BEST BRAINS U.S. PRIVACY POLICY

1. Introduction

Best Brains, Inc. (“Best Brains,” “we,” “us,” or “our”) respects your privacy and is committed to handling personal information responsibly, transparently, and securely.

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you:

• Visit a United States Best Brains website or webpage that links to this Privacy Policy
• Request information about a Best Brains program or learning center
• Begin a student registration or request a placement test or orientation
• Communicate with us through a contact form, telephone call, email, text message, or online chat
• Submit a franchise inquiry or application
• Apply for employment with Best Brains
• Subscribe to marketing communications
• Participate in a promotion, survey, event, or other website feature or
• Otherwise interact with Best Brains in a context covered by this Privacy Policy.

Our U.S. State Privacy Rights Addendum, which appears after this Privacy Policy, provides additional information for residents of states with applicable consumer privacy laws.

2. Scope of This Privacy Policy

This Privacy Policy applies to the U.S. corporate and franchise websites, webpages, forms, and online services operated by Best Brains that link to this Privacy Policy, collectively referred to as the “Sites.”

This Privacy Policy does not automatically apply to:

• bbConnect, bbSlate, bbSupport, or another Best Brains application or learning platform that has its own privacy notice
• Information collected directly by an independently owned and operated Best Brains learning center outside the Sites
• Employee information maintained as part of an employment relationship, except where applicable law requires otherwise
• Third-party websites, platforms, social networks, payment services, or applications that we do not control or
• Best Brains services offered outside the United States that are governed by another regional privacy policy.

Where another Best Brains privacy notice applies to a particular application, service, or program, that notice will control information collected through that application, service, or program.

3. Best Brains Learning Centers and Franchisees

Many Best Brains learning centers are independently owned and operated franchise businesses.

When you request information, register your interest, select a location, request an orientation, or begin enrollment, we may send your information to the appropriate Best Brains learning center. The center may contact you directly and may process your information as a separate business responsible for its own operations.

This Privacy Policy governs Best Brains’ handling of information through the Sites. An independently operated center may provide an additional privacy notice governing its own collection and use of information.

4. Personal Information We Collect

The information we collect depends on how you interact with us.

4.1 Contact and Identification Information

We may collect:

• First and last name
• Mailing address
• City, state, and ZIP code
• Email address
• Telephone number
• Communication preferences
• Account username or similar account identifier, where applicable and
• Other information you provide to identify yourself or allow us to contact you.

4.2 Parent, Guardian, and Student Information

When a parent or legal guardian requests information or begins registration, we may collect:

• Parent or guardian name and contact information
• Number of students
• Student name
• Student age or date of birth
• Student grade level
• School or general educational information
• Program and subject interests
• Preferred Best Brains location
• Scheduling preferences
• Placement-test, orientation, or enrollment information
• Referral information and
• Information included in questions or messages submitted to us.

Parents and guardians should provide only the student information reasonably necessary for the inquiry, placement, registration, or enrollment process.

4.3 Location Information

We may collect:

• An address you enter to locate a nearby center
• Approximate location derived from your Internet Protocol address and
• More precise device location if you select a “use my current location” feature and permit location access through your browser or device.

You may disable location access through your browser or device settings. You may also search for a center by manually entering an address.

4.4 Franchise Inquiry Information

When you inquire about owning a Best Brains franchise, we may collect:

• Name and contact information
• Desired city, state, territory, or ZIP code
• Professional and employment background
• Whether you are a certified teacher
• Veteran or military-service status, when voluntarily provided
• General qualifications and business experience
• How you learned about the franchise opportunity
• Information included in your inquiry or application and
• Financial qualification information if requested later through an appropriate application process.

Please do not submit Social Security numbers, government identification numbers, bank account credentials, or other highly sensitive financial information through a general website form.

4.5 Employment Applicant Information

If you apply for a position with Best Brains, we or a recruitment provider may collect:

• Contact information
• Résumé or curriculum vitae
• Employment and professional history
• Education and certifications
• References
• Work authorization information
• Position preferences
• Interview information and
• Other information you voluntarily submit during the application process.

