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PRIVACY NOTICE

Last Updated July 23, 2024

 * Scope of this Notice
 * Changes to this Notice
 * How We Collect Personal Data
 * How We Use Personal Data
 * Sharing Personal Data
 * How Long We Keep Personal Data
 * Opt Out of Marketing
 * Cookies and Similar Technologies
 * Children's Online Policy
 * Legal Basis of Processing
 * International Transfers
 * Your Rights
 * Contact Us


SCOPE OF THIS NOTICE

We are Articulate Global, LLC ("Articulate," "we," "us," or "our"), a provider
of tools for workplace learning, located at 244 5th Avenue, Suite 2960, New
York, NY 10001, USA. This Privacy Notice describes how we collect, use, share,
and store your personal data when individuals visit our websites, access our
Articulate 360 and Rise e-learning services, participate in our E-Learning
Heroes Community, register to attend our events and webinars (online and in
person), participate in surveys or sweepstakes, apply to our job posting, and
contact us through various communication methods (the "Services"). This Notice
also describes your choices as related to your personal data.

Links to Other Websites. This Notice does not apply to websites we do not own or
control. We are not responsible nor liable for how third parties manage their
own sites. Please refer to the privacy notices posted on those sites for more
information.

Personal Data. Personal data refers to information relating to an identified or
identifiable individual including name, phone number, company name, job, email,
and postal address. By providing the Services, we do not knowingly collect
sensitive personal data such as precise geolocation data, racial or ethnic
origin, political opinions, religious or philosophical beliefs, or trade union
membership, genetic data, biometric data, data concerning health or data
concerning a natural person's sex life or sexual orientation.

Usage Data. Passively or automatically collected data (referred to as "Usage
Data") is collected as you use our websites or access our services. We, our
affiliated entities, our service providers, and our marketing partners may use
automated means to collect various types of information about you, your computer
or other device used to access the sites and Services. This information is based
on your usage of our sites and services and may be based on your visitation to
other websites.

Data Controller. We act as the data "Controller" for the personal data you
provide directly to us. Examples include when you fill out the "Contact Us"
form, create an account, participate in surveys or sweepstakes, participate in
our E-Learning Heroes Community, attend events, apply to one of our jobs, or
contact us via other methods.

Data Processor. If you are an employee or an authorized user of one of our
customers, which has entered into an agreement with us for the provision of our
Services, we will be acting as the "Processor" of your personal data transmitted
by such customer. That customer will be acting as the Controller of your
information. As a processor, we do not own, control, or direct the use of any
data provided to us by our customers who act as the Controllers. If you have
questions on how your personal data is being handled, please direct your
inquiries to our customer, the Controller. If you contact us, we may be
obligated to inform our customer of your request.


CHANGES TO THIS NOTICE

We may update this Notice from time to time. If we make changes, we will revise
the date at the top of this Notice. If we make material changes, we may provide
additional notice such as sending you an email or posting a statement on our
homepage prior to the changes taking effect as required by law. We encourage you
to review this Notice periodically.


HOW WE COLLECT PERSONAL DATA

INFORMATION YOU PROVIDE TO US

We collect personal data directly from you or through our third-party service
providers such as when you make an inquiry through our "Contact Us" web page,
chat, support or by other contact methods, apply to our job posting, and when
you request that we send you emails. Depending on where you reside, you may have
the option to provide your consent before we collect your personal data to send
you marketing emails. You may unsubscribe to our marketing emails by using an
opt-out link contained  in the marketing email or by updating your marketing
preferences on your account page. We also store the files or other information
that you upload or provide to us as part of your subscription.

PROFILE INFO

We collect information about you when you register with us for an Articulate ID,
create or modify your online account, join our E-Learning Heroes Community,
access and use our services, participate in a survey, contest, or event, make a
purchase, apply for a job, request customer support, communicate with us via
third-party social media sites, or otherwise communicate with us.

The types of information we may collect directly from you include your name,
user name, email address, avatar, postal address, phone number, employer's name,
transactional information (including services purchased or subscribed to and
billing address) as well as any contact or other information you choose to
provide.

Please be aware that the information you choose to provide in your Articulate ID
profile may reveal information that is not expressly stated (for example, if you
choose to provide your picture, your picture may reveal your gender).

JOB CANDIDATES

We collect information from you when you apply to one of our posted positions.
The types of information we may collect directly from you include your name,
email address, phone number, LinkedIn Profile, personal website, and information
in your résumé and cover letter. You have the option to provide demographic
information that will be used on an aggregate basis (e.g. gender, ethnicity,
veteran status, disability status). Demographics information will not be used to
identify you nor used to evaluate your qualification for the role.

