Effective Date April 5th, 2021
We refer to a Huntington Learning Center® business as a “Center”. Centers are owned and operated by independent businesses (which we call “Franchisees”). When you enroll your student at a Center, Center staff will collect certain information about your student, as described below and share it with us. This Policy applies only to information collected by Centers wholly owned by us and to information Franchisees share with us. It does not apply to any other information our Franchisees may collect.
INFORMATION WE COLLECT
We collect information about you directly from you and from third parties, as well as automatically through your use of our Services.
Information We Collect Directly from You
When you inquire about our Services we may collect your name, phone number, address, ZIP Code, and email.
As part of the intake process we will collect additional information from the student’s parents (or guardians) about the student, including name, age, gender, birth date, health history, educational history, presence of any learning difficulties, names of parents and siblings, parents’ contact information, and emergency contact information. In addition, we also collect information about the student’s parents (or guardians), including marital status, contact information, and occupation.
Information regarding any student who is a minor must only be provided by the student’s parent or legal guardian.
If you pay fees or tuition at a Center, its staff may collect credit card information.
When you apply to own a franchise we also collect birth date, marital status, citizenship, education background, employment and compensation history, military experience, financial information including assets and liabilities, and bankruptcy history.
Information We Collect Automatically
We may collect the following information automatically about you and your use of our Sites through cookies, web beacons, and other current and future technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Sites; and the referring URL, or the webpage that led you to our Sites, and the following: access time, browser type, device ID, domain name, IP address, page views and referring URL. We may combine this information with other information that we have collected or will collect, about you, including, where applicable, your name, email address, and other personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
Third Parties or Publicly Available Sources
We may receive information about you from third parties and public sources such as:
- Order & Payment. When you make a purchase online, you will be re-directed to our commerce platform vendor. We do not receive your full credit card, debit card or other financial information when you make a payment; such information is provided directly to the vendor. However, we do receive information about your purchase and your contact information (e.g. name, credit card type, last four digits of your credit or debit card number, email address, mailing address, phone number). We keep a record of your purchases. We may collect tax identification numbers you submit for tax-exempt purposes.
- Social Media. We are active on social media, including but not limited to Facebook, Instagram, YouTube, Twitter, and LinkedIn (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on our websites and Social Media pages any comments or content that you post on our Social Media pages. Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.
HOW WE USE YOUR INFORMATION
We may use your information to:
- Communicate with you about our educational services to respond to your inquiries and for other current and future customer service purposes.
- To evaluate students as part of the enrollment process to determine the services we believe appropriate and throughout their enrollment to measure performance.
- To evaluate your application to own a Huntington Learning Center® franchise.
- Contact you via email, SMS text message, telephone, or standard mail to inform you about educational, tutoring, or test prep services or about events and promotions (including by sending you e-newsletters, marketing communications, and announcements from us and our education partners).
- Tailor the content and information we may send or display to you using location customization and personalization across our Sites and Services.
- Better understand how users access and use our Sites and Services, both on an aggregated and individualized basis, in order to modify or improve our Sites and Services and respond to user desires and preferences, and for other research and analytical purposes.
HOW WE SHARE YOUR INFORMATION
We may share your information, including your personal information, as follows:
- Franchisees and affiliates. We may disclose the information we collect from you to our Franchisees and affiliates; and, if we do so, their use and disclosure of your information will be subject to this Policy.
- Service providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.
- Business transfers. If we are acquired by or merged with, another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we collected from you to another company or individual.
- In response to legal process. We may disclose the information we collect from you to comply with the law, judicial proceedings, court orders, or other legal processes, such as in response to court orders or subpoenas.
- Aggregate and de-identified information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research, or similar purposes.
Cookies. Cookies are alphanumeric identifiers that we transfer to your device through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Sites, while others allow us to track your activities at our Sites. There are two types of cookies: session and persistent cookies.
- Session cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Sites. This allows us to process your online transactions and requests and verify your identity after you have logged in, as you move through our Sites.
- Persistent cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity and to display advertising both on our Sites and on third-party sites.
Disabling cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Sites who disable cookies will be able to browse certain areas of the Sites, but some features may not function.
Do Not Track. Our systems do not recognize and we do not respond to “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third-Party Links section.
We may also implement additional add-on services to Google Analytics, such as:
- Demographics and Interest Reporting, which gathers information such as the age and gender of users, along with certain interests those users express through their purchasing activities and other online activities, by tracking users across websites and across time.
- Remarketing with Google Analytics, which uses user behaviors on our Site and within our App to help us identify users for our remarketing campaigns.
- Google Display Network Impression Reporting, which provides us information about how often our ads are shown.
Interest-based Advertising. We use third parties and/or service providers for interest-based or targeted advertising services. These services may serve advertisements on our behalf that are customized based on predictions about your interests generated from your visits to websites (including our websites) over time and across different websites. The data collected may be associated with your personal information. These advertisements may appear on our websites and onother websites, and may be sent to you via email.
To change your preferences with respect to certain online ads or to obtain more information about ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads. Opting-out of targeted advertising does not opt you out of all ads, just those targeted to you.
