Privacy Policy

Use of Cookies: Cookies are pieces of information that a website transfers to an individual’s computer hard drive for record keeping purposes. Cookies make using our Site easier by, among other things, saving your passwords and preferences for you. These cookies are restricted for use only on our Site, and do not transfer any personal information to any other party. Most browsers are initially set up to accept cookies. You can, however, reset your browser to refuse all cookies or indicate when a cookie is being sent. Please consult the technical information relevant to your browser for instructions. If you choose to disable your cookies setting or refuse to accept a cookie, some parts of the Site may not function properly or may be considerably slower.

Kajabi uses the following cookies on the Site:

Cookie	Name	Purpose
_kjb_session	Kajabi session cookie	Tracks your active admin session so you don't need to re-login
kjba	Kajabi affiliate token	Tracks which affiliate has referred an offer purchase
_abv	Admin bar hidden	Tracks whether the user wishes their admin previewing bar to be hidden

Malware/Spyware/Viruses: Neither the Company nor the Site knowingly permit the use of malware, spyware, viruses, and/or other similar types of software.

Privacy Policy  Effective Date: November 29, 2021  Welcome to The Imagination Station San Diego (IMS), which is owned and operated by Scripps Performing Arts Academy. We are committed to providing children with a learning environment where every activity is just as fun as it is educational and where you can feel confident that your children’s privacy is protected.  This Privacy Policy describes the ways in which Scripps Performing Arts Academy, and its subsidiaries (collectively, we, our, us, or the Company) collect, use, and disclose information about you and the children who use your Account through The Imagination Station, and any other websites, applications, and online services (Apps) that link to this policy (collectively, the Services), including Imagination Station for Schools, operated by our wholly owned subsidiary Scripps Performing Arts Academy.  (SPAA).  SPAA provides School Accounts (as defined below) for schools, school districts, licensed childcare facilities, or other licensed educational institutions or programs (each, an Educational Institution). Our Services are directed toward preschool- through second grade-aged children.  Please read this Privacy Policy closely. By using the Services, you agree to the handling of your information in accordance with this Privacy Policy. If you provide us with your information (directly or indirectly through our service providers) we treat your information according to this Privacy Policy. We will only use your Personal Information in accordance with this Privacy Policy. If we need to use your Personal Information for any other purpose, other than as disclosed herein, we will update this Privacy Policy, as explained under Section 12, Changes to Our Privacy Policy below.  Summary of Key Points  You should read this entire Privacy Policy and also our Terms & Conditions but here are some key points:  The Services are backed by our Child Safe guarantee. This means that Accounts will never include any pop-up ads or other advertisements directed to children. Imagination Station is also certified under kidSAFE’s FTC approved COPPA Safe Harbor program. Personal Information, or PI, is defined in this policy to mirror the text of the California Consumer Privacy Act (CCPA) and means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  We take your privacy very seriously, and we never monetize your Personal Information; we use it to enhance your experience with opportunities like special promotions and offers. During Imagination Station  registration, the only information we may ask you to provide about a child who will be using the Services is the child’s first name (or nickname), birth month and year.  Our Services do not support social or federated login. Other than in the places and for the purposes explicitly disclosed in this Privacy Policy, we do not knowingly collect any PI directly from Child Users under age 13. We do not ask for certain sensitive PI such as social security numbers, driver’s license numbers, or biometric data. However, paying subscribers are asked for payment information when they subscribe. Please see Section 3 (Information Collection) for more information about how we safeguard payment information. Because the security of your Personal Information is important to us, we only ask for PI where it serves a business purpose and try to limit the collection of PI to only what is necessary to accomplish those purposes. We also use commercially reasonable physical, technical, and administrative security measures designed to safeguard all information collected by the Services. Adult Users (as defined below) may contact us or their Educational Institution, when applicable, at any time as described in Section 13 (Contact Us) to request that we provide for their review, or delete from our records, any PI they have provided about Child Users associated with their Accounts, or to cease collecting PI from those Child Users. For information about when we automatically delete PI due to Account cancellation or inactivity, please see Section 10 (Location of Information Processing).  Additional Protections and Information for School Accounts