PERSONAL DATA WE COLLECT FROM THIRD-PARTY SOURCES

We use third-party applications to add firmographic information to the data we
collect from you. This data enhancement allows us to provide more helpful,
personalized communication.

PERSONAL DATA WE COLLECT AUTOMATICALLY

USAGE DATA

We collect Usage Data about you when you access and use the Services, including
your Internet Protocol (IP) address, access times, browser type and language,
Internet Service Provider (ISP), the web pages that you visit, behavior during
the visit, the content you use, and the URL of the web page you visited before
navigating to our Services.

We collect Usage Data through cookies and similar technologies. For additional
information and how to set your browser to reject cookies, see the Cookies and
Similar Technologies section below.

Subject to your right to opt-out, we may combine Usage Data with personal data
that we collect, and use the combined data to create profiles about you only for
purposes of improving our products and services and your user experience with
our products and services.

We may use Usage Data for analytics, to customize re-marketing ads, offers and
content made available to you based on your visits to and/or usage of our sites
or the Services, and to analyze the performance of those ads, offers and
content, as well as your interaction with them.

MOBILE DEVICES

If you access the Services from a mobile device, we collect information about
the device, including the hardware model, operating system and version, unique
device identifiers, mobile network information (as allowed by the mobile
network), or platform information (as allowed by the specific platform type). We
do not ask for, access, or track any location-based information from your mobile
device at any time while you are downloading.


HOW WE USE PERSONAL DATA

We may use the information we collect about you for a variety of purposes,
including to:

OPERATE OUR SERVICES

We use the information we collect about you to provide, operate, maintain, and
improve our Services. We also use this information to help you use the Services,
including uploading, downloading, collaborating on, and sharing content,
delivering e-learning content to learners, as well as delivering emails on your
behalf such as sending emails to your collaborators when you comment in Review
360.

We also use information about you to provide and deliver the Services and
features you request, to process and complete transactions, and to send you
related information, including purchase confirmations and invoices.

COMMUNICATE WITH YOU

We also use the information we collect about you to send you technical notices,
updates, security alerts, support and for administrative messages. We'll also
use that information to communicate with you about Services, features, surveys,
newsletters, offers, promotions, contests, and events, as well as provide other
news or information about us and our select partners.

Of course, we'll also use your information to respond to your comments,
questions, chat or other contact requests (including recordings of your chat or
communication transcripts), provide customer service and support, and deliver
contest entries and rewards.

PROTECT OUR SERVICES

We also use information about our users to investigate and prevent fraudulent
transactions, unauthorized access to our services, and other illegal activities.

IMPROVE OUR APPS AND SERVICES

If you're an Articulate 360, Rise, perpetual product customer or trial
subscription user, we track what apps you use and some of the features that you
use when you're using those apps. We may also track information about the
websites you visit, the sizes and names of the files or folders you upload,
download, share, or access while using our Services, the content you access, and
any actions taken in connection with the access and use of your content in our
Services.

This app usage information helps inform our product development. We also use
this information to send you targeted content to support you in using our apps.

PERSONALIZE OUR WEBSITE AND COMMUNICATION WITH YOU

We use cookies and similar technologies to help us see what pages you view on
our site and any actions you take. That helps us develop helpful content and
serve you customized web content and communication that best meets your needs.
Please review the Cookies and Similar Technologies section for more information.

HELP YOU USE OUR SERVICES

If you're an Articulate 360 or Rise customer, we analyze your product usage
information to see how you're doing with our apps and resources. We use customer
profiles to prioritize outreach from our team, send you helpful information, and
guide us in creating content to help customers make the most of their
subscriptions.

ADVERTISE TO YOU

When you've visited our sites, we place cookies and a tracking pixel in your
browser that helps us show you targeted ads on other sites you visit. We only
place cookies and a tracking pixel in your browser as described below in the
Remarketing section under Cookies and Similar Technologies. 

PROCESS YOUR JOB APPLICATION

We will use the information you have provided us to manage job applications and
comply with legal reporting requirements such as affirmative action.


SHARING PERSONAL DATA

General Disclosure Policy. We may share and disclose your personal data as
described below. We may share and disclose Usage Data without restriction,
including without limitation, as described below.

We may share and disclose your personal data to the following types of third
parties.

