SCHOOL FAMILY MEDIA, LLC

CALIFORNIA CONSUMER PRIVACY ACT NOTICE

Effective Date: January 1, 2020

Last Updated on: June 5, 2024

Last Reviewed on: June 5, 2024

• INTRODUCTION
• INFORMATION WE COLLECT
• USE OF PERSONAL INFORMATION
• SHARING PERSONAL INFORMATION
• SALE OF PERSONAL INFORMATION
• PRIVACY FOR CONSUMERS UNDER THE AGES OF 13 AND 16
• YOUR RIGHTS AND CHOICES
• CALIFORNIA “SHINE THE LIGHT” PRIVACY RIGHTS
• CONTACT US; SUBMIT A REQUEST

INTRODUCTION:

This CALIFORNIA CONSUMER PRIVACY ACT NOTICE (“CCPA Notice”) supplements and expands the information contained in School Family Media’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this CCPA Notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this CCP Notice. For the avoidance of doubt, our Privacy Policy is incorporated by reference, and any terms used that are not defined in this CCPA Notice or in the CCPA, shall have the meaning assigned to them in our Privacy Policy. For the purposes of this CCPA, the term “personal information” shall have the meaning ascribed to it under the CCPA.

This CCPA Notice is being provided to you to inform you of, among other things, how we, collect, use, and share your personal information, that we may collect from your or that you may provide to us through (i) our Websites or (ii) though the Services, and the rights you have with respect to your personal information.

PLEASE REVIEW THIS CCPA NOTICE CAREFULLY to understand our policies and practices regarding your personal information and how we will treat it. If you DO NOT AGREE with our policies and practices as stated herein, you may choose not to use this Website.

If you do not provide us with your personal information as we reasonably require, may be unable to provide you with information, goods, or services that you have requested from us. By accessing and/or using our Websites or Services, you are agreeing to the terms of this CCPA Notice.

This CCPA Notice is effective on the Effective Date and has either been reviewed, updated, or reviewed and updated, as of the date or dates set forth at the top of this CCPA Notice. By accessing our Websites and Services, you agree to the terms of this CCPA Notice. We reserve the right to update, revise, and/or modify this CCPA Notice at any time and at our sole discretion. Your continued use of our Websites, Services, products, and services, constitutes your acceptance of this CCPA Notice.

YOU CAN WITHDRAW YOUR CONSENT AT ANY TIME.

INFORMATION WE COLLECT:

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”).

Personal information DOES NOT include:

Publicly available information that is lawfully made available from federal, state or local government records, or that a consumer has otherwise made available to the public;
Deidentified or aggregated consumer information;

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, clinical trial data, or other qualifying research data; and
Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act or California Financial Information Privacy Act, and the Driver's Privacy Protection Act of 1994.

The chart below sets forth the categories of personal information we have collected from consumers within the last twelve (12) months (some categories overlap), which is based on those sources listed in the Sources Of Which We Collect Information section of our Privacy Policy. We Process Personal Data for those purposes set forth in the Use of Information Collected section of our Privacy Policy.

CATEGORY	EXAMPLES	COLLECTED
IDENTIFIERS	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
PERSONAL INFORMATION CATEGORIES LISTED IN THE CALIFORNIA CUSTOMER RECORDS STATUTE (CAL. CIV. CODE § 1798.80(E))	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Note, some personal information included in this category may overlap with other categories.	YES
PROTECTED CLASSIFICATION CHARACTERISTICS UNDER CALIFORNIA OR FEDERAL LAW	Age (40 years or older), 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, genetic information (including familial genetic information).	NO
COMMERCIAL INFORMATION	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
BIOMETRIC INFORMATION		NO
INTERNET OR OTHER SIMILAR NETWORK ACTIVITY		YES
GEOLOCATION DATA	Physical location or movements.	YES
SENSORY DATA	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
PROFESSIONAL OR EMPLOYMENT-RELATED INFORMATION	Current or past job history or performance evaluations.	NO
NON-PUBLIC EDUCATION INFORMATION (PER THE FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT (“FERPA”; 20 U.S.C. SECTION 1232G, 34 C.F.R. PART 99))	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.	NO
INFERENCES DRAWN FROM OTHER PERSONAL INFORMATION	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

As more fully described Sources Of Which We Collect Information section of our Privacy Policy, we obtain the categories of personal information listed in the above chart from the following categories of sources:

