THE GROWING PLACE
DATA PRIVACY AND COOKIE NOTICE
Effective Date: September 15, 2025
This Data Privacy and Cookie Notice (“Notice”) applies to visitors to our website (the “Site”), and any affiliated or related websites or webpages, as well as students and parents of our schools, employees, and others (“Consumers” or “you”). The purpose of this Notice is to inform you of our privacy policy, cookie policy, YOUR CALIFORNIA PRIVACY RIGHTS and provide you with a comprehensive description of (i) our online and offline practices regarding the collection, use, disclosure, and sale of Personal Information (as hereinafter defined) and (ii) your rights regarding the Personal Information (as hereinafter defined) we collect. We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (the “CCPA”), as amended by the California Privacy Rights Act (the “CPRA”), enacted as a result of Proposition 24, the California Online Privacy Protection Act (“CalOPPA”), and other applicable state and federal laws and regulations. Any terms defined in the CCPA or other applicable law have the same meaning when used in this Notice.
1. COLLECTION, USE, PROTECTION, AND DISCLOSURE OF PERSONAL INFORMATION
The Growing Place, and its subsidiaries and affiliates (the “Growing Place,” “we,” or “us”), collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household (“Personal Information”). We collect the categories of Personal Information specified below, online and/or offline. We may use, share, or disclose these categories of Personal Information for one or more of the indicated business or commercial purposes. Nothing in this Notice limits our ability to use or disclose information in any materials provided to you, such as a parent/student handbook (e.g., transcripts, record requests) or an employee handbook (e.g., employment verifications, benefits elections).
Consistent with the Student Online Personal Information Protection Act (“SOPIPA”) and the Early Learning Personal Information Protection Act (“ELPIPA”), the Growing Place utilizes reasonable physical, technical, and administrative safeguards (including implementing and maintaining appropriate data security procedures and practices, and deleting Personal Information or Covered Information, when appropriate) in order to protect Personal Information and other relevant data entrusted to us. We also have in place security protocols and procedures to guard against and quickly and effectively respond to any data breach which may occur with respect to the Site or the Growing Place’s data storage systems.
a. What You Give Us
Some parts of the Site may ask you to submit Personal Information so that you may benefit from the specified features or to participate in an activity. For example, you may voluntarily provide Personal Information to us in the following ways:
Application Forms: We collect the Personal Information you voluntarily provide when you complete an application form on the Site. This information may include your name, street address, email address, telephone number, employer, the name, birth date, and gender of the child that is applying, and academic information regarding that child.
Contact Us Forms: If you contact us, we collect the information that you provide on the “contact us” form available on the Site.
Registration for an Account: If you register for an account with us, we will collect the information that you voluntarily provide when registering, which will include your username and password.
Employment Applications: Some areas of the Site may allow you to submit information related to job opportunities with the Growing Place.
Forums: If you participate in message boards, blogs, or chat features, we receive any Personal Information you reveal in those forums.
We may combine Personal Information you submit through the Site with other information we have collected from you, whether on-line or off-line. We treat the combined information in accordance with this Notice.
b. Categories of Personal Information Collected
In the past 12 months, we may have collected the following categories of Personal Information:
“Identification Information,” such as name, mailing address, email address, phone number, a copy of your government-issued identification, and your account information and password;
“Sensitive Information,” such as your driver’s license number, insurance policy number, education, employment information, financial information, medical or health insurance information, age, race, ethnicity, physical or mental disability status, gender, or veteran or military status;
“Commercial Information,” such as information about products or services purchased, used, or considered;
“Internet Activity Information,” such as internet “Traffic Data” (meaning information about your use of the Site that does not identify you directly but may identify your computer or device) and other information automatically collected when you use the Site, including your IP address, the hostname of your computer, and so on;
“Geolocation Information,” such as physical location when you use the Site;
“Professional/Employment Information,” such as current or past job history; and,
“Education Information,” such as education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
c. Sources of Personal Information
As previously described, we may collect the Personal Information described above from the following sources:
Directly from you, such as your communications with us, registering to use our parent portals, enrolling your child, completing forms or submitting an inquiry;
Indirectly from you, such as Traffic Data collected automatically from your use of the Site or Education Information from activities inherent to enrolling and attending school; and,
Third parties, such as partners we contract with to provide targeted online advertisements based on Traffic Data or educational and applicant/employee service providers using Personal Information on our behalf and only for the contracted business purpose.
