Time4Learning Direct Commercial Services Privacy Notice

Effective: 7-26-24

This Privacy Notice Applies to Time4Learning’s Direct Commercial Services.

This Privacy Notice (or “Notice”) applies to the personal information collected, used, and disclosed by VKidz Holdings, Inc. , a subsidiary of Cambium Intermediate Holdings, LLC ( “Time4Learning,” “we,” “us,” or “our” unless a specific business entity is referred to) when we are the business that has discretion to process personal information for our own commercial business affairs outside of the personal information processed as part of our Learning Applications Services. For example, this Notice applies when we process your personal information collected through operating our own commercial website (or “Site”) or mobile application which links to this Notice and not when supporting an educational institution customer. It also applies if we conduct a symposium or engage in other business functions outside of when we process personal information associated with our supporting educational learning platform services to our business units. This Notice does not apply to Time4Learning’s privacy practices with respect to supporting learning applications services.

This Privacy Notice also does not apply to our employees, candidates, or application for employment with us which is covered in our Human Resources Privacy Statement and/or specific notices and disclosures relating to benefits plans.

What We Mean by Personal Information.

We categorize personal information as data elements we process which either alone, or combined, identifies, or reasonably could be used to identify any natural person; or, which directly identifies a user’s electronic processing device or specific location.

Our Treatment of Sensitive Personal Information.

With respect to sensitive personal information or equivalent term, as they are defined under applicable privacy laws, we follow certain practices as follows:

• We do not sell (or share for any value) sensitive personal information to any person or entity at any time.
• We only use sensitive personal information as specifically required to support the educational purposes for which we are contracted; to send communications and reminders; and/or as specifically authorized by a parent/guardian or authorized school official in relation to those educational purposes and consistent with applicable law.
• We do not collect, maintain, use, or disclose personal information of students under 18 years of age other than as needed for authorized educational/school purposes; or, as otherwise required by applicable law.
• We do not share, transfer, provide access to or otherwise disclose sensitive personal information with any person or entity unless they are a service provider (as described later in this Notice).
• Time4Learning only uses sensitive personal information for the following uses and no others:
• To perform the services or provide the goods reasonably expected by an average person who requests those goods or services.
• To prevent, detect, and investigate security incidents that could compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal
  information.
• To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
• To protect the health or safety of natural persons.
• To perform necessary services on behalf of the business.
• To verify or maintain the quality or safety of a product, service, or device that we provide.
• To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a person.

We retain sensitive personal information only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection, including as necessary for compliance with laws, the exercise or defense of legal rights, and archiving, back-up and deletion processes.

What We Mean by “Process” Personal Information.

When we use the term “process” or “processing” we mean collection, use, storage, disclosure, transmission, or any activity related to, or which uses, that personal information.

How We Collect Personal Information and the Types of Personal Information We Collect.

We strive to only collect and process data elements which are reasonably necessary, proportionate, and not excessive for the uses for which we need to process that data.

The type of personal information we process about you depends upon how you interact with us. We generally collect information directly from you through your use of our websites and mobile apps and the related services you request. This information may be directly sent to us by you, or we may passively collect it through technologies used on websites linking to this Notice. For more information about such passive technologies and how you may exercise choice relating to their use, please see the sections of this Notice entitled, “Passive Collection Technologies and Tracking” and “How to Opt-Out of Tracking.” We may also collect information about you from third parties such advertising providers; analytics providers and advertisers and marketers.

The categories of personal information we may collect about you include:

• “Identifiers” including, your name and surname, email address, demographics, such as state or country of residence, and account credentials, such as your username and password.
• “Commercial Information” including records of products or services you purchased, obtained or considered, details of your transactions, information related to fulfillment of orders, and payment information, such as your credit card information.
• “Device Information”including Internet Protocol (IP) address, device information including unique identifiers associated to your browser or device, mobile device advertising identifiers, your device type and settings, software used, browser type and operating system, language preferences, websites or other services you visited before and after visiting one of our websites (referring URL), pages viewed, content, and advertisements you view and interact with and links you click on, what search queries you may have run on our sites, dates and times you access or use a website or an email we send you, location information, including the city, state and zip code associated with your IP Address, and precise location information from GPS-based functionality on your mobile apps (such as if you attended a conference) if you have enabled sharing that, the operating system, application version, and click path taken through our websites or mobile applications.
• “Other Personal Information”including subject to applicable law, user generated content, such as content within any messages you send to us, including feedback and questions. We may also link and/or combine the information we collect about you from the various devices you use.

