SCHOOL FAMILY MEDIA, LLC | COLORADO CONSUMER PRIVACY NOTICE
SCHOOL FAMILY MEDIA, LLC
COLORADO CONSUMER PRIVACY NOTICE
Last Updated: June 5, 2024
• INTRODUCTION
• INFORMATION WE COLLECT AND PROCESS
• DISCLOSURE OF PERSONAL DATA FOR OUR BUSINESS OR COMMERCIAL PURPOSES
• SALES OF PERSONAL INFORMATION
• PRIVACY FOR CONSUMERS UNDER THE AGE OF 13
• YOUR RIGHTS AND CHOICES
• VERIFICATION OF IDENTITY AND PROCESSING OF REQUESTS
• CONTACT US; SUBMIT A REQUEST
INTRODUCTION:
This COLORADO CONSUMER PRIVACY NOTICE (“CCP Notice”) supplements and expands upon the information contained in School Family Media’s Privacy Policy and applies solely to consumers in the State of Colorado who interact with us in an individual or household context (“consumers” or “you”). We adopt this CCP Notice to comply with the Colorado Privacy Act (“CPA”) and any terms defined in the CPA 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 CCP Notice or in the CPA, shall have the meaning assigned to them in our Privacy Policy.
This CCP Notice is being provided to you to inform you of, among other things, how we, in our capacity as a “Controller”, collect, use, and share your Personal Data, that we may collect from your or that you may provide to us through (i) our Websites or (ii) our Services, and the rights you have with respect to your Personal Data.
PLEASE REVIEW THIS CCP NOTICE CAREFULLY to understand our policies and practices regarding your Personal Data 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 our Websites or access our Services.
If you do not provide us with your Personal Data as we reasonably require, may be unable to provide you with the 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 CCP Notice.
This CCP Notice is effective as of the Last Updated date set forth at the top of this CCP Notice. We reserve the right to update, revise, and/or modify this CCP Notice at any time at our sole discretion. Your continued use of our Websites, Services, products, and services, constitutes your acceptance of our CCP Notice.
YOU CAN WITHDRAW YOUR CONSENT AT ANY TIME.
INFORMATION WE COLLECT AND PROCESS
The CPA defines Personal Data as “information that is linked or reasonably linkable to an identified or identifiable individual.” Sensitive Data is a subset of Personal Data, which is denoted with an Asterix (“*”), below. Personal Data does not include de-identified data or publicly available data. The chart below sets forth the categories of Personal Data we have collected from consumers within the last twelve (12) months, 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 |
| CUSTOMER RECORDS PERSONAL INFORMATION CATEGORIES | Name, signature, address, telephone number, education, employment | YES |
| PROTECTED CLASSIFICATION CHARACTERISTICS UNDER COLORADO 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 |
| GENETIC OR BIOMETRIC INFORMATION* | 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. | NO |
| INTERNET OR OTHER SIMILAR NETWORK ACTIVITY | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | YES |
| PRECISE GEOLOCATION DATA* | Information derived from technology, including but not limited to global positioning system level latitude and longitude coordinates or other mechanisms, that directly identifies the specific location of a natural person with precision and accuracy. | YES |
| SENSORY DATA | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| PROFESSIONAL OR EMPLOYMENT-RELATED INFORMATION | Current or past job history, job title, occupation, practice type/specialty, year of school graduation, professional provider number, performance evaluations. | NO |
| NON-PUBLIC EDUCATION INFORMATION (PER THE FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT (“FERPA”; 20 U.S.C. § 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 |
DISCLOSURE OF PERSONAL DATA FOR OUR BUSINESS OR COMMERCIAL PURPOSES:
We may share your Personal Data by disclosing it to a third-party for business or commercial purposes. We only make these business or commercial purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Data confidential, and prohibit the recipient from using the disclosed information for any purpose except performing under the contract. For more information on the circumstance in which we may disclose your Personal Information, including Personal Data, please refer to the Disclosure of Information section of our Privacy Policy. In the preceding twelve (12) months, we have disclosed the following categories of Personal Data for business or commercial purposes to the following categories of third parties:
| CATEGORIES OF THIRD-PARTIES TO WHOM PERSONAL DATA WAS DISCLOSED | CATEGORIES OF PERSONAL DATA DISCLOSED | PURPOSE FOR DISCLOSING PERSONAL DATA |
| SUBSIDIARIES AND AFFILIATES | Identifiers, Customer Records Personal Information Categories, Commercial Information, Internet or Other Similar Network Activity, Precise Geolocation Data* | For the purpose of providing, enhancing, personalizing, troubleshooting and customizing user experience as well as completing a transaction or service requested by you. |