d. Purpose of Personal Information Collection and Disclosure
We may use or disclose the Personal Information we collect about you for one or more of the following purposes:
to provide you with our services, communicate with you, ensure that your child is receiving safe and appropriate care, and comply with licensing regulations and other legal requirements;
for our direct marketing efforts, including when we send you marketing communications about our services that may be of interest to you, respond to your inquiries, and send you promotional messages, advertising, surveys, and other information that may be of interest to you;
to create and maintain a trusted and safe educational environment (e.g., to detect and prevent fraud, abuse, or security incidents, conduct security investigations and risk assessments, enforce our policies, or comply with our legal obligations and licensing requirements);
to evaluate your job application or employment-related activities (e.g., time cards for payroll);
to maintain and improve the security and functionality of the Site by processing the Personal Information (e.g., Traffic Data) we collect automatically from your use of the Site to personalize your user experience, ensure that our web pages appear and function properly, improve the Site, programs, products, services, advertising, and content, and perform other functions; and,
for other purposes as permitted by law, such as notifying you about changes to the Site, protecting our rights and property, complying with a law, regulation, legal process or court order, or fulfilling any other purpose with your consent.
e. How we use the information we collect from you
Requests, Inquiries, and Applications: We may use your Personal Information to process, evaluate, and respond to your requests, inquiries, and applications. So, if you provide us with information to schedule a tour, we will use the information you provide for that purpose. If you request certain information from us, we will use your Personal Information to process and respond to your request. If you fill out an application form on the Site, we may combine the Personal Information you provide on the Site with information we receive offline about you or your child to process the application.
Use of Parent and Student Portals: If you are a parent or student and have a registered account, we may use your Personal Information to allow you access to our parent and student portals.
Manage Our Relationship with You: We may use your Personal Information to send you important information regarding our relationship with you or regarding the Site, such as information about changes to our terms, conditions, policies, and other administrative information. If your child is enrolled in the school, we also use Personal Information to manage your family’s relationship with the school. Further, we may use Personal Information to contact you about special events, school news, or your child’s academic progress.
Access to Interactive Features: We use your Personal Information to allow you to participate in interactive features of the Site, when you choose to do so, such as online message boards, blogs, and chat features.
Internal Business Purposes: We may use your Personal Information for internal business purposes, including without limitation, to help us operate, evaluate, and improve the quality of the Site; to better understand those individuals that utilize the Site; to verify your identity; to prevent, protect against, identify, or address fraud, unauthorized activity, claims, liabilities, and other wrongdoing; to provide you with customer service; and, to generally manage our business.
Employment: If you provide Personal Information to apply for a job with the Growing Place, we may use the Personal Information you provide to evaluate your job application, consider you for that job or for similar jobs in the future, and contact you regarding possible employment.
Online Advertising: We may use Traffic Data for marketing and advertising purposes, including determining appropriate advertising channels and venues to place ads, placing advertising on such channels and venues, measuring and managing the effectiveness of our advertising and marketing, and performing market research and data analytics. To learn more about how we use Traffic Data for interest-based advertising, please see Sections 4 and 5 of this Notice.
Legal Requirements, Industry Standards, and Contractual Obligations: We may use your Personal Information for complying with and enforcing applicable legal requirements, industry standards, and our contractual obligations.
f. Non-Personal Information
We may use non-personal information or aggregate information that does not identify an individual without restriction, and we may share such information with third parties.
g. With Whom we may Share your Personal Information
Affiliates: We may share your Personal Information with our affiliates for purposes consistent with this Notice. Our affiliates will be bound to maintain that Personal Information in accordance with this Notice.
Agents, Consultants, and Service Providers: We may share your Personal Information with individuals or companies that we hire to provide services to us, such as website hosting services.