Purpose of Collection and How We Use Personal Information We Collect.

In general, we use personal information we collect for the following purposes:

• to provide the functionality of the websites and related services you may request including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, or providing similar services;
• for short-term, transient use, including, but not limited to, the contextual customization of ads or website content shown as part of the same interaction;
• for analytics purposes (such as determining how many users use one of our websites, when, what portions of websites and contents are used, user demographic information, the sites referring to our websites and sites to which users may navigate);
• to market and/or advertise our goods and services, or the goods and services of others, to you;
• to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity;
• to debug, identify and repair errors that impair existing intended functionality;
• to conduct internal research and development for new services and features related to our business;
• to undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by, us and to improve, upgrade, or enhance our services; and
• to advance our commercial or economic interests, such as by referring you to other sites and services by us, our affiliated business units, or other third parties for which we may receive payment.

Legal Bases of Processing Personal Information Under Applicable Privacy Laws.

Where required by applicable law, we collect the above personal information for the above purposes based on the following legal bases:

• Necessary to perform a transaction and to operate your account;
• Necessary for legitimate interests to improve the services;
• On the basis of your consent; and
• Necessary to comply with applicable law.

How We Disclose Personal Information.

Other than as stated in this Notice, we will not rent, sell, or share your personal information. For example, if you request information from us, we will not disclose your email address to other companies, unless we otherwise later ask you, and you provide your consent, such as if we conduct a joint promotion or with another company. We do not sell your personal information as that term is traditionally understood. However, some of our disclosures of personal information may be considered a “sale” or “share” as those terms are defined under applicable privacy laws, as further detailed in this Notice.

We may disclose your personal information to non-affiliated service providers who help us support our services such as delivering products, protecting the security and integrity of our systems, correcting technical problems and malfunctions and otherwise providing information technology support services, carrying out support functions such as financial accounting and services, legal advice and services, and taking precautions to protect health and safety and preventing crimes or fraud. When we share your personal information with such service providers we will take steps to assess their privacy and information security practices with an aim to ensure that they can properly protect your personal information commensurate with its sensitivity. When we share your information with service providers, we enter into agreements with them designed to ensure that they will manage your personal information in accordance with the statements in this Notice.

We may disclose and/or transfer your personal information in connection with a sale, merger, consolidation, change in control, transfer of assets, reorganization or liquidation of our business. In such circumstances we will take reasonable steps designed to ensure that the entities to whom we disclose your personal information and/or any successor entity will treat your personal information in accordance with the statements in this Notice.

We may disclose your personal information to law enforcement and related governmental agencies if we are required to do so by law, and to private parties of we are compelled to do so in accordance with applicable legal requirements such as if we receive an enforceable subpoena from a court of competent jurisdiction. We also may disclose your personal information to third parties if we have reason to believe that disclosing such information is necessary to conduct investigations of possible breaches of law, to cooperate in any legal investigation, or to identify, contact, or bring legal action against someone who may be violating any agreement or policy with us.

Additionally, we may disclose your personal information to entities providing passive technologies on our websites, mobile applications, or other technology resources as described below.

Passive Collection Technologies and Tracking.

When you interact with our websites, mobile applications, or other services (such as electronic communications with us, or attending a virtual or in-person conference) we, and other parties, use technologies to automatically and passively collect data such as about how one of our websites is being accessed and used, or whether you checked in at one of our booths, which can include information about your devices and/or your browser (“Device Information”, as defined above).

We (and the parties acting on our behalf) may collect this Device Information directly from your browser interacting with our websites, apps, and through emails we send to you. We may also collect it through cookies, scripts, pixels, tags, local storage, and similar technologies, which typically work by placing a small file (like a text file or graphic) on your browser or reading unique identifiers from your device.

Cookies, Beacons, Local Storage, and Tags.

Cookies are small pieces of data saved to your browser or device that allow us to identify your device as you use our websites or access your account. We categorize cookies as strictly necessary or essential (such as those needed to allow you to use your account), functional (such as those that may help you use of navigate a site during a session), and tracking or advertising (such as those that allow us to understand your use of our sites or electronic communications, infer your interests, advertise to you, or track and measure purchases you may make from us or other websites).

We use both session and persistent cookies. Session cookies are cookies that disappear from your computer or browser when you turn off your computer or leave the Site. Persistent cookies stay on your computer even after you log off, navigate to another site, or turn off your computer.