If you have access to the Services through a School Account, additional privacy protections apply because your Educational Institution may provide us with student personally identifiable information (Student Data) as defined by the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g) and its implementing regulations (34 CFR Part 99) (collectively, FERPA). The Educational Institution is responsible for obtaining parental consent and/or ensuring that an exception applies prior to transferring Student Data to the Company, which acts as a third-party vendor school official in this context. 

We will only access, collect, record, organize, use, or disclose (collectively, Process) Student Data collected through the Services as described in Imagination Station’s agreement(s) with the applicable Educational Institution and this Privacy Policy. Imagination Station will Process the data consistent with all applicable laws, including, but not limited to, FERPA.

We will delete, or if requested by the Educational Institution, transfer to the Educational Institution all Student Data within 90 days (or a shorter time frame if required by applicable law) following the termination of the IMS  agreement with the applicable Educational Institution. 

We may de-identify Student Data received in connection with providing the Services and use such data as described in this Privacy Policy. 

 

 

Table of Contents 

1.       Child Safe Guarantee 
2.       Types of Accounts, Services, and Users 
3.       Information Collection 
4.       How We Use Information 
5.       When We Disclose Information to Third Parties 
6.       How to Access, Change, or Delete Account Information 
7.       Account Cancellation and Reactivation; Data Deletion 
8. Child Safe Guarantee and COPPA Safe Harbor 
9.       California Privacy Rights 
10.       Links to Other Services 
11.     Location of Information Processing 
12.     Security
13.     Changes to Our Privacy Policy 
14.     Contact Us 

The Services are backed by our Child Safe Guarantee. This means that Accounts will never include any pop-up ads or other advertisements directed to children. In addition, There are no external links.

WHEN APPROVED-IMS is part of the kidSAFE Seal Program. This means that the product has been independently, reviewed, and certified by kidSAFE to meet certain standards of online safety and privacy, and is authorized to display the kidSAFE Seal under kidSAFE’s FTC approved COPPA Safe Harbor program. Under the kidSAFE program users can also report concerns or complaints directly to kidSAFE through this link: https://www.kidsafeseal.com/certifiedproducts.html

2. Types of Accounts, Services, and Users 

How we collect, use, and disclose information depends on the type of Account and the type of user. We currently offer the following types of Accounts through the Services: Family Accounts, Teacher Accounts, and Classroom-Linked Accounts (collectively, Consumer and Other Accounts), which are described in our Terms & Conditions. 

We also provide School Accounts, which are only for Educational Institutions. Consumer and Other Accounts and School Accounts are collectively referred to as Accounts, and the provisions of this policy apply to all Accounts. Any difference in how the Consumer and Other Accounts and School Accounts are treated is identified below. 

THEY DON’T HAVE SEPARATE ACCOUNTS-Users of the Services include Child Users (any child under age 18 who uses the learning portion of the Services) and Adult Users (including parents and legal guardians of Child Users, Gift Account purchasers, and teachers), collectively referred to as Users. 

3. Information Collection 

There are two general categories of information that we collect. 

1. Information Users Provide to Us As more fully set forth below, we and our third-party service providers collect information that Users provide when using the Services, including when Adult Users create an Account, sign up for Services, or contact us with a question, comment, and/or request. However, we will only use or disclose this information in accordance with this policy and applicable law. Please see Section 5 (When We Disclose Information to Third Parties) below for more information and how we limit disclosure of User information. 

Adult Users 

Adult Users are asked to provide certain Personal Information about themselves when registering for any Account, including first and last name, email address, and telephone number (which is optional). The other information provided at registration depends on the type of Account or Adult User. For example: 

Payment information is collected from Adult Users who purchase a Family Account, including those who purchase a Gift Account for others. For your security, we do not store your complete credit card number in our databases but retain only the first six digits and last four digits so that we can identify your Account and respond to your requests and questions. 