Service Providers. We may share your personal data and Usage Data with our
third-party service providers, vendors, and consultants working on our behalf to
provide the Services to you and to operate and maintain our sites. For example,
we may contract with service providers to process payments, host our servers,
provide security, provide support via chat or other methods, and provide
production, fulfillment, optimization, analytics, reporting, and software
maintenance and development services. In addition, our service providers will be
given access to your information only as is reasonably necessary to provide the
Services for which they are contracted.
For a list of service providers we use to deliver Articulate 360 e-learning
services to you, please click to see our trusted sub-processors.

Marketing Partners for Purposes of Re-Marketing. We may share your personal data
with service providers, vendors and consultants for purposes of re-marketing.
For a description of re-marketing and your opt-out rights, see the Remarketing
within the Cookies and Similar Technologies section below.

Affiliated Entities. We may provide your personal data and Usage Data to any
affiliated entities we may have, including our subsidiaries. Affiliated entities
are entities that we legally control (by voting rights) or that control us.

Successors.  If we sell or otherwise transfer part or all of our business or
assets to another organization, such as in the course of an acquisition, merger,
bankruptcy or liquidation, we may transfer your personal data.

Authorized Resellers. If you acquire our Services through an authorized reseller
or partner, we may share your personal data and Usage Data with those authorized
resellers and partners so that they can provide customers with timely, helpful
information about our products and the Services. Our resellers are contractually
obligated to abide by this privacy notice, preventing them from sharing your
personal data with any other third parties. Several of our resellers are located
in the European Union (EU) and/or the United Kingdom. For more information
regarding our authorized resellers and their safeguards, request descriptions
via our Contact Us section below.

Additional Disclosures. We may disclose your personal data where (a) we believe
that disclosure is reasonably necessary to comply with any applicable law,
regulation, legal process, or governmental request, (b) to enforce our
agreements, policies, and Terms of Use, (c) to protect the security or integrity
of our Services, (d) to protect us, our customers, or the public from harm or
illegal activities, (e) to respond to an emergency which we believe in good
faith requires us to disclose information to assist in preventing the death or
serious bodily injury of any person, or (f) to respond to claims that any
content violates the right of third parties.

We may also share aggregated or anonymized information that does not directly
identify you with third parties.


HOW LONG WE KEEP PERSONAL DATA

We will not retain your personal data for longer than required. This means that
we will keep your personal data for any or a combination of time periods
described as follows: (i) for as long as required by law, (ii) until we no
longer have a valid reason for keeping it, (iii) until you request us to stop
using it, or (iv) for so long as our customer for which you are an authorized
user remains a customer. In addition, we retain your personal data to preserve
history in the E-Learning Heroes Community and to provide the ongoing ability to
participate. When we delete your personal data from our databases, it will
remain in our backup system until it cycles out.


OPT OUT OF MARKETING

If you reside in the EU, EEA Switzerland or the UK, you have the option to grant
your consent for receiving marketing emails from us to promote our own Services.
Regardless of your location, you may unsubscribe to those emails at any time by
using an opt-out link contained in every marketing email, by updating your
marketing preferences on your account page, or by visiting our email
subscription preferences for Articulate 360 services or Rise services.


COOKIES AND SIMILAR TECHNOLOGIES

We may automatically collect Usage Data through the use of persistent or session
cookies, javascripts, pixels, web beacons, local storage (HTML5), and similar
technologies, which we jointly refer to here as "cookies." Cookies are small
text files or a piece of code a website uses to recognize repeat users,
facilitate the user's ongoing access to the site, and facilitate the use of the
site. Cookies also allow a site to track usage behavior and compile site-usage
information that will allow for the improvement of content. View the cookies
used by Articulate 360 sites and the cookies used by Rise sites. You may reject
cookies by activating the setting on your internet browser. However, if you
select this setting you may be unable to access certain parts of our sites.
Unless you have adjusted your browser setting so that it will reject cookies,
our system will issue cookies when you log on to our site.

If you would like to modify your cookie preferences or opt-out, visit the page
Information We Collect.

You can also use the Global Privacy Control (“GPC”) to opt-out of tracking
through cookies or similar technology. To learn more about the GPC, please visit
https://globalprivacycontrol.org. If you delete cookies or reset your device,
you may need to set your preference again to ensure we continue to honor your
preferred choice.

REMARKETING

We use third party vendors' remarketing tracking cookies and pixels, including
the Google Adwords tracking cookie. This means we will continue to show ads to
you across the internet, specifically on the Google Content Network (GCN). The
third-party vendors, including Google, will place cookies on web browsers in
order to serve ads based on past visits to our websites. This allows us to make
special offers and continue to market our products to those who have shown
interest in them.

