Privacy Policy – Genius Programs LLC

Updated May 1, 2024

This privacy policy describes the types of personal information Genius Programs LLC (“Genius Programs” or “we” or “us”) collects about Users (“User” or “you”) and Participants of the My Food Program and/or Ready Records web site (“Web site”) and the My Food Program and/or Ready Records Mobile App (“App”), how we use the information, and with whom we may share it. We also describe the measures we take to protect the security of the information and how Users can contact Us about our privacy practices.

Personal Information We Obtain and How We Use It

When you use My Food Program and/or Ready Records web site or mobile app, you create a username and a password to access My Food Program and/or Ready Records. Users have the option to provide a ten-digit mobile number and an email address in order to receive email messages for the purposes of certain notifications and password resets. My Food Program and/or Ready Records does not require any other personally identifying information about users of the web site or mobile application.

Participants at sites and sponsors using My Food Program and/or Ready Records will have some personally identifying information (“Participant Personal Information”) registered in the system. This information includes the participant’s name, date of birth, guardian name, address, email address and phone number and household income eligibility, enrollment and data on dietary preferences and restrictions. My Food Program and/or Ready Records retains this information solely for the purposes of helping sponsors and sites administer the USDA Child and Adult Care Food Program or Summer Food Service Program using My Food Program and/or Ready Records. It is not used for any other purposes. Participant Personal Information is the property of the sponsor and can not be sold, aggregated, or otherwise disclosed by Genius Programs except as noted below.

How We Protect the Personal Information We Collect

We implement reasonable administrative, technical, and physical safeguards that are designed to protect User Personal Information provided from unauthorized access, use, or disclosure. We also employ the same measures to protect Participant Personal Information.

Sharing of Personal Information

We do not sell, trade, or otherwise disclose the personal information we collect from or about users or participants, except as described herein. We may share user personal information with Service providers who perform services on our behalf, such as sending text/SMS messages. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

Additionally, we may disclose anonymous, aggregated information about our Users or Participants, including you, to third parties for any purpose if we deem such disclosure to have sound business reasons or justifications.

Lastly, we may disclose information about you (1) if we are required to do so by law or legal process, (2) to law enforcement authorities or other government officials, or (3) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

California Residents: for information about how we share your data, please see below.

Opt-Out

You may opt-out of certain communications we send you, for example, by clicking on the “unsubscribe” link in marketing emails or texting “STOP” in response to text/SMS messages. Please be aware that there may be a brief period before we are able to process your opt-out, but we will always respect your legal rights to opt-out of receiving unwanted messages.

Children’s Policy

The Web site or App is not intended for use by persons under the age of eighteen (18).

Updates to this Privacy Policy

This privacy policy may be updated periodically on our website (www.myfoodprogram.com) and without prior notice to you to reflect changes in our personal information practices. We will indicate at the top of the privacy policy when it was most recently updated. To view this privacy policy online, please visit www.geniusprograms.com/privacy.

Contact Us

If you have any questions about this privacy policy, or would like to receive an electronic copy, contact Genius Program’s Privacy Officer at:

260 Wentworth Ave E Ste 155
West Saint Paul, MN 55118-3525
privacy@myfoodprogram.com
www.myfoodprogram.com

California Privacy Policy

This Privacy Policy for California Residents supplements the information contained in Genius Programs LLC (“Genius Programs” or “we” or “us” or “our”) general Privacy Policy, the My Food Program and/or Ready Records website (“Website), the My Food Program and/or Ready Records Mobile App (“App”), and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). Any terms defined in the CCPA have the same meaning when used in this Policy.

This policy provides information about the categories of information that we collect from California residents generally, the sources of the information, the purposes for which we use the information, and the categories of third parties to whom we disclose the information for business purposes and to whom we sell Personal Information as defined by CCPA. It also includes information on how to opt-out.

Information Genius Programs Collects for Participants
When a family child care home, child care center, adult day care or other site (“site”) uses the Website or App, the Website or App is collecting information about participants (“participant information”) in the CACFP program. Sites are affiliated with an entity referred to as a “Sponsor” who is the customer of Genius Programs. This participant information is either directly linked to the participant or could reasonably be linked, directly or indirectly with a particular consumer or household. Participant information is controlled by the Sponsor. Genius Programs acts as a third party processor.

Requests to exercise rights under the CCPA as a participant are to be sent to the Sponsor.

Information Genius Programs Collects for Website and App Users
When you use the Website or App we collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“User Personal Information”). The following are the categories of User Personal Information that we have collected from consumers who have used the Website or App the last twelve (12) months, and examples and the types of information those include.

