Washington and Nevada Consumer Health Data Privacy Policy

Effective Date: July 1, 2024

This Consumer Health Data Privacy Policy (the “Policy”) describes how Primrose School Franchising Company LLC (“Primrose,” “we,” “us,” or “our”) Processes Consumer Health Data under Washington and Nevada law (the “CHD Laws”). In the event of a conflict between any other policy, statement, or notice and this Policy, this Policy will prevail as to Consumer Health Data Collected under the CHD Laws. Capitalized terms that are not otherwise defined in this Policy shall be defined as they are in the CHD Laws.

Consumer Health Data Collected

“Consumer Health Data” means Personal Information that is linked or reasonably linkable to a Consumer and that identifies the Consumer’s past, present, or future physical or mental health status. Consumer Health Data does not include Publicly Available Information or Deidentified Data, or Personal Information collected when an individual is acting in an employment context.

We Collect the following categories of Consumer Health Data:

Individual health condition, status, treatment, disease, or diagnosis information;
Health-related surgery or procedure information;
Use or purchase of medication information;
Diagnosis or diagnostic testing, treatment, or medication information;
Data that identifies a Consumer seeking Health Care Services.

Purposes for Collection and Use of Consumer Health Data

Primrose Collects and uses the Consumer Health Data described above to the extent necessary to:

Support the provision of a safe and healthy environment for students enrolled at a Primrose school;
Assist Primrose franchisees in accommodating student dietary restrictions or other health needs;
Satisfy applicable legal requirements;
Otherwise with your consent.

Sources of Consumer Health Data

We may obtain the Consumer Health Data described above from the following sources:

Directly from you or your representative;
From your family members;
From Primrose franchisees;
From healthcare providers whose contact information you provide (in the event it becomes necessary to directly communicate with a provider).

Sharing Consumer Health Data

Primrose does not Sell or Share Consumer Health Data. We may disclose Consumer Health Data to:

Our Processors to provide goods and services in a manner consistent with the purpose for which the Consumer Health Data was Collected and disclosed;
Parties with whom the Consumer has a direct relationship for the purpose of providing a product or service requested by the Consumer, in circumstances where we maintain control and ownership of the data and the party only uses the Consumer Health Data at our direction for the purpose for which the Consumer Health Data was Collected or Consented to;
External parties as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the party may assume control of all or part of our assets;
Otherwise with your consent.

Consumer Health Data Rights

Washington and Nevada Consumers have the right to submit certain requests relating to their Consumer Health Data. To exercise your privacy rights, please submit a request to privacy@primroseschools.com.

Any privacy rights request you submit to us is subject to a verification process. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we Collected Consumer Health Data.

Changes to This Policy

If we change this Consumer Health Data Privacy Policy, we will post those changes to this page on the website and other places we deem appropriate. If we make material changes to this Policy, we will notify you (in our sole discretion) by posting an updated version and updating the “Effective Date” at the top of this page, by email at the most recent email address you provided to us (if any), or by means of a notice on our website.

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