Forums: Students who participate in live classes or message boards through our student portal are sharing Personal Information with other students who also participate in those classes or boards. Parents may participate in message boards, blogs, and chat features. Please be aware that if you use these forums you are disclosing Personal Information to the other users of the forums and we cannot control whether those other users will further use or disclose any Personal Information that is shared with them.
Business Transfers: We may transfer your Personal Information in the event of a business sale, merger, consolidation, change in control, transfer of substantial assets, bankruptcy, liquidation, or reorganization. We may also disclose your Personal Information in the course of due diligence of such a transaction. You acknowledge and agree that any successor to or acquirer of the Growing Place (or its assets) will continue to have the right to use your Personal Information and other information. Whether the recipient of your Personal Information in these cases will handle your Personal Information pursuant to this Notice will depend on the applicable law and other factors.
Legal Requirements: We use and disclose Personal Information as we believe to be necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iv) to enforce our terms and conditions; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and, (vii) to allow us to pursue available remedies or limit the damages that we may sustain.
Passively Collected Information: We may share Traffic Data that does not identify you directly, but may identify your computer or device.
h. Disclosure and Sale of Personal Information
We may have disclosed each of the categories of Personal Information described above for one or more of the business purposes described in this Notice to service providers and other vendors; parent entities, affiliates, and subsidiaries; medical providers; and, enforcement, regulatory and other governmental agencies.
We do not make your Personal Information available for purchase or otherwise share your information with third parties in exchange for monetary compensation. Certain sharing of your information, however, may be considered a “sale” under the CCPA’s broad definition. In particular, if you have visited our Site, we may have shared your Commercial Information, Internet Activity Information, and/or Geolocation Information with advertising partners and social media platforms to match and serve our targeted advertisements on third-party websites.
We do not knowingly “sell” the Personal Information of consumers under the age of 16.
i. Data about Children
The Site is not directed to children under the age of 13. Consistent with the Children's Online Privacy Protection Act (“COPPA”), we do not knowingly collect Personal Information through the Site from children under the age of 13. We reserve the right to delete any information identified as having been provided through the Site from children under the age of 13. Any use or disclosure of Personal Information from any children shall, consistent with COPPA and subject to applicable law and regulations, be solely after prior, written consent by their parent or guardian.
Consistent with SOPIPA and ELPIPA, we do not engage in targeted advertising aimed at children on the Site, nor do we use information, including persistent unique identifiers, created or gathered by the operator's site, service, or application, to amass a profile about a pupil, except in furtherance of our legitimate educational purposes. Disclosures of students’ Personal Information or Covered Information is made only in furtherance of legal duties and responsibilities of the Growing Place, including to ensure legal and regulatory compliance, to respond to or participate in a judicial process, or other reasons stated in Business and Professions Code section 22586(b).
2. COOKIES AND OTHER PASSIVE COLLECTION TECHNOLOGIES
As you navigate the Site, certain Traffic Data may be passively collected, meaning it is gathered without your actively providing it. This is done using the following technologies in the following ways:
Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type and operating system type and version screen resolution, and Internet browser type and version.
Through your device: If you access the Site through a mobile device or other network-connected product, certain information may be collected about that device, including your device type, network service provider, and other identifiers. We may collect unique device identifiers (such as IDFA and AID tags and UUID and UDID identifiers) associated with the devices you use to access the Site.
Using cookies: Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, and language preferences. We and our service providers use this information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Site. More specifically, we use cookies to:
recognize your computer or device to make your use of the Site easier, such as to remember your locations of interest and other preferences with the Site;
gather statistical information about use of the Site in order to continually improve its design and functionality, understand how individuals use it, and to assist us with resolving questions regarding it;
select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Site and on other websites, applications, and online services that you use; and,
track consumer responses to online advertisements.
To learn more about cookies, please visit http://www.allaboutcookies.org.
Should you view any embedded YouTube video on the Site, please be aware that YouTube applies its own cookies. For further information regarding their policies, please refer to the Google Privacy Policy.