A separate applicant privacy notice may apply where required.

4.6 Transaction and Payment Information

If a Site permits a registration, deposit, purchase, or payment, we may collect information concerning:

• The product or service purchased
• Transaction amount
• Transaction date
• Billing contact information
• Payment status and
• Limited payment card information supplied by a payment processor.

Payment-card numbers and security codes may be collected directly by a third-party payment processor. We generally do not receive or retain complete payment-card numbers.

4.7 Communications

We may collect information contained in:

• Contact-form submissions
• Emails
• Online chats
• Text messages
• Telephone calls
• Customer-service requests
• Surveys and feedback
• Social-media communications and
• Other correspondence with Best Brains.

Where legally permitted, calls or online interactions may be monitored or recorded for training, quality, security, or documentation purposes. We will provide notice or obtain consent where required.

4.8 Device and Website-Usage Information

When you use the Sites, we and our service providers may automatically collect:

• Internet Protocol address
• Browser type and version
• Device type
• Operating system
• Device and advertising identifiers
• Language and time-zone settings
• Referring website or advertisement
• Pages viewed
• Links selected
• Date, time, and duration of visits
• General interaction and navigation information
• Approximate geographic area
• Cookie and tracking-technology identifiers
• Error logs and diagnostic information and
• Information about interactions with emails or advertisements.

4.9 Marketing and Advertising Information

We may collect:

• Marketing preferences
• Email subscription status
• Responses to advertisements
• Campaign attribution information
• Referral sources
• Social-media interactions and
• Information used to measure the effectiveness of advertising.

4.10 Inferences

We may draw limited inferences from other information, such as likely program interests, preferred center location, or the effectiveness of a marketing campaign.

We do not use sensitive personal information to infer highly personal characteristics about an individual.

4.11 Sensitive Personal Information

Depending on your interaction and state law, certain information may be considered sensitive, including:

• Precise geolocation when you authorize location access
• Account credentials
• Personal information concerning a known child
• Certain financial information
• Veteran or military status and
• Information concerning a disability or requested accommodation if voluntarily submitted.

We process sensitive personal information only for purposes reasonably necessary to provide the requested service, comply with law, protect security, or obtain consent where legally required.

Please do not submit medical, diagnostic, or detailed disability information through a general contact or registration form unless we specifically request the information through an appropriate process.

5. How We Collect Information

We collect personal information from:

5.1 You

We collect information when you complete a form, communicate with us, begin registration, submit a franchise inquiry, apply for a job, enable location access, subscribe to communications, or otherwise provide information.

5.2 Parents and Legal Guardians

Parents and guardians may provide information concerning their children for placement, enrollment, scheduling, or educational-service purposes.

5.3 Best Brains Learning Centers and Affiliates

A center or affiliated company may provide information to us when necessary to respond to an inquiry, manage a referral, support enrollment, address a concern, or administer the Best Brains system.

5.4 Service Providers and Business Partners

We may receive information from companies that provide website hosting, communications, online chat, analytics, advertising, scheduling, payment processing, customer relationship management, recruitment, security, or similar services.

5.5 Your Device or Browser

Cookies, pixels, software development kits, server logs, local storage, and similar technologies may automatically collect information when you use a Site.

5.6 Public and Commercial Sources

For franchise development, recruiting, security, or business purposes, we may receive information from public records, professional networking services, referral sources, or commercially available business information.

6. How We Use Personal Information

We may use personal information to:

6.1 Provide and Administer Services

• Operate and maintain the Sites
• Respond to questions and requests
• Identify nearby learning centers
• Connect parents with a selected or nearby center
• Arrange placement tests, orientations, appointments, or consultations
• Support registration and enrollment
• Provide requested information about programs
• Manage accounts, transactions, or service requests
• Provide customer support.

6.2 Communicate with You

• Respond by email, telephone, text message, or chat
• Provide administrative or service-related notices
• Confirm appointments or registration activity
• Send security and policy notices
• Follow up on an inquiry
• Communicate with a franchise application or employment application.

