Privacy Policy

Last Updated and Effective 11/2022

INTRODUCTION

This Service is operated by KidsPark, Inc. (“KidsPark,” “us,” “our,” or “we”) on behalf of itself and KidsPark franchisees (“Franchisees”). This Privacy Policy (“Privacy Policy”) explains how we collect, disclose, and process your Personal Data (defined below) when you use our Services. We also describe your rights and choices with respect to your Personal Data and other important information. Please read this Privacy Policy carefully before using our Services and/or providing us with your Personal Data. You can download a copy of this Privacy Policy by clicking here.

SCOPE OF THIS POLICY 

This Privacy Policy applies to Personal Data collected through our “Services,” which include the KidsPark corporate website at www.KidsPark.com (including any subdomains or mobile versions, the “Website(s)”), any of our web and mobile applications (“App(s)”) that link to/post this Privacy Policy, online or offline services provided by KidsPark in support of its Franchisees (e.g. support requests or back office administration), and the Centers operated by KidsPark.

Our Services may be provided to visitors to our Websites and Apps (“Users”), children and families that are registered with KidsPark (“Registrants”), applicants to register with KidsPark (“Applicants”), and Registrants that attend or visit our one of our centers operated by KidsPark or our Franchisees (“Centers”).

Please note: This Privacy Policy applies only to KidsPark, and any Services that KidsPark provides to its Centers and Franchisees. Franchisees may have access to Personal Data through our Services or may deliver services that you request via our Services. Franchisee’s use of Personal Data collected via our Services may be subject to additional privacy notices or practices of the Franchisee. Franchisees’ own processing of Personal Data is outside the scope of this Privacy Policy and is not under the control of KidsPark. Please review any Franchisee privacy policies for more information. 

Similarly, this Policy does not apply to Personal Data processed by other third parties, for example, when you visit a third-party website or interact with third-party services, unless and until we receive your Personal Data from those parties or contract with such third party to process Personal Data on our behalf. Any processing not done at the direction or on behalf of KidsPark is outside the scope of this Privacy Policy. We are not responsible for the privacy policies, content or security of third party services. We recommend that you check the privacy policies of third party services that you use.

WHO WE ARE

The “Business” or “Controller” processing your Personal Data subject to this Privacy Policy is KidsPark, Inc. Our Franchisees are separate Businesses/Controllers.

If you have any comments or questions about this Privacy Policy or KidsPark’s privacy practices, or to exercise your rights as described below, please contact us at the following addresses:

General Inquiries: Email
Physical Address: KidsPark Inc. Corporate Office, 812 S Winchester #150, San Jose, CA 95128
Web Info: Contact Us
Data Rights Inquiries: Contact Corporate
Centers/Franchises: Contact our Centers/Franchises

CATEGORIES AND SOURCES OF PERSONAL DATA 

“Personal Data” is data relating to identified or identifiable individuals and households.

Categories of Personal Data We Process
The categories of Personal Data we collect and use include (specific data elements are examples that may be subject to change):
Identity Data – Information such as:

• your name, unique identifiers, username;
• address, email address, telephone number, account handle (“Contact Data”); or
• account login details.

Biographical Data – Information such as gender, date of birth, age and/or age range, profile photo, and photograph or videos containing your image, employer, family living situation, and pertinent legal orders.

Device/Activity Data – Information about interactions with our Services (e.g. IP Address, MAC Address, SSIDs or other device identifiers or persistent identifiers), online user ID or device characteristics, and usage information such as your session time, session length, usage history, search history, metadata regarding date/time/features used, or other data similarly related to your use of our Service.

Commercial Data – Information such as details of products/services received, price, and locations visited.

Inference Data – Information relating to inferred preferences (such as the services/locations users seem to prefer based on your use of our Services), as well as demographics or interests, and information and analysis related to the use of our Services.

Audio/Visual Data – Photos, videos, recordings, and images collected from audio/video recordings.

User Content – Information such as unstructured/free-form data that may include any category of Personal Data, e.g. data provided in free text fields such as messages, comments, forms, or responses.

Sensitive Data – Information defined as “sensitive personal information” or “sensitive personal data” under applicable law, such as:

• Government IDs;
• Payment Card Data (“Payment Data”);
• Health insurance information (e.g. policy number); or
• Information relating to physical or mental health (e.g. asthma, hearing/visual conditions, allergies, medications, etc.) (“Health Data”).