Using Monitoring Tools: Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”) to better tailor the Site in order to provide a better service. These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Site. These technologies usually work in conjunction with cookies. To disable cookies used on our Site,
and therefore any other tracking technologies that work in conjunction with these cookies, please follow the instructions below.
IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your internet service provider. An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many online service providers, including website operators. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.
Social Media Plug-Ins: We use social media plug-ins from social media networks like Facebook, Pinterest, Instagram, YouTube and Twitter, which are labeled on our Site with the well-known symbols of the respective social network. If you interact with these plug-ins, your activity on the Site will also be made available to those social networks. To understand how those social networks use and disclose your Personal Information, please review the privacy policies available on the websites of those social networks.
Analytic Tools: We also use tools and third-party services to collect information about usage of the Site, including Google Analytics. To learn more, please consult the Google Privacy Policy. Google Analytics collects information on how often users visit the Site, what aspects of the Site they visit when they do so, and what other websites users visited prior to accessing the Site. You may prevent your data from being collected and used by Google Analytics by opting out through the use of the Google Analytics Opt-Out Browser Add-On.
Our Site currently responds to “Do Not Track” (DNT) signals and operates as described in this Notice.
4. INTERNET BASED ADVERTISING
We may collect information about your online activities on the Site to provide you with advertising tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our ads are served. This section of our Notice provides details and explains how to exercise your choices.
You may see certain ads on other websites because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities. Our advertising partners allow us to target our messaging to users through demographic, interest-based and contextual means. These partners track your online activities over time and across websites by collecting information through automated means, including use of third-party cookies, web server logs, and web beacons. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Site and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. For example, we utilize certain of our ad partners’ targeted advertising services to show you our ads on other websites based on your prior visits to the Site and other online activity.
Provided that an advertising partner participates in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising, you also may opt out of ad network interest-based advertising generally through the Network Advertising Initiative or the Digital Advertising Alliance.
5. DATA RETENTION
We generally retain Personal Information for so long as it may be relevant to the purposes above, or for longer when required by law. To dispose of Personal Information, we may anonymize it, delete it, or take other appropriate steps. Even if we delete your Personal Information, it may persist on backup or archival media for an additional time period for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes.
6. INTERNATIONAL TRANSFERS OF PERSONAL DATA
The Growing Place is based in the United States. The recipients of the Personal Information disclosures described in this Notice may be located in the United States or elsewhere in the world. Privacy laws in these countries may not provide protections equivalent to those of your country of residence, and your government may or may not deem such protections adequate. If we transfer personal data outside of the European Economic Area (“EEA”) or the United Kingdom, we take legally required steps to make sure that the appropriate safeguards are in place to protect your Personal Information.
7. THIRD PARTY SITES
The Site may contain links to other websites for the convenience of users in locating information or services that may be of interest. If you access a third-party website from a link on the Site, any information you disclose on that website is not subject to this Notice. It is possible that these links may be used by third parties or others to collect personal or other information about you. The Growing Place is not responsible for the privacy practices of such websites, advertisers, or third parties or the content of such websites. The Growing Place does not control these third parties’ use of cookies, collection of information, or how they manage such information. It is solely your obligation to review and understand the privacy practices and policies of these other websites, advertisers and any third parties.
8. YOUR PRIVACY RIGHTS AND CHOICES
a. Opt-Out from Direct Electronic Communications
Where it is in accordance with your preferences, the Growing Place may send you direct electronic communications, such as through email or text message. You may “opt-out” of receiving these electronic communications by following the instructions in the message that you receive, or by sending an e-mail to privacy@growingplace.org indicating which communications you no longer wish to receive. Note that if you are a parent of a student enrolled at the school, we may still send certain administrative messages to you by email that relate to the student’s relationship with the school.
b. Opt-Out from Cookie-Related Processing and Interest-Based Advertising
You can opt-out from certain cookie-related processing and interest-based advertising, as described in this Notice.
c. How You Can Access, Update, Correct, or Delete Your Personal Information
If you would like to submit a data access, correction, restriction, or deletion request, you can do so by contacting us at privacy@growingplace.org and we will process such request with respect to any Personal Information that we are able to link to you individually based on the information that you can provide to us. If you choose to delete or restrict the use of your Personal Information, you may not be able to use certain functionality on the Site or to be enrolled at the school. These rights and options that you have with respect to Personal Information are subject to limitations and exceptions under our policies and applicable law. In addition to those rights, if you live in certain jurisdictions, you have the right to submit a complaint to your relevant supervisory authority. However, we encourage you to contact us first at privacy@growingplace.org and we will try to resolve your concerns.