The email address of a parent or legal guardian is collected when the Adult User purchasing a Family Account, or if a teacher or community center administrator provides such addresses in order for parents or legal guardians to connect to the Teacher Account, create their own Family Account linked to the Teacher Account or School Account. 

The school or community center name and address(state and ZIP code only) are collected from Adult Users who register for a Teacher or School Account. Adult Users who register for a Family, Teacher, Classroom-Linked, or School Account are asked to provide the first name (or nickname) and may be asked for the birth month and year of Child Users who will be accessing the Services through their Accounts. 

In addition, Adult Users can provide us with information through separate password-protected sections (i.e., the Parent Section or Teacher Dashboard) of the Services. These sections, accessible via the Menu or Settings link on the Services, allow Adult Users to administer their Accounts, including when they provide testimonials, seek customer support, or submit comments or questions. 

If you submit any information relating to other people in connection with the Services, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy. 

 

1. Information We Collect from Users We and our third-party service providers collect Personal Information directly from Users of the Services in the form of the actions they take and activities they complete when using the Services. For example, from Adult Users, we may collect information about patterns of usage and order history, which activities a user commences and completes, when a user starts and stops an activity, and which areas of the Services the user frequents. 

We and our third-party service providers also use a variety of technologies, such as cookies (small text files that the Services save on your computer or mobile device), to automatically collect certain technical information from your computer or mobile device over time and across different websites, including when you use the Services, such as your browser type, operating system, device type, the page served, your IP address, the approximate geolocation of your computer or mobile device, and the websites you visited prior to visiting the Services. When you download and use one of our Apps, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number. 

We and our third-party service providers may use the information collected through these technical methods for a number of purposes, including delivering content, tracking and enhancing our Users’ experience on the Services, and delivering advertising to visitors to www.imaginationstationsandiego.com when they visit other websites and applications. For example, when you return to the Services after logging in, cookies help the Services recognize who you are without having to log back in. The information collected through these technical methods on the child-directed portions of the Services are used only to support the internal operations of the Services. We do not allow third-party advertising networks to collect information about Users who are logged in to their Accounts. 

More information about the use of cookies is set forth below. 

What Are Cookies? 

Cookies are small text files placed on your device to collect standard internet log information and visitor behavior information. The cookies may transmit information via your browser with a purpose of authenticating or identifying the computer (via, e.g., the IP address) or the User. Cookies may contain information such as registration data and User preferences. 

We use cookies to: 

1. automatically collect certain technical information from your computer or mobile device over time and across different websites, including when you use the Services, such as your browser type, operating system, device type, the page served, your IP address and your geolocation. When you download and use our App(s), we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number; 
2. collect and store information about your location to provide you with educational experiences or email updates that are tailored for your region. The location information we have access to may include (1) your postal code, if you provide one to us; and (2) the approximate geographic region your computer or mobile device is located in, as determined from your IP address. However, we do not collect your street name and the name of your city/town. You may be able to change the settings on your computer or mobile device to prevent it from providing us with such IP information. We also have access to your school or classroom location if you (as a teacher) provide it to us; 

iii. we may collect information from your mobile device if you have downloaded our App(s). This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your IP address, geographic location, how you use the App(s), and information about the type of device you use. In addition, in the event our App(s) crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our App(s). This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual. In addition, if you choose to turn on your Bluetooth, wi-fi or other geolocation functionality when you use our App(s), we may collect and use your geolocation information; and 

1. we may also use third-party advertising networks to collect cookie information about Adult Users’ visits to the non-child-directed portions of the Services and to (1) deliver interest-based advertising to those Adult Users, including ABCmouse-branded advertising, when those Adult Users visit third-party websites; and (2) provide us with statistics about the effectiveness of our advertising on third- party websites. These third-party advertising networks may use this cookie information in accordance with their own privacy policies. Please refer to Section 5 (When We Disclose Information to Third Parties) above for more information about what Personal Data is transferred to our third-party advertising measurement partner. 

