Thank you for using Early Beginnings Day School!

This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of the Instapage and Early Beginnings Day School Platforms (collectively).

If you see an undefined term in this Privacy Policy (such as “our website” or “platform”), it has the same definition as in our Terms of Service.

When this Policy mentions “Early Beginnings Day School,” “we,” “us,” or “our,” it refers to its website that is responsible for your information under this Privacy Policy, Early Beginnings Day School (the “Data Controller”). Please see Section 12 for the contact details of the Data Controllers.

Early Beginnings Day School complies with the requirements of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively “Privacy Shield”), as set forth by the U.S. Department of Commerce and the Federal Trade Commission (“FTC”), regarding the collection, use, and retention of Personal Information transferred from the European Economic Area and Switzerland to the United States. Early Beginnings Day School has been certified by the Department of Commerce that it adheres to the Privacy Shield Principles and Supplemental Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program and to view Early Beginnings Day School certification, please visit Privacy Shield. Early Beginnings Day School may protect information through other legally valid methods, including international data transfer agreements.

This Policy applies to all Early Beginnings Day School operating divisions, subsidiaries, affiliates, and branches, including its U.S. affiliates certified under the Privacy Shield and any additional subsidiary, affiliate, or branch of Early Beginnings Day School that we may subsequently form.

An Important Note: This Privacy Policy does not apply to any of the personal information that our customers may process using Early Beginnings Day School’s products and services (“Customer Data”). Our customers’ respective privacy policies govern the collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Policy. Any questions or requests relating to Customer Data should be directed to our customer.

0. DEFINITIONS

“Agent” means any Third Party that processes Personal Information pursuant to the instructions of, and solely for, Early Beginnings Day School or to which Early Beginnings Day School discloses Personal Information for use on its behalf.

“Customer Data” means any Personal Data that Early Beginnings Day School processes on behalf of Customer as a Data Processor in the course of providing Services, as more particularly described in our DPA.

“Data Protection Laws” means all data protection and privacy laws applicable to the processing of Personal Data under this Privacy Policy, Terms of Service, and DPA, including, where applicable, E.U. Data Protection Law.

“Data Controller” means an entity that determines the purposes and means of the processing of Personal Data.

“Data Processor” means an entity that processes Personal Data on behalf of a Data Controller.

“EEA” means, for the purposes of this Privacy Policy, the European Economic Area and Switzerland.

“Privacy Shield” means the seven (7) principles of the Privacy Shield Framework: (1) notice, (2) choice, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access, and (7) recourse, enforcement, and liability. Additionally, it includes the fourteen (14) supplemental principles described in the Privacy Shield: (1) sensitive data, (2) journalistic exceptions, (3) secondary liability, (4) performing due diligence and conducting audits, (5) self-certification, (6) verification, (7) access, (8) obligatory contracts for onward transfers, (9) dispute resolution and enforcement, (10) choice – timing of opt-out, (11) travel information, (12) pharmaceutical and medical products, (13) public record and publicly available information, and (14) access requests by public authorities.

“Process” or “Processing” has the meaning given to it in the GDPR, and “process,” “processes,” and “processed” shall be interpreted accordingly.

“Services” means any product or service provided by Early Beginnings Day School to Customer pursuant to this Privacy Policy, Terms of Service, and DPA.

1. INFORMATION WE COLLECT

There are three general categories of information we collect.

1.1 INFORMATION YOU GIVE TO US.

1.1.1 INFORMATION THAT IS NECESSARY FOR THE USE OF THE Early Beginnings Day School PLATFORM.

We ask for and collect the following personal information about you when you use the Early Beginnings Day School Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.

Account Information. When you sign up for an Early Beginnings Day School Account, we require certain information, such as your first name, last name, and email address.

Communications with Early Beginnings Day School and other Users. When you communicate with Early Beginnings Day School or use the Early Beginnings Day School Platform to communicate with other Users, we collect information about your communication and any information you choose to provide.

1.1.2 INFORMATION YOU CHOOSE TO GIVE US.

You may provide us with additional personal information to obtain a better user experience when using the Early Beginnings Day School Platform. This additional information will be processed based on your consent.

Additional Profile Information. You may provide additional information as part of your Early Beginnings Day School profile. Some of this information, as indicated in your Account settings, is part of your personal profile page and will be visible to other users or team members within your Account.

Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend conferences, trade shows, and other events.

Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

Other Information. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your Early Beginnings Day School Account, respond to surveys, post to community forums, and participate in promotions or referral programs, or use other features of the Early Beginnings Day School Platform.

Job Applications. We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV, and/or cover letter to us, we will collect and use your information to assess your qualifications.

