Introduction

Kumon North America, Inc. and its wholly-owned subsidiaries, Kumon Canada, Inc., Kumon Mexico, Inc., (collectively, "Kumon" or "We") respect your privacy, whether you are a Kumon Franchisee, a Kumon Associate, or simply an individual visiting one of our websites, and we are committed to protecting your privacy through our compliance with this policy. The use of personal information collected through our services shall be limited to the purpose of providing the service for which our Customers have engaged Kumon.

This policy describes our practices in connection with information that we collect through our domestic and international websites (collectively, our "Websites"), through our web-based and mobile software applications and services (collectively, our "Applications"), as well as through HTML-formatted email messages that we send to you (collectively, including the Websites and the Applications, our "Services").

This policy also applies to information about you that we collect or receive:

• In e-mail, text and other electronic messages between you and Kumon.
• When you interact with our advertising and applications on third-party websites and services.

It does not apply to information collected by:

• Any third party, including through any third-party application or content (including advertising) that may link to or be accessible from our Services.

Please read this policy carefully to understand our policies and practices regarding the collection of information about you, whether via our Websites, Applications, or from other sources, and how we will treat it. If you do not agree with our policies and practices, you may choose not to use our Services.

Your Privacy Classification

Personally identifiable information pertaining to visitors subject to this policy is maintained in one or more Kumon marketing databases and Website analytics and management systems that are physically and logically separate from Kumon production systems and databases where Application end-user information is maintained. Kumon may use the contact information you provide as a visitor to send you promotional materials, as further described in this policy.

Personally identifiable information of you will not be used for any purpose other than providing and supporting our Applications (other than for limited exceptions described in the section below titled "How We Use Information" where applicable).

Information We Collect and How We Collect It

Kumon, and our Customers that use our Applications to organize and manage meetings and events or to provide other services, may collect several types of information from and about End-Users, including:

• "Personal Information" that identifies an End-User as an individual or relates to an identifiable person. For example, this includes name, organization, title, postal address, e-mail address, telephone number, fax number, social media account ID or other identifiers by which End-Users may be contacted online or offline. This also may include information that permits End-Users to purchase products or services from Kumon or from our customers through the Applications, such as credit or debit card number, or other payment account number, as well as applicable expiration dates and billing/shipping addresses;
• "Other Information" that does not reveal a person’s identity or directly relate to an individual, on its own or in combination with other information we have collected, such as browser and device information, operating system, device type, system and performance information, app usage data, information collected through cookies, pixel tags and other technologies, general geographic location, demographic information and other information provided by a person, such as dietary preferences, interests, activities, age, gender, education and occupation.

Kumon may also collect Personal Information and Other Information from Customers and Website Visitors. In some instances, we may combine Other Information with Personal Information (such as combining a Website Visitor’s name with information we gather about this individual’s use of the Websites). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.

We collect this information:

• Directly from individuals when they provide it to us.
• Automatically from End-Users as they use the Applications, or from Website Visitors as they navigate through the Websites, using technologies described in the section below titled "Third Party Advertisers and Analytics." Information collected automatically may include browser and device information, details regarding use of the Services, IP addresses and information collected through cookies, web beacons and other technologies.
• From third party sources, such as public databases, joint marketing partners, and social media platforms. For example, if a Website Visitor elects to connect his social media account to his account for our Websites, certain Personal Information from the social media account will be shared with us, which may include Personal Information that is part of the Visitor’s profile or his friends’ profiles.

Information Provided to Us.

The information we collect through our Services may include:

• Information that a person provides when utilizing one of our Services, for instance at the time an End-User registers to attend a meeting being organized by a Kumon customer (Kumon Event Registration), uses a web chat function with our sales team, submits a request for proposal ("RFP") to a meeting space provider (Kumon Supplier Network), or downloads a mobile software application to the End-User’s iPhone or Android device.
• Information that Website Visitors provide by filling in forms on our Websites. This includes information provided at the time of registering to receive product information or white papers, attend online demos, or access other special content on our Websites. We may also ask Customers or Visitors for information when they enter a contest or promotion sponsored by us.
• Information that Customers and End-Users provide when receiving technical or customer account support. This includes records and copies of Customer and End-User correspondence (including e-mail addresses).
• Responses to surveys that we might ask Customers, End-Users or Website Visitors to complete for research purposes.
• Details of transactions Customers carry out through our Applications and of the fulfillment of Customer orders.
• Records of search queries on our Services.

