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EINIGE FUNKTIONEN DIESER WEBSITE ERFORDERN IHRE ZUSTIMMUNG, DAMIT COOKIES
RICHTIG FUNKTIONIEREN.


ICH STIMME COOKIES ZU ICH WILL MEHR INFORMATIONEN
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PRIVACY NOTICE

Skillsoft Corporation and its subsidiaries (“Skillsoft”) take the privacy of
personal data seriously. This Privacy Notice (“Policy”) explains how we collect,
use, and disclose data, and your choices and rights with respect to your data.
The Policy applies to data we collect about you in the course of our business,
including through our various websites that link to this Policy and our platform
(collectively, the “Services”). This policy centers around 7 pillars of data
privacy – click on any of them to learn more.




PRIVACY MATTERS. THIS NOTICE CENTERS AROUND 7 PILLARS OF DATA PRIVACY. CLICK ON
ANY OF THEM TO LEARN MORE.

TransparencyPurpose SpecificationData MinimizationAccuracySecurityIndividual
rightsAccountability


1. TRANSPARENCY

We are committed to providing you with information about what data is being
collected about you, how it will be used, and to whom we disclose it.

A. THE DATA WE COLLECT

Personal data, or personal information, means any information about an
individual from which that person can be identified, either directly or
indirectly. The data we collect about you depends on the Services you use, how
you use them, and the information you provide to us. We collect data (1) when
you or your employer provide it directly to us, (2) automatically through
technology when you use the Services, and (3) from other sources.

 1. DATA YOU OR YOUR EMPLOYER PROVIDE DIRECTLY TO US
    
    You or your employer may provide data to us when you use the Services, such
    as when you register for an account, participate in one of our programs, or
    communicate with us. This data may include:
    
    * Identity Data includes first name, last name, username or similar
      identifier, title, and your employer.
    * Contact Data includes business address, corporate or personal email
      address and telephone numbers.
    * Marketing and Profile Data includes your interests and preferences in
      receiving marketing from us and select third parties, your communication
      preferences and survey responses.
    * Customer Service and Inquiry Data, such as information you provide us when
      you contact customer support or ask us a question about our Services.
    * User-Generated Content, such as information you provide to our instructors
      and coaches in connection with your participation in our business
      Services.

 2. DATA COLLECTED AUTOMATICALLY WHEN YOU USE THE SERVICES
    
    When you use our Services, we may automatically collect certain data using a
    variety of tools, including server logs, cookies, and other technologies.
    This data may include:
    
    * Device and Network Data includes internet protocol (IP) address, browser
      type and version, time zone setting and location, browser plug-in types
      and versions, operating system and platform and other technology on the
      devices you use to access this website.
    * Usage Data includes information about how you use the Services, such as
      which Services you use, content accessed within the Services, date and
      time of use, amount of time spent on the Services, navigation within the
      Services, and entering and exiting URLs.

 3. DATA FROM OTHER SOURCES
    
    We may also collect data about you from other sources, such as information
    you post publicly on social media platforms.
    
    De-Identified Data. We may also aggregate or de-identify personal data such
    that it does not directly or indirectly reveal your identity (“De-Identified
    Data”). For example, we may aggregate information about use of our websites
    to calculate the percentage of users accessing specific website features. We
    may use and disclose such De-Identified Data for any purposes. However, if
    we combine or connect De-Identified Data with your personal data so that it
    can directly or indirectly identify you, we treat the combined data in
    accordance with this Privacy Notice.
    
    We do not collect any Special Categories of Personal Data about you – also
    considered sensitive data. Special Categories of Personal Data include, but
    are not limited to, details about your race or ethnicity, religious or
    philosophical beliefs, sexual orientation, or political opinions. Nor do we
    collect any information about criminal convictions and offences.

B. WHAT WE DO WITH YOUR DATA

How we use your data depends on your relationship with us and the Services that
you use:

 1. DATA COLLECTED FROM LEARNERS UNDER AN ENTERPRISE (EMPLOYER) ACCOUNT
    
    We process data collected from individuals in their capacity as learners
    associated with enterprise accounts in accordance with the relevant
    customer’s instructions and in fulfillment of the contractual relationship
    with such customer. This data may include the learner’s identity data,
    contact data, device and network data, and usage data. Consistent with our
    contractual commitments, we use this data to provide the Services to
    learners, support, and troubleshooting, to analyze and improve the Services,
    to secure our Services, and for legal and compliance purposes, or as
    otherwise requested by the customer.