When a server receives a request from a device which stores a cookie from a website, the server is able to use the information stored in the cookie in combination with the information stored on the server to allow the website to respond to you as an individual and to tailor their operations to your needs, likes, and dislikes by gathering and remembering information about your preferences. A cookie cannot collect information from your computer and cannot carry any viral or other damaging files. 

Types of Cookies 

We use the following cookies: 

Essential Cookies 

These cookies are essential to provide you with services available through Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Services and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services. 

Functionality Cookies 

These cookies allow us to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details, and remembering the changes you make to other parts of Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Services. 

Analytics and Performance Cookies 

These cookies are used to collect information about traffic to our Services and how users use the Services. The information gathered does not identify any individual visitor. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information, and to monitor the level of activity on our Services. 

Social Media Cookies 

These cookies are used when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter, or Google+. The social network will record that you have done this. 

Except as otherwise provided in this policy, such as when a California resident has opted-out of our sharing Personal Information for valuable consideration, by continuing to use our Services, you are accepting our use of these cookies that make advertising and communications more relevant to you and your interests and further help us to improve our Services. 

 

We and our third-party service providers may use the information collected through these technical methods for a number of purposes, including delivering content, tracking and enhancing our Users’ experience on the Services, and delivering advertising to visitors of www.imaginationstationsandiego.com when they visit other websites and applications. For example, when you return to the Services after logging in, cookies help the Services recognize who you are without having to log back in. For more information, see (What are Cookies) above. The information collected through these technical methods on the child-directed portions of the Services are used only to support the internal operations of the Services. We do not allow third-party advertising networks to collect information about Users who are logged into their Accounts. 

If you do not want the Services to collect information through the use of cookies, you can set your web browser to reject cookies from 

the Services. Each browser is different, so you should check your browser’s Help menu to learn how to change your cookie preferences. However, please note that if you reject or block cookies from the Services, the Services may not function as intended. For example, you will not be able to remain logged into your Account, and therefore you would have to log in during each page transition. 

 

4. How We Use Information 

We will never monetize the Personal Information of any User of the Services by providing it to a third party in exchange for money, except as described in this policy in the context of a sale of the Company. 

We and our third-party service providers may use the information collected from Users as follows: Adult User Information Information collected from Adult Users may be used: 

To permit you to register and use the Services, including, for example, to send you communications about Child User progress or your Account, or to allow you to provide Feedback through the Parent Section. For security purposes, the Parent Section is password protected. For certain Consumer and Other Accounts, to complete and fulfill your purchase, such as to process your payments, communicate with you regarding your purchase, and provide you with related customer service. 

To respond to your inquiries and fulfill your requests, retrieve your password, or provide technical support. For Consumer and Other Accounts to provide marketing communications that we believe may be of interest to you. While it is never our intention to send any marketing messages to children, if you believe a Child User has received such a marketing communication, please contact us as described in Section 13 (Contact Us) below. You can always choose to stop receiving these marketing messages by simply following the instructions contained in the message or, if the communication is by phone, informing the caller of your desire not to receive further phone communications. For all Accounts, you may not opt out of receiving administrative messages from us regarding your Account, such as password reset emails, customer support messages, and progress reports for School Accounts. 

To deliver IMS advertising to you based on your visits to the non-child-directed portions of the Services (such as www.imaginationstationsandiego.com), for example when you visit third-party websites and applications or via postal mail. We will never use information collected in the child-directed portions of the Services for targeted advertising purposes. We do not currently respond to web browser “do not track” signals due to lack of standardization regarding how that signal should be interpreted; however, you may opt out of receiving online interest-based advertising from our interest-based advertising providers by visiting www.aboutads.info/choices. For more information about web browser “do not track” signals, visit www.allaboutdnt.org. California residents have additional rights under the CCPA. For more information please see Section 8 below. 

