GLOBAL PRIVACY NOTICE

Last updated 20.12.19
Effective: 25 December 2019

Introduction

When you use Bright Horizons’ services, you trust us with your personal data. We are committed to keeping that trust, which starts with sharing our privacy practices. This Privacy Notice explains in detail what personal data we collect and how we use that information.

This Notice applies to any user of Bright Horizons’ services, websites, apps and social media anywhere in the world. Bright Horizons’ services include child and adult care, consulting, educational advising and tuition assistance.

This Notice is not intended to apply to any user whose personal data we are processing as a job applicant, apprentice, agency worker, employee and supplier.

Effective Date of Privacy Notice: 25 May 2018

Who controls your personal data?

Bright Horizons is made up of a number of related companies. This section gives you the legal name of the Bright Horizons’ company processing your personal data as the data controller and tells you how to get in touch with us.

  • If you use our services in the United States, Canada, or India, Bright Horizons Family Solutions LLC at 200 Talcott Avenue South, Watertown, Massachusetts 02472, USA is the data controller.This entity also includes services under our brand names Care Advantage, Special and Exceptional Needs, Workforce Consulting, EdAssist and College Coach.
  • If you use our services in the United Kingdom or Ireland, Bright Horizons Family Solutions Limited (Co. No. 2328679) at 2 Crown Court, Rushden, Northamptonshire, NN10 6BS, UK is the data controller.This entity also includes services under our brand names Care Advantage, Yellow Dot, Zoom, Asquith, Active Learning, Kids Unlimited, Active Learning, Casterbridge and Teddies.
  • If you use our services in the Netherlands, Kindergarden Nederland B.V. (Co. No. 33303797) at Herengracht 244, 1016 BT Amsterdam, Netherlands is the data controller.

For any questions, please contact our Global Privacy Officer by email at dataprivacy@brighthorizons.com or by post at the United Kingdom address listed above.

For simplicity throughout this Notice, ‘we’ and ‘us’ means Bright Horizons, its related companies and brands.

Why does Bright Horizons collect personal information?

Consent: We rely on your consent to process your personal data in very limited circumstances such as when you provide personal data to receive publications (e.g. newsletters, brochures, research studies), information on events or webinars and news about our company and services. After you sign up to receive communications you have the right to opt out at any time.

Performance under a Contract: Most of your personal data we process is necessary to perform our obligations under a contract we have with you, or your employer if you receive our service as an employee benefit. We can only provide the service to you or your dependents, if you provide us with the personal data necessary to perform the contract.

Legal Obligations: Across all of the services we provide, there are many laws that require us to process your personal data. We can only provide the service to you or your dependents, if you provide us with the personal data required under law. Examples include child/adult care regulations, safeguarding/health/safety regulations, tax and government funding regulations.

Legitimate Interests: In some situations, we process your personal data to pursue our legitimate interests as a business. We will only process your personal data if our legitimate interests do not materially impact your interests, fundamental rights, or freedoms. Examples include:

  • If you are a prospective, current or former customer, using your contact details to follow-up either by email, post, telephone or in-person to obtain your feedback on our service offering, reasons for choosing or not choosing our services and your experiences with our company.
  • If you are a prospective, current or former customer, using your email address to send you our newsletters, invitations to our webinars, informational publications, and new/enhanced service updates. You have the right to opt out of receiving these communications at any time.
  • Using your purchase, utilization and inquiry history to make personalized offers for our services available to you.
  • Combining the demographic information of our customers such as post codes, number of children and children’s ages to identify service trends, location expansions/closures, and new locations.
  • Combining the care and service information of our customers to identify trends, learning opportunities and training needs within the company, as well as, to calculate statistics and support improving our service or developing new services.
  • Tracking your website interactions to determine the effectiveness of our websites, promotional campaigns and advertising.
  • In some locations, using CCTV cameras/footage to assist with crime prevention, monitoring our policies/procedures, training and development, internal and external investigation/proceedings and law enforcement activities.
  • Recording your contact center calls to assist with monitoring our policies and procedures and identifying opportunities for training and development.

When do we collect your personal data?

How you interact with us, determines when we collect your personal data.

When you use our websites, apps and social media:

  • Visiting any of our websites or engaging with us on an app or social media.
  • Contacting us for information or customer service.
  • Creating an account and updating your account information.
  • Registering or making a reservation for our services.
  • Making a payment for our services.
  • Downloading or installing one of our apps.

