protected], and we will try to resolve your concerns.

CALIFORNIA NOTICE AT COLLECTION AND SUPPLEMENTAL PRIVACY NOTICE
This California Notice at Collection and Supplemental Privacy Notice supplements the information in our Privacy Policy above, and except as provided herein, applies solely to California residents. It applies to personal information we collect on or through the Services and through other means (such as information collected offline, in person, and over the telephone). It does not apply to personal information we collect from our employees and job applicants in their capacity as employees and job applicants. It also does not apply to personal information we collect from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services.

California law requires us to disclose information regarding the categories of personal information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as those terms are defined by applicable law) for which the information was collected, and the categories of parties with whom we share personal information.

As described further in our Privacy Policy above, in the preceding twelve months, we or our service providers may have collected the below categories of personal information for business or commercial purposes:
- Identifiers: We may collect identifiers such as name, email address, phone number, government identifiers, and other account information.
- Commercial Information: We may collect commercial information, such as transaction data regarding the transactions you’ve made with or through us.
- Demographic Information: We may collect demographic information through photo identification information.
- Financial or Payment Information: We or our service providers may collect payment or other financial information, such as to process tuition payments.
- Employment Information: We may collect employment and business contact information, such as job positions and titles, and business contact information.
- Education Information: We may collect information related to your educational history, such as college attended.
- Internet or Other Network or Device Activity: We may collect network or device information, such as an IP address, unique device identifiers, advertising and app identifiers, browsing history, or other usage data.
- Location Information: We may collect general location information (such as those inferred from an IP address), or specific geolocation where you grant us access to such information.
- Sensory Information: We may collect sensory information, such as audio recordings if you call our customer service.Health Information: We may collect health information, such as if users provide us with health information related to enrollment at childcare centers.
- Personal Information Related to Protected Classifications: Our users may provide us with information that reveals information related to protected classifications, such as gender, sexual orientation, marital status, political opinions, or ethnicity.
- Other Information that Identifies or Can Be Reasonably Associated With You: We may also collect other information that identifies or can be reasonably associated with you, such as when you send us communications.

We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the Services; (3) affiliates; and (4) third parties such as screening services, childcare providers, other users, social networks, and data brokers.

We collect the categories of personal information identified above for the following business and commercial purposes, which are also described further above in our Privacy Policy:
- Provide the Services (e.g., account servicing and maintenance, order processing and fulfillment, customer service, advertising and marketing, analytics, and communication about the Services);
- Operational purposes (e.g. to enable and troubleshoot our Services);
- Auditing consumer interactions on our site (e.g., measuring ad impressions);
- Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;Bug detection, error reporting, and activities to maintain the quality or safety of our Services;
- Short-term, transient use, such as customizing content that we or our service providers display on the Services;
- Improving our existing Services and developing new services (e.g., by conducting research to develop new products or features);
- Other uses that advance our commercial or economic interests, such as third-party advertising and communicating with you about relevant offers from third-party partners;
- Other uses about which we notify you.

We describe our information sharing practices in the Privacy Policy above. In the previous twelve months, we may have shared certain categories of personal information with third parties for business purposes. For example, you may direct us to share information with childcare providers offering childcare through the Services. The information we share may include the following categories of personal information: (1) identifiers; (2) demographic information; (3) employment information; (4) health information; (5) information related to protected classifications; and (6) other information that identifies or can reasonably identify you.

If you are a California resident, you may have certain rights. California law may permit you to request that we:
- Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
- Provide access to and/or a copy of certain information we hold about you.
- Delete certain information we have about you.

You have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services.

If you would like to exercise any of these rights, please submit a request using this form or contact us at [email protected]. You will be required to verify your identity before we fulfill your request. If you have an online account with us, logging into your account will serve to verify your identity and request, although we may request additional information if we believe your account has been compromised. If you do not have an account with us, or if we have reason to suspect that the security of your account is compromised, we will request additional information from you to match with our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought.

You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

The CCPA requires businesses that “sell” personal information, as the term “sell” is defined under the CCPA, to provide an opt-out from such sales. Some people have taken the position that when a website uses third parties’ cookies or similar technology for its own analytics or advertising purposes, the website is engaged in a “sale” under the CCPA if the third parties have some ability to use, disclose or retain the data to improve their service or to take steps beyond the most narrowly drawn bounds of merely providing their service to the website/app. Some take this position even when the website pays the third party (not vice versa), and in most cases merely provides the third party with an opportunity to collect data directly, instead of providing personal information to the third party. If you take the position that any of those relationships involve a “sale” within the meaning of the CCPA, then you may consider Wonderschool to have “sold” what the CCPA calls “identifiers” (like IP addresses), “internet or other electronic network activity information” (like information regarding an individual’s browsing interactions on a Wonderschool website), and “commercial information” (like the fact that a browser visited a page directed to people who are considering obtaining childcare through our Services) to those sorts of companies. While Wonderschool does not believe these are “sales” as that term is defined under the CCPA, you can opt out of this activity by following the directions in Section 5 above.

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of personal information to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at [email protected].

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