Privacy Policy

Effective Date: January 1, 2025

Code Ninjas, LLC respects the importance of the privacy of your personal information. This Privacy Policy describes how Code Ninjas LLC and/or independently owned and operated Code Ninjas franchised locations ("Franchised Locations") ("we" or "us") will make use of your information.

It outlines our processing of personal information in connection with the services described below and the use of our websites under codeninjas.com, codeninjas.co.uk, codeninjasfranchise.com, codeninjasfranchise.co.uk, and other related sites (the "Sites"), and private access portals for Code Ninja students and parents including our proprietary learning platforms and point of sale systems ("Portals").

It also describes your data protection rights under data protection law in the European Economic Area (“EEA”) and the United Kingdom (“UK”) to the extent such law applies, including the right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “YOUR DATA PROTECTION RIGHTS (UNDER EEA AND UK LAW)” section.

Through the Sites and Portals, you can (a) find information about products and services offered at Franchised Locations, including educational programs for children; (b) schedule, modify, and/or cancel programs or services with any Franchised Locations; (c) find information on how to complete forms with your Franchised Location; (d) enter into and use benefits under any membership agreement entered into with your Franchised Location; (e) purchase and/or redeem gift cards at Franchised Locations; (f) purchase services or product at any Franchised Location as a guest; (g) view information about and find the nearest Franchised Location; (h) request franchise information; and (i) complete customer satisfaction surveys about any Franchised Location (collectively, together with any other services offered through the Sites and Portals, the "Services").

Please read this Privacy Policy carefully prior to accessing or using the Sites, Portals, and/or Services to understand our views and practices regarding your personal information and how we will treat it. If after reading this Privacy Policy you still have questions feel free to drop us a line by using the contact details set out in the Contact Us section below and we will be happy to help.

We may provide additional information about our privacy practices at other points, for example, when we ask you to provide personal information in connection with a particular Service or use of a particular Portal, and where this will help us provide more relevant and timely information.

INFORMATION COLLECTION

We collect information about you directly from you, including when you request program information on the Sites or at a Franchised Location, make a purchase through the Sites or Portals, contact us, make a reservation for a program or service through the Sites or Portals, purchase memberships or gift cards, create, manipulate or update accounts on or through the Sites or Portals, complete surveys, purchase other products or services, participate in forums or submit user generated content, access our or a Franchised Locations Wi-Fi System or other systems and platforms in connection with the Sites, Portals, and/or Services, sign up for promotions or to receive newsletters or other materials about or otherwise for any reason associated with our business.

We also collect personal information automatically through your use of the Sites, Portals and/or Services.

This personal information includes:

Category	Details
Identification Information	Your name, email address, phone number and country
User Information	Information about your child or children that you provide to us (e.g., name and birthdate or any other information provided to the Franchised Location)
Payment Details	Your payment details, where you make purchases from us. Note that we do not process your credit card or debit card information. This is securely handled by our payment processor (currently Stripe) who is responsible for billing and processing this information in connection with your purchase. However, we may receive a payment token and confirmation of your purchase from our payment processor in order to allow us to provide our Portals and Services to you.
Location Data	Information about your location if you give us permission for this. This is in order to provide certain features of our Sites and to improve and customize our Sites. You can enable or disable location services when you use our Sites, Portals and/or Services at any time by way of your device settings.
Feedback Data	The content you post on the Sites or Portals. If you submit a review, recommendation, endorsement, or other user generated content through our Sites and Portals, or through other websites including Facebook, Instagram, Google, Yelp, and other similar channels, we may share that review, recommendation, endorsement or content on the Sites, Portals or other locations. Note that this content may become public and will be available to our authorized personnel (including personnel at the Franchised Locations) as well as other users of our Sites, Portals or Services.
Marketing Information	Your marketing preferences, including any consents you have given us
Automatically Collected Information	We automatically collect the following information about your use of the Sites, Portals and/or Services, including through cookies, web beacons and other similar technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit the Sites, Portals and/or Services; and the referring URL or the webpage that led you to the Sites. In addition, we collect information regarding application-level events, such as crashes, and associate that temporarily with your account to provide customer services. We combine this information with other personal information collected from you (and third-party service providers may do so on behalf of us or Franchised Locations). If you want to know more about our use of cookies and similar technologies, please refer to our Cookie Notice.