Information You Provide to Us such as: order products and/or services from us; (ii) create an account on our Website [or mobile services]; (iii) participate in a contest, sweepstake, or survey; (iv) request customer service or by contacting us; or (v) interact with our official social media pages (e.g., commenting, following, reposting, etc.).
Information We Receive From Third-Parties such as: information about you from subsidiaries and/or affiliates of School Family Media; (ii) information you provide on behalf of a third-party, or from a third-party on your behalf, including, but not limited to, gift recipients, online registration or purchases, or participation in a contest or sweepstake with our business partners; or (iii) from other sources, including, but not limited to public databases; social medial platforms; marketing partners; and from third-party service providers that provide us feedback about our Website and analytics and general information about browsing patterns to improve our Website.
Information We Collect Through Automatic Data Collection Technologies such as: details of your visits to our Website, including location data, logs, traffic data, and other communication data and the resources that you access and use on the Website; (ii) information about your computer and internet connection, including your IP addresses, device characteristics (such as connection type, operating system, browser type, screen resolution); or (iii) if you are accessing the Website using a mobile device, information about your mobile device, including device model, operating system, and network information. For more information on Data Technologies we may use, please see Information We Collect Through Automatic Data Collection Technologies Privacy Policy. For more detailed information about the cookies we use and the purposes for which we use them, please see our Cookie Policy.

USE OF PERSONAL INFORMATION:

As described in Use of Information section of our Privacy Policy, we may use, sell or disclose the personal information we collect for a “business purpose” or “commercial purpose” (as defined under the CCPA), which may include one or more of the following examples:

To present our Websites and its contents and/or Services to you.

To provide, enhance, personalize and customize your user experience.

To provide you with information, products, or services that you request from us.

To fulfill orders, validate payments, and allow for repeat ordering.

To process credit card payments, returns, and other like transactions.

To register and service your account to which you have registered.

To allow us to better service you and respond to your customer service requests.

To advertise our products and services to you and those of our partners that may be of interest to you.

To provide and conduct marketing and promotions.

To conduct research and analysis.

To administer contests, promotions, events, surveys or other features.

To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

To notify you about changes to our Websites or any products or services we offer or provide though it.

To allow you to participate in interactive features on our Websites.

In any other way we may describe when you provide your information to us.

For any other purpose, with your consent.

To comply with legal obligations to which we are subject.

To protect the security and integrity of our Services and overall business practices.

As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes sated herein or in Use of Information section of our Privacy Policy without providing you notice.

SHARING PERSONAL INFORMATION:

We may share your personal information by disclosing it to a third-party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, School Family Media has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

CATEGORY	CATEGORY OF RECIPIENT	BUSINESS PURPOSE DISCLOSURES
IDENTIFIERS	Service providers (such as advertising networks, analytics providers, IT systems, for example for managing customer relations, etc.).	For the purpose of providing, enhancing, personalizing, troubleshooting and customizing user experience as well as completing a transaction or service requested by you.
PERSONAL INFORMATION CATEGORIES LISTED IN THE CALIFORNIA CUSTOMER RECORDS STATUTE (CAL. CIV. CODE § 1798.80(E))	Service providers, such as providers of IT systems, for example for managing customer relations or payments; or providers of software and services for digital marketing automation and analytics, or Service providers such as ones who are assisting to provide a product or service to you.	For the purpose completing a transaction or service requested by you, for example if we use a third-party payment processor.
PROTECTED CLASSIFICATION CHARACTERISTICS UNDER CALIFORNIA OR FEDERAL LAW.	Not Applicable	Not Applicable
COMMERCIAL INFORMATION	Service providers such as ones who are assisting to provide a product or service to you.	For the purpose completing a transaction or service requested by you, for example if we use a third-party payment processor.
BIOMETRIC INFORMATION.	Not Applicable	Not Applicable
INTERNET OR OTHER SIMILAR NETWORK ACTIVITY.	Service providers (such as advertising networks, analytics providers, etc.).	For the purpose of providing, enhancing, personalizing, troubleshooting and customizing user experience.
GEOLOCATION DATA.	Service providers that receive data to provide services to a School Family Media entity (e.g., analytics providers, advertising networks, cloud storage providers, etc.).	For the purpose of providing, enhancing, personalizing, troubleshooting and customizing user experience and completing transactions requested by you.
SENSORY DATA.	Not Applicable	Not Applicable
PROFESSIONAL OR EMPLOYMENT-RELATED INFORMATION.	Not Applicable	Not Applicable
NON-PUBLIC EDUCATION INFORMATION (FERPA; 20 U.S.C. SECTION 1232G, 34 C.F.R. PART 99)).	Not Applicable	Not Applicable
INFERENCES DRAWN FROM OTHER PERSONAL INFORMATION	Not Applicable	Not Applicable

