SCHOOL FAMILY MEDIA, LLC
Privacy Policy for California Residents

Effective Date: January 1, 2020

Last Updated on: August 28, 2023

Last Reviewed on: August 28, 2023

This “PRIVACY POLICY FOR CALIFORNIA RESIDENTS (this “ Policy ”) supplements and expands the information contained in School Family Media LLC’s (“ Company ” or “We ”) Privacy Policy - School Family Media (the “Privacy Policy”) and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this 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 Policy. For the avoidance of doubt, the Privacy Policy is incorporated by reference to this Policy.

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:

• Commercial conduct that takes place wholly outside the state of California;

• Publicly available information from federal, state or local government records; and

• Deidentified or aggregated consumer information.

The following is a list of categories of personal information which We may collect or may have been collected from consumers within the last twelve (12) months:

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. 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.	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
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 (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

Please note, the above listed categories and examples are those categories and examples defined in the CCPA. A responsive selection to a category of personal information does not mean that the Company has collected all the examples within that category of personal information, but reflects the Company’s good faith belief, and to the best of the Company’s knowledge, that some of the information from an applicable category of personal information may be or may have been collected within the last twelve (12) months.

We obtain the categories of personal information listed above from the following categories of sources:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our Service, posting material, or requesting further services from our third-party business partners. We may also ask you for information when you enter a contest or promotion sponsored or administered by us, and when you report a problem with our Website.

• Records and copies of your correspondence (including email addresses), if you contact us.

• Your responses to surveys that We might ask you to complete for research purposes.

• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

• Your search queries on the Website.

• You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although We limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, We cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, We cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

• We may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns. For further information on automatic data collection technologies We may use, please see the Privacy Policy.

Use of Personal Information. We may use or disclose the personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include one or more of the following examples:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, We will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, We will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

• To provide, support, personalize, and develop our Website, products, and services.

• To create, maintain, customize, and secure your account with us.

• To process your requests, purchases, transactions, and payments and prevent transactional fraud.

• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).

• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• 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 without providing you notice.

Sharing Personal Information. We may share your personal information by disclosing it to a third party for a business purpose or commercial purpose. We only make these business purpose or commercial 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, We have disclosed the following categories of personal information for a business purpose:

• Identifiers;

• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));

• Commercial information;

• Internet or other similar network activity; and

• Geolocation data.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may share personal information for a business purpose or commercial purpose, that We collect, or you provide to the Company, with the following third parties:

• Subsidiaries and affiliates of the Company;

• Contractors, service providers, and other third parties We use to support our business, including website hosting providers, email platform providers, and credit card payment processors;/p>

• A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company regarding customers is among the assets transferred;/p>

• Third parties to market their products or services to you; or/p>

• Other third parties with your consent./p>

In addition to the above, We may also disclose your personal information:

• 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.

• If We believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Sales of Personal Information. We may also share your personal information by selling it to third parties, subject to your right to opt-out of those sales. Our personal information sales do not include information about individuals We know are under age 16. In the preceding twelve (12) months, Company has sold the following categories of personal information for a business purpose:

• Identifiers;

• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));

• Commercial information;

• Internet or other similar network activity; and

• Geolocation data.

We may sell your personal information to the following categories of third parties:

• Fundraising companies.

• Consumer brand companies.

• Education-related software companies.

Your Rights and Choices. The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

1. Right to Know and Data Portability Right. 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, 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).

2. Right to Delete. You have the right to request that We delete any of your personal information that We collected from you and retained, subject to certain exceptions. Once We receive and confirm your verifiable consumer request, We will delete (and direct our service providers to delete) your personal information from our records, unless an exception 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 may also limit our deletion to the extent permitted by applicable law.

3. 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.

4. Exercising Your California Rights. To exercise your rights as a California resident, please submit a verifiable consumer request:

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

• Full name;

• Email address associated with your use of our Website 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 Website 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 only make a verifiable consumer request for access or data portability twice within a 12-month period.

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.

Response Timing and Format. 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 a 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.

You have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers We actually know are less than sixteen (16) years old. If you are under sixteen (16) years of age, you are not permitted to use the Website or Services. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following webpage: Personal Information Sales Opt-Out

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 back in to personal information sales at any time by emailing us at privacy@schoolfamilymedia.com.

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.

Notice of Financial Incentives

In addition, We may offer you certain financial incentives for the collection, sale, retention, and use of your personal information as permitted by the CCPA that can, without limitation, result in different prices, rates, or quality levels. We currently provide certain financial incentives which you can voluntarily opt into whenever these programs are available on our Website 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 Website or Services, the consumer sharing posts on social media, or the consumer participating in one of our surveys.

Any CCPA-permitted financial incentive We offer will reasonably relate to your personal information's value to the Company 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 emailing us at privacy@schoolfamilymedia.com.

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 Company’s business, and other relevant factors related to the estimated value of such information to the Company’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 such a request, please send an email to privacy@schoolfamilymedia.com or write us at: 100 Stonewall Boulevard, Suite 3, Wrentham, MA 02093.

Changes to Our Privacy Policy. We reserve the right to amend this privacy policy at our discretion and at any time. When We make changes to this privacy policy, We will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information. If you have any questions or comments about this notice, the ways in which the Company collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

• Phone: (800) 556-9216

• Website: https://schoolfamilymedia.com/

• Email Address: privacy@schoolfamilymedia.com

• Postal Address:

School Family Media, LLC

Attn: Legal Department

100 Stonewall Blvd., Suite 3

Wrentham, MA 02093

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.