As described above, you can control the information cookies collect on our site
as described above. You may also opt-out of Google's use of cookies by visiting
the Ads Preferences Manager and out of other third-party marketing cookies by
visiting the Network Advertising Initiative opt-out page.

If you are subject to the laws and regulations in the European Union,
Switzerland, or the United Kingdom, we will only use remarketing tracking
cookies and pixels collected through the use of non-essential cookies with your
consent. You are not obligated to give consent for our use of non-essential
cookies. You may modify your cookie preferences or opt out through our website
by visiting the page Information We Collect.

ANALYTICS

We engage third party analytics partners to monitor and analyze our web traffic
and to keep track of user behavior on our sites.

Google Analytics (Google). Google Analytics is a web analysis service provided
by Google Inc. ("Google"). Google utilizes the data collected to track and
examine the use of our sites, to prepare reports on its activities, and to share
them with other Google services. You may opt-out of the Google Analytics service
with Google's Browser Add-on that's available
at https://tools.google.com/dlpage/gaoptout.


CHILDREN'S ONLINE POLICY

Our websites are general audience sites and not directed to children. Consistent
with the U.S. Children's Online Privacy Protection Act (COPPA), we do not
knowingly collect any personal data from, or sell to, children under the age of
13. If you are a parent or guardian who has discovered that your child under the
age of 13 has submitted his or her personal data without your permission or
consent, we will remove the personal data from our active list, at your request.
To request the removal of your child's information, please contact us as
provided below under the Contact Us section and be sure to include in your
message the login information that your child submitted.


LEGAL BASIS OF PROCESSING

We collect and use your personal data based on the following legal grounds.

Consent. In these situations, you have given us consent to process your personal
data. For example, when you register for one of our webinars by filling out a
webform containing your name and email address.

Legitimate Interest. We process personal data when we have a legitimate interest
to do so. Some examples are to maintain and improve our Services, inform you of
changes to our Services, securing our Services, and analyze your use of our
Services and potential sales leads.

Performance of a Contract. This is where we process your personal data to
fulfill our contractual obligations to you. For example, we use your personal
data to deliver e-learning services you have requested.

Other Legal Bases. There may be times when we are legally obligated to process
or share your personal data, such as in response to a subpoena or court order,
to protect the vital interests of others, or to defend against legal claims
asserted against us.


INTERNATIONAL TRANSFERS

If you are from outside the U.S., you understand and agree that your personal
data and Usage Data may be stored and accessed in the United States. That
personal data may be then transferred within the U.S. or back out of the U.S. to
other countries outside of your country of residence. Our collection, storage,
and use of your personal data and Usage Data will at all times be governed by
this Privacy Notice, and in compliance with the General Data Protection
Regulation, including the use of Standard Contractual Clauses. Please see
our GDPR page for more information on international data transfers.

By accessing or using our services or otherwise providing information to us, you
consent to the processing and transfer of information in and to the U.S. and
other countries and territories, which may have different privacy laws from your
country of residence.

EU-U.S. AND SWISS-U.S. DATA PRIVACY FRAMEWORK NOTICE

This section applies to individuals located in the European Economic Area (EEA)
and Switzerland, and the United Kingdom, through the UK Extension.

We have certified our adherence to the EU-U.S. Data Privacy Framework and
Swiss-U.S. Data Privacy Framework, along with the UK Extension (together, the
"DPF Program") regarding the transfer of personal data from the EEA and
Switzerland to the United States. To learn more about the DPF program and to
view our certification, please visit https://www.dataprivacyframework.gov/s. We
are responsible for processing personal data we receive under the DPF Program
and subsequent transfers to a third party acting as agent on our behalf. We
comply with the DPF Program for all onward transfers of personal data from the
EEA and Switzerland.

In compliance with the DPF Program, we commit to resolve complaints about our
collection or use of your personal information. EEA and Swiss individuals with
inquiries or complaints regarding our participation in the DPF Program should
first contact us at privacy@articulate.com regarding Articulate 360 services
and privacy@rise.com regarding Rise services.

If we do not resolve your complaints, you may contact your local data protection
authority. We are subject to the investigatory and enforcement powers of the
U.S. Federal Trade Commission. Contact details for the EU data protection
authorities can be found
at https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm .
Contact details for the United Kingdom Information Commissioner (ICO) can be
found at https://ico.org.uk/. Contact details for the Swiss Federal Data
Protection and Information Commissioner (FDPIC) can be found
at https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html#:~:text=For%20questions%20on%20data%20protection,058%20462%2043%2095.
You may be entitled to invoke binding arbitration when other dispute resolution
procedures have been exhausted.