6.3 Marketing

Subject to applicable law and your choices, we may:

• Send promotional emails or messages
• Provide information about Best Brains programs, events, promotions, or openings
• Personalize website content
• Measure advertising effectiveness
• Conduct audience analytics
• Advertise Best Brains services on third-party platforms.

Consent to receive promotional communications is not a condition of purchasing or receiving Best Brains services.

6.4 Improve Our Services

We may use information to:

• Understand how the Sites are used
• Improve website design and performance
• Develop or evaluate programs and services
• Analyze trends
• Conduct surveys
• Train personnel
• Improve the user experience.

6.5 Protect Best Brains and Others

We may use information to:

• Authenticate users
• Protect accounts and systems
• Detect fraud, misuse, or security incidents
• Investigate complaints
• Enforce applicable agreements and policies
• Protect the rights, safety, and property of Best Brains, our centers, families, employees, and others
• Maintain business records.

6.6 Legal and Compliance Purposes

We may process information to:

• Comply with federal, state, and local laws
• Respond to valid legal process
• Exercise or defend legal claims
• Fulfill tax, accounting, recordkeeping, and regulatory obligations
• Conduct compliance reviews
• Respond to government or law enforcement requests where legally required.

6.7 Corporate Transactions

We may use and transfer information in connection with an actual or proposed merger, financing, restructuring, acquisition, sale, bankruptcy, or transfer of some or all of our business or assets.

7. When We Disclose Personal Information

We may disclose personal information to the following categories of recipients.

7.1 Best Brains Learning Centers

We may disclose inquiry, registration, contact, student, scheduling, and related information to the Best Brains learning center you select or to a nearby center that can respond to your request.

7.2 Affiliates

We may disclose information among Best Brains affiliates for administrative, operational, support, security, marketing, and compliance purposes.

7.3 Service Providers

We may disclose information to vendors that provide:

• Website hosting
• Cloud storage
• Customer-relationship management
• Email and text communications
• Online chat
• Call management
• Scheduling
• Payment processing
• Analytics
• Advertising
• Information technology
• Cybersecurity
• Recruitment
• Document management
• Professional consulting
• Other services performed on our behalf.

We require service providers to handle personal information consistently with applicable contractual and legal obligations.

7.4 Advertising and Analytics Partners

Subject to your privacy choices, we may permit advertising and analytics providers to collect or receive online identifiers, device information, browsing activity, approximate location, and related information.

These providers may use the information to measure website activity, evaluate advertising, limit repeated advertisements, or provide advertising based on activity across websites or services.

7.5 Professional Advisers

We may disclose information to attorneys, accountants, auditors, insurers, consultants, financial institutions, and other professional advisers where reasonably necessary.

7.6 Government and Legal Recipients

We may disclose information when we reasonably believe disclosure is necessary to comply with law, respond to valid legal process, investigate unlawful conduct, protect safety, or protect our legal rights.

7.7 Corporate-Transaction Recipients

Information may be disclosed to potential or actual purchasers, investors, lenders, advisers, or other parties involved in a business transaction, subject to appropriate confidentiality measures where applicable.

7.8 At Your Direction or With Your Consent

We may disclose information when you direct us to do so or provide consent.

8. Sale, Sharing, and Targeted Advertising

Best Brains does not sell personal information in exchange for money.

Some state privacy laws define "sale," "sharing," or "targeted advertising" broadly. Under those definitions, allowing an advertising or analytics provider to collect online identifiers and website activity for cross-context behavioral advertising may be considered a sale, sharing, or targeted advertising.

Depending on the technologies operating on the Sites and your cookie selections, we may disclose the following categories for these purposes:

• Online identifiers
• Internet or network activity
• Device information
• Approximate geolocation
• Advertising-interaction information
• Related inferences.

You may opt out by:

• Selecting the "Your Privacy Choices" or "Do Not Sell or Share My Personal Information" link in the website footer
• Changing your selections through our Cookie Preferences tool
• Using a legally recognized browser-based opt-out preference signal, such as Global Privacy Control, where required by law.