 2. DATA COLLECTED FROM LEARNERS WITH A DIRECT RELATIONSHIP WITH SKILLSOFT
    
    We process data collected from individuals in their capacity as learners who
    have a direct relationship with us pursuant to our contractual relationship.
    This data may include the learner’s identity data, contact data, device and
    network data, usage data, and customer service and inquiry data. We may use
    this data to provide the Services, support and troubleshoot the Services, to
    analyze and improve the Services, to market our other Services to you, to
    communicate with you about the Services (such as updates or notices about
    changes to our terms or policies), to secure the Services, and for legal and
    compliance purposes, or for other purposes for which we seek your consent.

 3. DATA COLLECTED FROM WEBSITE VISITORS AND OTHERS
    
    We process data collected from individuals outside of their capacity as
    learners (such as visitors to our website) for a variety of purposes. This
    data may include any of the data listed in Section 1.A above. We may use
    this data to provide the Services, support and troubleshoot the Services, to
    analyze and improve the Services, to provide you with information about our
    other Services, to communicate with you about the Services (such as updates
    or notices about changes to our terms or policies), to market and advertise
    our Services, to personalize the Services, to secure the Services, and for
    legal and compliance purposes, or for other purposes for which we seek your
    consent.

C. DISCLOSURE OF YOUR DATA

We disclose your data in the following ways:

 * Within the Skillsoft family of companies: We disclose your data within the
   Skillsoft family of companies under common ownership and/or control to
   provide and enhance the Services and to operate our business.
 * With your employer. If you are a learner using a Skillsoft Business Services
   account provided by your employer, information about your activity on
   Skillsoft is accessible to, and may be disclosed to, your employer. Please
   note that this does not apply to information we collect from individuals who
   have established an independent relationship with us.
 * With our service providers. Skillsoft may share your personal data with
   vendors and other partners that provide services on our behalf. We require
   all service providers to respect the security of your personal data and to
   treat it in accordance with the law. We do not allow our third-party service
   providers to use your personal data for their own purposes and only permit
   them to process your personal data for specified purposes and in accordance
   with our instructions.
 * Online advertising partners. We work with third-party online advertising
   partners that, where permitted by law and consistent with any consent or opt
   out elections you have made, collect information both on our Services and on
   third-party platforms to help tailor and serve you advertisements online.
   These partners may use cookies, pixel tags and similar technologies on many
   online services, including ours, to collect information to serve you more
   relevant ads. You can learn more about how we and our partners use cookies
   and similar technologies, and about your rights and choices with respect to
   cookies, by reviewing our [Cookie Policy] and following the instructions in
   the "Individual Rights and Choices" section below.
 * Business transfers. We may also share your data with third parties to whom we
   may choose to sell, transfer, or merge all or parts of our business or our
   assets. Alternatively, we may seek to acquire other businesses or merge with
   them. If a change happens to our business, then the new owners may use your
   personal data in the same way as set out in this Privacy Notice.
 * Legal, compliance, security, and safety. We may also disclose your personal
   data as required by law, such as to comply with a subpoena or other legal
   process, when we believe in good faith that disclosure is necessary to
   protect our rights, protect your safety or the safety of others, investigate
   fraud, or respond to a government request.

Please note that Skillsoft is a global company and serves customers and
individuals around the world. As such, when we disclose data as described above,
we may transfer data to other jurisdictions that may have data protection laws
that differ from those in your home country. When we transfer, store, or process
your data, we take reasonable steps to protect your personal data in accordance
with this Privacy Notice and applicable laws. For instance, we may implement
Standard Contractual Clauses to govern the transfer of your data, or other means
recognized by applicable laws.