When you call our Contact Centers

  • Contacting us for information or customer service.
  • Booking a visit or appointment for one of our services.
  • Creating an account and updating your account information.
  • Registering or making a reservation for our services.
  • Making a payment for our services.

When you contact or receive services directly

  • Contacting us for information or customer service on the telephone, email or in person.
  • Booking a visit or appointment for one of our services.
  • Registering for our services.
  • While receiving services, completing electronic and paper forms, assessments and other documentation.

What personal data do we collect and process?

The main reason we collect and process your personal data is to provide, evaluate and improve our services and your experiences with us.

Information you provide voluntarily (by telephone, online or in-person):

  • If you are a prospective customer, your contact details and other information necessary to fulfill your request for information. .
  • If you are a customer, when registering for our services or during the course of receiving our services:
    o For child/adult care services, types of personal data may include your: personalized registration user name and password; personal and work contact details; proof of identity records such as driver’s license or passport) dependent’s details such as birth certificate, name, date of birth, gender, allergies, food restrictions, special needs, health information, and emergency contact details for doctors and alternative care providers; and payment details.

    o For College Coach services, types of personal data may include your: personalized registration user name and password; personal and work contact details; financial information in relation to saving/paying for college; dependent’s details such as name, date of birth, gender, ethnicity, educational preferences, career/educational goals, school transcripts, entry exam results, applications, registrations and any other information you provide for advisory assistance; and payment details.

    o For EdAssist services, types of personal data may include your: personalized registration user name and password; personal and work contact details; course details, transcripts and receipts; and any other information required by your employer to implement their tuition assistance benefit.

Information we create/process when you use our services:

  • Details of your visits to our websites, apps, and social media, as well as information gathered by the use of cookies in your web browser. Learn more about how we use cookies and similar technologies.
  • For all our services, we create records during the course of providing services to you or your dependents such as notes from meetings/calls. Records created during child/adult care include notes or the completion of forms recording activities and behaviors such as illness, sleep, diaper changes, meals, medication, learning, interactions with others, and accidents. For childcare we take photographs of children to share with their parents and as part of their learning journey records.
  • Utilization information, such as dates of service, type of service, user of service and reasons for service.
  • Payment information.
  • For locations with CCTV cameras we may capture your and your dependent’s image, as well as your car license plate.
  • Social media username and public comments/feedback on social media so that we can respond to comments, questions or feedback. These online and social media sites typically have their own privacy policies explaining how they use and share your personal data. You should carefully review those privacy policies before using these sites to make sure that you are happy with how they collect and share your personal data.

Information from third parties:

  • If you receive our service as part of an employee benefit, we may receive personal data from your employer on your eligibility to use the service and other reporting identifiers.
  • If you receive government funding, we receive personal data from the government on your eligibility for the funding and other reporting identifiers.
  • Government agencies may provide us with personal data to support their regulatory obligations or investigations.
  • Third party marketing companies provide us with contact details for individuals who have consented to receive marketing materials. You have the right to opt-out of these communications at any time.

Why do we collect personal data?

We limit the collection of personal data to what is necessary to provide you with high-quality services, to support your requests, and to meet our business needs in connection with the services. We do not sell your personal data to any third parties. Below we have highlighted our reasons for collecting your personal data:

  • Respond adequately to your requests for services or information.
  • Provide services to individuals, families and employers that include childcare and other dependent care, education (general, higher and accredited education), wellbeing and work/life support, and consulting.
  • Provide a safe, healthy, and environment for those to whom we provide services.
  • Provide resource material/information regarding our services and areas of interest to our customers, such as parenting, childcare, adult care, education, wellbeing, and work/life balance.
  • Aid in the administration of our services to our customers.
  • Administer first aid, emergency and other medical care, when necessary.
  • Comply with laws, and government regulations/standards.
  • Support with education, training, curriculum, communication, administration, and record-keeping.
  • Provide utilization reports and other information to employers offering our services as an employee benefit.
  • Facilitate and process payments for the services.
  • Fulfill tax, reporting, and other financial requirements and obligations.
  • Prevent or detect unlawful acts.

Where do we process and store your personal data?

Electronic Information:

Although some personal data may remain on electronic storage data systems in the country where we provide the service, it may also be processed and stored in the United States. For example, the contact centers and systems supporting our back-up care services are located in the United States. Please see below for more information on our adherence to the EU-US Privacy Shield Framework.

Hardcopy information:

The hardcopy of personal information we collect remains in the country where you receive the services or provide the information.