To measure the effectiveness of our advertising to adults.

We don’t do this yet- but for future can we leave in? Child User Information Information collected from Child Users may be used: 

To measure a Child User’s performance in activities and to adapt a Child User’s learning experience to the Child User’s learning needs. 

To analyze, provide progress reports on, or provide an assessment of a Child User’s performance to the Adult User on the Account. 

Both Adult and Child User Information Information collected from both Adult and Child Users may be used: 

To allow us to assess and improve the Services, its educational content, and other services we provide, for example, to improve our content and user experience; to research, evaluate, and improve the Services’ educational efficacy; and to inform our understanding of the Services’ user base. 

To customize, adapt, and personalize Users’ viewing and content-consumption experience, for example, by measuring a Child User’s performance in activities and adapting the Child User’s learning path to his or her learning needs. 

To maintain and analyze the functioning of the Services. 

As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to detect violations of and enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates, including the security of the Services; (f) to protect our rights, privacy, safety, or property, or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain (collectively, (a)-(g) are Other Uses and Disclosures). 

5. When We Disclose Information to Third Parties 

Information collected from both Adult and Child Users will not be disclosed except as follows: 

To third parties who perform certain services for us, such as process credit cards or conduct or evaluate research (such as on the educational impact of the Services), provided that the service providers agree to keep the information confidential and to use it only for purposes that are permitted by this Privacy Policy. By continuing to use the Services, you are intentionally directing us to transmit of the information submitted to us by Adult User to our affiliates and business partners for business purposes, such as executing transactions and preventing fraud. 

Where we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. If required or permitted to do so under the law, and if deemed necessary or warranted, we may provide notice to Users prior to the disclosure.

Subject to confidentiality agreements, the terms of this Privacy Policy, and applicable law, information may be disclosed to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, transfer, or license all or a portion of our assets in bankruptcy or otherwise. This means that if some or all of our assets are acquired or otherwise transferred or licensed, including in bankruptcy, that such acquirer shall be subject to the same commitments stated under this Privacy Policy. 

In addition, with respect to Consumer and Other Accounts, we may use third-party advertising networks and other affiliates in association with cookies for Adult Users’ visits to the non-child-directed portions of the Services and to (1) deliver interest-based advertising to those Adult Users, including IMS-branded advertising, when those Adult Users visit third- party websites; and (2) provide us with statistics about the effectiveness of our advertising on third-party websites. These third-party advertising networks may use this cookie information in accordance with their own privacy policies. 

We do not disclose the Personal Information of any Child User to third parties for any marketing or promotional purposes. This also means that we do not share the Personal Information of children under the age of 16 for valuable consideration. 

We also may disclose de-identified and/or aggregated User information for any other purpose as permissible by applicable law—for example, the distribution of de-identified user records to outside researchers or the distribution of reports containing aggregate user demographic and traffic patterns—provided that no individual Adult User or Child User or any specific end-user device can be readily identified. 

6. How to Access, Change, or Delete Account Information 

Consumer and Other Accounts: An Adult User can review or change the information they provided when they registered for the Services, including by adding or removing Child Users to or from the Account, by updating information through the Parent Section of the Services. In addition, Adult Users may contact us at any time as described in Section 13 (Contact Us) below to request that we provide for their review, or delete from our records, any PI they have provided about Child Users associated with their Accounts, or to cease collecting PI from those Child Users, as applicable. Please keep in mind that a request to delete PI may lead to cancellation of your Account or the inability to use certain Services, and if a Teacher Account or Community Center Account is linked to a Family Account, a request to delete PI in one of the Accounts may be reflected in your other Account. 

When we change or delete any PI at your request, we will make good faith efforts to make the changes in our then-active databases as soon as reasonably practicable, generally within 24–48 hours. Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules. Please note that information may remain in backup or archive records, and we may retain certain data relevant to preventing fraud or future abuse or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable or de-identified data, Account recovery, or if required by law. All retained data will continue to be subject to the Privacy Policy in effect at that time. 