Some of our Websites allow Visitors to create or post content on message boards, chat, profile pages and blogs and other services to which Visitors are able to post information and materials. Please note that any information posted or disclosed through these sections of our Websites will become public information, and may be available to other Website Visitors and to the general public. We urge caution to anyone deciding to disclose their Personal Information, or any other information, on our Websites. Anyone submitting Personal Information relating to other people to Kumon in connection with the Services represents that they have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

How We Use Information

We may use information that we collect or that is provided to us, including Personal Information, for any of the following purposes:

• To present our Services and their contents.
• To provide End-Users with information, products, or services they request from Kumon or our Customers using our Applications, for example by processing event registrations, enrolling End-Users in programs in which they choose to participate, or providing End-Users with mobile application access for a meeting organized by a Customer.
• To manage Application accounts, provide customer service, and process payments for purchases by End-Users.
• To provide Customers with notices about their Kumon accounts, including expiration and renewal notices.
• To notify Customers and End-Users about changes to our Services, any products or services we offer or provide though our Services, our terms and conditions applicable to the Services, or this Privacy Policy.
• To communicate with Customers and Visitors by e-mail, postal mail, telephone and/or mobile devices about products or services that may be of interest and that are offered by us, our affiliated companies or other third parties.
• To allow Customers and Visitors to participate in online product demos, surveys, and online sweepstakes or contests (including to verify participant eligibility and deliver prizes), access and download materials, and use other interactive features on our Services.
• To better tailor Website experience to Visitors interests, Application experience to End-User or Customer interests, and display content according to user preferences.
• To facilitate social sharing functionality.
• To perform research and analyze use of, or interest in, our products, services or content (or products, services or content offered by others on our Website).
• For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
• 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 carry out our obligations and enforce our terms and conditions applicable to the Services and other agreements, including for billing and collection purposes; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to protect against or identify fraudulent transactions. This includes exchanging information with other companies and organizations where reasonably necessary for the purposes of fraud protection and credit risk reduction.
• In any other way we may describe when you provide the information.
• To fulfill any other purpose for which you provide it or with your consent.

We may also use contact information of Customers and Visitors to contact them via email, telephone or direct mail about products and services that may be of interest to them. Where required, we will seek and obtain recipients’ express authorization before we send marketing emails. If you do not want us to use your information in this way, please adjust your email preferences on the profile page that is accessible by clicking the unsubscribe link provided at the bottom of emails you receive from us. For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

We may disclose aggregated information about users and the use of our Services, and information that does not identify any individual, without restriction.

If you choose to use our Services to transact business with Customers (for example, register for an event, respond to an online survey, or download a mobile application), any information you provide in connection with that transaction will be transferred to, and under the control of, the Customer. Customers will also have access to information (including Personal Information and Application usage data) related to how End-Users interact with the Applications that they use to organize and manage meetings and events. Although our own use and disclosure of your information will be in compliance with this Privacy Policy, Kumon cannot and does not take responsibility for the privacy practices of Customers.

We may disclose Personal Information that we collect or you provide as described in this Privacy Policy:

• To our subsidiaries and affiliates for the purposes described in this Privacy Policy, including but not limited to the providing Services to our Customers and to End Users. Kumon, Inc., is the party responsible for the management of the jointly-used Personal Information.
• To contractors, service providers, and other third parties as reasonably necessary or prudent to provide, maintain and support our Services, such as, for example, payment processors, data analytics providers, and data center or Web hosting providers.
• To a third party in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Kumon’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by Kumon about our Website Visitors, Customers and End-Users is among the assets transferred.
• To fulfill the purpose for which information is provided. Here are some examples:
• §If End-Users provide an email address when registering for an event, we will use the e-mail address to send the End-User information and announcements relating to that event.
• §If End-Users utilize one of our Applications to pay for event registration fees or other products and services using their credit cards, we will pass the credit card information to payment card processors to validate the payment information and complete the transactions.
• To enable processing of RFPs: When a Customer or End-User submits a request for proposal ("RFP") to a meeting space provider listed on the Kumon Supplier Network, Kumon will contact that venue or its management company and disclose information necessary for it to respond to the RFP, which may contain Personal Information.
• To your friends associated with Visitors’ social media accounts and to Visitors’ social media account providers, in connection with social sharing activity, such as if a Visitor connects her social media account to her Website profile. Kumon will also share End-User information with social media account providers where an End-User logs into one of our Applications using a social media account (where such an option is available for establishing a Kumon account login). Kumon will not post responses or other content on your behalf under your social media account, nor will we transfer your Personal Information in our possession to your social media account except as reasonably necessary for social sharing. However, you agree that by connecting your social media account to your Website profile (in the case of Visitors), or to your Application account (in the case of End-Users), you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media site’s privacy policy. If you do not want your Personal Information shared with your social media account provider, please do not connect your social media account with your Services account and do not participate in social sharing on 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 carry out our obligations and enforce our terms and conditions applicable to the Services and other agreements, including for billing and collection purposes; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, our customers, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. This includes exchanging information with other companies and organizations where reasonably necessary for the purposes of fraud protection and credit risk reduction.
• For any other purpose disclosed by us when you provide the information or with your consent.

