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. DA’s principal business address is 800 Kinderkamack Road, #100 S., Oradell, NJ 07649. Should you need to contact us regarding this Privacy Policy, you can do so via email (customerservice@myeyelevel.com) for general inquiries and privacy@myeyelevel.com for data subject requests. You can also call us at 888.835.1212. We are incorporated in California.

II. Some Main Points Before the Details

We describe in this Privacy Policy how we collect, store, use and/or share (“Process”) your information when you use our various services (“Services”). Some of the most common use of our Services are as follows:

• Visiting our website at myeyelevel.com, or any website of ours, that links to this Privacy Policy
• Engaging with us in other related ways, including any sales, marketing, or participation in one of our events that are open to the general public
• Enrolling your child in an Eye Level Learning Center or our online programs
• Using our Knowre Math platforms for online instruction
• Signing up for and using a third party (Acuity - https://www.acuityscheduling.com/) to enroll in Tuni Tuni and Plamu, two programs for pre-school children
• Applying for, or inquiring about, a job opportunity
• Applying for, or inquiring about, our franchise opportunity
• Participating in our training sessions for Eye Level franchisees throughout the franchisee life cycle

If you are a California resident, please refer to Section XI in addition to the rest of this Privacy Policy. 

Sometimes in this Privacy Policy we refer to personal information as simply “PI.”

III. What Information Does DA Collect?

Summary: We collect personal information you disclose to us.

We collect personal information that you voluntarily provide to us when you register for our Services, express an interest in obtaining information about us or our products and Services, when you participate in one of our Services, or otherwise when you contact us. The personal information that we collect depends on the context of your interactions with us and the Services you choose to engage with us.

We collect the following:

 (1) Personal information provided by you:

• Names
• Phone numbers
• Parent email address
• Date of birth
• Contact preferences
• Authentication data
• Nationalities
• Account Name
• Cookie preferences
• Job titles (employees or franchisees)
• Personal email address for account recovery (employees or franchisees)
• Mailing addresses
• Billing addresses for franchisees

 (2) Sensitive information. 

When necessary, with your consent or as otherwise permitted by law, we process the following categories of sensitive information:

• Student data
• Gender
• Familial relationship
• Financial data for prospective franchisee applicants only
• Electronic Funds Transfer (EFT) for franchisee collection of royalty payments
• Social Security numbers or other government identifiers (only for employees or franchisees while undergoing a background check, or as needed for employees as it pertains to administering payroll and employee benefits during the employment life cycle).
• Signatures

 (3) Payment data.

• General: We collect data necessary for payment processing when you make purchases. This may include your payment instrument number and the associated security code.
• PayPal: We use PayPal for certain payment processing tasks. Specifically, online payments for event registrations are only available during specified registration periods for non-member event registration fees. All payment data processed via PayPal is administered and stored by PayPal directly. For more details, you can review PayPal’s privacy policy here: PayPal Privacy Policy.
• Stripe: For payments related to Tuni Tuni and Plamu we use Stripe, a third-party payment processing vendor. All relevant payment data for these transactions is managed and stored by Stripe. For more information on Stripe's data handling practices, please refer to their privacy policy here: Stripe Privacy Policy.
• Eye Level Tuition Payments: While DA provides the overarching management and franchising for Eye Level learning centers, it's important to note that we do not process member tuition payments directly. Each of our franchisee-operated learning centers is responsible for processing and managing tuition payments. If you have questions about how your payment data is handled at a specific learning center, we recommend reaching out to that center directly. 
• EFT Payments from our Franchisees: We collect payments from our franchisees via Electronic Funds Transfer. In order to do this we will collect your banking information.

 (4) Information automatically collected.

Summary: Some information, such as your Internet Protocol (IP) address, or browser, or both, and device characteristics is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate our Services. This information does not reveal specific identity (like your name or contact information). However, such information may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, and country location. Automatic collection will also provide us information about how and when you use our Services, and other technical information.

Automatically collected information is necessary primarily for maintaining the security and operation of our Services. It is also used for analyzing and reporting purposes.

 (5) Use of Cookies and Other Automatic Data Collection Methods.

Cookies

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 our cookies. Users will receive a pop up banner when first logging on to our public websites. You can accept or decline our use of cookies through our pop-up. Our cookie pop-up states:

We use essential cookies to make our site work. With your consent, we may also use non-essential cookies to improve user experience, personalize content, and analyze website traffic. For these reasons, we may share your site usage data with our social media and analytics partners. By clicking “Accept,“ you agree to our website's cookie use as described in our Cookie Policy. You can change your cookie settings at any time by clicking “Preferences.”

If you initially indicated your Cookie preferences on our websites and then login again on the same browser, you will not receive the above pop-up message, as your Cookie preferences will be stored for one year. If you clear your Cookie preferences, then the pop-up message will appear again. The pop-up message will also appear if you log on using a different browser.