Your selection will apply to the browser and device from which it is submitted. You may need to repeat your selection when using another browser or device or after deleting cookies.

We do not knowingly sell or share personal information belonging to individuals under 16 years of age. We do not knowingly use the personal information of children or teens for targeted advertising where prohibited by law.

We do not sell precise geolocation information.

9. Cookies and Similar Technologies

9.1 What These Technologies Are

Cookies are small files placed on a browser or device. Pixels, tags, local storage, software development kits, and similar technologies may also collect or store information.

9.2 Types of Technologies We Use

We may use:

Strictly Necessary Technologies:

Required to operate the Sites, provide security, remember privacy choices, process forms, or provide requested features.

Functional Technologies:

Used to remember preferences, provide chat features, improve functionality, or personalize basic website features.

Analytics Technologies:

Used to understand website usage, traffic, performance, and errors.

Advertising Technologies:

Used to measure campaigns, understand referrals, build advertising audiences, or provide advertisements based on activity across services.

9.3 Managing Cookies

You can manage nonessential cookies through our Cookie Preferences tool. You can also adjust browser settings to delete or block cookies, although certain Site features may not function properly.

Where applicable law requires consent before nonessential tracking technologies are activated, we will request that consent.

9.4 Global Privacy Control and Do Not Track

Where required by applicable law, we process recognized opt-out preference signals, including Global Privacy Control, as a request to opt out of sale, sharing, or targeted advertising for the browser or device sending the signal.

Some browsers also offer a "Do Not Track" setting. Because there is not currently a uniform industry standard governing traditional Do Not Track signals, the Sites may not respond to those signals unless required by law.

10. Your Communication Choices

10.1 Promotional Emails

You may unsubscribe from promotional emails by using the unsubscribe link included in the message.

Even after you unsubscribe from marketing, we may continue sending nonpromotional messages concerning an inquiry, appointment, registration, transaction, account, security issue, or other ongoing relationship.

10.2 Text Messages

Where Best Brains offers promotional text messages, you may opt out by replying STOP. Message and data rates may apply.

10.3 Telephone Communications

You may ask us not to make promotional calls to a particular telephone number. Requests may take a reasonable period to process.

10.4 Cookie and Advertising Choices

Use the Cookie Preferences or Your Privacy Choices link to manage nonessential tracking and advertising choices.

11. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including providing services, maintaining records, complying with law, resolving disputes, preventing fraud, and enforcing agreements.

Retention is determined using factors such as:

• The nature and sensitivity of the information
• The purpose for which it was collected
• Whether an inquiry, application, registration, or customer relationship remains active
• Legal, tax, accounting, employment, franchise, or contractual requirements
• Applicable limitation periods
• Security and fraud-prevention needs
• Whether deletion is technically feasible in active systems and backups.

Generally:

• Website inquiry and lead information is retained for the period reasonably necessary to respond, follow up, manage the relationship, and document consent or preferences
• Registration, transaction, and enrollment-related records may be retained for the duration of the relationship and an appropriate period afterward
• Franchise inquiry and application records may be retained while an opportunity is under consideration and for an appropriate compliance and recordkeeping period afterward
• Applicant information may be retained for recruitment, legal-compliance, and future-opportunity purposes as permitted by law
• Marketing subscription and suppression records may be retained as necessary to document and honor communication choices
• Cookie and analytics information is retained in accordance with the applicable technology's configured retention period
• Security logs may be retained for a period appropriate to investigate and prevent security incidents.

Personal information collected from a child is not retained indefinitely and will be deleted when it is no longer reasonably necessary for the purpose for which it was collected, subject to legal obligations.

Information may remain temporarily in encrypted or access-restricted backups until those backups are overwritten or securely deleted through ordinary system processes.