Sources of Personal Data we Process
We collect Personal Data from various sources, which vary depending on the context in which we process that Personal Data:

From You – We may collect Personal Data from you when you apply or register with KidsPark, visit a Center, use our Websites or other Services.

From Centers – We may receive information from our Centers, which may be operated by Franchisees.

Automatically when you use our Services – We automatically collect, store, and use technical information about your device and interaction with our Services when you visit our Website or use our Apps. This data is sent from your computer or personal device to us using a cookies, scripts, or automated technologies.

Personal Data we create or receive from third parties – We may receive Personal Data from service providers that provide services on our behalf, e.g. through cookies and similar technologies. We may also receive Personal Data from our partners, e.g. in relation to products or services you receive or in connection with reward redemptions.

Data that we create or infer – We may create Personal Data relating to inferences drawn from Personal Data we process, or generate Personal Data relating to your predispositions, behavior, and attitudes.

CONTEXTS FOR COLLECTING AND PROCESSING PERSONAL DATA / NOTICE AT COLLECTION
Our use of Personal Data depends on who you are and how you interact with us. When you use our Services, we process Personal Data in specific contexts and for certain specified purposes, as well as for our general Business Purposes. Residents of certain jurisdictions may be entitled to additional notices under applicable law; see the “Supplemental Privacy Rights and Notices” section below for more information.

Applications & Customer Records
We collect Identity Data, Biographical Data, Device/Activity Data, Audio Visual Data, User Content, and Sensitive Data from Applicants (including their relatives, children, dependents, and certain designated parties), and we may generate Inference Data, relating to the application to register to attend our Centers. We use the Personal Data collected in this context in order to process the application, contact you with questions or concerns, and process your registration and enrollment. We also use the information submitted in connection with an application in order to create your family profile with KidsPark and create a master customer record (“Customer Record”). This Customer Record is used primarily to provide us and our Centers with vital information about you, your child, your preferences, and our relationship with you.

We or our Franchisees may also collect additional Identity Data, Commercial Data, and User Content, and we may generate Inference Data from Registrants that use our Services, for example, when you check-in or check out (including via our Apps) or when your child visits our Centers. We use the Personal Data collected in this context in to supplement and maintain your Customer Record, provide information that assists our Centers in providing better care to your child, track progress/behavior, and similar matters.

We use this Personal Data, and the Contact Data you provide, to contact you about your application or Customer Record with KidsPark, with transactional communications, and where permitted by law, with marketing communications.

We may also use Personal Data collected in this context for our Business Purposes. We do not sell/share Personal Data collected in this context. See below for information regarding how long we retain Personal Data.

We collect Sensitive Data in relation to your application & Customer Record. Specifically, we collect and process:

• Government ID Data for parents and other designated individuals so we can verify individuals’ identities, for security, fraud prevention, and in some cases, reporting purposes.

• Health Data relating to your child so that we can administer medication, manage dietary and environmental preferences, and as otherwise appropriate ensure the comfort, health, and safety of children in our Centers.

• Payment Data in relation to you application or registration so that we can process application/registration or other service fees. We (or our service providers) may keep this information on file to process recurring fees or for your convenience in paying future service fees.

• Health insurance information if you elect to provide it in order to handle any emergencies and in the vital interests of your child.

All Sensitive Data is processed and disclosed only as necessary to provide our Services and for permitted Business Purposes and subject to any further limitations on processing for such purposes that are set forth in applicable law.

We share application/registration data with the Center(s) you designate. When you submit an Application or visit a center, we will share information in the application/registration/check-in with the designated Center, which may be operated by a Franchisee. We process data to evaluate your application, and to create or manage your Customer Record. Franchisees may collect additional data, and may access and use Personal Data collected as part of the application or Customer Record. Franchisees may use your Personal Data for additional purposes, and may have supplemental privacy notices that apply to data collected as part of your application or as part of your visit.

User Accounts
When you create a User account on our Services (“User Account”), we process Identity Data, Device/Activity Data, Biographical Data, and Contact Data. We may also collect or create certain Inference Data and associate that data with your User Account. User Accounts are linked with your related Customer Record. We process Personal Data relating to User Accounts primarily to create, maintain, and provide you with  information about your User Account, provide account-based services you request, and provide you with information about your Registrations, and Customer Record.