SECURITY OF PERSONAL INFORMATION
We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite these efforts, no data security measures can guarantee 100% security.
CHILDREN UNDER 13
Our Sites are not directed at children under 13. We do not knowingly collect, use, or share personal information from children under 13 without appropriate parental consent. If a parent or legal guardian learns that their child provided us with personal information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such personal information.
INDIVIDUALS OUTSIDE THE UNITED STATES
This section provides additional terms that apply to residents of California. In the event of a conflict between this section and the remainder of this Policy, this section shall take precedence for California residents. In this section only, any capitalized terms not defined in this Policy have the meanings set forth in the California Consumer Privacy Act of 2018 (the CCPA).
Collection, Source, Purpose, and Sharing of your Personal Information
We collect the following categories of Personal Information described in more detail above in the section Information We Collect:
- Identifiers and Contact Information
- Financial and Transactional Information
- Customer Records and Commercial Information
- Electronic and Internet Activity
- Professional or Employment Information
- Education Information
- Geolocation Data
- Protected Classification Information
We collect Personal Information from the following categories of sources:
- Directly from you
Our purposes for collecting your Personal Information are described above in the section How We Use Your Personal Information .
Categories of Personal Information Disclosed for a Business Purpose
In the last 12 months we disclosed the following categories of Personal Information for our Business Purposes:
- Identifiers and Contact Information
- Electronic and Internet Activity
- Geolocation Data
We share your personal information with the categories of third parties and/or service providers described above in the section How We Share Your Personal Information.
We Do Not Sell Personal Information
In the last 12 months we have not Sold your Personal Information and we currently do not Sell Personal Information.
Subject to certain limitations, if you are a California resident you have the following rights with regard to your Personal Information.
Right to Request Disclosure of Categories. You have a right to request access to the following information: (a) the categories of Personal Information we collected about you in the 12-month period prior to your request, (b) the categories of sources from which the Personal Information was collected, (c) the business or commercial purpose for which we collected your Personal Information, (d) the categories of Personal Information we disclosed in the 12-month period prior to your request, and (e) the categories of third parties with whom we shared your Personal Information. You also have a right to request disclosure of the categories of Personal Information that we have sold or disclosed for a business purposes in the 12-month period prior to your request, if any, and the categories of third parties to whom we have sold or disclosed it.
Right to Request Access. In addition, you have a right to request that we disclose to you the specific pieces of Personal Information that we have collected about you in the 12-month period prior to your request.
Right to Request Deletion. You have a right to request that we delete Personal Information we collected about you.
Right to Opt-Out of the Sale. You have the right to request that we do not sell your Personal Information as defined by California law.
Non-discrimination. You have a right to exercise the above requests and we will not discriminate against you for exercising these rights.
How to Exercise Your Rights. To exercise your rights described in this Policy, you may submit your request to us by contacting us at any of the following:
Who May Exercise Your Rights. You may make a request to exercise the above rights on behalf of yourself or on behalf of a child, if you are a parent or legal guardian of the child. In addition, you may authorize an agent to exercise your rights on your behalf, if you provide the agent with written permission and if the agent is a business entity, provided the agent is registered with the California Secretary of State. If an authorized agent contacts us to exercise the above rights, we will need to verify their identity as well as your identity. We will also require proof of your written authorization to the agent to be your agent and to make the specific request submitted, unless the agent is subject to a Power of Attorney under California probate laws. If the agent is a Power of Attorney under California probate laws, we may require evidence of that status.
Verification of Your Request. Once we receive your request, we will contact you to confirm receipt of your request. In addition, we may contact you to provide us with additional information to allow us to verify your identity based on the Personal Information we have in our systems. In order to verify your request, you must provide sufficient information that allows us to reasonably verify you are the person that is the subject of the Personal Information you have requested. This information may vary depending on the Personal Information we already have. Certain types of requests may require additional verification to ensure you are who you say you are. If you have used an agent to make your request, we will also need to verify the identity of the agent. Verification of your request may require you, or your agent if applicable, to sign a declaration verifying identity under penalty of perjury. We may deny your request as permitted by law, if we are unable to verify your identity, or if an agent makes the request on your behalf, if we are unable to verify their identity or proof of their authorization.
When We Will Respond. We will respond to a request to opt-out of the sales of data within 15 business days. For all other requests, we will confirm receipt of your request within 10 business days and we will try to respond to your request within 45 calendar days. If we require additional time to respond, we will inform you of the reason and may take an additional 45 calendar days to respond. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. We may charge a fee to process or respond to your request, if it is excessive, repetitive, or manifestly unfounded.
Shine the Light
California residents may request and obtain from us once a year, free of charge, information about the Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at the address provided below.
CHANGES TO THIS POLICY
This Policy is current as of the Effective Date set forth above. We may change this Policy at any time and from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Sites. If we make any changes to this Policy that materially affect our practices about the personal information we previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Sites.
Huntington Mark LLC
496 Kinderkamack Road
Oradell, NJ 07649