1.2 INFORMATION WE AUTOMATICALLY COLLECT FROM YOUR USE OF THE Early Beginnings Day School PLATFORM AND PAYMENT SERVICES.

When you use the Early Beginnings Day School Platform, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Early Beginnings Day School Platform and Payment Services.

Geo-location Information. When you use certain features of the Early Beginnings Day School Platform, we may collect information about your precise or approximate location as determined through data such as your I.P. address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable location services for applications in the device’s settings menu.

Usage Information. We collect information about your interactions with the Early Beginnings Day School Platform, such as the pages or content you view, your feature usage, the number of pages in use, the design, and content of pages, and other actions on the Early Beginnings Day School Platform.

Log Data and Device Information. We automatically collect log data and device information when you access and use the Early Beginnings Day School Platform, even if you have not created an Early Beginnings Day School Account or logged in. That information includes, among other things: details about how you’ve used the Early Beginnings Day School Platform (including if you clicked on links to third-party applications), I.P. address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Early Beginnings Day School Platform.

Cookies and Similar Technologies. We use cookies and similar technologies, such as web beacons, pixels, and mobile identifiers (“Technologies”). We may also allow our business partners to use these tracking Technologies on the Early Beginnings Day School Platform or engage others to track your behavior on our behalf. While you may disable cookies through your browser settings, the Early Beginnings Day School Platform currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to a lack of standardization regarding how that signal should be interpreted.

• Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;

Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);

Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;

Advertising- or Targeting-Related. We may use first-party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or third-party websites.

See Section 6 below to understand your choices regarding these Technologies.

Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include:

• Segment. For more information, please visit Segment’s Privacy Policy.
• Alexa Metrics. For more information, please visit Alexa Metrics’ Privacy Policy.

Payment Transaction Information. Early Beginnings Day School collects information related to your payment transactions through the Early Beginnings Day School Platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date, billing postcode, IBAN information, your address, and other related transaction details. This information is necessary for the adequate performance of the contract between you and Early Beginnings Day School.

1.3 INFORMATION WE COLLECT FROM THIRD PARTIES.

Early Beginnings Day School may collect information, including personal information, that others provide about you when they use the Early Beginnings Day School Platform and the Payment Services, or obtain information from other sources and combine that with information we collect through the Early Beginnings Day School Platform and the Payment Services. We do not control, supervise or respond to how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

Third-Party Services. If you link, connect, or log in to your Early Beginnings Day School Account with a third-party service (e.g., Google or Facebook), the third-party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.

Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third-party service providers and/or partners and combine it with information we have about you. For example, we may receive fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Early Beginnings Day School Platform through partnerships or about your experiences and interactions from our partner ad networks.

2. HOW WE USE THE INFORMATION, WE COLLECT

We use, store, and process personal information about you to provide, understand, improve, and develop the Early Beginnings Day School Platform, create and maintain a trusted and safer environment and comply with our legal obligations.

2.1 PROVIDE, IMPROVE, AND DEVELOP THE Early Beginnings Day School PLATFORM.

Enable you to access and use the Early Beginnings Day School Platform.

Enable you to communicate with other Team Members.

Operate, protect, improve, and optimize the Early Beginnings Day School Platform and experience by performing analytics and conducting research.

Provide customer service, including logging into a User’s account to troubleshoot with their consent, and providing email support, or phone support for Enterprise customers.

Send you service or support messages, updates, security alerts, and account notifications.

To operate, protect, improve, and optimize the Early Beginnings Day School Platform and experience, and personalize and customize your experience (such as making design suggestions or recommending features), we conduct profiling based on your interactions with the Early Beginnings Day School Platform, your profile information, and preferences, and other content you submit to the Early Beginnings Day School Platform.

We process this information given our legitimate interest in improving the Early Beginnings Day School Platform and our users’ experience with it and where it is necessary for the adequate performance of the contract with you.

2.2 CREATE AND MAINTAIN A TRUSTED AND SAFER ENVIRONMENT.

Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.

Conduct security investigations and risk assessments.

Comply with our legal obligations.

Resolve any disputes and enforce our agreements with third parties.

Enforce our Terms of Service and other policies.

In connection with the activities above, we may conduct profiling based on your interactions with the Early Beginnings Day School Platform, your profile information and other content you submit to the Early Beginnings Day School Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Early Beginnings Day School Platform if such processes detect a User or activity that we think poses a safety or other risk to themselves, the Early Beginnings Day School Platform, other Users, or third parties.

We process this information given our legitimate interest in protecting the Early Beginnings Day School Platform, measuring the adequate performance of our contract with you, and complying with applicable laws.