Additionally, we use the Identity Data, and Contact Data as necessary to provide you with information regarding your User account, and we may send you marketing communications (subject to your consent where required by law) as described further below.

We may also process Personal Data collected in this context for our Business Purposes. We do not sell/share Personal Data collected in this context. See below for information regarding how long we retain Personal Data.

Apps and Websites
When you use our Apps and Websites, we automatically collect and process Identity Data and Device/Activity Data. We use this data as necessary to provide the service you request, initiate or fulfill your requests for certain features or functions through our Services, such as keeping you logged in, delivering pages, etc. In addition to Device/Activity Data, we may also collect and process Contact Data, and that we collect, create, and/or receive (including through the use of cookies and similar technologies).

If you use our App, we may provide you with features that allow you to interact with our Centers. For example, we may process Identity Data, Commercial Data, User Content and Audio/Visual Data to provide you with messaging or image sharing features. Teachers and other staff from the Center may process this information using our Services and make such information available to App users associated with your family record with KidsPark. We will otherwise process any Personal Data collected through the app as necessary to provide the features and functionality provided by our Apps from time to time.

Additionally, we process Personal Data collected from our Apps and Websites as necessary to ensure the security of our Services and other technology systems, to prevent fraud, and otherwise analyze the use of our Services, to help us develop new features, products, or service, or make improvements.

We may also process Personal Data collected in this context for our Business Purposes. We do not sell/share Personal Data collected in this context. See below for information regarding how long we retain Personal Data.

Please note – our Apps are operated by KidsPark on behalf of our Centers. Our Centers and Center personnel may have access to data collected via the Apps, and may make available Personal Data to App users. Centers may be operated by Franchisees, and information provided to or shared by Franchisees may be subject to the privacy policies of the Franchisee.

Cookies and other tracking technologies
We use cookies and similar technologies (such as scripts or web tokens) on our Services. These technologies may be used to collect or create Device/Activity Data, certain Identity Data (e.g. device identifiers), or Inference Data. Third parties may be allowed to view, edit, or set their own cookies or place web beacons on our Services. Cookies and similar technologies allow us and third parties to distinguish you from other users of our Services.

We and authorized third parties may use cookies and similar technologies for the following purposes:

• for “essential” or “functional” purposes, such as to maintain User sessions, to deliver content, for security functions, and enable certain features of our Services; and
• for “analytics” purposes, such as to analyze the traffic to and usage of our Services (for example, how many people have looked at a page, how visitors navigate our Services, what website they visited prior to  using our Services, and use this data to understand user behaviors and improve the design and functionality of the Services).

We may also process Personal Data collected in this context for our Business Purposes. We do not sell/share Personal Data collected in this context. See below for information regarding how long we retain Personal Data.

Please note – Certain third parties may be able to identify you across sites and services using the cookies and similar tracking technologies. The use of third party technologies may be subject to the privacy policies of that third party.

Marketing communications
We may send you automated marketing and promotional messages via email, SMS, or (if you use our App) via push notification. You may receive these messages if you are an Applicant, Registrant, or User of our Service (subject to your consent where required by law), or if you consent to such communications. We may also send you these communications if you contact us. We may also collect Device/Activity Data and Contact Data so that we can determine whether you have opened or forwarded an email or interacted with our communications.

We may also process Personal Data collected in this context for our Business Purposes. We do not sell/share Personal Data collected in this context. See below for information regarding how long we retain Personal Data.

When you contact us
When you contact us (e.g. as part of a contact us form, online chat, or support request) we may collect and process Identity Data, including the Contact Data you provide, Device/Activity Data, and any Audio/Visual data or User Content you provide. We use this Personal Data as necessary to address your request, fulfill the purpose for which that information was provided, or for other related purposes, including but not limited to communicating with you about our Service or KidsPark. Additionally where you consent, if relevant to your request, or if otherwise permitted by law, we may send you marketing communications (described above).

We may also process Personal Data collected in this context for our Business Purposes. We do not sell/share Personal Data collected in this context. See below for information regarding how long we retain Personal Data.

Feedback and surveys
We may process Contact Data, Inference Data, Audio/Visual Data, and User Content collected in connection with user surveys or questionnaires. We generally process this Personal Data as necessary to respond to user requests/concerns, and create aggregate analytics regarding user satisfaction. We may store and analyze feedback for our purposes, for example, to personalize the Services, and help recommend relevant offers or services.

