Privacy Policy

ⓘ Effective date: July 1, 2023

The Learneo Companies take privacy seriously. This privacy policy describes the personal data we collect, the purposes for which it is used, and your choices regarding its use.

This privacy policy consists of two parts:

For purposes of Part One:

This policy does not cover the practices of companies we don't own or control or people we don't manage.

If you have a disability, you may access this policy in an alternative format by contacting us at privacy@learneo.com .

PART ONE: PRIVACY PRACTICES ACROSS LEARNEO COMPANIES

Personal Data We Collect

To learn about the personal data collected by a Learneo Company and the category of third parties with whom your personal data is shared, please read Part Two.

We will not collect additional categories of personal data or use the personal data we collected for materially different, unrelated or incompatible purposes without providing you notice.

Information That is Not Personal Data

We may create aggregated, de-identified or anonymized data from the personal data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it amongst Learneo Companies and with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

Tracking Tools, Interest Based Advertising And Opt-Out

Learneo Companies and our third-party providers use cookies and other tracking technologies ("Cookies") on the Services to collect information. Detailed information about the Cookies used (including the purpose for using them), interest-based advertising, how to manage Cookies, and do-not-track signals, can be found in each Learneo Company's respective Cookie Policy, which is linked in the respective company's privacy statement in Part Two.

Why We Share Your Personal Data Amongst Learneo Companies

Our Shared Purposes

Learneo Companies share your personal data amongst each other:

Each Learneo Company is considered a controller of personal data for the purposes described above.

For a description of other purposes for which a Learneo Company collects or processes your personal data, other than for the purposes described above, please read Part Two.

How We Share Your Personal Data Amongst Learneo Companies

Your personal data is shared amongst Learneo Companies, as follows:

For how each Learneo Company shares your personal data with third parties other than amongst Learneo Companies, please read Part Two.

Marketing Communications

If you sign up to receive marketing communications from a Learneo Company, that Learneo Company will collect your email address as well as other information on a voluntary basis to help tailor communications to you. You can unsubscribe at any time by clicking the "unsubscribe" link included at the bottom of each email. Alternatively, you can opt-out of receiving marketing communications either through your account settings or by contacting us (see Contact Us section below). Please note that you will continue to receive transactional or account-related communications.

Data Security

We seek to protect your personal data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of personal data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Examples of data security measures include scanning our Services on a regular basis for security holes and known vulnerabilities in order to make your visit to or use of our Services as safe as possible; maintaining your personal data behind secured networks that are only accessible by a limited number of persons with special access rights to such systems and who are under obligation to keep the information confidential; and implementing a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal data.

Data Retention

For Services requiring an account, the relevant Learneo Company will retain your personal data for as long as you have an open account or as otherwise necessary to provide you with Services. In some cases we retain personal data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information indefinitely in a de-identified, anonymous or aggregated form where that information would not identify you personally, as described in the policy and permitted under applicable privacy laws.

Changes To This Privacy Policy

We are constantly improving our Services, so we may need to change this policy from time to time, but we will alert you to any material changes by placing a notice on the product specific website to which the changes apply, by sending you an email and/or by some other reasonable means.

Additional Terms For Canadian Residents

If you reside in Canada, the following additional terms apply. If there are any conflicts between this section and any other provision of this policy, the provision that is more protective of personal data will apply.

Transfers of Personal Data Outside Canada

We may share your personal data amongst Learneo Companies, with third party service-providers and other third parties that require such information to assist us in providing Services to you. In the course of providing these Services, your personal data may be accessed, collected, stored and processed in the U.S. or other foreign jurisdictions by a Learneo Company or its third party service providers. Learneo Companies and third-party service providers may disclose your personal data in response to a search warrant or other legally valid inquiry or order or as otherwise required or permitted by Canadian, US, or other law (which may include disclosure to US and foreign courts, law enforcement or governmental authorities). In the case of a transfer of personal data to Learneo Companies or third-party service providers that process or store personal data on behalf of a Learneo Company, the Learneo Company and/or third party recipient will have agreed to safeguard personal data and use the information only for the purpose(s) for which it has been provided.

Canadian Resident Rights

Subject to applicable law, you have the right to access, update and correct inaccuracies in your personal data in our custody or control. You can request this by email or by writing to us at the contact information set out in the Contact Us section below. We may request certain personal data for the purpose of verifying the identity of the individual seeking access to his or her personal data records.

Additional Terms For California Residents

This section provides information in accordance with the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act for California residents about how Learneo Companies handle certain personal data collected over the past 12 months. If you are a California resident, you have the rights set forth in this section. For how to exercise these rights, see the Exercising Your CCPA Rights section. If there are any conflicts between this section and any other provision of this policy, the portion that is more protective of your personal data will apply.