We also collect your personal information from third parties. For example, if we make gift cards available for purchase through the Sites and/or Portals, we may collect the recipient’s and the purchaser’s Identification Information and purchaser’s Payment Details.

We collect information about you from social media websites (e.g., Facebook, LinkedIn, Twitter, Instagram and Snapchat) if you use, access or interact with the Sites or Portals on or through social media websites or any features of the social media websites (such as a Facebook Like button),. The information that we will receive depends on the social network and your privacy settings and this information may be linked to targeting/advertising activities.

Third-party providers provide [insert categories of personal data] to us for the purposes of enhancing the information we collect about customers of the Franchised Locations.

Any information about you that we collect from such third-party sources may also be subject to the privacy policies and practices of such third parties. If you have any questions about how these sources use your personal information or their privacy policies, you should contact them directly.

HOW YOUR PERSONAL INFORMATION IS USED

We may use your personal information for the following purposes (and for the purposes of EEA and UK data protection law where it applies to our processing of personal information, we have set out the legal basis for each purpose):

To maintain the security of our Sites, Portals and Services and to detect, investigate, monitor, remediate and/or prevent security or cyber incidents.

Purpose	Legal basis (where EEA/UK data protection law applies)
To provide the Services to you and to fulfill your orders. In addition, if you use the Sites and/or Portals to make a purchase or reservation, you will receive several emails throughout the transaction process and you may sometimes receive phone calls from our Customer Service Department and/or Franchised Locations to ensure smooth transactions. These communications can relate to the completion of your registration, correction of your data, change of password and other similar communications essential to your transactions on or through the Sites, Portals and/or Services.	It is necessary for us to process your personal information in order to perform our contract with you, or to take steps at your request prior to entering into a contract with you.
To communicate with you about your use of the Services, to respond to your inquiries and for other customer service purposes. If you are a customer of a Franchised Location, you will also receive emails and notifications from us regarding your children(s) activities or progress at the Franchised Location. We and Franchised Locations may also occasionally send out service-related announcements, for instance, if service on the Sites is temporarily suspended for maintenance. Generally, these communications are not promotional in nature, and you will receive them as long as you have an account with us.	We also have a legitimate interest in managing our business, providing Services to you and providing you with relevant service information.
For marketing and promotional purposes, including using your personal information, such as your email address and/or mobile phone number, to send you notifications, text messages, alerts, posts, notices, emails or other communications regarding news and newsletters, special offers, and promotions, or to otherwise call or contact you about products or information that may interest you by email and SMS. We may also provide you with tailored content and ads on this and other sites, apps or social media platforms based on your interactions on the Sites and other sites or apps or social media platforms.	Your consent in relation to direct marketing activities when required under law and the use of cookies and similar technologies. Otherwise, we have a legitimate interest in promoting our products and services, and in keeping you informed about updates and offerings that may be relevant to you.
To better understand how users access and use the Sites, Portals, and/or Services, both on an aggregated and individualized basis, in order to improve the Sites, Portals, and/or Services and respond to user desires and preferences and for other research and analytical purposes. We may share aggregated demographic data with some of our partners for their research and analytical purposes.	Your consent when cookies or similar technologies are used. Otherwise, we and third parties have a legitimate interest in analyzing user behavior to improve the Sites, Portals, and/or Services, enhance user experience and to develop new features.
To protect our business interests, to establish, exercise, or defend legal claims and to protect and enforce the rights, contracts, property, security or safety of us, our business or others, including investigating and helping to prevent fraud or other unlawful activity. Our business interests can sometimes involve undertaking mergers, acquisitions, reorganizations or disposals, as permitted/required in accordance with applicable law.	When we have a legal obligation under EEA/EEA Member State or UK law, we process the data in order to comply with applicable law and regulations. When we have a legal obligation under laws outside the EEA/UK or our processing is not pursuant to a legal obligation, we have a legitimate interest in protecting our business interests and legal rights, and the interests and legal rights of our users.
To meet requests and requirements to disclose from any regulatory, prosecuting, law enforcement, tax or governmental authorities, courts or tribunals.	Where we have EEA or UK legal obligations to meet these requests, it is necessary for us to comply with our legal obligations. Otherwise, it is in our legitimate interests to meet the requests from these sources.
To maintain the security of our Sites, Portals and Services and to detect, investigate, monitor, remediate and/or prevent security or cyber incidents.	Where we have a legal obligation under EEA/EEA Member State or UK law, we process the data in order to comply with applicable law and regulations. Otherwise, it is in our legitimate interests to maintain the security of our Sites, Portals and Services.