9. CALIFORNIA PRIVACY RIGHTS
To the extent provided for by law and subject to applicable exceptions, if you are a resident of the State of California, you have the following privacy rights in relation to the Personal Information we collect about you and your children, as applicable:
The right to request that we disclose what Personal Information we collect, use, disclose, and sell;
The right to request access to the specific pieces of Personal Information we have collected;
The right to request deletion;
The right to request a correction or deletion;
The right to opt-out of the “sale” of Personal Information; and
The right to be free from discrimination for the exercise of your privacy rights.
Additionally, subject to certain limits under California Civil Code section 1798.83 (the California “Shine the Light” Law), including that we shall only provide to you details about Personal Information which may have been disclosed within the precedent twelve (12) months prior to receipt of your request, you may ask us to provide you with:
(1) a list of certain categories of Personal Information that we have disclosed to certain types of third parties for their direct marketing purposes during the immediately preceding calendar year; and,
(2) the identity of the third parties that received certain Personal Information from us for their direct marketing purposes during that calendar year.
Parents and guardians are permitted certain rights and privileges with respect to the Personal Information and other data of their children who are enrolled with us, consistent with law and our policies, including:
To review Personal Information and other data collected from their children; and,
To request a correction or deletion of their children’s Personal Information and other data;
10. EXECISING YOUR RIGHTS
To submit a request in exercise of your rights under CalOPPA, COPPA, this Notice, or other applicable law or regulations, please call [PHONE NUMBER], or email us at privacy@growingplace.org. You may also contact us at the following mailing address:
The Growing Place
Attn: Privacy Request
401 Ashland Ave.,
Santa Monica, CA 90405
11. VERIFICATION OF IDENTITY
In order to protect your Personal Information from unauthorized access or deletion, we may require you to verify you are the person about whom we collected Personal Information, such as by supplying proof of identification prior to our fulfilling a request. If we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information for verification. If we cannot verify your identity, we will not provide or delete your Personal Information.
a. Authorized Agents
You may use an authorized agent to submit a request on your behalf. If you do so, we may require the agent to provide their name, email address, phone number, and written permission from you that includes your contact information. We may contact you using the information provided and verify your identity directly with us and confirm that you have provided the agent permission to submit the request.
12. CONTACT FOR MORE INFORMATION
If you have any questions or concerns about our privacy policies and practices or would like to receive a copy of this Notice in an alternative format, please do not hesitate to contact us at privacy@growingplace.org or by phone 310-434-3811. You may also contact us at the following mailing address:
The Growing Place
Attn: Privacy Request
401 Ashland Ave.,
Santa Monica, CA 90405
13. CHANGES TO THIS PRIVACY NOTICE
The business and operations of the Growing Place may change from time to time. As a result, at times it may be necessary for us to make changes to this Notice to reflect changes in the law, our data handling practices, or the features of our services, websites, and apps. We reserve the right, in our sole discretion, to update or modify this Notice at any time. Modifications to this Notice will be posted on this webpage and the new Effective Date will be displayed at the top of this Notice. In certain circumstances, the Growing Place may, but need not, provide you with additional notice of such modifications, such as via e-mail. Where required by applicable law, we will apply changes only with your consent.
Please review this Notice periodically, and especially before you provide any Personal Information. This Notice was updated on the date indicated above. Your continued participation in our programs, services, and events following the effectiveness of any modifications to this Notice constitutes your acceptance of those modifications. If any modification to this Notice is not acceptable to you, you should cease accessing, browsing, and otherwise utilizing the Growing Place’s website, as well as its programs, services, and events.