School Accounts: If you are using the Services through a School Account that is integrated with a school student information system (SIS), unless otherwise required by law, any request to access or make changes to or delete PI including Student Data must be made by the Educational Institution within the SIS. Once the changes are made within the SIS, the changes will automatically appear within the School Account. 

If you are using the Services through a School Account and the Educational Institution is not integrating its SIS with the Services, unless otherwise required by law, any request to access, make changes to, or delete PI including Student Data must be made by the Educational Institution's designated administrator for the School Account. The administrators will be provided access to the School Account User Profile pages in order to update, correct, or delete the information contained therein. 

7. Account Cancellation and Reactivation; Data Deletion 

At any time, Adult Users, with the exception of School Accounts, may cancel their Accounts through the Settings section of the Services or by email as referred to below in Section 13.

For Family Accounts that have been canceled, if the Account remains inactive for 24 months, we will delete all PI in our active databases associated with the Account (Account Information), unless otherwise stated in this Privacy Policy. The 24 months is provided so that you have the ability, following cancellation of a Family Account or inactivity, to reactivate your Account and potentially recover previous information and resume where the Child User left off. However, we provide no guarantee, and shall have no liability or obligation to ensure that all Account Information and Services-related progress will be available or accessible or all learning or personalization features will be able to be recovered or resumed. If a User requests that PI be deleted prior to the end of the 24-month period of inactivity, we will take commercially reasonable steps to satisfy that request; provided, however, that if the User is a California resident the provisions of Section 8 below shall be followed. 

For Teacher Accounts, if you cancel your Account, we will delete all Account Information 48 hours after the cancellation, unless a Child User’s parent or legal guardian has linked to the Account, in which case we will delete that Child User’s Account Information as described in the previous paragraph. Please note that canceling an entire Teacher Account will result in the loss of access to curriculum, activities and progress data for every User on that Account. If a Teacher Account is not canceled, we will delete all Account Information 24 months after the last activity on the Account. 

For School Accounts, Adult Users should contact their respective Educational Institution for any questions regarding Account cancellation and data deletion. If an Educational Institutional terminates its agreement with us, we will delete, or if requested by the Educational Institution, transfer to the Educational Institution all Student Data within 90 days (or a shorter time frame if required by applicable law) following the termination of the agreement with the applicable Educational Institution. 

Upon Account cancellation, de-identified Adult and Child User information may nonetheless persist internally in our archive files or similar databases, and may still be used, on a de-identified basis, for our internal support, administrative, and record-keeping purposes including, but not limited to, allowing us to improve the Services and other services we provide through research, evaluation, and analytics as permissible by applicable law. 

Please note that following a request to delete information or your Account under Sections 6 or 7 of this Privacy Policy, information including PI may remain in backup or archive records, and we may retain certain data if required by law, relevant to preventing fraud or future abuse, or for legitimate business purposes, such as account recovery and customer support, and all subject to our internal records retention periods. All retained data will continue to be subject to the Privacy Policy in effect at that time and applicable law. 

8. California Privacy Rights 

Effective January 1, 2020, the CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. In this section “you” or “your” refers to California residents. Under the new law we are required to disclose the categories of sources from whom we collect personal information, and the third parties with whom we share it, which we have explained above. We are also required to communicate information about rights you have under California law, such as: 

• Right to access Personal Information. You may be entitled to receive the specific pieces of your Personal Information we hold. 
• Right to data portability. You may be entitled to receive a copy of your electronic Personal Information in a readily-usable format. 
• Right to disclosure. You may be entitled to receive information regarding the categories of Personal Information we collected, the sources from which we collected Personal Information, the purposes for which we collected and shared Personal Information, the categories of Personal Information that we sold and the categories of third parties to whom the Personal Information was sold, and the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding your request. 
• Right to deletion. You may be entitled to request that we delete the Personal Information that we have collected from you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws. Please note, however, that we may need or be required to keep such information, such as for our legitimate business purposes or to comply with applicable law. 