Our adherence to the EU-US Privacy Shield Framework

Bright Horizons Family Solutions LLC complies with the EU-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data we transfer from the European Union to the United States. Bright Horizons Family Solutions LLC certified to the Department of Commerce that it adheres to the Privacy Shield Principles. The Federal Trade Commission has jurisdiction over our compliance with the Privacy Shield.

If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program and view our certification, please visit https://www.privacyshield.gov.

Under certain circumstances, you have the right to invoke binding arbitration for complaints regarding our Privacy Shield compliance that you have been unable to resolve through any of the other Privacy Shield mechanisms. To learn more about the binding arbitration mechanism, please visit https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

In compliance with the Privacy Shield Principles, Bright Horizons Family Solutions LLC commits to the following:

  • Resolve complaints about our collection or use of your personal data. If you have questions or complaints regarding our adherence to the EU-US Privacy Shield Framework, please contact our Global Privacy Officer at dataprivacy@brighthorizons.com or 2 Crown Court, Rushden, Northamptonshire, NN10 6BS, United Kingdom.
  • Cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to personal data transferred from the European Union.
  • Remain responsible and liable for the processing of personal data we receive under the Privacy Shield and subsequently transfer to a third party acting as an agent on our behalf.

Who do we share your personal data with?

We consider your personal data confidential and do not share it with others except as described in this Privacy Notice. There are limited circumstances that require us to disclose your personal data to others in order to deliver services, or to meet our legal obligations or legitimate business interests. Examples include:

  • Your Employer: Bright Horizons services are often made available to you as an employee benefit. In order to meet our obligations with your employer, we provide details of your use of the services, which may include your name, dates of use, reasons for use, and other employer requested utilization details. We disclose only information relevant to the utilization of the services or necessary for their administration of the benefit.
  • Subcontractors and Other Agents: We sometimes employ or contract with other companies and individuals to perform functions on our behalf, such as providing dependent care services, recruiting services, and supporting our systems and contact centers. Depending upon the type of service they are providing, we may share sensitive personal data only as appropriate and necessary for the performance of the service. These parties are under contractual obligations to use your personal data only as directed by us and as needed to perform these functions. All are under a legal duty to handle such data in accordance with Bright Horizons’ information security and confidentiality standards, and this Privacy Notice.
  • Business Transfers: As we continue to develop our business, we might sell or buy assets. If any Bright Horizons business unit is sold or substantially all of Bright Horizons is acquired, personal data relevant to the operation sold may be transferred as part of the transaction.
  • Meet Legal Requirements: We share personal data if required by law/regulations or as we reasonably determine to be necessary to protect our rights or the rights of others, to prevent harm to persons or property, to fight fraud, or to enforce our website terms of use. For example, a government (in the United States, European Union, Canada or India) may require us to disclose personal data for national security or law enforcement purposes.

How long do we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected and as required under law. At the end of that retention period, your data will either be deleted completely or anonymized, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

What rights do you have over your personal data?

You have the right to request:

  • Access to the personal data we hold about you, free of charge in most cases.
  • The correction of your personal data when incorrect, out of date or incomplete.
  • That we stop using your personal data for direct marketing (either through specific channels, or all channels).
  • That we stop any consent-based processing of your personal data after you withdraw that consent.

To ask for copies of your personal data, please complete our Data Subject Access Request Form and return it to dataprivacy@brighthorizons.com or the relevant address on the Form. To ask for your information to be amended, please update your online account, or contact our contact center team or the location providing the service directly.

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request. There are several ways you can stop direct marketing communications from us:

  • Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular mailing list.
  • If you have an account, log in into your account and change your preferences.
  • In our apps, you can manage your preferences and opt out from one or all of the different notifications by selecting or deselecting the relevant options in the ‘Settings’ section.

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Notice. If you have authorized a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the relevant data protection regulator.

  • UK Regulator: Information Commissioner’s Office at www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites.)
  • Ireland Regulator: Data Protection Commissioner/An Coimisinéir Cosanta Sonraí at www.dataprotection.ie/docs/Home/4.htm (opens in a new window; please note we can't be responsible for the content of external websites.)
  • Netherlands Regulator: Autoriteit Persoonsgegevens (Dutch Data Protection Authority – Dutch DPA) at https://autoriteitpersoonsgegevens.nl/en/contact-dutch-dpa/contact-us (opens in a new window; please note we can't be responsible for the content of external websites.)
  • Canada Regulator: Office of the Privacy Commissioner of Canada at https://www.priv.gc.ca/en/ (opens in a new window; please note we can't be responsible for the content of external websites.)