12. Information Security

We use administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

Safeguards may include:

• Access controls
• Authentication measures
• Encryption where appropriate
• Network and endpoint security
• Vendor-management procedures
• Employee confidentiality obligations
• Security monitoring
• Incident-response procedures
• Data minimization and retention controls.

No website, transmission, or storage system can be guaranteed to be completely secure. You should use caution when transmitting information online and should not send highly sensitive information through a general email, chat, or website form.

13. Children's Privacy

13.1 Corporate Sites

The general Best Brains corporate and franchise Sites are intended primarily for parents, guardians, educators, job applicants, franchise candidates, and other adults. They are not intended to collect personal information directly from children under 13 without appropriate parental involvement.

Parents and legal guardians may provide information about a child for the purpose of obtaining information, locating a center, scheduling an orientation, completing registration, or enrolling in an educational program.

13.2 Information Collected Directly From Children

When a Best Brains online service is directed to children under 13 or we have actual knowledge that personal information is being collected online directly from a child under 13, Best Brains will provide appropriate notice and obtain verifiable parental consent unless an exception under applicable law applies.

The applicable child-directed service may provide a separate Children's Privacy Notice explaining:

• The information collected from children
• How the information is used
• Whether it is disclosed
• The operators collecting the information
• The parental-consent method
• Parent and guardian rights
• Applicable retention practices.

13.3 Parent and Guardian Rights

Subject to verification and applicable law, a parent or legal guardian may request to:

• Review personal information collected from their child
• Correct inaccurate information
• Delete the child's personal information
• Revoke consent
• Refuse further collection or use
• Ask questions about our children's privacy practices.

Best Brains will not require a child to provide more personal information than is reasonably necessary to participate in an activity.

We do not condition participation in an educational activity on consent to disclose a child's personal information for targeted advertising or unrelated third-party commercial purposes.

13.4 Information Submitted Without Authorization

If we learn that personal information was collected directly from a child under 13 without legally required parental authorization, we will take reasonable steps to delete it.

Parents and guardians may contact privacy@bestbrains.com regarding children's information.

14. Consumer Health Information

The general Sites are not designed to collect detailed consumer health information.

Please do not submit medical diagnoses, treatment information, mental health information, reproductive or sexual health information, genetic information, or similar health data through a general Site form or chat.

If limited information concerning accommodation is provided, we will use it only as reasonably necessary to respond to the request, route it to an appropriate center or service, comply with law, or protect safety.

If Best Brains introduces a service that collects consumer health data subject to a state consumer health privacy law, we will provide a separate Consumer Health Data Privacy Policy and obtain consent where required.

15. Third-Party Websites and Services

The Sites may contain links to websites, social networks, payment services, scheduling services, or applications operated by third parties.

We do not control the privacy practices of third parties. Their privacy policies apply to information they collect directly. We encourage you to review those policies before providing personal information.

16. Social Media

If you interact with Best Brains through a social media platform, the platform may collect information about your activity under its own privacy policy.

Information you post publicly may be visible to other users. Do not post student information or other sensitive information in a public comment or public social media message.

17. International Processing

Best Brains and its service providers may process information in the United States and other countries.

Privacy and data protection laws may differ between jurisdictions. Where required, we use reasonable contractual, organizational, and technical measures designed to protect information transferred across borders.

18. Automated Decision-Making

We do not currently use personal information collected through the general Sites to make decisions that produce legal or similarly significant effects concerning a consumer.

We may use automated tools for routine functions such as spam detection, fraud prevention, lead routing, website personalization, and analytics.

If our practices materially change, we will update this Privacy Policy and provide any legally required notices or opt-out rights.

19. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our services, technologies, legal obligations, or business practices.

The "Last Updated" date will show when the Policy was most recently revised. When required, we will provide additional notice of material changes through the Sites or another appropriate communication method.

20. Contact Us

Questions, concerns, and privacy requests may be submitted through the following methods:

Email: info@bestbrains.com

Telephone: (800) 817-1025

Mail:

Best Brains, Inc.
Attn: Privacy
135 E. Algonquin Road, Suite B
Arlington Heights, Illinois 60005
United States