We may also process Personal Data collected in this context for our Business Purposes. We do not sell/share Personal Data collected in this context. See below for information regarding how long we retain Personal Data.

BUSINESS PURPOSES OF PROCESSING PERSONAL DATA
We, our Franchisees, and our service providers process Personal Data for our business purposes and in connection with our legitimate business interests, as described below (“Business Purposes”):

Service Provision and Contractual Obligations
We process any Personal Data as is necessary to provide our Services, to process applications/registrations, to process requests, to authenticate users, and as otherwise necessary to fulfill our contractual obligations to you. Additionally, we may use Personal Data as necessary to audit compliance, and log or measure aspects of service delivery (e.g. to document ad impressions).

Internal Processing and Service Improvement
We may use Personal Data for analyzing and improving our Services, to develop new features or functionality, understanding how our Services are used, for customer service purposes, in connection with logs and metadata relating to service use, and for debugging, and similar purposes.

Security and Incident Detection
We may process Personal Data to improve the security of our Services, to identify and prevent crime, and prevent fraud. We may analyze network traffic, device patterns and characteristics, maintain and analyze logs and process similar Personal Data in connection with our information security and anti-fraud activities.

Compliance Safety, and Public Interest
We may also process any Personal Data as necessary to comply with our legal obligations, such as where you exercise your rights under data protection law and make requests, for the establishment and defense of legal claims, or where we must comply with our legal obligations, lawful requests from competent government or law enforcement officials, and as may be required to meet legal or law enforcement requirements or prevent illegal activity. We may also process data to protect the vital interests of individuals, or on certain public interest grounds, each to the extent allowed under applicable law. See the Sharing/Disclosure of Personal Data section below for more information

Aggregated/Anonymized data
We process Personal Data about our users and users in order to identify trends, such as to create aggregated or anonymized data about buying and spending habits, use of our Services, and other similar information (“Aggregated Data”). For example, we may process Aggregate Data to determine aggregate trends, how our Services are used, and other information relating to our Services. We may also retain and use this information in connection with the development of our Services. We may pass Aggregated Data to certain third parties to give them a better understanding of our business and to improve our Services. Aggregated Data will not contain information from which you may be personally identified.

Personalization
We may personalize or customize aspects of the Services based on your interactions with our content, and other Personal Data we process. For example, we (or our Franchisees) may tailor our marketing communications to your location, user profile, activity in the Service, and your preferences.

Corporate Events
Any Personal Data may be processed in connection with our corporate activities (e.g. accounting, sales forecasting, investor matters) or in the event we go through business transition, such as a merger, acquisition, liquidation, sale of all or a portion of our assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.

DISCLOSURE OF PERSONAL DATA
Personal Data we collect may be disclosed to or made available to a variety of parties, depending upon the purpose for and context in which that information was provided. We generally disclose Personal Data to the parties and in the contexts described below.

Please note: Franchisees may disclose Personal Data for additional purposes and to additional third parties. Please review any supplemental privacy notices that apply to data processed by Franchisees in order to understand how Franchisees may disclose Personal Data.

Parents, Guardians, Designees
We share certain Personal Data relating to children that is contained in a Customer Record with the child’s parents, guardians, and other parties designated in the application/Customer Record (e.g. an alternate caregiver or pickup). The specific Personal Data we share with these parties depends on the relationship between you, the child, and the third party, and we generally disclose data only as necessary to provide our Services and facilitate our Business Purposes. However, we may disclose any Personal Data relating to your child with these parties where disclosure is in the best interest of the child (e.g. for health or personal safety), where required by law, and in accordance with the direction of parents or guardians. We do not disclose Customer Record data relating to parents/guardians, or other adult designees with third parties, except as otherwise described below.

Centers and Franchises
We share Customer Records with our Centers, which may be operated by Franchisees. We may also disclose other Personal Data collected through our Services with our Centers and Franchisees, where appropriate (e.g. feedback/surveys, or if you contact us about our Centers). We disclose this Personal Data in order to allow our Centers and Franchisees to provide their services, ensure a consistent experience across all KidsPark Centers, and to better manage the relationship between you, KidsPark and our Centers/Franchisees, and in connection with our Business Purposes. Teachers and directors at each Center may have access to such Personal Data, as appropriate.