Right to opt-out of certain sharing with third parties. You may be entitled to direct us to stop disclosing your Personal Information to third parties for monetary or other valuable consideration. You can exercise such right to opt-out Do Not Sell My Personal Information. 

As stated in the Summary of Key Points above, we will never monetize the Personal Information of any User of the Services by providing it to a third party in exchange for money. The CCPA has a broader definition of the term “sell” which includes disclosing Personal Information to any third party for valuable consideration. When we work with our advertising partners we are disclosing certain information such as cookies for their services, which are of value to us. You may be entitled to direct us to stop disclosing your Personal Information to third parties for monetary or other valuable consideration. You can exercise such right to opt-out Do Not Sell My Personal Information. 

Information we Collect and Share 

In addition, we are required to provide you certain information about the business and commercial purposes for which we collect and share your personal information. 

Business and Commercial Purposes for which we use Personal Information: We use and disclose the information we collect from each of the Categories of Personal Information listed below for the business purposes described in this policy, including but not limited to: process payments, conduct research, detect security incidents and prevent fraud, debug and repair errors, maintain your account, provide customer service, enabling and affecting commercial transactions and advancing our commercial and economic interests, such as delivering interest-based advertising to Adult Users and analyzing the effectiveness of our advertisements and other activities to improve our service, show advertising, market our services, and understand how users interact with our services. 

Categories of Personal Information we collect: In the preceding 12 months, we have also disclosed the following categories of personal information for one or more business purposes: identifiers, commercial information, internet or electronic network activity information, geolocation data, and inferences we draw or derive about users. 

Categories of Sources from which we collect Personal Information: We collect Personal Information from each of the aforementioned Categories of Personal Information from You, your child and, if applicable, your child’s teacher or school. 

Categories of Third Parties with whom we share Personal Information: We share Personal Information from each of the aforementioned Categories of Personal Information with the categories of Third Parties described in Section 5, including as part of a sale or for commercial or business purposes. 

Categories of Personal Information we share with Third Parties: We share, and have shared during the past 12 months, the following categories of Personal Information with Third Parties, including as part of a sale or for commercial or business purposes: personal identifiers such as name and credit card number; commercial information, such as services subscribed to, obtained or considered; and information regarding your interaction with or use of our products and services, including the Services. We do not sell the Personal Information of children under 16 years of age. 

Exercising Access, Disclosure, Data Portability, and Deletion Rights 

To exercise the access, disclosure, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either contacting us as set forth in in Section 13 (Contact Us) below, or by visiting: 

•  Privacy Portal

Only you or a person registered with the California Secretary of State that you authorize 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 Child. 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: 

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. We will verify your request by asking you to provide information related to your interactions with us. We will not otherwise ask for Personal Information from you that we would not otherwise maintain as part of us providing our Services. 
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 

Non-Discrimination

We fully support your privacy rights and will not discriminate against you for exercising any of your CCPA rights. 

Offering Financial Incentives: 

We provide price discounts, coupons, services and other perks for members of our mailing list and other consumers who have opted to receive certain communications from us (collectively “programs”). Through these offerings, consumers provide us with some personal information (e.g., names, emails, and phone numbers) when they opt-in to our programs. There is no obligation to opt-in and consumers may opt-out at any time. The details of each program are contained in the program offering. We offer these programs, among other things, to enhance our relationship with you so you can enjoy more of our products/services at a lower price. We invest heavily in our marketing and brands, in part, so we can provide programs to our customers. The value to our business of any individual consumer’s personal information is dependent on a number of factors, including, for example, whether and to what extent you take advantage of any offerings, whether and to what extent you opt out of any offerings, and whether we are able to enhance the data through our efforts described below. Our ability to create any value from the programs is heavily based on our ability to leverage the data we collect. We do not calculate the value of consumer data in our accounting statements. We make this good faith estimate for California residents. To the extent we create overall value from our programs to our business that could be directly or reasonably related to the value of customer data, the method for calculating same would include: the costs associated with (1) our intellectual property; (2) enhancing customer data by our skilled marketing team’s efforts; (3) leveraging our significant investments in understanding you as our existing and future customers; (4) all other costs reasonably related to the programs; and (5) for each program, and in the aggregate, whether the sales generated by the program(s) exceed the cost to us of offering them. 

