(Effective January 1, 2024)

PRIVACY SHIELD POLICY

This Privacy Shield Policy (“Policy”) applies to all personal information received by Great Horizons Learning Centers.
This Policy sets out our practices for collecting, using, maintaining, protecting, and disclosing that personal information.

DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Great Horizons Learning or to which Great Horizons Learning discloses personal information for use on Great Horizons L behalf.

“Personal information” means any information or set of information that identifies or could be used by or on behalf of Great Horizons Learning to identify (together with other information) a living individual. Personal information does not include information that is anonymized or aggregated.

“Sensitive information” means any personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; information that concerns health or sex life; information specifying personal sexuality, ideological, or trade union-related views or activities; and information about criminal or administrative proceedings and sanctions (which are treated outside pending proceedings), or social security measures.

PRINCIPLES

Notice

Great Horizons Learning uses this information to provide our educational, customer support for such services, to bill customers, and to correspond with customers. Great Horizons Learning is subject to the investigative and enforcement authority of the Federal Trade Commission (FTC), is obliged to disclose personal information in response to lawful requests by public authorities, for law enforcement, and national security purposes, and has potential liability for onward transfers to third parties.

Additionally, an individual may be allowed to invoke binding arbitration to resolve disputes under certain limited conditions.

Choice

Great Horizons Learning will offer individuals the opportunity to choose whether their personal information is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. An individual may opt-out of such uses of their personal information by contacting us at the address given below. Great Horizons Learning does not disclose personal information to non-agent third parties. If this changes, Great Horizons Learning will offer an opt-out to individuals. Great Horizons Learning will not use sensitive personal information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual unless Great Horizons Learning has received the individual’s affirmative and explicit consent (opt-in). Great Horizons Learning will treat as sensitive any personal information received from a third party where the third party identifies and treats it as sensitive.

Data Integrity

Great Horizons Learning will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Great Horizons Learning will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete and current.

Transfers to Agents

Great Horizons Learning contracts with third parties who perform business functions on our behalf
Great Horizons Learning uses these third parties to manage its IT system infrastructure, provide live, online support to customers, and to manage email lists. These entities may have access to personal information if needed to perform their functions for Great Horizons Learning. Great Horizons Learning does not disclose personal information to non-agent third parties.

Access and Correction

Great Horizons Learning acknowledges the right of individuals to access their personal information. Upon request, Great Horizons Learning will grant individuals reasonable access to personal information that it holds about them. In addition, Great Horizons Learning will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. An individual may request to access their information, or otherwise correct, amend, or delete their information by contacting us at the address given below.

Security

Great Horizons Learning will take reasonable and appropriate precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration, and destruction.

Enforcement

Great Horizons Learning will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Great Horizons Learning determines is in violation of this policy will be subject to disciplinary action.

Great Horizons Learning is subject to the investigative and enforcement authority of the FTC.

LIMITATIONS & CHANGES

We may also be required to disclose an individual’s personal information in response to a lawful request by public authorities or in connection with a legal obligation. Adherence by Great Horizons Learning to these Privacy Shield Principles may also be limited to the extent required to respond to a legal obligation, to the extent necessary to meet national security, public interest, or law enforcement obligations, and to the extent expressly permitted by an applicable law, rule or regulation.

This Policy may be amended from time to time, consistent with the requirements of the Privacy Shield Principles. The amended Policy will be made publicly available via Great Horizons Learning website.