In certain circumstances, some of the above grounds for processing will overlap and there will be several grounds which justify our use of your personal information.

You aren't always required to give us your personal information, but where we need to collect or process your personal information by law, or under the terms of a contract we have with you, and you fail to provide that personal information when requested (or fail to consent to the processing of that data, if necessary), we may not be able to perform the agreement or arrangement we have or are trying to enter into with you, or provide you with certain goods and services.

RETENTION OF DATA

We keep your personal information to enable us to fulfil our contract with you or to provide services, whilst you are an active user of our Sites, Portals or Services or where required by law or to protect legal rights.

We always look to keep your personal information for the minimum time in line with data protection principles and processes. For example:

Personal information related to your membership, for as long as personal information is required in order for us to fulfil our contract with you and for 6 years from performance of our contract with you;
Records of Payment Information in line with tax law and audit requirements
Customer feedback and correspondence with our customer services team for up to 2 year afterwards, depending on the nature of the interaction and any applicable law. This enables us to respond to any questions or complaints.

If you unsubscribe from marketing communications or request that we erasure your personal information,, we keep a record of this request indefinitely to ensure we can respect your request in the future.

We will retain your information for longer periods as reasonably required in connection with legal requirements, legal proceedings or claims.

For more information about our retention policies, please contact us using the contact details at the end of this Privacy Policy.

TRANSFER OF DATA

Your personal information, is transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including your personal information, to United States and process it there.

Where these locations do not provide an adequate level of data protection, we ensure appropriate safeguards are in place to protect the transfer of your personal data to these countries. Where EU or UK data protection law, the measures we take are as follows:

Country	Mechanism
United States	Standard contractual clauses as approved by the European Commission Implementing Decision (EU) 2021/914 of 4 June 2021 (available at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32021D0914), and the UK equivalent

A copy of the relevant mechanism can be obtained for your review on request by using the contact details below.

SHARING INFORMATION

We share your personal information with third parties in the following instances:

Code Ninjas LLC and Franchised Locations:

Code Ninjas LLC and the Franchised Locations will share your personal information with each other for the purposes of providing the Sites, Portals and Services, managing your accounts, hosting, IT, security, support, billing, marketing, and communications.

Regulatory, prosecuting, law enforcement, tax or governmental authorities, courts or tribunals:

We disclose your personal information when required by law or upon request to regulatory, prosecuting, law enforcement or governmental authorities, courts or tribunals and any other third parties as required by law..

We also share your personal information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, to protect our property or interests or that of their agents and employees, and to protect guests of a Franchised Location, personal safety, and/or the public.

Third parties in relation to legal claims

We disclose your personal information with third parties where necessary in order to establish or exercise our or their legal rights or defend against legal claims.

Business Transaction:

In the event that our business or our assets (or any part thereof) is/are sold or integrated with another business or company or there is a restructuring or reorganization, your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to prospective counterparties and counterparties as appropriate. You will be notified via email and/or a prominent notice on our Sites of any change in ownership or uses of your personal information if applicable, as well as any choices you may have regarding your personal information.

Advertising, Analytics and other partners:

If you have given consent through our cookie settings (where available), we may share analytics and targeting cookie data with select partners for the purposes of performance metrics, audience selection and targeted advertisement. If you want to know more about our use of cookies, please refer to our Cookie Notice

Third-Party Service Providers:

We disclose your personal information to third party providers (“Service Providers”) who provide services to us and Franchised Locations or have a contractual relationship with us. These Service Providers provide of the following services to us :, , IT services, management or support of our Sites, Portals or Services, data hosting, customer support, tracking internet marketing campaigns, point-of-sale systems and professional services such as auditing, consulting and legal services. We may also use third-party email providers to assist with sending marketing emails for us or on behalf of Franchised Locations.