D. USING ARTIFICIAL INTELLIGENCE (AI)

Skillsoft leverages AI technologies to improve our products and services,
providing a better experience for our learners. The use of AI, and similar
emerging technologies must be done in accordance with our code of conduct and
AI-related policies and procedures – in compliance with applicable law and
regulations. Our policies and procedures ensure that any use of AI is done in an
ethical and responsible manner. Generally, and with the exception of a very
limited set of circumstances, personal data is not used or processed using AI.


2. PURPOSE SPECIFICATION

Skillsoft collects and uses personal data for specific purposes and does not use
the data in ways that are incompatible with those purposes.

We will only use your personal data for the purposes stated in this Privacy
Notice, for other purposes we have specifically disclosed to you, or for which
we seek your consent.

Our Services are not intended for children, and we do not knowingly collect data
relating to children. If you become aware that a child has provide us with
information, please contact us immediately at privacy@skillsoft.com so we can
delete such information from our system.

The laws in some jurisdictions require us to tell you about the legal bases we
rely on to use or disclose your “personal data” as such term is defined under
applicable law. To the extent that those laws apply, our legal grounds are as
follows:

 * To honor our contractual commitments: Much of our processing of personal data
   is to meet our contractual obligations to our customers, or to take steps at
   customers’ requests in anticipation of entering a contract with them. For
   example, we handle personal data on this basis to provide learners with the
   Services.
 * Legitimate interests: In many cases, we handle personal data on the ground
   that it furthers our legitimate interests in ways that are not overridden by
   the interests or fundamental rights and freedoms of the affected individuals,
   such as to provide customer support and troubleshooting and to protect and
   secure our Services.
 * Consent: Where required by law, and in some other cases, we handle personal
   data on the basis of your implied or express consent, such as when we seek
   your consent to engage in direct marketing where legally required.
 * Legal compliance: We need to use and disclose personal data in certain ways
   to comply with our legal obligations.
 * Vital interest: To protect the vital interests of the individual or others.


3. DATA MINIMIZATION

We collect and retain the personal data we deem necessary for the purposes for
which it was collected and for the length of time required for our legitimate
business and legal purposes.

We will only retain your personal data for as long as necessary to fulfill the
purposes we collected it for, including for the purposes of satisfying any
legal, accounting, or reporting requirements. To determine the appropriate
retention period for personal data, we consider the amount, nature, and
sensitivity of the personal data, the potential risk of harm from unauthorized
use or disclosure of your personal data, the purposes for which we process your
personal data and whether we can achieve those purposes through other means, and
the applicable legal requirements.

In some circumstances you can ask us to delete your data – see, “Individual
rights” (below) for further information.


4. ACCURACY

We take reasonable steps to ensure that personal data is accurate and up to
date.

Where Skillsoft acts as a controller of data, Skillsoft takes reasonable steps
to ensure that personal data is accurate and up to date. We have implemented
technical and organizational measures to ensure the information we collect
remains accurate

Users have the right to update or correct their personal data, and Skillsoft
provides mechanisms to enable users to do so – see, “Individual rights” (below)
for further information. It is important that the personal data we hold about
you is accurate and current. Please keep us informed if your personal data
changes during your relationship with us.


5. SECURITY

Skillsoft takes appropriate measures to protect personal data from unauthorized
access, use, disclosure, alteration, and destruction.

Skillsoft takes a variety of measures to protect personal data from unauthorized
access, use, disclosure, alteration, and destruction, including encryption,
access controls, and monitoring. Skillsoft conducts regular security assessments
and maintains an incident response and notification plan in the event of a data
breach. However, please note that no transmission of data across the internet
can be guaranteed to be secure.

In addition, we limit access to your personal data to those employees, agents,
contractors and other third parties who have a business need to know. They will
only process your personal data on our instructions, and they are subject to a
duty of confidentiality.

Our website, products, and services may include links to third-party websites,
plug-ins, and applications. Clicking on those links or enabling those
connections may allow third parties to collect or share data about you. We do
not control these third-party websites and are not responsible for their privacy
and security practices or statements. When you leave our environment, we
encourage you to read the privacy policy of every website you visit.