| CONTRACTORS, SERVICE PROVIDERS, AND OTHER THIRD-PARTIES WE USE TO SUPPORT OUR BUSINESS | Identifiers, Customer Records Personal Information Categories, Commercial Information, Internet or Other Similar Network Activity, Precise Geolocation Data* | For the purpose of (i) providing, enhancing, personalizing, troubleshooting and customizing user experience as well as completing a transaction or service requested by you; and (ii) completing a transaction or service requested by you, for example if we use a third-party payment processor. |
| THIRD-PARTY MARKETING | Identifiers, Customer Records Personal Information Categories, Internet or Other Similar Network Activity, Precise Geolocation Data* | For the purpose of (i) providing, enhancing, personalizing, troubleshooting and customizing user experience as well as completing a transaction or service requested by you; and (ii) completing a transaction or service requested by you, for example if we use a third-party payment processor. When you expressly consent to and/or OPTED-IN to (i) participate in a contest, sweepstake, or survey administered by a third-party or (ii) receiving third-party marketing of products and/or services. |
| CURRENT OR PROSPECTIVE ADVERTISERS, SPONSORS, AND OTHER BUSINESS PARTNERS | Identifiers, Customer Records Personal Information Categories, Commercial Information, Internet or Other Similar Network Activity, Precise Geolocation Data* | For marketing purposes. |
| THIRD-PARTIES INVOLVED IN BUSINESS TRANSFERS | Not Applicable | For example, in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the School Family Media’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the School Family Media about our Websites users is among the assets transferred. |
| THIRD-PARTIES AUTHORIZED BY LAW TO RECEIVE PERSONAL DATA | Not Applicable | To comply with any court order, law, or legal process, including to respond to any government or regulatory request; to enforce or apply our Terms of Use or Terms of Sale and other agreements, including for billing and collection purposes; or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the School Family Media, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. |
| THIRD-PARTIES TO WHOM YOU OR YOUR AGENTS REQUEST OR AUTHORIZE US TO DISCLOSE YOUR PERSONAL DATA IN CONNECTION WITH PRODUCTS OR SERVICES WE PROVIDE TO YOU. | Not Applicable | For the purpose of completing a transaction or service requested by you. |
SALES OF PERSONAL INFORMATION:
We may also share Personal Data by selling it to third-parties and we may process Personal Data for targeted advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. 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, we have sold or shared the following categories of ‘Personal Data” for a business or commercial purpose:
| CATEGORIES PERSONAL DATA SOLD OR SHARED | BUSINESS OR COMMERCIAL PURPOSE | CATEGORIES OF THIRD PARTIES PERSONAL DATA WAS SOLD OR SHARED |
| IDENTIFIERS | For the purpose completing a transaction or service requested by you or presenting advertising offers to you. | Third party advertisers and clients. |
| CUSTOMER RECORDS PERSONAL INFORMATION CATEGORIES | For the purpose completing a transaction or service requested by you or presenting advertising offers to you. | Third party advertisers and clients. |
| PROTECTED CLASSIFICATION CHARACTERISTICS UNDER COLORADO OR FEDERAL LAW* | Not Applicable | Not Applicable |
| COMMERCIAL INFORMATION | For the purpose completing a transaction or service requested by you. | Third party advertisers and clients. |
| GENETIC OR BIOMETRIC INFORMATION* | Not Applicable | Not Applicable |
| INTERNET OR OTHER SIMILAR NETWORK ACTIVITY | For the purpose completing a transaction or service requested by you or presenting advertising offers to you. | Third party advertisers and clients. |
| PRECISE GEOLOCATION DATA* | For the purpose completing a transaction or service requested by you or presenting advertising offers to you. | Third party advertisers and clients. |
| SENSORY DATA | Not Applicable | Not Applicable |
| PROFESSIONAL OR EMPLOYMENT-RELATED INFORMATION | Not Applicable | Not Applicable |
| NON-PUBLIC EDUCATION INFORMATION (PER FERPA (20 U.S.C. § 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 AGE OF 13:
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. Under the CPA, Personal Data of a child under 13 years of age is considered Sensitive Data, which requires a consumer’s consent to process. 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 the Privacy for Children under the Age of 13 section of our Privacy Policy.
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 CPA provides you with specific rights regarding your “Personal Data.” This section describes your rights under the CPA and explains how you can exercise those rights.
