Unless prohibited by law, Crème reserves the right to modify this Policy. If revisions are made that change the way We collect, use, or share personal information, We will post those changes in this Policy. You should review this Policy periodically so that You keep up to date on our most current practices.
Collection of Personal Information. Personal information refers to information that is connected to Your name and may include things such as Your email address, mailing address, social security number, and date of birth. Crème collects personal information when Users voluntarily submit it to Us. For example, We may collect or receive information from You when You fill out an application for enrollment or employment, provide us with payment information, or enroll a child in one of our facilities or services.
In addition to personal information that We may receive from You, Crème may collect other information from Users using the following technologies:
Cookies. “Cookies” are small bits of information that the Web Site places on the hard drive of Your computer. Cookies remember information about Your activities on the Web Site to make Your visits to the Web Site more enjoyable and valuable to You by providing a customized experience and recognizing Your preferences when You visit the Web Site. If You’ve chosen to disable cookies on Your browser, some of the functionality of the Web Site may be lost. Certain services provided by Crème require that cookies be enabled in Your browser and cannot be used when You have disabled cookies in Your browser.
Flash Cookies. (also called Local Shared Objects or “LSOs”) Flash cookies are data files similar to cookies, except that they can store more complex data. Flash cookies are used to remember settings, preferences, and usage, particularly for video, interactive gaming, and other similar services.
Web Beacons or Clear Pixels. Web beacons are small graphic images on a web page or in an email that can be used for such things as recording the pages and advertisements that You select, or tracking the performance of email marketing campaigns.
Web Server Logs. Web server logs are records of activity created by the computer that delivers the webpages You request to Your browser. For example, a web server log may record the search term You entered or the link You clicked to bring You to the webpage. The web server log also may record information about Your browser, such as Your IP address and the cookies set on Your browser by the server.
USE OF PERSONAL INFORMATION. Crème’s primary purpose in collecting personal information is to provide you, or your child, with services. Crème may also use personal information for various purposes, including without limitation:
To enhance your child’s experience while at one of our facilities.
To maintain emergency contact information about your child.
To help diagnose problems with our Web Site, to administer our Web Site, and to enhance the Web Site for optimal User experience.
To monitor the usage and performance of our Web Site, and to determine aggregate information about our Users.
To provide maintenance, support, and customer service for the Web Site.
To contact Users for information verification purposes and to administer User accounts.
To communicate with You about, and administer Your participation in promotions, surveys, and studies.
To allow You to pay for services performed by Crème, or to collect payment for services that have been provided to you.
To operate, evaluate, and improve our business (including developing new services).
To manage Your employment application, assess Your qualifications and manage Your employment with Us (in accordance with Section 4).
To send You promotional materials, newsletters, and other communications.
Sharing of Personal Information.
Crème Affiliates. We may share personal information with our affiliates and subsidiaries, including companies that We own or control, that own or control Us, or that are under common ownership or control with Us, regardless of whether these companies share our same name.
Service Providers. We may share Your personal information with service providers that perform services for Crème. These services are used for the operation of Crème’s business and in the operation of the Web Site, such as providing marketing assistance, analyzing User content, and processing payment card information. Crème contracts with service providers, such as payment processing providers to process payment card information made by Users.
Advertisers. We may share personal information with our third party advertisers. Our advertisers may use Your personal information to display advertisements to You through the Web Site and advertisements for Us on third party web sites.
Law Enforcement. We may share personal information with law enforcement agencies if We reasonably believe unlawful activities have occurred or the personal information may aid in an ongoing investigation. We may also share personal information with law enforcement if We determine, in our sole judgment, that You have violated our agreements or policies or that the release of Your personal information may protect the rights, property, interests, or safety of Crème or any third party.
Legal Processes. We may share personal information as required by, or permitted by, law, whether in response to subpoenas, court orders, other legal processes, or as we believe is necessary to exercise our legal rights, including defending against legal claims that have been or might be brought against Us.
Business Transfers. Your personal information may be transferred to a third party as a part of our business assets in a sale, merger, reorganization or other transaction involving part or all of Crème. If this should happen, We will provide notice to You.
Social Networking. The Web Site may offer You the ability to share Your personal information through a social networking site (e.g., Facebook, Twitter), using such site’s integrated tools (e.g., Facebook “Like” button or Twitter “Tweet” button). The use of such integrated tools enables You to share personal information about Yourself with other individuals or the public, depending on the settings that You have established with such social networking site. For more information about the purpose and scope of data collection and use in connection with such social networking site or a site’s integrated tools, please visit the privacy policies of the entities that provide these social networking sites.