6. INDIVIDUAL RIGHTS AND CHOICES

This section explains your rights and choices with respect to your data where
Skillsoft acts as a data controller; e.g., for learners with whom we have a
direct relationship and website visitors. If you are a learner using a Skillsoft
Business Services account, please contact your employer to exercise your rights
under applicable law. We cooperate with our enterprise account customers to
respond to individual requests in accordance with our contractual obligations.

A. EXERCISING YOUR RIGHTS AND CHOICES

Skillsoft provides mechanisms to enable users to exercise their rights under
applicable law with respect to their data and to make requests concerning their
personal data. If you wish to make any of the requests set out below, please
fill-out our form [hyperlink] and select the type of request you are making.

 * Access: Request access to your personal data (commonly known as a “data
   subject access request”). This enables you to receive a copy of the personal
   data we hold about you.
 * Correction: Request correction of the personal data that we hold about you.
   This enables you to request correction of any incomplete or inaccurate data,
   though we may need to verify the accuracy of the new data you provide to us.
 * Deletion: Request erasure of your personal data. This enables you to ask us
   to delete or remove personal data. You also have the right to ask us to
   delete or remove your personal data where you have successfully exercised
   your right to object to processing (see below), where we may have processed
   your information unlawfully or where we are required to erase your personal
   data to comply with local law. Note, however, that we may not always be able
   to comply with your request of erasure for specific legal reasons which will
   be notified to you, if applicable, at the time of your request.
 * Objection: Object to processing of your personal data where we are relying on
   a legitimate interest (or those of a third party) and there is something
   about your particular situation which makes you want to object to processing
   on this ground as you feel it impacts on your fundamental rights and
   freedoms. You may also object where we are processing your personal data for
   direct marketing purposes. In some cases, we may demonstrate that we have
   compelling legitimate grounds to process your information which override your
   rights and freedoms.
 * Restriction: Request restriction of processing of your personal data. This
   enables you to ask us to suspend the processing of your personal data in the
   following scenarios: (a) if you want us to establish the data’s accuracy; (b)
   where our use of the data is unlawful but you do not want us to erase it; (c)
   where you need us to hold the data even if we no longer require it as you
   need it to establish, exercise or defend legal claims; or (d) you have
   objected to our use of your data but we need to verify whether we have
   overriding legitimate grounds to use it.
 * Transfer: Request transfer of your personal data to you or to a third party.
   To the extent required by law, we will provide to you, or a third party you
   have chosen, your personal data in a structured, commonly used,
   machine-readable format. Note that this right only applies to automated
   information which you initially provided consent for us to use or where we
   used the information to perform a contract with you.

Please note that these rights are not absolute and are subject to certain
exceptions. If we cannot act on your request, we will explain the reason(s) why.
For example, a request might impact the rights of another person or another
company. Depending on applicable law, you may have the right to appeal our
decision to deny your request; if you would like to exercise this right, please
email us at privacy@skillsoft.com.

B. NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any
of the other rights). However, we may charge a reasonable fee if your request is
clearly unfounded, repetitive or excessive. Alternatively, we may refuse to
comply with your request in these circumstances.

C. WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your
identity and ensure your right to access your personal data (or to exercise any
of your other rights), which may include verification of your contact
information and about the Services you use. This is a security measure to ensure
that personal data is not disclosed to any person who has no right to receive
it. We may also contact you to ask you for further information in relation to
your request to speed up our response.

D. TIME LIMIT TO RESPOND

We try to respond to all verified requests within one month of our receiving
them. Occasionally it may take us longer than a month if your request is
particularly complex or you have made a number of requests.

E. DATA PROTECTION OFFICER

We have appointed a data protection officer (“DPO”) who is responsible for
overseeing questions in relation to this privacy notice. If you have any
questions about this privacy notice, contact our DPO at dpo@skillsoft.com. You
may also contact us by telephone at (866) 754-5435, or by mail to Skillsoft
Corporation, Attn: DPO, 300 Innovative Way, Suite 201, Nashua, New Hampshire
03062, U.S.A. with any general questions about our websites.

F. COMPLAINTS

If you have any concerns or complaints about our data processing activities, we
urge you to first try to resolve your issue directly with us by contacting our
Data Protection Officer via dpo@skillsoft.com or the contact information
provided above. However, you also may have the right to make a complaint to the
data protection supervisory authority in the country where you are based.