Right to Access Information/Correct Inaccurate Personal Data
You have the right to request access to Personal Data collected about you and information regarding the purposes for which we collect it and the third parties and service providers with which we share it. In addition, you have the right to correct inaccurate or incomplete Personal Data. To make a request to correct inaccurate or incomplete Personal Data, please submit your request to us at any method set forth in Contact Us; Submit A Request, below.
Right to Obtain a Copy of Personal Data
You have the right to request a copy of the Personal Data that you previously provided to us in a portable format (a “Data Portability Request”), once within a twelve (12) month period. For each Data Portability Request, we will select a format to provide your Personal Data that 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 Data Portability Request, unless it is excessive, repetitive, or manifestly unfounded. If we determine that the Data Portability Request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your Data Portability Request. In order to process your Data Portability Request, we must be able to verify your identity or authority to make the Data Portability Request and confirm the Personal Data relates to you. For more information regarding verification of your identity, please see Verification of Identity and Processing of Requests, below. To make a Data Portability Request, please submit your request to us at any method set forth in Contact Us; Submit A Request, below.
Right to Delete Personal Data
You have the right to request that we delete any Personal Data that we have collected directly from you or from a third-party, subject to certain exceptions. Once we receive and verify your identity, we will delete (and direct our service providers to delete) your Personal Data from our records in accordance with your request, unless an exception applies. We may deny your deletion request or not delete some of your Personal Data, if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Data, 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 a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We may also limit deletion to the extent permitted by applicable law. For more information regarding verification of your identity, please see Verification of Identity and Processing of Requests, below. To make a deletion request, please submit your request to any method set forth in Contact Us; Submit A Request, below.
Response to Your Request: 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 Data 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 a second or repetitive request within a twelve (12) month period. 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. To calculate a cost estimate, we will adhere to the calculation method set forth in Colorado Revised Statues Section § 24-72-205.
Right to Appeal Denial of Request Regarding Your Personal Data
If we decline your request, in connection with your rights set forth in Your Rights and Choices section of this VCDPA Notice, you have the right to appeal such decision by submitting your appeal request to at any method set forth in Contact Us; Submit A Request below. 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 resolve your appeal request within forty-five (45) days of receiving your appeal request. If we require more time, we will inform you of the reason and extension period in writing. We will inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for the decision.
If we deny your appeal request, you have the right to File a Complaint with the Colorado Attorney General. To learn more about how you can File a Complaint with the Colorado Attorney General please visit File a Complaint. Do note that the information provided at these links is third party information, and as such, we are not responsible for the completeness or accuracy of such information.
Right to Opt Out
You have the right to OPT OUT of our processing your Personal Data for the purposes of: (i) Targeted Advertising; (ii) Sale of Personal Data; or (iii) Profiling. To exercise the right to OPT OUT, you (or your authorized representative) must submit a request to us at any of the methods set forth in Contact Us; Submit A Request, below.
Non-Discrimination
We will not discriminate against you for exercising any of your rights under the CPA. Unless permitted by the CPA, we will not:
- Deny you goods or services.
- Increase the cost for goods or services.
VERIFICATION OF IDENTITY AND PROCESSING OF REQUESTS:
To protect Colorado consumers’ Personal Data and to comply with the CPA, as required or permitted under applicable law, we may take steps to verify your identity before processing any request set forth in Your Rights and Choices, above, before we act on your request. In order for your request to be processed, you must provide us with enough information to reasonably verify you are the Colorado consumer about whom we collected Personal Data or an authorized representative of that Colorado consumer. If you use an authorized representative to submit a request on your behalf, we may require that you (i) provide the authorized representative written permission to do so and (ii) provide us either a copy of that written authorization or a copy of the power of attorney for the authorized representative to act on your behalf.
In verifying requests, we employ reasonable measures to detect fraudulent requests and prevent unauthorized access to your Personal Data. To meet our obligations under the CPA, we are required to authenticate your identity and the identity of your authorized representative. You do not need to create an account with us to submit a request. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Data associated with that specific account.
We will confirm receipt of your request within ten (10) business days and provide information about how we process your request. We will attempt to respond to a verifiable 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.
CONTACT US; SUBMIT A REQUEST:
If you have any questions, comments, or concerns about this CCP Notice, the ways in which School Family Media collects and uses the information described herein or in our Privacy Policy, your choices and rights regarding such use, or if you wish to exercise your rights under the CPA, or if you need to access this CPP Notice in an alternative format due to having a disability 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 |