We also use pixels, beacons, local storage, or tags to read information from your device or clickstream data such as where you saw one of our advertisements for example. We refer to these technologies collectively as “tags” in this Privacy Notice. The information collected by the tags will be disclosed to or collected directly by the other parties we authorize through our website or through emails. We use the information from those tags to evaluate your use of our resources, personalize content, and through other services such as sending you emails and measuring if, when, and how often you open the emails from us, for example. We also use the information for advertising purposes to serve you interest-based advertisements on our websites or other websites you visit.

Cookies and tags are used to identify your device and to collect and share information and may be used to create profiles about your perceived interests to personalize your experience, and advertise to you through emails, texts, and on other web sites you may visit.

We do not control the use of your information when it is collected and used by these other companies we allow to operate on technology services such as websites.

We allow companies, including the below, to load cookies and/or operate tags on our website or in emails we send to you which are not deemed strictly necessary for operations or security:

• Google Analytics – We use Google Analytics to obtain information about your use of the Site and for targeted advertising. To find out more information about how Google uses your information collected through Google Analytics, please visit www.google.com/policies/privacy/partners/
• One method you may use to opt-out of processing personal information through Google Analytics is to load the Google Analytics browser opt-out plug-in which you can find here. You may also refer to the section of this privacy notice entitled How to Opt-Out of Tracking for more information on other methods of how to opt-out from passive technology collection and tracking.

Social Media Links

Some of our technology resources include social media features, such as the Facebook, X, and LinkedIn, links. If you use those links you may share personal information with those services. We are not responsible for how those services use your personal information if you navigate to those sites.

Social Media Widgets

Some of our technology resources include social media features, such as the Facebook, X, and LinkedIn, widgets. Widgets are software development kits embedded on our resources, such as our webpages to which this Privacy Notice is linked. These features may collect information about you such as your IP address and which page you are visiting on our sites. They may set a cookie or employ other tracking technologies to accomplish this. Social media features and widgets may be hosted by a third-party. Your interactions with those features are governed by the privacy policies of the companies that provide them.

How to Opt-Out of Tracking.

Cookie Consent Tool: We use an online tool that will allow you to make choices about whether to allow tracking technologies on our website. When you visit one of our websites to which this Notice is linked, a cookie consent banner will appear that will allow you choices. We categorize cookies as three types: strictly necessary, functional or performance, and tracking or advertising. You cannot disable strictly necessary cookies as they are required for the Site to work with your browser and for us to deliver the website content to you. We do not share or use data related to strictly necessary cookies for tracking, advertising, or any other purposes except to safely enable you to use the website. Functional or performance cookies are used to enhance features of the website and personalize it to You. We do not use or share data from functional cookies for advertising or to track you across sites or over time, but we do use them to track your use of the website and preferences. Tracking or advertising cookies are shared with other third parties and used to track you across sites and over time for advertising purposes such as to display online ads to you. The third parties with which we share the data from the website might also use the data to infer characteristics about your interests for their own business purposes. For more information about what cookies are running on the website and their uses, you can click on the “Preferences” button on our cookie banner. You may accept all cookies, reject all cookies, or select which types of cookies you wish to allow.

Browser Controls: In addition to our cookie consent tool, you may also disable cookies through your browser. You can find further Information about how to disable cookies in your browser here.

Global Privacy Control: Global Privacy Control (GPC) is a technology standard that allows you to send a signal to our websites. To find out more about GPC and how to enable it, you can refer to this site . If you send a GPC signal indicating an intention to opt-out from tracking, we will automatically turn off all non-essential cookies on our websites. That may affect your ability to use certain functions of the website.

Do Not Track: We do not recognize Do Not Track signals.

Opting Out from Advertising Network Providers: We use tools and companies that help us to track your use of the website and other sites to send you interest based advertising online. Some of these providers may participate in one of the following self-regulatory programs for online behavioral advertising, which provide other methods to allow you to opt-out from interest-based advertising that they may send you on our behalf or their other clients. You may exercise your choices by taking appropriate steps as outlined at the following links:

• Networking Advertising Initiative (http://www.networkadvertising.org/choices/) (US Only)
• Digital Advertising Alliance (http://www.aboutads.info/choices/) (US Only)
• European Interactive Digital Advertising Alliance (http://www.youronlinechoices.eu/) (EU Only)
• Digital Advertising Alliance – Canada (http://youradchoices.ca/choices) (Canada Only)
• DAA App Choices Mobile App (Mobile Devices Only) – For mobile devices (e.g., smartphone, tablets), you may consider downloading the DAA AppChoices Mobile App to manage such technology.