YOUR RIGHTS

You may refer to the Contact Us section below on how to inquire about your
rights.

Depending on your location and whether the privacy law of a geographic region
applies to you, you may have certain privacy rights such as the right to 1)
access – inquire what personal data we have about you, 2) correction – update
your personal data, 3) restrict processing – limit how we process your personal
data, 4) withdraw consent – request we stop processing your personal data when
permission was originally granted by your permission to do so, 5) deletion –
delete your personal data in our system, 6) portability – providing you with a
copy of the personal data for transfer to your chosen third party. If we decline
your request, we will generally provide you with the reasons.

Articulate Acting as a Processor. Please note that if you are authorized by one
of our customers to access our Services, our customer is the data controller of
your personal data. In those situations, please contact our customer directly
with your request. As our customer's data processor, we will gladly assist our
customers and do not have permission to directly honor your request.

US STATE PRIVACY RIGHTS

This section provides information about the personal data we collect about
California consumers and their rights under California Consumer Privacy Act
(CCPA) and similar statutes in Colorado, Connecticut, Utah, and Virginia,
including other states that subsequently enact such laws.

Under these state laws, consumers may have the following rights:

 1. Subject to certain limitations, right to request details about the
    categories or specific pieces of personal data we collect about you
    (including how we use and disclose this information)
 2. The right to request correction of inaccurate information about you
 3. Subject to certain limitations, right to delete your personal information
    (subject to certain limitations)
 4. Right to opt out of any "sales" or sharing for cross-context behavioral or
    targeted advertising that may be occurring
 5. Right to not be discriminated against for exercising your rights
 6. Right to appeal any decision regarding the above rights by contacting us

For more details about the personal data we may have collected about you over
the last 12 months, including the categories of sources, please see the How We
Collect Personal Data section above. We share this information with the
categories of third parties described in the Sharing Personal Data section.

You may exercise your privacy rights described above by sending an email to the
address in the 'Contact Us' section below and please include "Privacy Rights
Request" in the subject line, the domain name of the website you are inquiring
about, along with your name and email address. We will verify your identity
using the information associated with your account. You can also designate an
authorized agent to exercise your rights on your behalf.

You may exercise your rights under CCPA by sending an email to the address in
the 'Contact Us' section below and please include "California Privacy Request"
in the subject line, the domain name of the website you are inquiring about,
along with your name and email address. We will respond to you within thirty
days of receiving such a request and will verify your identity using the
information associated with your account. You can also designate an authorized
agent to exercise your rights on your behalf.

Note: We do not sell your personal data to data brokers, aggregators, and
similar third parties for monetary compensation. Thus, you do not need to
contact us to request an opt-out for that type of activity. However, we do use
third party cookies for our own advertising purposes, including cross-context
behavioral or targeted advertisements, as described in our Cookies and Similar
Technologies section and you can opt-out as described. As also noted above, we
have enabled and recognize the Global Privacy Control (“GPC”) to allow you to
opt-out of tracking through cookies or similar technology. To learn more about
the GPC, please visit https://globalprivacycontrol.org. If you delete cookies or
reset your device, you may need to set your preference again to ensure we
continue to honor your preferred choice.

ADDITIONAL SPECIFIC STATE RIGHTS

In California, you have the right to receive, once every twelve months,
information about third parties with whom we may have shared information about
you for our marketing purposes during the previous calendar year along with a
description of the categories of personal data shared.

Nevada consumers may submit a do-not-sell request of their personal information.
Articulate does not sell the personal data of our customers so no-opt out is
required. If you have questions, please email us by referring to the 'Contact
Us' section and note in the subject line "Nevada Privacy Request."


CONTACT US

If you have any questions or complaints about our use of your personal data as
related to our Services, please email us at privacy@articulate.com. For
questions or concerns about Rise services, please email us at privacy@rise.com.

Alternatively, you may write to us at the following address. Please be advised
you may receive a delayed response.

Articulate Global, LLC
c/o Compliance Department
244 5th Avenue, Suite 2960
New York, NY 10001
800-861-4880

If you're located in the European Economic Area, United Kingdom or Switzerland,
you can also contact your local data protection supervisory authority to lodge a
complaint. Contact information can be found in the EU-U.S. and Swiss-U.S. Data
Privacy Framework Notice section above.

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