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California Consumer Privacy Act

LINDAMOOD-BELL LEARNING PROCESSES PRIVACY NOTICE
ADDITIONAL CALIFORNIA PRIVACY DISCLOSURES

Last Updated: Dec 30, 2021

 

Scope of Disclosures

These Additional California Privacy Disclosures (the “CA Disclosures”) supplement the information contained in our Privacy Notice and apply solely to individual residents of the State of California (“consumers” or “you”).

These CA Disclosures provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).

Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.

Personal Information Disclosures

When we use the term “personal information” in these CA Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

For the purposes of these Disclosures, personal information does not include:

  • Publicly available information from government records.
  • Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
  • Information excluded from the CCPA’s scope, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

 

Collection and Use of Personal Information

In the last 12 months, we have not sold personal information about you, but we have collected and disclosed for a business purpose the following categories of personal information:

 

Category of Personal Information

Collected

Categories of Sources

Commercial or Business Purpose

Identifiers, such as name, alias, postal address, unique personal identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers X
  • Directly from you
  • To fulfill the reason the information was provided
  • To comply with applicable law or government regulations
California Customer Records (Cal. Civ. Code § 1798.80(e)), such as Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification number, insurance policy number, education, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information X
  • Directly from you
  • To comply with applicable law or government regulations
Protected Classification Characteristics, such as age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status X
  • Directly from you
  • To comply with applicable law or government regulations
Commercial Information, such as records of personal property and products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
  • Indirectly from you
Biometric Information, such as genetic, physiological behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information such as fingerprints, faceprints and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health or exercise data
Internet/Network Information, such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement X
  • Indirectly from you
  • To market our services and to determine the effectiveness of such advertising and marketing
Geolocation Data, such as physical location or movements X
  • To operate, evaluate, and improve our business
Sensory Information, such as audio, electronic, visual, thermal, olfactory, or similar information
Professional/Employment Information, such as current or past job history or performance evaluations
Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99), 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 x
  • Directly from you
  • Clients and third parties in connection with provided services
  • To fulfill the reason the information was provided
Other Personal Information
Inferences, such as profile reflecting a person’s preferences characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

 

Disclosure and Sale of Personal Information

In the last 12 months, we have not sold personal information about you, but we have disclosed for a business purpose the following categories of personal information, which reference the categories of personal information described above:

 

Category of Personal Information

Disclosure for a Business Purpose

Sold*

Identifiers X X
(See Third-Party Tracking and Online Advertising Below)
California Customer Records (Cal. Civ. Code § 1798.80(e)) X
Protected Classification Characteristics
Commercial Information
Biometric Information
Internet/Network Information X
Geolocation Data
Sensory Information
Profession/Employment Information
Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99)
Other Personal Information
Inferences

 

* Note about “Sales”: We do not “sell” personal information as most people would typically understand that term. However, we do allow certain third-party partners and providers to collect information about consumers directly through our services for purposes of analyzing and optimizing our services, delivering ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. To the extent this practice is interpreted to constitute a “sale” under the CCPA, please see our Cookie Notice for more information including how to exercise your rights to opt-out of cookies, analytics and personalized advertising.

 

Recipients of Personal Information

As described in the Our Disclosure of Personal Information section of the Privacy Notice, we share personal information within Lindamood-Bell Learning Processes and with a variety of third parties for business purposes, or we may sell your personal information to third parties, subject to your right to opt out of those sales.

In addition to the categories of third parties identified in the Our Disclosure of Personal Information section of the Privacy Notice, we disclose personal information to the following categories of third parties:

  • Service Providers
  • Payment processors
  • Our business partners
  • Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

 

Your California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):

The Right to Know You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity: 

  • The specific pieces of personal information we have collected about you; 
  • The categories of personal information we have collected about you; 
  • The categories of sources of the personal information we have collected about you; 
  • The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; 
  • The categories of personal information we have sold about you (if any), and the categories of third parties to whom this information was sold; and 
  • The business or commercial purposes for collecting or, if applicable, selling personal information about you.
The Right to Request Deletion You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
The Right to Opt Out
of Personal Information Sales
You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. 

If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales. 

The Right to Non-Discrimination You have the right not to receive discriminatory treatment for exercising any of the rights described above. 

However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.

 

How to Exercise Your California Privacy Rights 

 

To Exercise Your Right to Know or Right to Deletion

To exercise your right to know and/or right to deletion, please submit a request by: 

  • Emailing privacy@lindamoodbell.com with the subject line “California Rights Request,” 
  • Calling 800-233-1819.

We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems.  Although we try to limit the personal information collected in connection with a request to exercise the right to know and/or the right to deletion, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity. 

 

To Exercise Your Right to Opt Out of Personal Information Sales

As noted above, we do not “sell” personal information as most people think of that term. You may, however, exercise your right to opt out of any future potential sales by clicking the link below and following the instructions: 

Do Not Sell My Personal Information

You do not need to create an account with us to exercise your Right to Opt Out of Personal Information Sales. However, we may ask you to provide additional personal information so that we can properly identify you in our dataset and to track compliance with your opt out request. We will only use personal information provided in an opt out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems. 

Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by contacting us at privacy@lindamoodbell.com.

 

Third-Party Tracking and Online Advertising

As noted above, we do not “sell” personal information as most people would typically understand that term. However, we do allow certain third-party partners and providers to collect information about consumers directly through our services for purposes of analyzing and optimizing our services and ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. To the extent this practice is interpreted to constitute a “sale” under the CCPA, please see our Cookie Notice for more information including how to exercise your rights to opt-out of cookies, analytics and personalized advertising. 

 

Minors Under Age 16

We do not and will not “sell” the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. 

 

Updates to These CA Disclosures

 

We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the “Last Updated” date at the beginning of these CA Disclosures. If we make material changes to these CA Disclosures, we will notify you by email to your registered email address, by prominent posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

 

Contact Us

 

If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to privacy@lindamoodbell.com.

Alternatively, inquiries may be addressed to:

Lindamood-Bell Learning Processes
Attn: Data Privacy Team
416 Higuera Street
San Luis Obispo, CA 93401
United States of America

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