How do we protect your personal data?

We utilize appropriate technical, administrative and physical safeguards to protect your personal data we collect in both physical and electronic format. We provide training to our staff and conduct periodic quality assurance audits. However, no computer system or information can ever be fully protected against every possible hazard. As a result, Bright Horizons cannot guarantee the security and privacy of the information you provide to us.

You also play a valuable part in protecting the security of your information. Your password to access your registration information should never be shared with anyone and should be changed frequently. After you have finished using our site, you should log out and exit your browser to prevent unauthorized users from returning to your online Bright Horizons account. If you believe that someone has improperly used your account or provided information about you that you did not authorize, please contact us immediately at dataprivacy@brighthorizons.com.

Will this Privacy Notice change?

This Privacy Notice is subject to change and we will post revisions on our website. Please check back periodically, especially before you provide any personal information. This privacy policy was last updated in May 2018.

Questions?

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven’t been covered, please contact our Global Privacy Officer who will be pleased to help you:

  • Email us at dataprivacy@brighthorizons.com
  • Or write to us at Attn: Global Privacy Officer, 2 Crown Court, Rushden, Northamptonshire, NN10 6BS, United Kingdom.

Privacy Notice for California Consumers (Residents) ONLY

About this supplemental Privacy Notice

This Privacy Notice for California Consumers (Residents) supplements the information contained in the Bright Horizons Global Privacy Policy and applies exclusively to all visitors, users, and others who reside in the State of California (“consumers” “households” or “you”). We adopt this Privacy Notice to comply with the California Consumer Privacy Act 2018 (CCPA) and its Regulations that are laid down by the Attorney-General of California from time to time. Any terms defined in the CCPA have the same meaning in this Privacy Notice.

A separate supplemental Privacy Notice for prospective, current and former staff members and suppliers (including Bright Horizons’ employees, apprentices, agency workers and contractors) working in the State of California is accessible here.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a California consumer/household or device (“personal information”).

Categories of Personal Information

of California consumers processed by us during the last twelve (12) months:

Excluded from the definition of ‘personal information’ under the CCPA is ‘aggregate consumer information’ that’s defined as data that’s ‘not linked or reasonably linkable to any consumer or household, including via a device,’ as well as information that’s publicly available from federal, state or local government records.
Also excluded from the definition of ‘personal information’ is:

  • information excluded by the CCPA including health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act 1994.

Under the definition of ‘personal information’ under the CCPA, Bright Horizons obtains the categories of personal information from the following sources:

  • directly from you, for example, when you complete an online form or enter into an agreement with us; or
  • indirectly from you, for example, when we track how you utilise our Websites;
  • If you receive our service as part of an employee benefit, we may receive personal information from your employer on your eligibility to use the service and other reporting identifiers.
  • If you receive government funding, we may receive personal information from the government on your eligibility for the funding and other reporting identifiers.
  • Government agencies may provide us with personal information to support their regulatory obligations or investigations.
  • Third party marketing companies provide us with contact details for individuals who have consented to receive marketing materials. You have the right to opt-out of these communications at any time.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:
  • To fulfil or meet the reason you provided the personal information. For example, if you share your name and contact information to ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a service, we’ll use that information to process your payment and ensure you receive that service. We may also save your personal information to facilitate new orders for our services.
  • To provide, support, personalize, and develop our Website and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and respond to your concerns and monitor and improve our responses.
  • To personalize your Website experience.
  • For testing, research, analysis, and product development, including to develop and improve our Website and services we deliver to you.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise provided under the CCPA and its Regulations.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Bright Horizon’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Bright Horizons about our Website users is among the assets transferred.

Sharing Your Personal Information

We may be required to share your personal information as part of delivering our services to you. This could be with our subsidiaries, affiliates, business lines or other third-party interests. The following lists the categories of third parties whom we may share your personal data as well as the purposes for doing this.

  • Our affiliates, subsidiaries and business lines

    We may share your personal information within our company and subsidiaries insofar as reasonably necessary for the purposes and legal bases as set out under this supplemental privacy notice.

  • Contractors and service providers

    We may disclose your personal information to contractors and service providers, such as our insurers and professional advisors, insofar as reasonably necessary for the purposes of obtaining or maintaining insurance cover, managing risks, obtaining professional advice or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure in the State of California.

  • Contractors and service providers

    We may disclose categories of personal information as listed in this supplemental privacy notice to our suppliers and subcontractors insofar as reasonably necessary for delivering our services to you.

  • Third Parties with whom we partner

    Financial transactions relating to our website and services may be handled by our payment services providers. Well share transaction data with our payment service providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

  • Legal, regulatory, federal, state or local government body/agency

    In addition to the specific disclosures of personal information as set out in this supplemental privacy notice, we may disclose your personal information where such disclosure is necessary for compliance with a legal obligation under federal law or state/local laws of California to which we are subject. We may also disclose your personal information where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure in the State of California.

Sale of your personal information

Bright Horizons will never sell your personal information.

Your rights and choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Personal Information/Right to Data Portability

ou have the right to request that Bright Horizons disclose certain information to you about the personal information we have collected over the past 12 months. Once we receive your request for access to certain information and are able to verify your identity or the identity of your representative that has the legal authority to act on your behalf, we’ll disclose to you:
  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you.
  • Where we disclosed personal information for a business purpose, the categories of personal information that each category of recipient obtained from us.

In addition, you have the right to data portability. This applies where we respond to an access request electronically. In such circumstances, we are required to provide the personal information to you in a portable, technically feasible, and ready-to-use format.

Deletion of Personal Information

You have the right to request that Bright Horizons delete all/any of your personal information that we have collected in the last 12 months.
Once we receive your request for deletion and are able to verify your identity or the identity of your representative that has the legal authority to act on your behalf, we’ll delete (and also direct our service providers to do the same) your personal information from our records, unless an exception under the CCPA applies. If this is the case, we will inform you.
There are circumstances under which we may deny your deletion request under the CCPA. For example, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Exercise freedom of speech and ensuring the right of another consumer to exercise their right to free speech or exercise another right provided for by federal or state laws.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation under federal, state or local laws in the State of California.
  • Make other internal and lawful uses of that personal information that are compatible with the context in which you provided that information.

Exercising Your Access, Data Portability and Deletion Rights

To exercise the access, data portability, and deletion rights as outlined above, please submit your request by either:
Mail: Attn of the Global Privacy Officer, 2 Crown Court, Rushden, Northamptonshire, NN10 6BS, United Kingdom
Webform: Click Here
Toll free: 1-855-853-4204 (8:00-5:00, Pacific Time, Monday-Friday). Outside of office hours, please inquire by using our webform.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your child under the age of 16 years old.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we processed personal information or a legally authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We can’t respond to your request or provide you with personal information if we can’t verify your identity or legal authority to make the request and confirm the personal information relates to you or the subject of the request.

Making a verifiable consumer request doesn’t require you to create an account with us. We’ll only use personal information provided in a verifiable consumer request to verify the requestor’s identity or legal authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we’ll deliver our written response to that account. If you don’t have an account with us, we’ll deliver our written response by mail or electronically in accordance with your preference.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we can’t comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that’s readily useable and should allow you to transmit the information from one entity to another entity without any technical difficulty.

We don’t charge a fee to process or respond to your verifiable consumer request unless in exceptional circumstances it’s excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will advise you why we made that decision and provide you with a cost estimate before completing your request.

Non-discrimination

We’ll never discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we won’t:

  • Deny you services.
  • Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of services.
  • Suggest that you may receive a different price or rate for services or a different level or quality of services.

However, at our discretion, we may offer certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write or email to us at:
Mail: Attn of the Global Privacy Officer, 2 Crown Court, Rushden, Northamptonshire, NN10 6BS, United Kingdom
Emaildataprivacy@brighthorizons.com

Will this Supplemental Privacy Notice change?

This Privacy Notice is subject to change in order to remain compliant with data protection and privacy laws in the State of California. We will post revisions to this Privacy Notice on our websites. Please check back periodically, especially before you provide any personal information.

This Notice was last updated in December 2019. Your continued use of our Websites following the posting of changes to this Supplemental Privacy Notice constitutes your acceptance of such changes.

Any Questions?

We hope this Supplemental Privacy Notice has been helpful in setting out the way we process your personal information and how we do this in accordance with the CCPA.

If you have any questions that haven’t been covered by this Privacy Notice, please contact our Global Privacy Officer at:
Email:  dataprivacy@brighthorizons.com; or
Mail:  Attn: Global Privacy Officer, 2 Crown Court, Rushden, Northamptonshire, NN10 6BS, United Kingdom.