2.3 PROVIDE, PERSONALIZE, MEASURE, AND IMPROVE OUR ADVERTISING AND MARKETING.

With your consent, we may send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Early Beginnings Day School or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google.

Personalize, measure, and improve our advertising.

Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Early Beginnings Day School or its third-party partners.

Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Early Beginnings Day School Platform, and information obtained from third parties) to send you promotional messages, marketing, advertising, and other information that we think may be of interest to you.

We will process your personal information for the purposes listed in this section, given our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest. You can opt out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Early Beginnings Day School Account.

2.4 HOW THE PAYMENTS DATA CONTROLLER USES THE INFORMATION COLLECTED.

Detect and prevent fraud, abuse, security incidents, and other harmful activity.

Conduct security investigations and risk assessments.

Conduct checks against databases and other information sources.

Comply with legal obligations (such as anti-money laundering regulations).

With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.

The Payments Data Controller processes this information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.

3. SHARING & DISCLOSURE

3.1 WITH YOUR CONSENT.

Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third-party application or website to access your Early Beginnings Day School Account or when you participate in promotional activities conducted by Early Beginnings Day School partners or third parties.

3.2 COMPLIANCE WITH LAW, RESPONDING TO LEGAL REQUESTS, PREVENTING HARM, AND PROTECTION OF OUR RIGHTS.

Early Beginnings Day School may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Early Beginnings Day School, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service, or other agreements with Users, or (v) to protect the rights, property or personal safety of Early Beginnings Day School, its employees, its Users, or members of the public.

Where appropriate, we may notify Users about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Early Beginnings Day School’s property, its Users and the Early Beginnings Day School Platform. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

3.3 SERVICE PROVIDERS.

Early Beginnings Day School uses a variety of third-party service providers to help us provide services related to the Early Beginnings Day School Platform and the Payment Services. Service providers may be located inside or outside the European Economic Area (“EEA”). In particular, our service providers are based in Europe, India, Asia Pacific, and North and South America.

For example, service providers may help us: (i) with fraud prevention and risk assessment, (ii) perform product development, maintenance, and debugging, and (iii) allow the provision of the Early Beginnings Day School Services through third-party platforms and software tools (e.g., through the integration with our APIs), or (iv) provide customer service, advertising, or payments services. These providers have limited access to your information to perform these tasks on our behalf and are contractually bound to protect and use it only for the purposes it was disclosed and consistent with this Privacy Policy. Early Beginnings Day School has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements. Our main subprocessors are Google Cloud Platform, Google Workspace (formerly G Suite), Amazon Web Services, HubSpot, and Cloudflare.

Early Beginnings Day School will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.

3.4 CORPORATE AFFILIATES.

To enable or support us in providing the Early Beginnings Day School Platform, we may share your information, including personal information, within our corporate family of companies that are related by common ownership or control, including Early Beginnings Day School

Sharing with Early Beginnings Day School. Even if your Country of Residence is not the United States, your information may be shared with Early Beginnings Day School, which provides the technical infrastructure for the Early Beginnings Day School Platform, product development and maintenance, and customer support, trust and safety, and other business operation services to other Early Beginnings Day School entities. The data sharing is necessary for the performance of the contract between you and us and is based on our legitimate interests in providing the Early Beginnings Day School Platform globally.

Sharing with Early Beginnings Day School even if your Country of Residence is not the United States, your information may be shared with Early Beginnings Day School, which provides the technical infrastructure for the Early Beginnings Day School Platform, product development and maintenance, customer support, trust and safety, and other business operation services to other Early Beginnings Day School entities. The data sharing is necessary for the performance of the contract between you and us and is based on our legitimate interests in providing the Early Beginnings Day School Platform globally.

We share your personal information with our corporate affiliates to support, integrate, promote, and improve the Early Beginnings Day School Platform and our affiliates’ services.

3.5 SOCIAL MEDIA PLATFORMS.

Where permissible according to applicable law, we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Early Beginnings Day School Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest.

The social media platforms with which we may share your personal data are not controlled or supervised by Early Beginnings Day School. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such a provider.

Please note that at any time, you may ask Early Beginnings Day School to cease processing your data for these direct marketing purposes by sending an e-mail to bynent@icloud.com.

3.6 BUSINESS TRANSFERS.

If Early Beginnings Day School undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

3.7 PRIVACY SHIELD.

With respect to onward transfers to Agents under Privacy Shield, Privacy Shield requires that Early Beginnings Day School remain liable should its Agents Process Personal Information in a manner inconsistent with the Privacy Shield Principles.