Service Providers
In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other lawful business interests, we may share Personal Data with processors, service providers, or subprocessors who provide services or process data on our behalf. For example, we may use cloud-based hosting providers to host our Websites or Apps, or we may disclose Personal Data as part of our own internal operations, such as security operations, internal research, and other Business Purposes.

Successors
Any Personal Data may be disclosed in the event that we go through a business transition, such as a merger, acquisition, liquidation, sale of all or a portion of our assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.

Corporate Affiliates
In order to streamline certain business operations and develop products and services that better meet the interests and needs of our users, we may share your Personal Data with any of our current or future affiliated entities, subsidiaries, and parent companies.

Lawful Recipients
In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data, any communications sent or received by you, and any other Personal Data that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime (including in connection with law enforcement, child welfare, or other legal investigations), to investigate violations of our Terms of Use, or when in the vital interests of us or any person.

We may also disclose any Personal Data on relevant public interest grounds. For example, we may process Personal Data as necessary to fulfill our legal obligations, to protect the vital interests of any individuals, for public health and other matters in the public interest.

Other Disclosures
We may disclose any Personal Data in accordance with your consent or requests to disclose data to third parties.

YOUR RIGHTS AND CHOICES
You may have certain rights and choices regarding the Personal Data we process. Please note these rights may vary based on the country or state where you reside, and our obligations under applicable law. Residents of certain jurisdictions may have additional rights under applicable law; see the “Supplemental Privacy Rights and Notices” section below for more information.

Your Rights
Generally
You may have certain rights and choices regarding the Personal Data we process. Please note these rights may vary based on the country or state where you reside, and our obligations under applicable law. Specific rights and disclosures are described further below. To exercise your rights under applicable law, you may submit a request by emailing us.

Rights Request Verification
All rights requests we receive directly must be verified to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your Personal Data. We may require that you log in to your account or verify that you have access to your account or the email on file in order to verify your identity. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf. There may be situations where we cannot grant your request, e.g. if we are legally obligated to keep Personal Data to comply with applicable law. We may also decline to grant a request where our interests in the continued processing of Personal Data outweighs individual privacy concerns, e.g. in relation to anti-fraud and security purposes, or a request for deletion of an account that is being investigated for security concerns. We may also deny your privacy request if it jeopardizes the privacy of others, is frivolous or vexatious, or as otherwise provided under applicable law.

Your Choices
Marketing Communications
You can withdraw your consent to receive marketing communications by clicking on the unsubscribe link in an email, following any opt-out instructions in the communication. In some cases, you may be able to opt-out by emailing us.

Withdrawing Your Consent/Opt-Out
Where we are processing your Personal Data based on your consent, you may change your mind and withdraw your consent at any time. The consequence of you withdrawing consent might be that we cannot perform certain Services for you.

Do-Not-Track
Our Services do not respond to your browser’s do-not-track request.

Cookies and Similar Technology
If you do not want information collected through the use of cookies, you can manage/deny cookies (and certain technologies) using your browser’s settings menu. Some devices allow you to control this through your device settings. You must opt out of third party services directly via the third party. For example, to opt-out of please see the Google Analytics Terms of Use, the Google Policy, and Google Analytics Opt-out. Disabling cookies and similar technologies may cause the Service to not function properly and certain features, functionality or services may not be available.

DATA RETENTION
As a general matter, we retain Personal Data for so long as it, in our discretion, is necessary to achieve the processing purposes described in this Privacy Policy, and in any event, for so long as is required by law. What is necessary may vary depending on the context and purpose of processing. We generally consider the following factors when we determine how long to retain data (without limitation):

• Retention periods established under applicable law;
• Industry best practices;
• Whether the purpose of processing is reasonably likely to justify further processing;
• Risks to individual privacy in continued processing;
• Applicable data protection impact assessments;
• IT systems design considerations/limitations; and
• The costs associated continued processing, retention, and deletion.

Certain Personal Data is retained pursuant to specific retention periods, as follows:

• Customer Records – We retain customer records for 7 years, or such longer period as is required by local law.
• User Accounts – We may disable User accounts after 2 years of User account inactivity (e.g. no log in), and then archive customer records associated with Applicants, Registrants, or Users that have not used our Services in 2 years.

We will review retention periods periodically and may sometimes pseudonymize or anonymize data held for longer periods.