PROSPECTIVE EMPLOYEE AND EMPLOYEE INFORMATION. If You submit an application for employment to or are currently an employee of Crème, Crème is authorized to collect the information in any form it obtains through Your application for employment or continued employment with Crème, and Your submission of employee related documents, including but not limited to the personal information that You submit in connection with Your employment or intended employment (collectively “Employee Information”). Examples of Employee Information collected in connection with Your employment or application for employment includes but is not limited to Your name, date of birth, government issued identification (passport, social security number, driver’s license number), banking information, marital status, health information, benefit information, title, employment history, education, job qualifications, and other relevant employee personal data. We also collect some of this information about Your dependents when You provide it to Us when You enroll in health and other benefits or provide contact information. By providing personal information about family members or other individuals, You represent that You have their consent to provide this information to Us for the purposes set forth in this Policy. Employee Information does not include any personal information that is available to the general public and excludes information generally available on a business card.
In accordance with applicable law, Crème may use Employee Information to evaluate applications for employment, manage work-related aspects of the employee-employer relationship (i.e., training, payroll, benefits, travel, reimbursement expenses, performance appraisals, succession planning, team member health and safety), investigate and respond to any claims related to Your employment, and comply with applicable laws and regulations. Your Employee Information will not be used for direct marketing purposes by Us or any third party service provider, unless You specifically consent to such use.
Crème shares Your Employee Information with third parties who provide outsourced human resource functions to Us. Those third parties are required to protect Your Employee Information. Crème may disclose Your Employee Information if required or permitted to do so by law (such as when part of a governmental agency action or litigation), governmental or quasi-governmental requests, or a regulatory organization, or to relevant third parties such as site technicians, brokers, auditors, lawyers, or professional advisors. In the event that Crème considers it necessary or where required by law to disclose Employee Information in certain situations where the health, safety, or wellbeing of a team member is at imminent risk, We may share Your Employee Information with our outside lawyers, law enforcement, or others who are legally authorized. As Crème continues to develop our business, We may buy or sell assets. In the event that Crème or substantially all of our assets are acquired, Employee Information may be one of the transferred assets.
Employee Information may be stored in hard copy or electronic format in the cloud in the United States or other countries where Crème, its affiliates, agents, or contractors conduct business. Your Employee Information may be transferred into our human resources systems and used to manage Your employment, may become part of Your personnel file, and may be used for other work-related purposes. Your Employee Information will be kept for as long as is legally required, and in some instances longer depending upon the needs of the organization and industry practices.
Social Security Number. Crème may collect, use, store and retain Your social security number in accordance with this Policy. Crème will not intentionally communicate or make available, in any manner, Your social security number to the general public.
Security. While there is no such thing as “perfect security,”, We take reasonable steps to ensure the safety of Your personal information.
RETENTION. Crème will keep Your personal information for as long as We have a business need and purpose to retain the personal information, including storage for archival purposes. When We believe We no longer need such personal information, We will destroy or otherwise dispose of your personal information in a manner intended to preserve Your privacy and security and as required by applicable law.
Other Websites. This Policy does not apply to web sites or applications offered by other organizations or individuals that may be displayed as content in a search on the Web Site. Crème encourages You to read the Policy of any third party web site or applications before transmitting personal information.
Communications. If You have any additional questions or concerns about our Policy or any other privacy or security issue, please contact Us at Corporate@cremedelacreme.com or at Crème de la Crème, Inc., 6400 S. Fiddler’s Green Circle, Suite 1400, Greenwood Village, CO 80111.
If Crème needs, or is required, to contact You concerning any event that involves information about You, We may do so by email, telephone, or mail.
Effective as of July 6, 2017
Crème de la Crème Retention Policy for Fingerscan and Handscan Data and Biometric Identifiers and Information
This Retention Policy applies to Fingerscan or Handscan Data (“Data”) and Biometric Identifiers and Information that may be collected from any customer, guardian, designee and/or employee (collectively, “Customer”) for identification and secure access purposes with respect to a Crème de la Crème facility, as well as from any employee in connection with a timekeeping system. This Data is an encrypted, mathematical representation of the fingerscan or handscan. This Data may be collected by and disclosed to one or more Vendors or as required by law. Crème de la Crème, Inc. and its subsidiaries (collectively, “Creme”) will not sell, lease, trade, or otherwise profit from the disclosure of such Data. This Data will be maintained in a confidential manner and will be stored, transmitted and protected using a reasonable standard of care and in the same manner that Crème stores other confidential and sensitive information.
The Data in Crème’s possession and/or to which it has access will be permanently deleted within three (3) months after the last date the Customer’s child(ren) attended the applicable Crème de la Crème facility and within thirty (30) days after the employee’s employment with Crème has ended.