Last Updated: July 7, 2020
I. Who is Daekyo America Inc.?
Daekyo America, Inc. (“DA” or “We”) is a franchisor of after-school learning centers. DA is a subsidiary of Daekyo Co. Ltd., located in Seoul, South Korea. DA grants franchises in the U.S. and Canada for locations operating under the “Eye Level Learning Center” name pursuant to a franchise agreement. Our franchised locations are independently owned and operated; we also operate two company-owned centers that are like our franchised locations. DA’s principal business address is 105 Challenger Road, Ridgefield Park, NJ 07660. We are a California corporation.
II. 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 particular consumer or device (“Personal Information” or “PI”). In particular, we have collected the following categories of Personal Information from consumers within the last 12 months:
Traditional personal identifiers- (i.e. real name, postal address, account name, center number, *Social Security Number, signature, birthdate)
Online personal identifiers (i.e. cookies, beacons pixel tags, Internet protocol address, email address)
Or other similar identifiers.
(*Social Security Number- collected only for employees or franchisees while undergoing a background check)
B. Internet or other electronic network activities
Your interaction with our websites and training portals (if you are a franchisee or currently participating in one of our training programs).
III. How We Use the Information Collected
We use the information we collect for the following purposes:
· To analyze learning results
· To provide learning progress consulting to parents
· To retarget our marketing
· To develop curriculum and training for DA’s franchisees
· To provide training to DA employees
· To verify a user’s identity
· To communicate with user’s via email, our social media platforms, postal mail, phone, instant messaging, or other means
· To monitor the progress of our franchisees in our training programs
· To respond to users’ inquiries
· To process PI or other information that you submit through us
· To comply with and enforce relevant standards, contractual obligations, and our policies
· To notify users of data privacy incidents
· To use in any other way we may describe and for which we obtain your consent when you provide the information and you give your consent
A cookie is a text file that is placed on your hard drive of your computer or mobile device. Cookies are uniquely assigned to you in the form of a unique number, and in some instances, an expiration date. Cookies are managed by the web browser on your computer or mobile device (i.e. Google Chrome, Internet Explorer, Safari).
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. Accordingly, when you return to our public websites (our main website is www.myeyelevel.com), the information you previously provided can be retrieved so that you can use the site features that you customized.
You can accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the DA services or website you visit.
Automatic Data Collection Methods/Data Collected
Certain Personal Information that we collect is automatically collected using your computer or mobile device and includes the following:
Traffic data, geolocation data, IP address, browser type, amount of time spent on our websites, and pages viewed on our websites.
We also utilize pixel tracking. Pixel tracking measures the effectiveness of our advertisements and helps us to analyze website visits, digital ad impressions, and conversions to an Eye Level member. A pixel tag is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity.
V. Sharing and Storing of Your Information
DA has never and will never rent or sell Personal Information to anyone.
We may disclose PI to employees, service providers, franchisees, and our corporate parent that (i) have a need to know that information for at least one of the purposes listed in Section III above and (ii) have agreed not to disclose PI to others.
As mentioned in I above, our parent company is in Seoul, South Korea. Some of the PI you provide to us is stored on servers at our parent company. We reserve the right to process, transfer or maintain your PI on servers or databases located in the U.S. and elsewhere. Your use of our websites or enrolling your child in our programs represents your agreement to such storage and transfer of PI. We also store PI on our service provider platforms that DA utilizes to perform our normal business functions.
DA also utilizes third party services such Google Analytics and Facebook Analytics to help us better understand the effectiveness of our advertising and the use of our services. DA does not share your personal information with these third party companies.
VI. Privacy Notice to California Residents
Subject to certain limitations, if you are a California resident, California law provides you with additional rights regarding DA’s use of your Personal Information under the California Consumer Privacy Act (“CCPA”) of 2018. Those rights include the following:
a. A right to access Personal Information collected over the past 12 months, including:
· Categories of PI collected about you
· Categories of sources from which that PI is collected
· Purpose for collecting that PI
· Categories of third parties with whom we share that PI
· Specific pieces of PI collected
b. A right of deletion of PI;
c. A right of disclosure of whether PI is sold; and
d. If c. is applicable, a right to opt-out of the sale of PI.
Regarding c. directly above, we, including our service providers, do not sell your Personal Information as “sell” is defined in CCPA.
Methods for Exercising Rights Under CCPA
To exercise a right afforded by CCPA you can do the following:
· Call us toll free 888.835.1212
Right to Deletion
You have the right to request that we delete any of your PI that we collected from you and retained. Once we receive and confirm your verifiable consumer request, DA will delete your PI from our records, unless an exception applies under CCPA.
The CCPA specifies numerous exceptions for a deletion request. We will notify you if DA thinks one of those exceptions applies to your deletion request.
Verification Process/Response Timing/Format
DA cannot respond to your request or provide you PI if we cannot verify your identity or authority to make the request and confirm that the PI relates to you.
If you have an account with DA, we will require you to submit the request through that account. If you do not maintain an account with DA, we will respond by regular mail or email, based on your request. You do not have to create an account with DA to make a verifiable consumer request.
Upon receiving a request for PI access or deletion request from you, we will ask you to respond to verify you as the consumer making the request. Upon receipt of your verification, we will match your information to that which DA has on file (if any). Upon verification of your identity, we will proceed to process your request.
DA will confirm receipt of your request within ten days of receiving it. We will respond to a verifiable consumer request within 45 days. If we require more time, we will inform you of such extension in writing before the initial 45 days has expired. The extension will not be more than 45 additional days.
We will not discriminate against you if you exercise any of the rights under CCPA. For example, we will not do the following:
· deny your right to enroll your child at an Eye Level Learning Center
· charge different prices, including by refusing to grant discounts or other benefits at our franchised centers
· change the level of the quality of goods or service
VII. How We Protect Your Personal Information
DA and its corporate parent maintain administrative, technical, and physical safeguards designed to protect the PI you provide to us against accidental, unlawful or unauthorized destruction, loss, altercation, disclosure or use of PI. While we strive to use commercially reasonable means to protect your PI (such as encryption and Secure Socket Layer protocol) we cannot guarantee its absolute security and will not be responsible for any accidental, unlawful or unauthorized destruction, loss, alternation, access, disclosure or use of any PI you have given to us.
VIII. General Retention and Deletion Policies
Absent federal or state law which will always take precedence, DA will retain PI for at least one year for a student’s last dropped subject. Sometimes parents may request to resume our programs for their child. Retaining this data for one year will help DA provide the accurate starting point upon resumption by analyzing the learning history of the student if the student resumes within a one-year period.
IX. General Rights with Regard to your PI
You may request the following from DA:
· Inquire and request a review your PI
· Make duplications of your PI, but you must explain the reason for such a duplication request
· Correct or supplement your PI
· Discontinue collection processing or using your PI
· You may request that DA delete your PI
DA may reject your above requests if it is inconsistent with our privacy procedures or DA has an obligation to keep such PI according to state or federal law.
You can decide whether to provide DA Personal Information. However, if your child enrolls in our programs, DA may not be able to provide relevant or optimal services due to the lack of PI that we typically use to determine educational progress for your child and consulting with you regarding your child’s progress in our programs.
You may exercise your rights under this policy by contacting us as indicated in XI below.
X. Children Under 13
DA does not knowingly solicit, collect, or maintain any PI about anyone under the age of 13 on our public websites. DA will only collect personal information about a child from their parent upon enrollment at one of our Eye Level Learning Centers. Once enrolled as a member, DA we then will use your child’s information, as noted in III. above, to analyze your child’s learning results and to provide learning progress consulting.
XI. How to Contact Us
· Call us toll free 888.835.1212