Category	Examples
Identifiers	A real name, unique personal identifier, email address
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, telephone number
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories, usage, or tendencies.
Biometric information	Photo
Inferences drawn from other Personal Information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes: survey information.

Sources from Which User Personal Information Is Collected

From your sponsor. For example, your sponsor may create an account with your personal information.
From your employer. Your employer may create an account with your personal information to use the Website and/or App.

We may use, sell, or disclose the Personal Information we collect for one or more of the following purposes:

To provide the services from the Website and/or App.
To create, maintain, customize, and secure your account with us.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To protect Genius Programs from potential civil and criminal liability.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your User Personal Information or as otherwise set forth in the CCPA.

We will not collect additional categories of User Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you an updated Privacy policy.

Sharing and Selling Personal Information
We will not disclose your Personal Information to a third party for a business purpose or sell your Personal Information subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights).

Disclosure of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has disclosed your Personal Information with the following categories of third parties:

Service providers, such as those that deliver our communications
Identifiers, Personal Information (mobile number), Commercial Information, Biometric Information, and Inferences Drawn from Personal Information

Sales of Personal Information
In the preceding twelve (12) months, Company has not sold your Personal Information to the following categories of third parties.

Exercising Your California Access, Deletion and Do Not Sell Rights
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information.

Your Access Rights
Upon request and subject to our verification, we will disclose to you:

The categories of Personal Information we collected about you.
The categories of sources for the Personal Information we collected about you.
Our business or commercial purpose for collecting or selling that Personal Information.
The categories of third parties with whom we share that Personal Information.
The specific pieces of Personal Information we collected about you.
The Personal Information that we sold or disclosed for a business purpose, including:
- For a sale, the categories of Personal Information a recipient purchased; and
- For a disclosure, the categories of Personal Information that each category of recipient obtained.

We will provide the requested information free of charge up to two (2) times in a 12-month period, but please note that where we receive unfounded, excessive or repetitive requests, we may elect to decline the request. As discussed below, Genius Programs will only disclose the requested information to the extent permitted by law once we receive and confirm your verifiable consumer request.

Your Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Upon request and subject to our verification we will delete (and direct our service providers to delete) your Personal Information from our records unless an exception (described below) applies.

Deletion Rights Exceptions
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Comply with a legal obligation.
Debug products to identify and repair errors that impair existing intended functionality.
Complete the transaction for which we collected the Personal Information, provide our services, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

To exercise the access and deletion rights described above, you may submit a request by contacting us via any of the methods below. Note, you must use your mobile phone or web browser for the website or email option.

Email: privacy@myfoodprogam.com

Address:
Genius Programs
260 Wentworth Ave E Ste 155 
West Saint Paul, MN 55118-3525

Verifying Requests
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. In order to verify your identity, you must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of the requestor, which may include:

Mobile number used in the Website/App
Email address used at a Website/App
Date of last transaction at a Website/App
Location of your last transaction at a Website/App

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided to verify the requestor’s identity or authority to make the request.

Authorized Representative
If you would like to authorize an agent to act on your behalf in submitting a request to know, request to delete, or request to opt-out of the sale of your Personal Information, you may do so by submitting a signed Declaration of Designated Agent to privacy@myfoodprogram.com. Please keep in mind that if we do not receive adequate proof that the request agent is authorized to act on your behalf, we may deny the request.

Response Timing
When you submit a verifiable request to (a) access the Personal Information we have collected, sold, disclosed, or (b) delete your Personal Information, we will (1) confirm receipt within ten (10) business days and (2) make every attempt to respond to the request within forty-five (45) days of receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

Personal Information Sales Opt-Out and Opt-In Rights
If you are 18 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “Right to Opt-out”). We do not sell the Personal Information of consumers we actually know are less than 18 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request by contacting us via any of the methods below. Note, you must use your mobile phone or web browser for the website or email option.

Email: privacy@myfoodprogam.com

Address:
Genius Programs
260 Wentworth Ave E Ste 155 
West Saint Paul, MN 55118-3525

We will only use Personal Information provided in an opt-out request to review and comply with the request. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. Should you use our Website or App again, you rescind your opt-out of sale request and reauthorize us to sell your Personal Information.

Users Younger Than 18
The Website and App are not to be used by users younger than 18 and, therefore, does not knowingly collect or sell Personal Information of minors younger than 18 years of age.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website or App that are California residents to request certain Information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@myfoodprogram.com, or write to us at:

Genius Programs
260 Wentworth Ave E Ste 155
West Saint Paul, MN 55118-3525.