3.8 AGGREGATED DATA.

We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other de-identified information for regulatory compliance, industry and market analysis, demographic profiling, marketing, and advertising, and other business purposes.

4. OTHER IMPORTANT INFORMATION

4.1 ANALYZING YOUR COMMUNICATIONS.

We may use technologies considered automated decision-making or profiling. We will not make automated decisions about you that would significantly affect you unless such a decision is necessary as part of a contract with you, we have your consent, or we are required by law to use such technology.

We may review, scan, or analyze your communications on the Early Beginnings Day School Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes.

For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites.

In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings.

We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools.

We will not review, scan, or analyze your communications to send third-party marketing messages to you, and we will not sell reviews or analyses of these communications.

These activities are carried out based on Early Beginnings Day School's legitimate interest in ensuring compliance with applicable laws and our Terms of Service, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.

4.2 LINKING THIRD-PARTY ACCOUNTS.

You may link your Early Beginnings Day School Account with your account at a third-party social networking service. When you create this link, the information you provide to us from the linking of your accounts may be stored, processed, and transmitted for fraud prevention and risk assessment purposes; and the publication and display of information that you provide to Early Beginnings Day School through this linkage are subject to your settings and authorizations on the Early Beginnings Day School Platform and the third-party site.

We only collect your information from linked third-party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.

5. THIRD-PARTY PARTNERS & INTEGRATIONS

The Early Beginnings Day School Platform may contain links to third-party websites or services, such as third-party integrations, co-branded services, or third-party-branded services (“Third Party Partners”). Early Beginnings Day School doesn’t own or control these Third-Party Partners. When you interact with them, you may be providing information directly to the Third-Party Partner, Early Beginnings Day School, or both. These Third-Party Partners will have rules about collecting, using, and disclosing information. We encourage you to review the privacy policies of the other websites you visit.

6. YOUR RIGHTS

Under Privacy Shield, you may exercise any of the rights described in this section by sending an email to bynent@icloud.com. Please note that we may ask you to verify your identity before taking further action on your request.

6.1 COOKIES AND INTEREST-BASED ADVERTISING.

You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, our services may not work properly if you adjust your preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

Please note you must separately opt out in each browser and on each device.

6.2 MANAGING YOUR INFORMATION.

You may access and update some of your information through your Account settings. If you have chosen to connect your Early Beginnings Day School Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.

6.3 RECTIFICATION OF INACCURATE OR INCOMPLETE INFORMATION.

You have the right to ask us to correct personal information concerning you that is inaccurate, incomplete, or has been processed in violation of the Privacy Shield Principles.

6.4 DATA ACCESS AND PORTABILITY.

In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

6.5 DATA RETENTION AND ERASURE, ANONYMIZATION, OR BLOCKING.

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Early Beginnings Day School Platform, you can request that we erase your personal information and close your Early Beginnings Day School Account. You may also request the deletion, anonymization, or blocking of your personal information when processing is based on your consent or when processing is unnecessary, excessive, or non-compliant. Please note that if you request the erasure of your personal information:

• We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Early Beginnings Day School Account for fraud or safety reasons, we may retain certain information from that Early Beginnings Day School Account to prevent that User from opening a new Early Beginnings Day School Account in the future.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Early Beginnings Day School may keep some of your information for tax, legal reporting, and auditing obligations.
• Information you have shared with others (e.g., forum postings) may continue to be publicly visible on the Early Beginnings Day School Platform, even after your Early Beginnings Day School Account is canceled. However, the attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database but are disassociated from personal identifiers.
• Because we maintain the Early Beginnings Day School Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

6.6 WITHDRAWING CONSENT AND RESTRICTION OF PROCESSING.

Where you have provided your consent to processing your personal information by Early Beginnings Day School, you may withdraw your consent at any time by changing your Account settings or by sending a communication to dpo@Early Beginnings Day School.com specifying which consent you are withdrawing. If you refrain from providing personal information or withdraw your consent to the processing, some features of our Service may not be available. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular, where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful, and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing pursuant to Section 6.7 and pending the verification, whether the legitimate grounds of Early Beginnings Day School override your own.

6.7 OBJECTION TO PROCESSING.

In some jurisdictions, applicable law may entitle you to require Early Beginnings Day School not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, Early Beginnings Day School will no longer process your personal information unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise, or defense of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time, ask Early Beginnings Day School to cease processing your data for these direct marketing purposes by opting out from your account settings.

6.8 BE INFORMED ABOUT THIRD PARTIES.

In some jurisdictions, applicable law may entitle you to be informed about the third parties with which your personal information has been shared. For more information about the third parties with which we have shared personal information, you may contact us at bynent@icloud.com.