Where we provide paid products and/or services within the Sites and/or Portals, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-

party payment processors whose use of your personal information is governed by their privacy policy as applicable. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

SECURITY

We take reasonable precautions to protect users’ information. When users submit information via the Sites and/or Portals, we take steps to protect users’ information both online and off-line.

EXTERNAL LINKS

The Sites, Portals and Services may contain links to other websites maintained by third parties. Please be aware that we exercise no control over linked sites and we are not responsible for the privacy practices or the content of such sites. Each linked site maintains its own independent privacy and data collection policies and procedures, and you are encouraged to view the privacy policies of these other sites.

YOUR DATA PROTECTION RIGHTS (UNDER EEA AND UK LAW)

Where EEA or UK data protection law applies to our processing of your personal information, you have certain data protection rights.

The right to access your personal data.
The right to have your information rectified if that information is inaccurate or incomplete. If any Sites, Portals and/or Services allows you to create an account with us, then you may be able to review or update some or all of your personal information (as applicable) by logging into those Sites, Portals and/or Services, visiting your account profile page and making changes.
The right to ask us to delete your personal information in certain circumstances.
The right to object. You have the right to object to our processing of your personal information on the basis of our legitimate interests (or those of a third party), including processing for direct marketing purposes or profiling for purposes of direct marketing, or where we are performing a task in the public interest - your objection will be upheld, and we will cease processing your personal data, unless the processing is based on compelling legitimate grounds or is needed for the exercise or defense of legal claims that may be brought by or against us.
In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
If you opt-out from receiving our marketing communications, you may continue to receive service-related communications, such as communications that are essential to your transactions on or through the Sites, Portals and/or Services.
The right to request that we restrict the processing of your personal information in certain circumstances.
The right request us to transmit personal data that you have provided to us, to a third party, or to be provided with a copy of the information we have on you, in a structured, machine-readable and commonly used format in certain circumstances.

These rights may be limited, for example if fulfilling your request would reveal personal information about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.

Whenever made possible, you can access, update or request deletion of our personal information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

If you wish to exercise any of these rights, please contact us at the contact details set out below. Please note that we may ask you to verify your identity before responding to such requests.

Wherever we rely on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its

withdrawal. You can withdraw your consent from marketing email communications by clicking on the unsubscribe process at the bottom of such communication.

You have the right to complain to a data protection authority in the country that you reside in or, the country of your place of work or the country where the alleged infringement took place. In the UK, this is the Information Commissioner’s Office.

SPECIAL INFORMATION FOR CALIFORNIA CONSUMERS

Your Rights Under the California Consumer Privacy Act :

If you are a California resident, California law may provide you with certain rights with regard to your personal information under the California Consumer Privacy Act ("CCPA"). Throughout this Privacy Policy you will find information required by CCPA regarding the categories of personal information collected from you, the purposes for which we use personal information, and the categories of third parties your information may be shared with. This information is current as of the date of the Policy and is applicable in the 12 months preceding the effective date of the Policy.

As a California resident, the CCPA provides you the ability to make inquiries regarding to your personal information. Specifically, the degree to which you have inquiries beyond what is already provided in this Privacy Policy, you have the right to request disclosure about the collection and use of your personal information over the past 12 months, including:

the categories of personal information collected about you;
the categories of sources for the personal information collected about you;
the business or commercial purpose for collecting your personal information;
the categories of third parties with whom your personal information was shared;
the specific pieces of personal information collected about you;
if your personal information was disclosed for a business purpose, the personal information categories disclosed and the categories of third parties to which the information was disclosed;
if your personal information was sold in the past 12 months, the personal information categories sold and the categories of third parties to which the information was sold (NOTE: CODE NINJAS DOES NOT SELL YOUR PERSONAL INFORMATION).

Please note that you may only make the above requests twice in a 12-month period. You also have the right to request that any of your personal information collected and retained be deleted, subject to certain exceptions. Finally, you have the right to not receive discriminatory treatment by Code Ninjas or any business for exercising any of the rights provided under CCPA.

