KUMON NORTH AMERICA, INC.
PRIVACY STATEMENT
Kumon North America, Inc. (as used in this Privacy Statement, “Kumon”, “us” or “we”) respects and shares your concern about your privacy and the privacy of your children. We are committed to protecting your Personal Information (as defined below). You have a right to know what information we collect and how we may use it. The following Privacy Statement describes the information we collect and how we use this information. By using our websites and/or by enrolling your child at a Kumon Center, you consent to the practices described in this herein. If you do not agree and consent, please discontinue use of our websites and Kumon Center services.
What Type of Information Do We Collect?
Most of the personal information we receive has been provided to us by you, typically when you visit one of our websites or enroll your child at a Kumon Center (whether in person or online through an e-enrollment form). As described in this Privacy Statement, “Personal Information” may include information collected from you, through various means (as described below), and may include information such as your name, phone number, address (including street address, city, state, zip code, and/or country), email address, age, gender, birth date, educational history, family contact information, and similar items. This information may be collected, in part, through our retention of a copy of your government-issued ID card or similar information. If you pay fees or tuition at a Kumon Center, Personal Information may also include credit card information.
Enrollment and Study at a Kumon Center
Most Kumon Centers are independently owned and operated, and the owners of these Centers are our franchisees (referred to as “Instructors”). When you enroll your child at a Kumon Center, the Instructor will have you fill out and sign an enrollment form, asking for your name, address, telephone number, e-mail address and other information necessary to serve your child’s education needs. Similar information will be collected regarding your child. This information is subsequently transmitted to us.
During your child’s enrollment at a Kumon Center, we will collect information about your child’s study progress from our Instructor and through visits to Kumon Centers. This information helps us support your Instructor with the operation of the Kumon Center, will serve to develop and improve Kumon instructional methods and learning materials, and for other purposes listed below in “How We Use Personal Information”. For these purposes and with your prior consent, we may also record videos of your child studying.
Kumon.com, KumonFranchise.com
If you request information through our website or request that we schedule a free assessment for your child at a Kumon Center, you will be prompted to provide your name, email address, physical address and telephone number. We collect and store this information to allow us to communicate with you and send you the information you have requested; or to schedule a free assessment. We also may use this information to periodically send you, by email or text, various marketing information.
Kumon also collects from visitors to our websites non-personally identifying information of the sort that web browsers and servers typically make available, such as browser type, language preference, date and time of each visitor request. We cannot use this information to identify, distinguish or trace you or your device, even if combined with other identifying formations. This data is used in an anonymous way, sometimes aggregated with other anonymous data about other users, for us to analyze the experience of visiting Kumon websites (see “Cookies & Other Tracking Mechanisms,” below).
In certain cases (including for the redemption of gift cards), we may also require you to complete a knowledge-based authentication (e.g., multiple choice question) or contact us through alternative means, such as via text message, email or phone.
Parents Portal
Prior registration and establishment of a password is required to access Parents Portal (allowing parental access the progress and study program for their children) website. To allow access to individual accounts on this website, at the time an account is created Kumon collects personally identifying information such as name, street address and email addresses for users. Information collected for Parents Portal will permit you to access your child’s study program and work progress.
Cookies & Other Tracking Mechanisms
A “cookie” is a string of information that a website stores on a visitor’s computer that the visitor’s browser provides to the website each time a visitor returns. Kumon uses cookies to identify and track return visitors and their use of our websites. Visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Kumon’s websites. By continuing to navigate our websites without changing your cookie setting, you are acknowledging and agreeing to Kumon’s use of cookies. Please note that if you choose to disable cookies, some features of our websites may not be available to you.
Our systems do not recognize, and we do not respond to, “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies). Access to and use of any linked websites are not governed by this Privacy Statement, and we are not responsible for the information practices of these third parties. You also may opt- out of targeted advertising by following the instructions in the third-party advertiser’s privacy policies.
Third-Party Analytics
We use automated devices and applications (such as Google Analytics) to evaluate usage of our website. These tools assist us to improve our websites and the user experience. We also use Remarketing within Google Analytics to analyze user behaviors on our websites and help us identify placements for our remarketing campaigns.