SALE OF PERSONAL INFORMATION:

We may also share your personal information by selling it to third parties, for targeted advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you and subject to your right to OPT-OUT of those sales. You can WITHDRAW YOUR CONSENT or OPT OUT at any time of the sale or sharing of your Personal Data. To WITHDRAW YOUR CONSENT or OPT OUT of the sale or sharing of your Personal Data, see Your Rights and Choices, below. In the preceding twelve (12) months, School Family Media has sold the following categories of personal information to the categories of third parties indicated in the chart below.

CATEGORY	SALES	BUSINESS PURPOSE DISCLOSURES
IDENTIFIERS	Third party advertisers and clients.	For the purpose completing a transaction or service requested by you or presenting advertising offers to you.
PERSONAL INFORMATION CATEGORIES LISTED IN THE CALIFORNIA CUSTOMER RECORDS STATUTE (CAL. CIV. CODE § 1798.80(E))	Third party advertisers and clients.	For the purpose completing a transaction or service requested by you.
PROTECTED CLASSIFICATION CHARACTERISTICS UNDER CALIFORNIA OR FEDERAL LAW.	Not Applicable	Not Applicable
COMMERCIAL INFORMATION	Third party advertisers and clients.	For the purpose completing a transaction or service requested by you.
BIOMETRIC INFORMATION.	Not Applicable	Not Applicable
INTERNET OR OTHER SIMILAR NETWORK ACTIVITY.	Third party advertisers and clients.	For the purpose completing a transaction or service requested by you or presenting advertising offers to you.
GEOLOCATION DATA.	Third party advertisers and clients.	For the purpose completing a transaction or service requested by you or presenting advertising offers to you.
SENSORY DATA.	Not Applicable	Not Applicable
PROFESSIONAL OR EMPLOYMENT-RELATED INFORMATION.	Not Applicable	Not Applicable
NON-PUBLIC EDUCATION INFORMATION (FERPA; 20 U.S.C. SECTION 1232G, 34 C.F.R. PART 99)).	Not Applicable	Not Applicable
INFERENCES DRAWN FROM OTHER PERSONAL INFORMATION	Not Applicable	Not Applicable

PRIVACY FOR CONSUMERS UNDER THE AGES OF 13 AND 16:
As stated in our Privacy Policy, our Websites are designed for a “general audience” and is not intended for use by children under 13 years of age. We do not knowingly collect personal information from children under 13 years of age, unless such information has been obtained in accordance with COPPA. For more information on this matter please refer to Privacy for Children under the Age of 13 section of our Privacy Policy.

Under the CCPA, when the consumer is between the age of 13 and 16 years old, we must obtain affirmative authorization from either (i) the consumer who is between the age of 13 and 16 years old or (ii) or in accordance with COPPA if the consumer is under the age of 13 years old, before selling that consumer’s personal information or processing it for targeted advertising. Consumers between the age of 13 and 16 years old (or their authorized representatives) who have OPTED-IN to the sale or processing of their personal information may OPT-OUT at any time by any method stated in Personal Information Sales Opt-Out and Opt-In Rights below.

YOUR RIGHTS AND CHOICES:

In addition to those rights set forth in the Choices About How We Use And/Or Disclose Your Information section of our Privacy Policy, the CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know

You have the right request that we provide you with access to the information to you about our collection and use of your personal information over the past twelve (12) months (the “right to know”). Once We receive your request and confirm your identity, as set forth in Exercising Your Rights to Know or Delete, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom We share that personal information.

If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

The specific pieces of personal information We collected about you (also called a data portability request).

Right to Delete

You have the right to request that we delete any of your personal information that we have collected directly from you or from a third-party, subject to certain exceptions. Once we receive and verify your identity, as set forth in Exercising Your Rights to Know or Delete, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request or not delete some of your personal information, if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete Your Personal Information

To exercise your rights to know or delete your personal information as described above, please submit a request by either:

By Email:

Email privacy@schoolfamilymedia.com and provide the following information:

Full name;
Email address associated with your use of our Websites or Service; and
Your specific CCPA request (e.g., right to access, right to portability, or right to delete).

