Sponsoring Partner Personal Information Protection Policy

SPONSORING PARTNER PERSONAL INFORMATION PROTECTION POLICY

1. Purpose

Sparkler Learning, Inc. ("Company") has adopted this Policy to govern the treatment of Personal Information. The loss of Personal Information can result in substantial harm to individuals, including embarrassment, inconvenience, and fraudulent use of the information. Protecting the confidentiality and integrity of Personal Information is a critical responsibility that must be taken seriously at all times.

2. Scope

This Policy applies to all sponsoring or partnering organizations, which includes, but are not limited to, early childhood centers, daycares, schools, school readiness organizations, school districts, health care organizations, home visiting agencies, and social service agencies (collectively “Sponsoring Partners”). These are organizations who have independent relationships with the parents and caregivers, and are making Sparkler available to the parents and caregivers as a supportive service.

3. Definition of Personal Information
"Personal Information" means information that identifies or can be used to identify or authenticate an

individual, including, but not limited to:

• Names, addresses, telephone numbers, email addresses;
• Personal characteristics or profiles connected to a unique individual, including interests, habits, or activities.
• Medical, health, or health insurance information and any information that qualifies as “ProtectedHealth Information” under HIPAA, to the extent applicable; and

  4. Using, Handling, and Retaining Personal Information

  Notice and Collection. Whenever the Sponsoring Partner collects Personal Information, it must inform the individual from whom it collects the information of how it will use, process, disclose, protect, and retain that Personal Information by presenting a privacy policy or privacy notice to the individual prior to collecting the individual’s Personal Information, whether directly from the individual or indirectly through third party service providers. The Sponsoring Partner may only collect Personal Information in compliance with applicable laws, and, obtain when needed, the individual's consent. The Personal Information collected must be limited to that which is reasonably necessary to accomplish the Sponsor's legitimate business purposes or as necessary to comply with law.

  Access, Use, and Sharing of Personal Information. The Sponsoring Partner may only access Personal Information when the information relates to and is necessary to perform the Sponsoring Partner’s job duties.

Any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person, or any information

that deemed to be “personal information” under applicable state privacy laws;

Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act, to the extent applicable.

The Sponsoring Partner may not access Personal Information for any reason unrelated to the Sponsoring Partner’s job duties. The Sponsoring Partner may not use Personal Information in a way that is incompatible with the notice given to the individual at the time the information was collected. The Sponsoring Partner may only share Personal Information with another Sponsoring Partner employee, agent, or representative if the recipient has a job-related need to know the information. Personal Information may only be shared with a third-party service provider if it has a need to know the information for the purpose of providing the contracted services and if sharing the Personal Information complies with the privacy notice provided to the individual.

Security. The Sponsoring Partner is responsible for protecting Personal Information.

The Sponsoring Partner shall safeguard the use, publication and disclosure of Personal Information on all individuals who receive services from the Sponsoring Partner with all applicable federal and state law concerning confidentiality. In particular, the Sponsoring Partner shall:

• Place reasonable restrictions on access to records containing Personal Information, including access to any locked storage where such records are kept;
• Create secure access controls to Personal Information, including but not limited to passwords; and
• Encrypt Personal Information that is stored on laptops, portable devices or being transmitted electronically.Retention and Disposal. Sponsoring Partner should keep Personal Information only for the amount of time it is needed to fulfill the legitimate business purpose for which it was collected or to satisfy a legal requirement. Sponsoring Partner must follow the applicable records retention schedules and policies and destroy any media containing Personal Information in accordance with the applicable records disposal policy.

  5. Training Employees and Supervising Contractors

  All Sponsoring Partner personnel who have access to Personal Information must be educated and trained on this Policy and the treatment of Personal Information. Whenever Sponsoring Partner entrusts Personal Information to a third-party service provider, Sponsoring Partner must also ensure proper management and supervision over the outside party's handling of that Personal Information through appropriate contracts. Sponsoring Partner personnel with responsibility for supervising employees or managing third-party service provider relationships must be trained on supervision over those employees and third-party service providers.

  6. Sparkler’s Online Terms

  You reaffirm that you agree to abide by Sparkler’s Terms of Service and Privacy Policy when using Sparkler’s web-based provider dashboard, family-facing mobile app, and any other applications, tools and services provided by Sparkler.

  7. Amendment and Revision

  This Policy may be revised from time to time. This Policy was last revised in July 2023.

Acknowledgment of Receipt and Review

I, _______________________ (name), ___________________ (title) of ______________________________(Sponsoring Partner entity name), acknowledge that on _____________________ (date), I received a copy of Sparkler Learning, Inc.’s Sponsoring Partner Personal Information Protection Policy and that I read it, understood it, and agree to comply with it.