We may also use third parties for Internet-based targeted advertising, which may allow users of our websites to see customized advertisements based on your visits to our websites and our predictions about your interests. In some cases, this information may also be used to advertise to groups of people with characteristics similar to yours. To change your preferences with respect to certain online advertising or to obtain more information about advertising networks and online behavioral advertising, visit the National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your preferences or settings within an individual browser will not necessarily carry over to other browsers or advertising networks. As a result, please note that you may still see advertisements from us after you opt-out of targeted advertising, though these advertisements are not specifically targeted to you.
How We Use Personal Information.
Kumon does not request Personal Information via e-mail or telemarketing. If someone contacts you in either of these manners and requests Personal Information on behalf of Kumon, do not respond. Delete, disregard or hang up. These requests are not from us.
We may use the Personal Information we collect for purposes allowed by applicable laws, including the following business or commercial purposes:
- Fulfilling contractual obligations of Kumon and its franchisees’ Instructors to provide educational enrichment in The Kumon Method to your child after enrollment at a Kumon Center;
- Our legitimate business interests, including, without limitation, our and our franchisees’ ability to provide effective and efficient educational enrichment to Kumon Method participants;
- Complying with a legal obligation or court order or to exercise or defend a legal claim;
- Developing and improving Kumon instructional methods and learning materials in the U.S. and around the world;
- Offering training of our employees and our Instructors in the U.S. and around the world;
- Verifying your identity when you return to one of our websites;
- Improving the user experience on the websites and effectuating marketing campaigns;
- Optimizing paid media campaigns to improve advertisement targeting efficiency and ROI;
- Communicating with you via email, postal mail, phone, and other means;
- Protecting against security threats, identify theft and prevention fraud or other unlawful activity;
- Complying with and enforcing relevant standards, contractual obligations and our policies; and/or
- Responding to your inquiries.
We may combine the information we collect from you with information that we collect from other sources. We may use and disclose non-personal, non-individualized statistics or demographics information in the aggregate, without restriction.
Information We Share.
Kumon discloses Personal Information to certain of its employees, contractors, Instructors, franchisees, corporate parent, subsidiaries, and affiliates (collectively, the “Related Parties”) that: (i) have a need to know such information in order for Kumon to provide and improve educational enrichment services to your child and/or for the purposes listed in “How We Use Personal Information”; and (ii) have agreed not to disclose any Personal Information to others. Information is disclosed to Related Parties for business purposes only. When we disclose Personal Information to a Related Party for business purposes, we enter a contract that both describes the purpose of sharing the Personal Information, and also requires the Required Party data recipient to keep the Personal Information confidential and not use the Personal Information for any purpose outside of performing its obligations under the contract with us.
Kumon may share Personal Information with third parties for commercial purposes, including to host our services, facilitate cross-contextual behavioral advertising, suppression advertising, and/or targeted advertising. When this happens, your Personal Information is encrypted, though it may still be attributable to you. We may also share anonymized Personal Information with third parties after it has been altered, combined with other information, or otherwise processed, such that it cannot be reasonable used to identify an individual person. Notwithstanding any of these uses, we do not sell or rent any Personal Information to third parties in exchange for monetary compensation.
In the prior 12 months, we have disclosed Personal Information to third parties that fall into the following categories, for commercial or business purposes set forth in this Privacy Statement:
- Personal identifiers such as your name, alias, postal address, online address, IP address, email, SSN, driver’s license, telephone number;
- Protected classifications such as race, religion, sexual orientation, age, and gender identity;
- Customer records and commercial information including purchase history, consumption history, and tendencies;
- Online Activity including network information, IP address, browsing and/or search history, and analytics regarding your interactions with us;
- Geolocation data
- Educational information that is not otherwise publicly available personally identified information; and
- Inferences drawn from your Personal Information, including your preferences and predispositions based on purchase and interaction history.
We will not capture and subsequently disclose to any third parties any audio and/or visual recordings involving your Personal Information without your prior consent.