In addition, 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 DA Services or our websites that you visit.

 Automatic data collection through cookies and similar technologies

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings.  

• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.  

• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

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.

Controls for DO-NOT-TRACK features 

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice. At this moment, you may submit a request by contacting us as indicated in XIII below. 

IV. How We Process the Information Collected

Summary: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other lawful purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.  

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.  

• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.  

• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.  

• To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.  

• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.  

• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of receiving our marketing and promotional communications by choosing to unsubscribe or by contacting us at customerservice@myeyelevel.com

• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more. You can opt out of receiving our marketing and promotional communications by choosing to unsubscribe or by contacting us at customerservice@myeyelevel.com

• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.  

• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.  

• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.  

• To verify a user’s identity. We may process your information to make sure you are you.  

• To collect, monitor, and analyze learning progress and result in order to provide accurate data and information for consultation. We may process information regarding learning completion on our apps and/or worksheets to make sure instructors know your child’s progress is on track or requires customization.  

• To provide learning progress consulting to parents. We may process information on your child’s learning progress and related information in order to provide accurate and precise information.  

• To process personal information or other information that you submit through us . We may process information if and when you provide it to us.  

• 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. We may process information in other ways as long as we have your consent.  

• To comply with and enforce relevant standards, contractual obligations, and our policies. We may process information to comply with regulations, fulfill contracts, and to make sure we abide by the policies set forth in this policy.

• To notify users of a data privacy incident. We may process information if a data privacy incident occurs and requires fast and orderly processing to make sure you and relevant authorities are notified.

• To introduce other products or services available from Daekyo and its affiliates. We may process your information to provide sound consultation and introduce products that may fit your needs.

• To conduct research about your opinion of Services or of potential new services that may be offered. We may process information about you to better our services and products to develop, enhance, redesign, repackage, improve, or introduce new products that may benefit you.

• To provide training to employees. We may process anonymized information about your behavior while using our Services to present examples and create training contents.

• To develop curriculum and training for franchisees. We may process anonymized information about your behavior while using our services to present examples and create training contents.

• To monitor the progress of our franchisees in our training programs. We may process your information to keep track of our training program goals.

V. Sharing and Storing of Your Information

Sharing of Information with Vendors, Consultants and Other Third Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that these third parties cannot do anything with your personal information unless we have instructed them to do it. Such third parties will also not share your personal information with any organization apart from us. They also commit to protect the data they retain on our behalf and for the period we instruct.

We use Google Analytics and Facebook Analytics to help us better understand the effectiveness of our advertising and the use of our services. Facebook and Google provide methods for users to consent universally by using their own account settings.  Additionally, Facebook provides ways for users to universally consent to Facebook related cookies (link). DA does not share your personal information with Facebook or Google for which we utilize the analytics described above.

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.  

• When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). To find out more about Google’s Privacy Policy, please refer to this link.

• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.  

• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.  

Links to Third-Party Websites

Our Services may contain links or references to third-party websites, products, or services ("Linked Sites"). These Linked Sites may have privacy policies that differ from ours. We are not responsible for the privacy practices or content of any Linked Sites or of any companies that we do not own or control. While we do not endorse any of these Linked Sites or the services or products they offer, we include them for your convenience. It is crucial for you to review each Linked Site's privacy policy to understand how your personal information is used and protected. If you have concerns about a Linked Site's privacy policy, please contact the respective third party directly. 

VI. Is Your Information Transferred Internationally?

We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States and South Korea. If you are accessing our Services from outside the United States and South Korea, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information.

Additionally, our workforce (employees and franchisees) uses Okta Workforce Identity, which is hosted in Europe to provide secure access to our internal systems.

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 employ commercially reasonable measures to protect your PI (such as encryption and Secure Socket Layer (SSL) 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. You should only access the Services within a secure environment.

Our internal workforce systems are also protected by Okta Workforce Identity ensuring secure employee logins through multi-factor authentication and advanced security measures. While this system is specific to our workforce, it reflects our broader commitment to maintaining a secure environment for all data handling processes across our organization.

For more information on Okta, please see Okta's Privacy Policy. 

VIII. General Retention and Deletion Policies

Absent federal or state law which will always take precedence, DA will retain PI for up to one year from 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.

For general inquiries about our Services or enrollment in our events for nonmembers, we will only keep your PI for as long as it is necessary for the purposes set out in this Privacy Policy.

DA complies with all applicable Federal and state laws regarding retention periods for employment and franchisee records.

IX. General Consumer Privacy Rights with Regard to your PI

You may request from DA or our franchisees the bulleted info below. If our franchisees cannot facilitate your request at a local Eye Level Learning Center, our franchisees will forward your request to DA:

• Access - Inquire and request a review of your PI.
• Port - Make duplications of your PI for a valid reason.
• Correct - Correct false or erroneous PI.
• Discontinue - Discontinue collection and processing or using your PI.
• Delete - You may request that DA delete your PI.