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services or this Policy link. The inclusion of a link on the Services or within this Policy does not imply endorsement of the linked site or service by us or by our affiliates.

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, BlackBerry, or any other company, including app developers, app providers, social media platform providers, operating system providers, wireless service providers or device manufacturers, including any Personal Information you disclose to other organizations through or in connection with the Applications.

Cookies and Similar Technologies

We and our partners use cookies or similar technologies as you navigate through and interact with our Websites, our Applications, and with third party websites or other online services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• Details of your visits to our Services, such as the date and time you access our Services, length of time you spend on our Services, websites you visited before or after our Services, the resources and content that you access and use on the Services, and whether your interaction with our Services results in your requesting information about Kumon or making a purchase.
• Information about your computer and internet connection, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, language, Internet browser type and version and the name and version of the Services (such as the Application) you are using.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access or receive certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites or receive our Services. For more information about cookies and how to disable them, see www.allaboutcookies.org.
• Session Cookies and Persistent Cookies. A "session" cookie lasts for a single browser session only and is deleted when the user closes the web browser. A "persistent" cookie remains on the user’s device (even while powered off) until it expires or is deleted. A persistent cookie will be reactivated when a user returns to the website which posted the cookie. Cookies cannot read or access other cookies or any data from a user’s hard drive. Cookies alone will not personally identify a user, however a cookie may recognize a user’s individual web browser or device through an IP Address, browser version, operating system and other information, and end users of our Services who log in to their Kumon accounts may be individually identifiable to particular Services using session cookies.
• Flash Cookies. Certain features of our Services may use local storage, such as "Flash cookies" to collect and store information about your preferences and navigation to, from and on our Websites. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices about How We Use and Disclose Your Information.
• Web Beacons. Pages on our Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs). Web beacons differ from cookies in that the information is not stored on your hard drive, but invisibly embedded on web pages or in email. Web beacons permit us to track online movements of web users -- for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). This enables Kumon to provide a website experience more tailored to your preferences and interests.

At this time we do not respond to browser ‘do not track’ signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted. You can learn about how you can adjust your browser’s settings to limit or disable cookies and other tracking technologies by visiting the section below titled "Choices about How We Use and Disclose Your Information."

Advertising and Analytics

When you access and use the Services and other websites, we or a third party partner may serve you advertisements regarding goods and services that may be of interest to you (or in some cases, to users who our service providers deem to have characteristics similar to our customers) based on information relating to your access to and use of the Services and other websites. To do so, we or our service providers may place or recognize a unique cookie on your browser (alone or in conjunction with web beacons, pixel tags or other tracking technologies). If you would like more information about this practice and to learn about your choices in connection with these practices, please visit http://preferences-mgr.truste.com, http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/. If you are located in the European Union click here.

We use Facebook Custom Audiences to deliver advertisements to Website Visitors on Facebook based on email addresses that we have collected. You may learn more about Facebook Custom Audiences by visiting https://www.facebook.com/help/381385302004628/, and you may learn how to opt-out of receiving advertisements from Kumon based on your email address by visiting the section below titled "Choices About How We Use and Disclose Your Information." We also may use information associated with Visitor social media accounts, such as demographic and other information about an individual’s title, industry or organization, to improve our marketing efforts if that individual connects those social media accounts to a Website profile.

We may use the information we have collected from you to enable us to display advertisements from our Customers to their target audience of users. As one example, meeting space providers may purchase advertisements which are presented selectively through the Kumon Supplier Network to meeting planners who have previously awarded a minimum volume of meetings business to that provider or to competing venues in the target metropolitan area. Even though we do not disclose Personal Information for these purposes, if an End-User clicks on or otherwise interacts with an advertisement, the advertising Customer may assume that the End-User meets its target criteria.

We use third party analytics providers, including Quantcast, Google, Adobe, Mixpanel, Mouseflow and others, to collect information about your use of the Services and enable us to improve how the Services work. The information allows us to see the overall patterns of usage on the Services, helps us record any difficulties you have with the Services, shows us whether our advertising is effective or not, and allows us to use responses to advertisements to optimize ad performance. Google Analytics, Adobe and Mixpanel use cookies and other, similar technologies to collect information about the Services use and to report website trends to us, without identifying individual End-Users or Visitors to us. See below for more information, or to opt out of these practices:

• You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
• You may opt-out of Adobe’s data aggregation and analysis about your use of the Services by clicking on this link: http://www.d1.sc.omtrdc.net/optout.html?omniture=1&popup=1&locale=en_US&second=1&second_has_cookie=0.
• You may opt-out of Quantcast interest-based content and advertisements by clicking on the Quantcast "Opt Out" link at https://www.quantcast.com/company/opt-out.
• You may opt-out of Mixpanel’s practices by visiting https://mixpanel.com/optout/.
• Mouseflow collects information related to mouse clicks, mouse movements, scroll behavior, and/or keystroke activity, but it does not collect personally identifiable information on our behalf or track users’ browsing habits across other websites that do not use Mouseflow. You can learn more about Mouseflow’s practices by visiting http://mouseflow.com/privacy.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You may set your web browser to restrict or to entirely block cookies, to configure cookie notification settings and/or to delete cookies already present on the browser or device. Information on how to do this should be provided in the web browser’s help/reference section. Visitors who block cookies may be able to access a Website but will not be able to use most of the content, applications and services available on that site. Limiting or restricting certain types of cookies may also prevent a Customer or End-User from using certain portions of the Applications, depending on how the browser settings are configured. For example, event registration cannot be completed successfully if cookies are disabled in an End-User’s web browser.
• Promotional Offers from Kumon. If you do not wish for Kumon to use your email address to send you promotional messages, or would like us to prevent a Customer from using the Applications to send you emails to promote its own or third parties’ products or services, you can (i) opt-out by checking the relevant box located on the form on which your data is collected (or, in some jurisdictions, by failing to opt-in), (ii) adjust your email preferences on the profile page which is accessible by clicking the unsubscribe link provided at the bottom of emails you receive from us (or from our Customer), or (iii) at any other time by sending an email stating your request to [email protected]. We will try to comply with your request(s) as soon as reasonably practicable. Please also note that if you, as a Website Visitor or Customer, opt-out of receiving marketing-related emails from us (or as an End-User opt-out of receiving marketing-related emails from one of our Customers), we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.
• Adobe Flash technology (including Flash Local Shared Objects ("Flash LSO") and other similar technologies. We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel available at http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html. You can also control Flash LSOs by going to the Global Storage Settings Panel, available at http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager03.html, and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to as "information" on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Services or our online content.

Accessing and Correcting Your Information

Upon request, Kumon will provide you with information about whether we hold any of your Personal Information. If you are a registered user of one of our Services, you can review, request deletion, and change your Personal Information and/or email marketing preferences by logging into the Services and visiting your account profile page. For example:

• Users of our Event Management application may update or correct their Personal Information, other profile settings and user preferences by using the User Profile Manager within the "My Account" section of the App.
• Users of Kumon mobile applications can update or correct their Personal Information or other profile information, using the Online Event Guide or within the native mobile application. Users who have opted to join an event attendee list (visible to other users of the mobile application for that event) have the option to later hide themselves from the list if desired.

You may also send us an e-mail at [email protected] to request access to, correct or delete any Personal Information that you have provided to us. In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information that you have provided to us. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will respond to your request within a reasonable timeframe. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Please note that we may need to retain certain personal information for the period of time necessary to fulfill the purposes outlined in this Privacy Policy, including, for example, record keeping purposes, including but not limited to completing any transactions that you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion), or to comply with applicable law. There may also be residual information that will remain within our databases and other records, which will not be removed.

Children Under the Age of 13

Our Services are not intended for children under 13 years of age. We do not directly solicit or collect Personal Information from children under 13. If you are under 13, do not (i) use or provide any information on these Services or on or through any of its features, (ii) register to use any of our Services, (iii) make any purchases through our Services, (iv) use any of the interactive or public comment features of our Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use.

Cross-Border Transfers (other than to the E.U. or Switzerland)

Although Services are controlled and operated by us from the United States, Your Personal Information may be accessed by Kumon personnel providing Services in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

Data Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the "Contact Information" section below.

Information Collected on behalf of our Customers

Kumon collects information under the direction of its Customers, and has no direct relationship with the End-User individuals whose Personal Information it processes. If you are an End-User of one of our Customers and would no longer like to be contacted by one of our Customers that use our Service, please contact the Customer that you interact with directly. We may transfer Personal Information to companies that help us provide our Service. Transfers to subsequent third parties are covered by the service agreements with our Customers.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate Personal Information should direct his query to Kumon’s Customer (i.e., the data controller). If requested to remove Personal Information we will respond within a reasonable timeframe.

We will retain Personal Information we process on behalf of our Customers for as long as needed to provide services to our Customer. Kumon will retain this Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Changes to Our Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by means of a notice on this Website thirty (30) days prior to the changes becoming effective, or by email (sent to the e-mail address specified in your account) seven (7) days prior to the changes becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: [email protected]

Please note that email communications are not always secure; so please do not include credit card information or sensitive information in your emails to us.