You can opt-in to, or opt-out of, our programs at any time through the same means they are offered, or by contacting us at the contact information provided in Section 13, below. 

9. Links to Other Services 

We do not have links to other services

10. Location of Information Processing  

The Services are controlled and operated by us from the United States. Your information may be stored and processed in any country where we have facilities or in which we engage service providers, including the United States, which may have data protection laws that are different from those of your country. In addition, your information may be subject to access requests from governments, courts, or law enforcement officials in countries where it may be processed, under the laws of those countries.  11. Security  The security of your personal information is important to us, and we employ physical, technical, and administrative security measures designed to safeguard the information collected by the Services. We use industry standard SSL (secure socket layer technology) encryption to transfer PI. Other security safeguards include, but are not limited to, data encryption, firewalls, and physical access controls to buildings and files. We also conduct periodic audits of our security (no less than annually) to apply best practices and reasonable industry standards. However, no data transmission over the Internet can be guaranteed to be completely secure. If there is a breach of our security, we will notify you where required by law or deemed necessary and appropriate under the circumstances.  Account holders create a password in the registration process. You can help protect against unauthorized access to your Account and PI by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account. At registration, we assign a Member ID (your email address provided) to each Account and use those Member IDs to authenticate logins, allow access to the subscription content, and monitor compliance. The Member ID is also used to authenticate users when requesting technical support. Access to information is limited (through user/password credentials) to those employees who require it to perform their job functions.  School Accounts  We are committed to maintaining the security and confidentiality of your and your children’s information, including, but not limited to, any Student Data, which we receive through School Accounts. Some of the precautions we take include (a) limiting employee access to your and your children’s PI to only those employees with a need to such access to fulfill their job responsibilities; (b) conducting background checks on our employees and, specifically, upon all employees that may have access to Student Data; (c) requiring employees to sign confidentiality agreements upon hiring; (d) conducting regular employee privacy and data security training and education; and (e) protecting PI with commercially reasonable technical, contractual, administrative, and physical security safeguards.  Please be aware, however, that no information system can be guaranteed to be 100 percent secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Services over networks that we do not control, including the internet and wireless networks. If you have reason to believe that your interaction with us is not secure, please contact us as described in Section 13 (Contact Us) below.  12. Changes to Our Privacy Policy  We constantly try to provide the best services, and accordingly our Privacy Policy will change from time to time. If we update this Privacy Policy, we will notify you by posting the revised Privacy Policy on the Services, and for certain revisions that materially expand the ways in which we use or share the information previously collected from you through the Services, either display an alert next to the Privacy Policy, display an alert upon login to the Services, or directly communicate with you (e.g., via the email address associated with your Account).  If you have a School Account, any modifications to this Privacy Policy will only apply to you and your Child User in accordance with the Imagination Station agreement with your Educational Institution.  13. Contact Us  Scripps Performing Arts Academy. is in the United States of America. Scripps Performing Arts Academy. is the operator of all the Services. You may contact us below if you have any questions, complaints, or other issues related to this Privacy Policy and issues related to your or a Child User’s information for which you are responsible:  For all Accounts  Mailing address: Scripps Performing Arts Academy 9920 Scripps Lake Dr. Suite #105 San Diego, CA 92131 Telephone Number:  858-586-7834 Email address: [email protected]

© 2021 Scripps Performing Arts Academy