GODDARD CONSUMER HEALTH DATA PRIVACY POLICY

Effective Date: July 1, 2024

This Consumer Health Data Privacy Policy (“Policy") governs Goddard Franchisor, LLC's ("Goddard." “we," “our," or “us") collection, use, sharing, and otherwise processing of Consumer Health Data (defined below) of students of our franchisees (each a “Goddard School"), and the rights of Washington and Nevada residents with respect to their Consumer Health Data.

“Consumer Health Data" means Personal Information (information that identifies or is reasonably capable of being associated or linked, directly or indirectly, with a particular consumer) that identifies the consumer's past, present, or future physical or mental health status, including, but not limited to, individual health conditions, treatment, diseases, or diagnosis; social, psychological, behavioral, and medical interventions; health-related surgeries or procedures; use or purchase of prescribed medication; diagnoses or diagnostic testing, treatment, or medication; or data derived from such categories of data.

We will not collect, use, or share categories of Consumer Health Data not disclosed in this Policy, or process the categories of Consumer Health Data disclosed in this Policy for purposes not disclosed in this Policy without first (1) disclosing the additional category of Consumer Health Data or purpose for processing the Consumer Health Data and (2) obtaining the student's (or parent/guardian's) affirmative consent.

Unless we obtain a student's affirmative consent, we will only collect, use, and disclose a student's Consumer Health Data that is necessary to provide the products or services that the student has requested through the Goddard School.

Source, Collection, and Use of Consumer Health Data

We collect the following Consumer Health Data from the Goddard School to provide services to the student that he/she has requested through the Goddard School.

1. Student Enrollment.

   We collect, from the Goddard School that uploads it to our franchise management system (“

   FMS

   ”), a student's individual health condition, status, treatment, disease, diagnosis, heath-related surgery or procedure information, use of medication, and dietary restrictions, which will be processed by the FMS to assist the Goddard School with preparing a health plan and to help accommodate the student's health needs.
   
   

2. Health or Medical Event.

   When a student gets sick, has surgery, or otherwise requires treatment, we may collect, from the Goddard School, the student's physical or mental health status and/or diagnosis and any treatment or medication information, which is processed by Goddard's email system to communicate with the Goddard School and by Goddard employees to prepare a medical release for the student and/or update the student's medical information on FMS.
   
   

3. Comply with the Law.

   We will collect, from each Goddard School that uploads it to our FMS, any Consumer Health Data, including immunization records, medical history, health appraisals, medication, diagnosis, allergies, medical action plans, and any other data which may be required to be maintained about the student by state childcare licensors if it is processed in FMS for the accessibility of such information.
   

A third party will not collect Consumer Health Data over time and across different internet websites or online services when the student uses Goddard's internet websites or online services.

Disclosure or Sharing of Consumer Health Data

1. Processors

   . We share a student's health condition, status, treatment, disease, diagnosis, heath-related surgery or procedure information, use of medication, present physical or mental health status, and dietary restrictions with processors that provide support services to us, such as the technology and software service providers to prepare and maintain health/medical plans and meal tracking.
   
   

2. Corporate Reorganization

   . In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share a student's health condition, status, treatment, disease, diagnosis, heath-related surgery or procedure information, use of medication, present physical or mental health status, and dietary restrictions with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We would share Consumer Health Data with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
   
   

3. Legal Purposes

   . Where we are legally required to do so, such as in response to legal process or law enforcement, to exercise our legal rights, to enforce our terms of service or other contracts, or to comply with the requirements of any applicable law or regulation, we will share a student's health condition, status, treatment, disease, diagnosis, heath-related surgery or procedure information, use of medication, present physical or mental health status, and dietary restrictions with the party with whom we are required to share such information (e.g., regulatory agency).
   
   

4. Consent

   . Apart from the reasons identified above, we may request a student's permission to share their Consumer Health Data for a specific purpose. We will notify the student and request consent before we provide the Consumer Health Data or before the Consumer Health Data that the student has already provided is shared for such purpose.
   

Sale of Consumer Health Data

We will not Sell students' Consumer Health Data.

Rights of Washington and Nevada Residents

1. A student who resides in Washington or Nevada has the following rights:

1. Right to Know/Access

   A Washington or Nevada student has the right to confirm whether we are collecting, sharing, or selling Consumer Health Data concerning the student and to access such data, including a list of all third parties and affiliates with whom we have shared or sold the Consumer Health Data and an active email address or other online mechanism that the student may use to contact these third parties.

2. Right to Withdraw Consent

   A Washington or Nevada student has the right to withdraw consent from our collection and sharing of Consumer Health Data concerning the student.

3. Right to Deletion

   A Washington or Nevada student has the right to have Consumer Health Data concerning the student deleted. If we receive a student's request to delete any Consumer Health Data concerning the student, we shall: (A) delete the Consumer Health Data from our records, including from all parts of our network, including archived or backup systems; and (B) notify all affiliates, processors, contractors, and other third parties with whom we have shared Consumer Health Data of the deletion request.

2. A student who resides in Nevada also has the right to request changes to any of his or her Consumer Health Data.

3. Exercising a Student's Rights

   
   
   

   A student, or parent/guardian of a student, may exercise the student's rights by calling Goddard toll-free at 1-800-GODDARD or via email at privacy@goddardsystems.com. You must provide us with sufficient information (student name, enrolled Goddard School, and address) that allows us to reasonably verify you are the student or parent/guardian of the student about whom we collected the Consumer Health Data and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your requests with the information provided, we may ask you for additional pieces of information.

   If the student or parent/guardian of a student does not agree with our decision regarding your request to exercise the student's right, a student or parent/guardian of a student may appeal our refusal to take action on a request within a reasonable period of time after your receipt of the decision by emailing us at privacy@goddardsystems.com with the subject line of the email as “Rights Request Decision Appeal” and attaching our original written decision to your email. Within 45 days of receipt of an appeal, we will inform the student in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may contact the attorney general to submit a complaint:

   1. Nevada Attorney General Complaint e-mail address: aginquiries@ag.nv.gov
   2. Washington Attorney General Online Complaint Form: https://fortress.wa.gov/atg/formhandler/ago/ComplaintForm.aspx
      

Changes to this Policy

If we make material changes to this Policy, we will post a notice of the change on our website (goddardschool.com), and, if required by applicable law, notify you directly by email to the email we have on file for you.

Contact Us

If you have any questions or comments about your Consumer Health Data or our practices with respect to your information, please contact us at: