Privacy Policy
Credits for this Privacy Policy are here.
Last Updated: March 8, 2025
Your privacy is critically important to us. At Wholesome Learning, LLC (“we,” “our,” and “us”), we have a few fundamental principles:
- We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
- We store personal information for only as long as we have a reason to keep it.
- We help protect you from overreaching government demands for your personal information.
- We aim for full transparency on how we gather, use, and share your personal information.
Below is our Privacy Policy, which incorporates and clarifies these principles.
Who We Are and What This Policy Covers
This Privacy Policy applies to information that we collect about you when you use:
- Our websites (including wholesome-learning.com);
- Our products, services, and features that are available on or through our websites; and
- Other users’ websites that use our Services, while you are using our Services.
This Privacy Policy also applies to information we collect when you apply for a job at Wholesome Learning, LLC.
Throughout this Privacy Policy we’ll refer to our websites and other products and services collectively as “Services.”
Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.
Creative Commons Sharealike License
We’ve decided to make this Privacy Policy available under a Creative Commons Sharealike license. You’re more than welcome to copy it, adapt it, and repurpose it for your own use. Just make sure to revise the language so that your policy reflects your actual practices. If you do use it, please credit and link to the company we adapted this policy from, Automattic, somewhere on your site.
Information We Collect
We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better.
We collect this information from three sources: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.
Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us directly. Here are some examples:
- Basic account or registration information: We ask for basic information from you in order to set up your account or registration and to enable us to provide our Services. For example, we require individuals who register for a summer camp to provide the student and parents’ names, phone number, email address, and similar information.
- Other account or registration information: To provide some of our Services, additional information is required. For example, we require individuals who register for a summer camp to provide medical information to help us respond as appropriately as we can in the case of an emergency. Our summer camp registrants will also sign agreements, such as a student conduct agreement, medical treatment authorization, and similar agreements. We store copies of these agreements, including any signatures provided.
- Payment and contact information: There are various ways in which you may provide us payment information and associated contact information. For example, if you buy something from us, we’ll collect information to process those payments and contact you. This may include personal and payment information like your name, credit card information, and contact information. We also keep a record of the purchases you’ve made.
- Communications with us (hi there!): You may also provide us with information when you respond to surveys, ask us a question, or sign up for a newsletter. When you communicate with us via form, email, phone, or otherwise, we store a copy of our communications.
- Financial aid-related information: If you apply for financial aid from us, you may provide us financial information that will be used to determine whether you are eligible for financial aid from us. We store a copy of this information.
- Job applicant information: You may provide us with information like your name, contact information, resume or CV, professional or personal references, similar professional and employment-related data, and work authorization verification as part of the application process. We may also collect additional information about you during the process, like background and credit checks (in applicable jurisdictions and only for certain job roles). You may also provide us with demographic information when required by law or if you voluntarily submit such information as part of your application. We collect demographic information in accordance with applicable law. We will only use this sensitive information to accommodate a disability or illness, comply with legal obligations, or protect the health and safety of our employees and students.
Information We Collect Automatically
We also collect some information automatically:
- Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services.
- Transactional information: When you make a purchase through our Services, we collect information about the transaction, such as product details, purchase price, and the date and location of the transaction. This includes when you purchase something we sell or when you use our Services to buy something from a third party.
- Usage information: We collect information about your usage of our Services. For example, we collect information about the actions that site administrators and users perform on a site — in other words, who did what and when. We also collect information about what happens when you use our Services (e.g., page views) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, get insights on how people use our Services so we can make our Services better, and understand and make predictions about user retention.
- Location information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions.
- Information from cookies & other technologies: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. We may use cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Services, as well as track and understand email campaign effectiveness and to deliver targeted ads.
Information We Collect from Other Sources
We may also get information about you from other sources. For example, our payment processor may provide us personal and payment information like your name, credit card information, and contact information.
The information we receive depends on which services you use or authorize and what options are available.
How and Why We Use Information
Purposes for Using Information
We use information about you for the purposes listed below:
- To provide our Services. For example, to register your student, operate our summer camp, provide customer service, process payments, and verify user information.
- To ensure quality, maintain safety, and improve our Services. For example, by monitoring and analyzing how users interact with our Services so we can make our Services easier to use.
- To market our Services and measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to groups of our users, advertising our Services, analyzing the results of our marketing campaigns, and understanding and forecasting retention.
- To protect our Services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of Wholesome Learning, LLC and others, which may result in us, for example, declining a transaction or terminating Services.
- To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
- To communicate with you. For example, by emailing you to ask for your feedback, texting you to verify your payment, or contacting you to share offers and promotions that we think will be of interest to you. If you don’t want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we’ll still send you important updates relating to your account or registration.)
- To recruit and hire new employees. For example, by evaluating job applicants (including verifying their identity, experience, and other information submitted) and communicating with them by phone, email, or social media platforms. If the application progresses, we may also collect interview information and background check information. This may also include verifying information required to initiate employment, for purposes such as confirming ability to legally work in a specific location, setting up payroll, and complying with statutory reporting requirements.
Legal Bases for Collecting and Using Information
Our use of your information is based on the grounds that:
(1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device or charge you for a paid Service; or
(2) The use is necessary for compliance with a legal obligation; or
(3) The use is necessary in order to protect your vital interests or those of another person; or
(4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or
(5) You have given us your consent.
Sharing Information
How We Share Information
We share information about you in limited circumstances, and with appropriate safeguards on your privacy. These are spelled out below:
- Subsidiaries and independent contractors: We may disclose information about you to our subsidiaries and independent contractors who need the information to help us provide our Services or process the information on our behalf. We require our subsidiaries and independent contractors to follow this Privacy Policy for any personal information that we share with them.
- Third-party vendors: We may share information about you with third-party vendors who need the information in order to provide their services to us, or to provide their services to you or your site. This includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, cloud storage services, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you, registrars, registries, and data escrow services that allow us to provide domain registration services); those that assist us with our marketing efforts (e.g., by providing tools for identifying a specific marketing target group or improving our marketing campaigns, and by placing ads to market our services); those that help us understand and enhance our Services (like analytics providers); those that make tools to help us run our operations (like programs that help us with task management, scheduling, word processing, email and other communications, and collaboration among our teams); other third-party tools that help us manage operations; and companies that make products available on our websites, who may need information about you in order to, for example, provide technical or other support services to you.
- Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.
- To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Wholesome Learning, LLC, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
- Business transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the event that Wholesome Learning, LLC goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.
- With your consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties when you authorize us to do so.
- Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services, or share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
- Published support requests: If you send us a request for assistance, we reserve the right to publish that request in order to clarify or respond to your request, or to help us support other users.
Information Shared Publicly
Information that you choose to make public is — you guessed it — disclosed publicly.
How Long We Keep Information
We generally discard information about you when it’s no longer needed for the purposes for which we collect and use it — described in the section above on How and Why We Use Information — and we’re not legally required to keep it.
If you are a job applicant, we will keep your personal data during the application process, and for a certain period thereafter. To determine that period, we take into account a number of factors, like our legal and regulatory obligations (such as equal opportunity obligations) and whether we may need to retain personal data for internal business purposes like analyzing our applicant pool.
Security
While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We monitor our Services for potential vulnerabilities and attacks.
Choices
You have several choices available when it comes to information about you:
- Limit the information that you provide: If you have an account or registration with us, you can choose not to provide information to us. Please keep in mind that if you do not provide certain information, we may not be able to provide certain Services to you. If you are a job applicant, and you choose not to provide certain data elements to us, we may not be able to proceed with the recruitment process.
- Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account or registration and legal notices.
- Set your browser to reject cookies: At this time, Wholesome Learning, LLC does not respond to “do not track” signals across our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using our website, with the drawback that certain features of our websites may not function properly without the aid of cookies.
- Close your account or registration: You can close your account or registration if you no longer want to use our Services. Please keep in mind that we may continue to retain your information after closing your account or registration, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.
Your Rights
If you are located in certain parts of the world, including some US states and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.
European General Data Protection Regulation (GDPR)
If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:
- Request access to your personal data;
- Request correction or deletion of your personal data;
- Object to our use and processing of your personal data;
- Request that we limit our use and processing of your personal data; and
- Request portability of your personal data.
You also have the right to make a complaint to a government supervisory authority.
US Privacy Laws
Laws in some US states require us to provide residents with additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it. You’ll find that information in this section (if you are a California resident, please note that this is the Notice at Collection we are required to provide you under California law).
In the last 12 months, we collected the following categories of personal information, depending on the Services used:
- Identifiers (like your name, contact information, and device and online identifiers);
- Commercial information (your billing information and purchase history, for example);
- Characteristics protected by law (for example, you might provide your gender as part of a research survey for us or you may choose to voluntarily disclose your race or veteran status as part of your job application);
- Internet or other electronic network activity information (such as your usage of our Services);
- Geolocation data (such as your location based on your IP address);
- Audio, electronic, visual or similar information;
- Professional or employment-related information; and
- Inferences we make (such as likelihood of retention or attrition).
If you are a job applicant, we may have also collected:
- Education information, such as the education you disclose in your job application.
You can find more information about what we collect and sources of that information in the Information We Collect section above.
We collect personal information for the business and commercial purposes described in the How and Why We Use Information section. And we share this information with the categories of third parties described in the Sharing Information section. We retain this information for the length of time described in our How Long We Keep Information section.
In some US states you have additional rights subject to any exemptions provided by your state’s respective law, including the right to:
- Request a copy of the specific pieces of information we collect about you and, if you’re in California, to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, and the categories of third parties we share it with;
- Request deletion of personal information we collect or maintain;
- Request correction of personal information we collect or maintain;
- Opt out of the sale or sharing of personal information;
- Receive a copy of your information in a readily portable format; and
- Not receive discriminatory treatment for exercising your rights.
Right to Opt Out
We never directly sell your personal information in the conventional sense (i.e., for money).
We may share your information as necessary with our third-party service providers to provide our services to you. To the extent that we share your information with certain advertising, marketing, or analytics vendors, this can be considered a “sale” or “share” in certain U.S. States, which you may have the right to opt out of.
We do not collect or process your sensitive (and potentially sensitive) personal information except where it is strictly necessary to provide you with our service, where the processing is not for the purpose of inferring characteristics about you, or for other purposes that do not require an option to limit under California law. We don’t knowingly sell or share personal information of those under 16.
Contacting Us About These Rights
When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. For example, if you are a user, we will need you to contact us from the email address associated with your account. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.
Appeals Process for Rights Requests Denials
In some circumstances we may deny your request to exercise one of these rights. For example, if we cannot verify that you are the account or registration owner we may deny your request to access the personal information associated with your account. As another example, if we are legally required to maintain a copy of your personal information we may deny your request to delete your personal information.
In the event that we deny your request, we will communicate this fact to you in writing. You may appeal our decision by responding in writing to our denial email and stating that you would like to appeal. In the event that your appeal is also denied this information will be communicated to you in writing. Please note that the appeal process does not apply to job applicants.
If your appeal is denied, in some US states you may refer the denied appeal to the state attorney general if you believe the denial is in conflict with your legal rights. The process for how to do this will be communicated to you in writing at the same time we send you our decision about your appeal.
How to Reach Us
Please contact us through our email or phone.
Other Things You Should Know (Keep Reading!)
Analytics Services Provided by Others
Other parties may also provide analytics services via our Services. These analytics providers may set tracking technologies (like cookies) to collect information about your use of our Services and across other websites and online services. These technologies allow these third parties to recognize your device to compile information about you or others who use your device. This information allows us and other companies to, among other things, analyze and track usage and determine the popularity of certain content. Please note this Privacy Policy only covers the collection of information by Wholesome Learning, LLC and does not cover the collection of information by any third-party analytics providers.
Third-Party Software and Services
Some of our Services utilize third-party software and services (for example, for payment processing). Interacting with those third parties may mean providing information about yourself to those third parties. For example, some third-party services may request or require access to your data via a pixel or cookie. Please note that if you use the third-party service or grant access, your data will be handled in accordance with the third party’s privacy policy and practices. We don’t own or control these third parties, and they have their own rules about information collection, use, and sharing, which you should review before using the software or services.
Privacy Policy Changes
Although most changes are likely to be minor, Wholesome Learning, LLC may change its Privacy Policy from time to time. We encourage visitors to frequently check this page for any changes to its Privacy Policy. If we make changes, we will notify you by updating the “Last Updated” field at the top of this document and, in some cases, we may provide additional notice (like adding a statement to our homepage). Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.
That’s it! Thanks for reading!