6.9 REQUEST A REVIEW.

You may have the right to request a review of decisions taken exclusively based on automated processing if that could affect data subject rights. For more information, please contact us at bynent@icloud.com.

7. OPERATING GLOBALLY

7.1 INTERNATIONAL DATA TRANSFERS.

To facilitate our global operations, Early Beginnings Day School may transfer, store, and process your information within our family of companies or with service providers based in Europe, India, Asia Pacific, and North and South America, including but not limited to the United States. These countries' laws may differ from those applicable to your Country of Residence. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy. Where we transfer, store, and process your personal information outside of the EEA, we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Early Beginnings Day School, you explicitly consent to the storage of your Personal Information in these locations. For more information, please see our Information Security Policy by sending a request to bynent@icloud.com.

7.2 OTHER MEANS TO ENSURE AN ADEQUATE LEVEL OF DATA PROTECTION.

If your information is shared with corporate affiliates or third-party service providers outside the EEA, we have established the necessary means to ensure an adequate level of data protection prior to sharing your information with such a corporate affiliate or third-party service provider. This may be an adequacy decision of the European Commission confirming an adequate level of data protection in the respective non-EEA country or an agreement on the basis of the E.U. Model Clauses (a set of clauses issued by the European Commission). For more information, please see our Information Security Policy by sending a request to bynent@icloud.com.

7.3 CALIFORNIA & VERMONT RESIDENTS.

Early Beginnings Day School will not share information it collects about you with its affiliates or third parties (both financial and non-financial), except as required or permitted by your state’s law.

7.4 “SALES” OF PERSONAL INFORMATION UNDER THE CCPA.

For purposes of the CCPA, Early Beginnings Day School does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Additional Privacy Rights for California Residents

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, contact us as set forth below.

Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify that you are the person we collected personal information or an authorized representative, which may include your name, email address, or additional profile information you provide.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth below. We will process such requests in accordance with applicable laws.

8. SECURITY

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Early Beginnings Day School Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Early Beginnings Day School Account, please contact us following the instructions in Section 12 below. We do not accept liability for unauthorized disclosure to the fullest extent permitted by applicable law.

By using our Services or providing personal information, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

9. REDRESS/COMPLIANCE AND ACCOUNTABILITY

If you have questions about our privacy practices, this Privacy Policy, or how to complain to the appropriate authority, please contact Early Beginnings Day School by email at bynent@icloud.com. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

If you are located in the European Economic Area, Switzerland, the United Kingdom, or Brazil, you have the right to complain to a supervisory authority if you believe our processing of your personal information violates applicable law.

This Policy shall be implemented by Early Beginnings Day School and all its operating divisions, subsidiaries, and affiliates. Early Beginnings Day School has put in place mechanisms to verify ongoing compliance with Privacy Shield Principles and this Policy. Any Employee that violates these privacy principles will be subject to disciplinary procedures. If you are an E.U. or Swiss citizen and feel that Early Beginnings Day School is not abiding by the terms of this Policy or is not in compliance with the Privacy Shield Principles, please contact Early Beginnings Day School at the information provided in Section 12 “Contact Us” below.

Early Beginnings Day School has also agreed to refer unresolved complaints related to Personal Information to JAMS Privacy Shield Dispute Resolution Program. For more information and to submit a complaint regarding Individual data to JAMS, a dispute resolution provider which has locations in the United States and E.U., visit https://www.jamsadr.com/eu-us-privacy-shield.

You may also have a right, under certain conditions, to invoke binding arbitration under Privacy Shield; for additional information, see https://www.privacyshield.gov/article?id=ANNEX-I-introduction. The FTC has jurisdiction over Early Beginnings Day School’s compliance with the Privacy Shield.

10. CHILDREN’S INFORMATION

The Services are not directed to children under 13 (or other ages as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and wish to review information collected from your child or have that information modified or deleted, you may contact us as described below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected unless we have a legal obligation to keep it and terminate the child’s account.

11. CHANGES TO THIS PRIVACY POLICY

Early Beginnings Day School reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Early Beginnings Day School Platform and update the “Last Updated” date at the top of this Privacy Policy. We will provide notice of any material changes via a notice on our website. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Early Beginnings Day School Platform will be subject to the revised Privacy Policy.

12. CONTACT US

If you have any questions or complaints about this Privacy Policy or Early Beginnings Day School’s information handling practices, you may email us at bynent@icloud.com or contact us in writing at

Early Beginnings Day School
Legal Department
338 Grove Street, Jersey City, NJ 07302