California Resident Rights under the CCPA

Exercising Your CCPA Rights. To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both criteria will be considered a " Valid Request ." We may deny requests that do not meet these criteria as permitted by applicable data privacy laws. You may appeal any denial by contacting the Learneo Company relevant to your request; you can find the contact details for the relevant company in Part Two below. We will only use personal data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request. Please see the Contact Us section for where to submit a Valid Request.

Authorized Agent. You may authorize an agent (an " Authorized Agent") to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Non-Discrimination. We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of personal data that we receive from you.

Categories of Third Parties We Have Shared Your Personal Data With

For the categories of third parties with whom a Learneo Company shares the personal data it collects and has collected about you over the past 12 months, please read the product specific section in Part Two .

Your Rights under California's Shine-the-Light Law

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of personal data to third parties for such third parties' direct marketing purposes. To submit such a request, please see the Contact Us section and specify "California Shine the Light Request" in the subject line.

Additional Terms For Residents of Other US States

This section provides information in accordance with US States other than California that may now or in the future have enacted state data privacy laws, including but not limited to the Virginia Consumer Data Privacy Act (the “VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTPA”), the Utah Consumer Privacy Act (“UPA”), and the Iowa Consumer Data Protection Act (“IPA”). For residents of these US States, this section provides Information about how Learneo Companies handle certain personal data that we have collected about you. If you are a resident of one of these US States, you have the rights set forth in this section. For how to exercise these rights, see the Exercising Your US State Privacy Rights section. If there are any conflicts between this section and any other provision of this policy, the portion that is more protective of your personal data will apply.

Rights Under Effective US State Laws

Exercising Your US State Privacy Rights. To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both criteria will be considered a “Valid Request.” We may deny requests that do not meet these criteria. You may appeal any denial by contacting the Learneo company relevant to your request; you can find the contact details for the relevant company in Part Two below. We will only use personal data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request. Please see the Contact Us section for where to submit a Valid Request.

Non-Discrimination. We will not discriminate against you for exercising your rights under applicable US State privacy laws. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights. However, we may offer different tiers of our Services as allowed by applicable data privacy laws with varying prices, rates or levels of quality of the goods or services you receive related to the value of personal data that we receive from you.

Additional State Law Privacy Rights

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal data to third parties who intend to license or sell that personal data. Please note that we do not currently sell your personal data as sales are defined in Nevada Revised Statutes Chapter 603A.

Complaints

If you have an unresolved privacy concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request . Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means.

If you are a European Economic Area or UK resident, please see the Additional Terms for European Economic Area and UK Residents section for where to lodge a complaint.

Additional Terms For European Economic Area And UK Residents

If you reside in the European Union, Lichtenstein, Norway or Iceland (collectively, the European Economic Area or " EEA") or the United Kingdom, the following terms apply. If there are any conflicts between this section and any other provision of this policy, the provision that is more protective of personal data will apply.

The personal data processed by Learneo Companies, as described in Parts One and Two, are processed under the following legal basis:

EEA and UK Resident Rights

Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include personal data, if necessary to verify your identity and the nature of your request.

If you wish to exercise any of your rights, please see the Contact Us section of this policy.

Cross Border Transfers of Personal Data

Learneo Companies are located in the United States, Israel, India, The Netherlands, and Canada and may continue to grow in other countries. We also have service providers both in the United States and throughout the world. As such, Learneo Companies and our service providers may transfer your personal data to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. When we transfer information about individuals based in the EEA or UK outside of those countries, we will take appropriate measures to safeguard the transfer as required by applicable law, including by using the European Commission-approved standard contractual data protection clauses or following an adequacy decision by the EU Commission. If you do not want your personal data transferred outside of the EEA or UK, please do not submit any personal data to us or use our Services. You may always contact us to request a copy of the transfer measures that we have taken to safeguard the transfer of your personal data.

Complaints

You have the right to lodge a complaint about our practices with respect to your personal data before a supervisory data protection authority.

Contact Us

If you subscribed to more than one Service at checkout and would like to exercise any of the rights under applicable privacy law, you can submit your request to Learneo, Inc. and indicate so on the request; Learneo, Inc. will process it accordingly. Otherwise, please contact the Learneo company relevant to your request; you can find the contact details for the relevant company in Part Two below.

Learneo, Inc.
Attn: Monique Ho, General Counsel
2000 Seaport Blvd, Floor 3
Redwood City, CA 94063 USA
866-634-9397
privacy@learneo.com
GDPR/US State Privacy Laws Request Form

EEA and UK residents may contact our EU and UK based representative regarding all requests related to data protection and privacy:

DP-Dock GmbH
Ballindamm 39
20095 Hamburg, Germany
www.dp-dock.com

DP Data Protection Services UK Ltd.,
16 Great Queen Street, Covent Garden
London, WC2B 5AH, United Kingdom
www.dp-dock.com

PART TWO: PRODUCT SPECIFIC PRIVACY DETAILS

This Part Two describes how each Learneo Company processes your personal data to deliver its Services to you. Please click on the applicable Service for details.

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