By Form:

Submit your request via our web form and provide the following information:

Full name;
Email address associated with your use of our Websites or Service; and
Your specific CCPA request (e.g., right to access, right to portability, or right to delete).

You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to know or delete related to your personal information.

You may also make a request to know or delete on behalf of your child by any of the methods set forth in this Exercising Your Rights to Know or Delete.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in the request to verify the requestor’s identity or authority to make it. YOU CAN WITHDRAW YOUR CONSENT OR OPT OUT AT ANY TIME OF THE SALE OR SHARING OF YOUR PERSONAL INFORMATION. To WITHDRAW YOUR CONSENT or OPT OUT of the sale or sharing of your personal information, please submit your request to us at any method set forth in this Exercising Your Rights to Know or Delete.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact privacy@schoolfamilymedia.com. We will attempt to respond to a verifiable consumer request within forty-five (45) days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the twelve (12) month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For Data Portability Requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

All consumers or their authorized representatives have the right to direct us to not sell their personal information at any time. As mentioned in Privacy For Consumers Under the Age Of 13 And 16, and in Privacy for Children under the Age of 13 section of our Privacy Policy, we do not (i) knowingly collect personal information from children under 13 years of age, unless such information has been obtained in accordance with COPPA or (ii) sell or process personal information of a child who is between the age of 13 and 16 years old unless we have obtained affirmative authorization from the consumer (or their authorized representative) or in accordance with COPPA.

Each consumer or their authorized representatives who OPT-IN to personal information sales may OPT-OUT of future sales at any time. To exercise your right to OPT-OUT, you (or your authorized representative) may submit a request to us by visiting the below link or by any method set forth in Contact Us; Submit A Request, below.

You do not need to create an account with us to exercise your OPT-OUT rights. We will only use personal information provided in an OPT-OUT request to review and comply with the request.

Once you make an OPT-OUT request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and OPT-IN to the sale of your personal information at any time by:

Non-Discrimination

We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:

Deny you goods or services;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you a different level or quality of goods or services; or
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program is entirely optional, you will have to affirmatively OPT-IN to the program and you can OPT-OUT of each program by following the instructions set forth in the instructions in the applicable program description and terms or by any method stated in Personal Information Sales Opt-Out and Opt-In Rights above.

We currently provide certain financial incentives which you can voluntarily OPT-INTO whenever these programs are available on our Websites or Services. These financial incentives are prizes (e.g., a gift card or supplies such as a box of tissue) in exchange for certain content or activities of the consumer, including the consumer updating his/her information on his/her school supply list on our Websites or Services, the consumer sharing posts on social media, or the consumer participating in one of our surveys.

Each financial incentive related to the submission and use of your personal information is based upon our reasonable but sole determination of the estimated value of such information, which takes into consideration, without limitation, estimates regarding the anticipated revenue generated from such information, the anticipated expenses which might be incurred in the collection, storage, and use of such information in the operation of the School Family Media’s business, and other relevant factors related to the estimated value of such information to the School Family Media’s business, as permitted under the CCPA.

CALIFORNIA “SHINE THE LIGHT” PRIVACY RIGHTS:
California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make a request, please submit your request to us at any method set forth in Contact Us; Submit A Request, below.

CONTACT US; SUBMIT A REQUEST:

If you have any questions, comments, or concerns about this CCPA Notice, the ways in which School Family Media collects and uses the information described herein or about our Privacy Policy, your choices and rights regarding such use, or if you wish to exercise your rights under the CCPA, please do not hesitate to contact us at one of the following methods:

Phone:		(800) 556-9216
Website:		https://schoolfamilymedia.com/
Email Address:		privacy@schoolfamilymedia.com
Mail:		School Family Media, LLC 100 Stonewall Blvd., Suite 3 Wrentham, MA 02093 Attention: Legal Department

If you need to access this Policy in an alternative format due to having a disability, please contact privacy@schoolfamilymedia.com or call us at (800) 556-9216.

SCHOOL FAMILY MEDIA, LLC | CALIFORNIA CONSUMER PRIVACY ACT NOTICE