You may submit a request regarding your rights under CCPA by emailing us at privacy@codeninjas.com or calling (855) 446-4652.

If we receive a CCPA request from you, we will first make a determination regarding the applicability of the law, and we will then take steps to verify your identity prior to responding. The steps to verify your identity may vary based on our relationship with you, but, at a minimum, it will take the form of confirming and matching the information submitted in the request with information already held by Code Ninjas and/or contacting you through previously used channels to confirm that you submitted the request (i.e. confirming identity through the email that we have on file, not the email submitted to make the request).

Your rights as stated here can also be exercised by an authorized agent on your behalf. Code Ninjas will follow the standards set by the Attorney General of California regarding designation of an authorized agent to exercise rights under CCPA. You may review information available through the Attorney General website (https://www.oag.ca.gov/privacy/ccpa) regarding how an individual can be designated as an authorized agent under CCPA.

Direct Marketing:

In addition to CCPA, California residents may have certain rights with regard to marketing under California Civil Code § 1798.83. Individuals who are residents of California and have provided their personal information to us may request information regarding our disclosures, if any, of their personally identifiable information to third parties for direct marketing purposes. Such requests must be submitted to us at: privacy@codeninjas.com.

California privacy rights requests must include the reference "Request for California Privacy Information" on the subject line and in the body of the message and must include the e-mail address or mailing address, as applicable, for us to send our response. This

request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted other than to the address specified above.

Do Not Track:

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

CHILDREN UNDER 13

We support the Children's Online Privacy Protection Act ("COPPA"), and our goal is to minimize the information gathered from and disseminated about kids under 13 while permitting them active participation with the trustworthy information and educational services that we and our Franchised Locations provide.

We have strict limitations about what personal information can be collected and viewed about kids under 13 and how and when they can be contacted. Please see our Children’s Privacy Policy for additional information pertaining to our policies relating to the use of the services by children under the age of 13.

SMS MESSAGING CONSENT and COMMUNICATION

By providing your mobile phone number and opting in to receive SMS messages from Code Ninjas, you agree to the following terms regarding SMS communication:

Consent to Receive SMS Messages:
You voluntarily provide your mobile phone number to Code Ninjas and expressly consent to receive SMS messages for informational, transactional, and promotional purposes related to Code Ninjas services and offerings.
Message Frequency:
Code Ninjas may send SMS messages to the mobile phone number you provided. Message frequency may vary and could include important updates, reminders, promotional offers, and transactional notifications.
Data Charges:
Standard message and data rates may apply to SMS messages sent and received. You are solely responsible for any charges incurred from your mobile carrier for receiving SMS messages from Code Ninjas.
Opt-Out and Cancellation:
If you wish to stop receiving SMS messages from Code Ninjas, you can opt out at any time by replying with "STOP" to the received SMS. This will unsubscribe you from further SMS communications. Opting out will not affect your other interactions with Code Ninjas.
Customer Support:
For assistance or questions regarding SMS messaging, you can contact Code Ninjas customer support by visiting our website or using other provided contact information.
Privacy and Data Usage:
Your privacy is important to us. We will only use your mobile phone number for SMS communication as outlined in our Privacy Policy. We will not share your mobile phone number with third parties for marketing purposes without your explicit consent.
Governing Law:
This SMS Messaging Consent section is governed by the same laws and regulations as the rest of the Code Ninjas website's Terms and Conditions.

For the purpose of data protection law in the EEA and the UK, the data controllers are Code Ninjas LLC and the applicable Franchised Locations where the student or parent visits to access the Services (contact details of which are available on our Sites). However, Code Ninjas LLC is responsible for maintaining this notice and handling all enquiries or requests in relation to your privacy and rights. As such, if you have any question about this Privacy Policy or concerns regarding your privacy, please contact us at privacy@codeninjas.com.

CHANGES IN THIS PRIVACY POLICY

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

By opting in to receive SMS messages from Code Ninjas, you acknowledge that you have read and understood this section and agree to its terms. If you do not agree with these terms, please do not provide your mobile phone number for SMS communication.