In the prior 12 months, we have disclosed each of the foregoing categories of Personal Information to the following categories of third parties:
- Our Related Parties;
- Our business partners who assist us to effectuate marketing campaigns and host our online services (Curious Jane, Salesforce);
- Our advertising networks and partners (Google Ads, Google Analytics, and Meta)
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Social networking vendors (Facebook, Instagram, and LinkedIn);
Any other third party to whom you explicitly authorize us to disclose your Personal Information, in connection with the services we provide to you
We are a U.S.-based company. We reserve the right to process, transfer or maintain your Personal Information on servers or databases located within the U.S. and elsewhere, including any state, province, country or other governmental jurisdiction. Some of our Related Parties may be located outside the United States, particularly our Related Party and corporate parent, Kumon Institute of Education, Co., Ltd., (a Japanese-based corporation). By enrolling your child at a Kumon Center or by using our websites, you consent to the transfer of Personal Information.
While this Privacy Statement does not apply to data processed solely by our franchisees on their own behalf in connection with Kumon Centers, websites, or applications they own and independently operate, we do share the same categories of information (noted above) with Instructors to ensure you have a seamless experience. For instance, we share information with Instructors if you register for an appointment through our Kumon website before visiting a franchised Kumon Center.
Where appropriate, we will limit (or expand) the sharing of your information in accordance with the choices you have elected and provided to us, and with applicable law. Other than as described in this paragraph, Kumon will only disclose actual or potentially personally identifying information to third parties in response to a subpoena, court order or other valid governmental request.
How We Protect Personal Information
We maintain administrative, technical and physical safeguards designed to protect the Personal Information you provide to us against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. This includes our encryption of any data we transmit to third parties as described in this Privacy Statement. We also maintain commensurate safeguards to protect the sensitive nature of Personal Information of children. However, while we exercise what we believe to be appropriate standards and safeguards, no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security and will not be responsible for any accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use of any Personal Information you have given to us.
Retention of Personal Information.
Except as otherwise permitted or required by applicable laws or regulations, we retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it, as needed to satisfy any legal obligations, or when required to resolve any disputes. To determine the retention period for Personal Information, we consider applicable legal requirements, the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, and whether we can achieve those purposes through other means.
Accessing and Updating Your information.
At the time of enrollment, you will receive a copy of your child’s enrollment form containing the Personal Information you have given to the Kumon Instructor. This information will be transmitted to us by the Instructor. You can update or edit Personal Information you have entered on your child’s enrollment form by updating this information with your child’s Kumon Instructor at the Kumon Center where he or she has enrolled.
Children’s Privacy Protection.
We understand the importance of protecting children’s privacy in the interactive online world. We never intentionally collect or maintain any Personal Information about anyone under the age of 13, other than as needed to enroll children in a Kumon Center or to obtain appropriate information to plan and assess your child’s study at a Kumon Center, without appropriate parental consent. If a parent or legal guardian learns that their child provided us with Personal Information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such Personal Information or otherwise treat it in accordance with COPPA and other applicable laws and regulations. In any event, we will not retain your child’s Personal Information longer than reasonably necessary to fulfill the specific purpose(s) for which it was collected (including providing services to your child).
We intend to use your child’s Personal Information in accordance with the other terms of this Privacy Statement. Specifically, this means sharing such Personal Information with third parties for specific commercial purposes, which include targeted advertising. Please note that you can consent to the collection and use of your child’s Personal Information by us to provide services to your child, without consenting to its disclosure to third parties for non-necessary purposes under applicable law. To opt out of the sharing of your child’s Personal Information with third parties, please contact us using one of the methods below.
Opt-Out Right.
From time-to-time we may send you by means of e-mail, postal mail, or text message, commercial messages we believe may be of interest to you, such as marketing campaigns or the availability for purchase of a Kumon franchise. If you do not wish to receive marketing or other commercial messages from us, simply follow the unsubscribe instructions contained in the message you receive from us, or contact the Kumon Privacy Statement Coordinator at 1-800-966-6284 or [email protected]. You can also opt-out of all communications from us by contacting us as specified in the “How To Contact Us” section of this Privacy Statement. We may ask you to provide more information to help confirm your identity before your request can be processed. You are not required to register for an account or otherwise provide a password to opt out of communications from us or exercise any of your other rights with regard to your Personal Information. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Kumon will inform you of the implications of such withdrawal, and depending on the scope of the withdrawal, we may no longer be able to provide you with services.
Please note that we may occasionally contact you for administrative purposes (including, without limitation, billing) even if you unsubscribe from our email list.
