PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
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”) collects 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., timecards 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.