DA will not discriminate against your for exercising your privacy rights above.

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 XIII below.

X. Children Under 13

In compliance with the Children’s Online Privacy Protection Act (COPPA), DA does not knowingly solicit, collect, or maintain any PI about anyone under the age of 13 on our public websites. We only collect personal information about children from their parents during enrollment at our Eye Level Learning Centers or our national or regional events open to non-members. Once a child is enrolled as a member, we use their information, as detailed in Section III above, to analyze their learning results and provide learning progress consulting to both the parent and child.

If you do not provide consent for the collection, use, disclosure and retention of your personal information or that of your minor child, you or your minor child may not be able to participate in or receive the full benefit of our Services.  

If you are under the age of 13, please do not send any personal information about yourself (such as your name, address, phone number or email address) to us. No one under the age of 13 should provide any personal information to or on our Services. In the event that we learn that we have collected personal information from a child under the age of 13 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database.

XI. Privacy Right Specific to California Residents

 1. 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 (and as amended by the California Privacy Rights Act of 2020). 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
• Email us at customerservice@myeyelevel.com for general inquiries and privacy@myeyelevel.com for data subject requests.

 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.

Non-Discrimination

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 (but please refer to Section IX with respect to a request for deletion.
• 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

 2. What categories of information do we collect?

We have collected the following categories of personal information in the past 12 months:

For each category listed above with a “Yes,” we will use and retain the collected personal information as needed to provide the Services or for a maximum of 1 year after termination of our contracts or agreements. For the personal information of employees and franchisees that is collected for any category listed above, we will retain the collected personal information per state and federal laws, which is longer than 1 year.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;  

• Participation in customer surveys or contests; and  

• Facilitation in the delivery of our Services and to respond to your inquiries.

 3. How do we use and share your personal information?

DA collects and shares your personal information through:

• Targeting cookies/Marketing cookies

• Social media cookies  

• Beacons/Pixels/Tags  

• Social media plugins: "LinkedIn Plugins" operated by LinkedIn Corporation., "Share Dialog" operated by Meta Platforms, Inc. and "Tweet Button" operated by X Corp. We use social media features, such as a "Like" button, and widgets, such as a "Share" button, in our Services. Such features may process your Internet Protocol (IP) address and track which page you are visiting on our website. We may place a cookie to enable the feature to work correctly. If you are logged in on a certain social media platform and you interact with a widget or button belonging to that social media platform, this information may be recorded to your profile of such social media platform. To avoid this, you should log out from that social media platform before accessing or using the Services. Social media features and widgets may be hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy notices of the companies that provide them. By clicking on one of these buttons, you agree to the use of this plugin and consequently the transfer of personal information to the corresponding social media service. We have no control over the essence and extent of these transmitted data or their additional processing.

More information about our data collection and sharing practices can be found in this Privacy Notice. 

You may contact us by email at (customerservice@myeyelevel.com) for general inquiries and privacy@myeyelevel.com for data subject requests.  You can also call us at 888.835.1212  

If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf. 

 4. Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information. 

DA has not sold or shared any personal information to third parties for commercial purpose in the preceding twelve (12) months. DA has disclosed the following categories of personal information to third parties for our business purposes in the preceding twelve (12) months:

• Category A. Identifiers, such as contact details like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.

• Category B. Personal Information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history, and financial information.

• Category C. Characteristics of protected classifications under California or federal law, such as gender or date of birth.

• Category D. Commercial information, such as transaction information, purchase history, financial details, and payment information.

• Category F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.

• Category G. Geolocation data, such as device location.

• Category I. Professional or employment-related information, such as business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us.

 5. California’s Shine the Light Law

In addition to the CCPA and its amendments, California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. 

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.). 

XII. Updates to This Privacy Policy

At DA, we want to be clear and open about how we protect your data. Here's why and when we might change our privacy statement:

• When our customers or partners give us feedback.
• When we make changes to our products or services.
• If we change how we handle data or our company rules.
• When state or federal laws change that we need to follow.

We promise not to take away any of your rights under this Privacy Policy without letting you know and getting your explicit consent. When we make changes, we'll change the "Last Updated" date at the top. You can find older versions of our statement in the “Version History” section at the bottom. If we make big changes, especially about why we collect data, we'll either put up a conspicuous notice or let you know directly. We suggest you revisit this statement now and then to remain aware of our data protection measures.

XIII. How to Contact Us 

If you have any questions about our Privacy Policy or want to exercise any right permitted under state law or under this policy, please contact us as follows:

• Call us toll free 888.835.1212
• For general inquiries email us at customerservice@myeyelevel.com
• For data subject requests or privacy concerns email us at privacy@myeyelevel.com