G. MARKETING OPT OUT

You can ask us or third parties to stop sending you marketing messages at any
time by checking or unchecking relevant boxes to adjust your marketing
preferences or by following the “Unsubscribe” links on any marketing message
sent to you.

Where you opt-out of receiving these marketing messages, this will not apply to
personal data provided to us because of a product/service purchase, warranty
registration, product/service experience or other transactions.

H. SALE/TARGETED ADVERTISING OPT OUT RIGHTS

Under the laws in certain US states, you also have the right to opt out of our
processing or disclosure of your information for online targeted advertising
purposes. Note that certain US states also allow you to opt out of the "sale" of
your information to third parties in exchange for valuable consideration
(monetary or otherwise). While we do not sell your personal data in exchange for
money, we may use online advertising and related analytics tools that result in
the disclosure of your information to our third-party partners and that are
subject to this opt out right. You can opt out of these activities by clicking
"Your Privacy Choices."


7. ACCOUNTABILITY

Skillsoft is responsible for implementing processes to comply with the data
privacy principles discussed in this Privacy Notice.

A. SKILLSOFT’S ROLE AND RESPONSIBILITIES

Skillsoft is responsible for complying with data protection laws and regulations
and has designated a DPO to oversee compliance. Skillsoft has implemented
policies and procedures to ensure compliance with data protection laws and
regulations, including regular audits and employee training. Skillsoft also
conducts due diligence on its vendors and partners to ensure that they comply
with applicable data protection laws and regulations.

Your use of Skillsoft Business Services is administered by your employer
pursuant to a business-to-business (“B2B”) contract between Skillsoft and your
employer. Skillsoft is the processor of, and responsible for, processing
personal data in connection with the performance of its contractual duties and
the provisions of the Skillsoft Business Services to its corporate clients
(“B2B” relationship). The agreement between Skillsoft and its business customer,
your employer, takes precedence when in conflict with this Privacy Notice. It
follows that your employer may have access to your personal data processed by a
Skillsoft Business Service and that your employer may have its own privacy
policy applicable to your use of one or more Skillsoft Business Services. Your
employer – as the controller of your personal data – administers your use of the
applicable Skillsoft Business Services. Accordingly, please contact your
employer with any privacy questions related to your use of Skillsoft Business
Services or about your employer’s privacy policy governing the same.

Skillsoft is the controller of, and responsible for, the contact information we
collect in connection with the provisions of direct-to-consumer services
(“B2C”), and also our marketing initiatives and employment opportunities that
often originate with our website located at Skillsoft.com.

The table below summarizes Skillsoft’s role according to the relationships it
has with the data subject.

Data Subject(s)

Controller

Processor

What governs the handling and use of the Personal Data of the Data Subject(s) as
between
Controller and Processor?

Licensed end-user

Corporate (B2B) Customer

Skillsoft Corporation

Master Services/License Agreement together with a Data Protection Addendum, as
applicable.

Marketing contacts (e.g., whitepaper registrants, webinar attendees) and job
applicants

Skillsoft Corporation

Our various service providers (e.g., Marketo)

Skillsoft’s Privacy Notice.

Individual learner customer employee

Employers under B2B contract

Skillsoft Corporation

Skillsoft’s Privacy Notice and Employer’s privacy notice or analogous document
disclosing for what purpose (e.g., corporate training) and by whom (e.g.,
Skillsoft) the personal data of an employee may be processed.

Individual leaners and direct consumer

Skillsoft Corporation

Our various service providers (e.g., Pendo.io)

Skillsoft’s Privacy.

B. CONTACT US

If you have any questions about this Privacy Notice or would like to otherwise
contact us about our privacy practices, please email us at dpo@skillsoft.com.

C. CHANGES TO THIS PRIVACY NOTICE

We may update this privacy notice to reflect changes to our data governance
practices. If we propose to make any material changes, we will notify you as
required by applicable law prior to the change becoming effective. We encourage
you to periodically review this page for the latest information on our privacy
practices.

This version was last updated on June 30, 2023.


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