Right of Access/Right of Deletion.
You have the right to receive, in a structured, commonly used and machine-readable format, the Personal Information you have provided to us or to the Kumon Instructor, about you or your child. You have the right to have the information transmitted to another company, where it is technically feasible.
With certain exceptions, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your Personal Information and we will apply your preference going forward. This will not affect the lawfulness of our use of your information based on your consent before it was withdrawn.
To exercise your rights, please contact us in the manner indicated in the “How To Contact Us” section of this Privacy Statement.
Notice to California Residents.
To exercise your rights, please contact us in the manner indicated in the “How To Contact Us” section of this Privacy Statement.
California residents have the following rights under the California Consumer Privacy Act (“CCPA”), the California Privacy Rights Act (“CPRA”), and related laws:
- A right to access data affecting Personal Information collected;
- A right of correction or deletion of Personal Information;
- A right to know (and request disclosure) if Personal Information is collected; and
- A right to opt-out of the sale or sharing of Personal information for commercial purposes.
To exercise a right afforded by CCPA, California residents may contact us as specified in the “How To Contact Us” section of this Privacy Statement. We will exercise due diligence in responding to any request within 45 days of receipt. If we require more time, we will inform you of the reason and extension time period (up to 90 days). The response we provide will also explain any reasons we cannot comply with a request, if applicable. If you are not happy with our response to your privacy request, you can ask us to reconsider our decision by responding to any communication you have received regarding your request.
We will not discriminate against you if you exercise any of the rights under CCPA. For instance, we will not deny your child’s enrollment in a Kumon Center, charge different prices, or change the level of the quality of goods or service should you decide to exercise those rights.
You may authorize an agent to make CCPA-related requests on your behalf. To fulfill requests made by authorized agents, you must provide us with enough information such that we can verify the authority of the agent.
If you are a registered user of Kumon’s services under the age of 18, and we have actual knowledge of your age, then under California law, you may request and obtain removal of certain content or information you have posted on our services. To do so, please contact us in the manner indicated in the “How To Contact Us” section of this Privacy Statement. Please note that removal does not ensure complete or comprehensive removal of the content. For example, removal may not be possible or permitted if another provision of law requires the content to be maintained, if it was posted or reposted by others, or if we paid compensation to you in exchange for the posting.
Notice to Residents of Additional States.
If you are a consumer who resides in the states in which state-level privacy law has been enacted (e.g., Colorado, Virginia, etc.), other than California, you may have the following rights (in each case under the conditions and to the extent set forth under applicable law):
- A right to access data affecting Personal Information collected;
- A right of correction or deletion of Personal Information;
- A right to know (and request disclosure) if Personal Information is collected;
- A right to opt-out of the sale or sharing of Personal information for commercial purposes;
- A right to opt-out of targeted advertising; and
- A right to appeal any action we make with regard to your privacy rights.
To exercise any of the above rights, you may contact us as specified in the “How To Contact Us” section of this Privacy Statement. We will exercise due diligence in responding to any request within 45 days of receipt. If we require more time, we will inform you of the reason and extension time period. Please note that, depending on the nature of your request, you may be asked to provide information to verify your identity before your request can be processed. We will confirm receipt of your request and respond to your request as soon as we reasonably can and no later than legally required. We use commercially reasonable efforts to authenticate the identity of the consumer submitting a request.
If you choose to exercise any of the privacy rights described above, you will not receive discriminatory treatment from us.
Privacy Statement Changes.
We will update this Privacy Statement as laws and our practices change. We will indicate the date of the last update by changing the “Effective Date” information at the top of this Privacy Statement. Please check back often to ensure you are aware of any changes to this Privacy Statement. Your use of Kumon’s services after any update to this Privacy Statement will constitute your acceptance of the changes.
How To Contact Us.
If you have any questions about Kumon’s privacy practices or to exercise any of your rights with regard to your Personal Information, contact our Privacy Coordinator in either of the following manners:
Kumon Privacy Statement Coordinator at:
1-800-966-6284
or
[email protected]
Please note: Before we can fulfill your request, we must be able to verify your identity. If a request is made by a child, we must be able to verify your status as a consenting parent or guardian of such child, prior to fulfilling the request. If we cannot verify your identity, we may not be able to fulfill your request.