Some of these methods may be based upon loading opt-out cookies into your browser. If you clear your cookies from your browser, you may have to re-visit these sites to make your selection.

Please note that even if you reject such technology, you may continue to receive advertisements, but the advertisements will not be tailored to your browsing activities and interests.

If you wish to disallow tracking pixels in the emails we may send to you, please disable images in your email platform.

Third-Party Links.

The Site may contain links to third-party websites that are not controlled by Time4Learning. Any such links are made available to you as a convenience, and you agree to use these links at your own risk. Please be aware that we are not responsible for the privacy practices or content of such third-party services. Consult their separate privacy policy in regard to their privacy practices. If you interact with one of our social sites on a third-party social sharing website (for example, a Time4Learning page on Facebook®), your use of the third-party platform is subject to its separate privacy and usage terms and you should take actions concerning your privacy preferences through those platforms to avoid their tracking activities.

Retention of Personal Information.

Personal information is retained for so long as necessary and required to support our services to you and for a reasonable period of time after that as necessary for our legal compliance obligations.

If you set up an account with us, send us communications, and/or we collect your personal information such as through a conference or symposium and your account is inactive or we do not have any further response or interaction with you, we may delete your information and close your account. We may contact you to provide notice that we intend to close your account and delete your personal information. Those later notices may advise you of further actions to take if you choose not to keep your account active.

International Transfers.

We are headquartered in the United States and currently our Site is designed for individuals located in the United States. The United States may have privacy and security laws that differ from those in your country. If you are located outside of the United States, be advised that any information you provide to us will be transferred to, stored in, and accessed by people in, the United States. By submitting information to us, you authorize its transfer, storage, and access within the United States. Some of the recipients of data identified above may be located in countries that do not provide an equivalent level of protection as your home country. Where required by applicable law, we have taken appropriate measures to allow and secure the transfer of information about you to these recipients for the purposes described above and in order to comply with local data privacy laws. Where required by applicable law, your continued use of our services indicates your consent to our privacy practices as described in this Notice.

Your Rights Under Applicable Privacy Laws.

Where required by applicable law, you may have the right to obtain confirmation that we maintain certain personal information relating to you, to verify its content, origin, and accuracy, as well as the right to access your personal information, request their update, integration or completion, request deletion or portability of your personal information.

You may also object to the processing of your personal information or request restriction of the processing, including for targeted advertising, as well as withdraw your consent to the processing of personal information (without affecting the lawfulness of processing based on consent before its withdrawal).

Additionally, in certain jurisdictions you may have the right to opt-out of the “sale” or “sharing” of your personal information, as the term is defined under applicable law. You can exercise your rights by contacting us as detailed under the “Contact Us” heading below.

In some jurisdictions, you can designate an authorized agent to make a request on your behalf. We will comply with your request as soon as reasonably practicable and as required by applicable law. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law. In any event, should you choose to exercise any of your rights as detailed above, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request. You may also have the right to lodge a complaint with the relevant data protection supervisory authority.

You always have the right to object to the processing of your personal information for direct marketing purposes at any time.

In certain jurisdictions, if we refuse to take action on a request, you may appeal our decision within a reasonable period of time by contacting us as outlined below in the “Contact Us” section and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the appropriate regulatory authority for your jurisdiction.

Supplemental Information for California Residents

If you reside in California, we are required by the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”) (collectively, “California Privacy Law”) to provide you with information about how we used and disclosed your personal information in the preceding 12 months. You may also have certain rights with regard to your personal information. We have included this California-specific information below.

CA Personal Information.We may collect certain categories and specific pieces of information about individuals that are considered “personal information” in California (“CA Personal Information”). Specifically, we may collect the following categories of CA Personal Information: identifiers, commercial information, internet or other electronic network activity information, geolocation data, and inferences.

Sources of CA Personal Information.We may collect this CA Personal Information from you and other third parties such as service providers, business partners, or other third party vendors.

Purposes of Collection.We collect and use CA Personal Information for the following business purposes:

• to provide the functionality of the websites and related services you may request including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, or providing similar services;
• for short-term, transient use, including, but not limited to, the contextual customization of ads or website content shown as part of the same interaction;
• for analytics purposes (such as determining how many users use one of our websites, when, what portions of websites and contents are used, user demographic information, the sites referring to our websites and sites to which users may navigate);
• to market and/or advertise our goods and services, or the goods and services of others, to you;
• to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity;
• to debug to identify and repair errors that impair existing intended functionality;
• to conduct internal research and development for new services and features related to our business;
• to undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by, us and to improve, upgrade, or enhance our services; and
• to advance our commercial or economic interests, such as by referring you to other sites and services by us, our affiliated business units, or other third parties for which we may receive payment.