DATA SECURITY
We implement and maintain commercially reasonable security measures to secure your Personal Data from unauthorized processing. While we endeavor to protect our systems, sites, operations and information against unauthorized access, use, modification and disclosure, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others.

MINORS
We do not knowingly collect Personal Data from an individual under age 18, and have no actual knowledge of collecting Personal Data from minors under 18. If you are under the age of 18, please do not submit any Personal Data through our Services. If you have reason to believe that we may have accidentally received Personal Data from an individual under age 18, please contact us.

CHANGES TO OUR PRIVACY POLICY
We reserve the right to change our Privacy Policy from time to time. Any such changes will be posted on this page. Your continued use of our Services constitutes your acceptance of any revised Privacy Policy.

SUPPLEMENTAL PRIVACY RIGHTS AND NOTICES
Rights under US State Laws
Under the California Consumer Privacy Act (“CCPA”) and other US state laws, you may have the following rights, subject to your submission of an appropriately verified request. Please note – These rights may be available only to certain individuals, and we may verify eligibility in connection with your exercise of any rights under applicable US state laws.

Right to Know/Confirm
You may have the right to confirm whether we process your Personal Data

Right to Know/Access; Portability
You may have the right to request any of following: (1) the categories of Personal Data we have collected about you, or that we have sold, or disclosed for a commercial purpose; (2) the categories of sources from which your Personal Data was collected; (3) the business or commercial purpose for which we collected or sold your Personal Data; (4) the categories of third parties to whom we have sold your Personal Data, or disclosed it for a business purpose; and (5) the specific pieces of Personal Data we have collected about you.

You may also request that we share this data with you in a common, portable format of our choice, subject to certain limitations under applicable law.

Please note – We may be prohibited under applicable law from sharing certain specific pieces of Sensitive Data in response to a right to know/access request. In such cases, we will provide information relating to the category of Sensitive Data.

Right to Correct
You may have the right to request that we correct Personal Data that you believe to be inaccurate.

Right to Delete
You may have the right to delete certain Personal Data that we hold about you, subject to exceptions under applicable law.

Right to Non-Discrimination
California residents have the right to not to receive discriminatory treatment as a result of your exercise of rights conferred by the CCPA.

Direct Marketing
California residents may have the right to request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year (if any).

Submission of Requests
You may submit requests by emailing us.

Verification of Requests
All rights requests (except for requests to opt out of sales of data) must be verified. We may require that you provide the email address we have on file for you (and verify that you can access that email account) as well as other data we have on file, in order to verify your identity. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.

Please note – we may request additional information, depending on the sensitivity of data you request. For example, we may require that your verification match three elements of the records we possess when you request information relating to Customer Records.

Supplemental Privacy Notices
Categories of Personal Data Disclosed for Business Purposes

For purposes of the CCPA, we may disclose to third parties, certain categories of Personal Data for “business purposes,” as specified below. See the “Business Purpose of Processing” section above for more information regarding these purposes.

Data Category	Business Purpose Recipients
Identity Data	Service Providers; Parents/Guardians/Designees; Centers/Franchisees; Partners;  Successors; Affiliates; Lawful Recipients
Biographical Data	Service Providers; Parents/Guardians/Designees; Centers/Franchisees; Partners;  Successors; Affiliates; Lawful Recipients
Device/Activity Data	Service Providers; Parents/Guardians/Designees; Centers/Franchisees; Partners;  Successors; Affiliates; Lawful Recipients
Commercial Data	Service Providers; Parents/Guardians/Designees; Centers/Franchisees; Partners;  Successors; Affiliates; Lawful Recipients
Inference Data	Service Providers; Parents/Guardians/Designees; Centers/Franchisees; Partners;  Successors; Affiliates; Lawful Recipients
Audio/Visual Data	Service Providers; Parents/Guardians/Designees; Centers/Franchisees; Partners;  Successors; Affiliates; Lawful Recipients
User Content	Service Providers; Parents/Guardians/Designees; Centers/Franchisees; Partners;  Successors; Affiliates; Lawful Recipients
Sensitive Data	Service Providers; Parents/Guardians/Designees; Centers/Franchisees; Partners;  Successors; Affiliates; Lawful Recipients

Categories of Personal Data Sold
We do not “sell” your Personal Data, and have not done so in the preceding 12 months. We do not have actual knowledge that we have sold or shared the Personal Data of any person 16 or under.