Selling, Sharing and Disclosing CA Personal Information. We do not sell your CA Personal Information as that term is traditionally understood. However, some of our disclosures of CA Personal Information may be considered a “sale” or “share” as those terms are defined under California Privacy Law. Under California Privacy Law, a “sale” is broadly defined to include a disclosure for something of value, and a “share” is broadly defined to include a disclosure for cross-context behavioural advertising. We disclose your CA Personal Information as follows:

• We shared the above categories of CA Personal Information with third-party vendors and business partners to provide you with cross-context behavioral advertising.
• Apart from the above, we disclosed the above categories of CA Personal Information as described in the “Information We Disclose with Others” section above, such as to service providers, third-party vendors, business partners and other third parties.

We do not knowingly disclose the CA Personal Information of individuals under 16 years of age, in a manner that constitutes a “sale” or “sharing” under California Privacy Law.

CA Sensitive Personal Information

Certain CA Personal Information that we collect about you may be considered sensitive personal information within the meaning of California Privacy Law, including: your account log-in, password and precise geolocation (if you have this enabled). We only use and disclose sensitive personal information as described in the “Our Treatment of Sensitive Personal Information” section above, including as necessary in connection with the performance of services and the provision of goods, compliance with federal, state, or local laws, and as otherwise permitted by California Privacy Law.

Retention of CA Personal Information

We retain your CA Personal Information as described in the “Retention of Personal Information” section above, for so long as necessary and required to support our services to you and for a reasonable period of time after that as necessary for our legal compliance obligations. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you; (ii) as required by a legal obligation to which we are subject to; or (iii) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).

Your Rights under California Privacy Law

Subject to certain exceptions detailed in California Privacy Law and other applicable laws and regulations, as a California resident, you have the right to: (i) request to know/access your CA Personal Information, including the specific pieces and the categories of CA Personal Information we have collected or shared about you and the categories of sources from which we have collected the CA Personal Information; (ii) request deletion of your CA Personal Information; (iii) receive information about the CA Personal Information about you that we have “sold” to (as such term is defined under California Privacy Law) or “shared” with third parties within the past 12 months, including the categories of third parties; and (iv) request correction of your CA Personal Information; (iv) opt-out of the “sale” or “sharing” of your CA Personal Information, as such terms are defined under California Privacy Law; and (v) limit the use and disclosure of sensitive personal information to purposes specified in Cal. Civil Code 1798.121(a). We do not use or disclose sensitive personal information for purposes other than those specified in Cal. Civil Code 1798.121(a).

Exercising California Consumer Rights.

If you are a California resident and wish to exercise your rights to know, delete or correct, please call (888) 771-0914 (toll free) or populate our web form https://www.time4learning.com/contact-us/.

• You may be asked to provide additional proof of identification so that we can verify your identity and validate the request.
• Please note that you are limited by law in the number of requests you may submit per year. In some instances, we may decline to honor your request. For example, we may decline to honor your request if we cannot verify your identity or confirm that the CA Personal Information that we maintain relates to you. In other instances, we may decline to honor your request where an exception under California Privacy Laws applies, such as where the disclosure of CA Personal Information would adversely affect the rights and freedoms of another consumer.
• In any case, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request.

Authorized Agents

To the extent that you elect to designate an authorized agent to make a request on your behalf, they must provide appropriate documentation including written signed permission from you, proof of your identity, and verification of their identity; or a valid, designated power of attorney as defined under the California Probate Code.

CA Shine the Light

We do not disclose personal information to third parties for such third parties’ use for direct marketing purposes. Under California’s Shine the Light law, customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To make a request, please write us at the email or postal address set out in the “Contact Us” section below and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

Notice to Residents of Countries Outside the United States.

We are headquartered in the United States. The United States may have privacy and security laws that differ from those in your country. If you are located outside of the United States, be advised that any information you provide to us will be transferred to, stored in, and accessed by people in, the United States. By submitting information to us, you authorize its transfer, storage, and access within the United States.

Changes to this Notice.

If we make material changes to this Notice, we will post the updated Notice on this page and take reasonable steps designed to alert you to the material changes. Your continued use of our services following the posting of changes constitutes your agreement to such changes.

Contact Us.

[email protected]