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EINIGE FUNKTIONEN DIESER WEBSITE ERFORDERN IHRE ZUSTIMMUNG, DAMIT COOKIES
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ICH STIMME COOKIES ZU ICH WILL MEHR INFORMATIONEN
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PRIVACY NOTICE

Last Updated: August 18, 2021

 1.  Important Information & Who We Are
 2.  Our Products & Services
 3.  The Data We Collect About You
 4.  How Is Your Personal Data Collected?
 5.  How We Use Your Personal Data
 6.  Disclosures of Your Personal Data
 7.  International Transfers
 8.  Data Security
 9.  Data Retention
 10. Your Rights in Your Personal Data
 11. Glossary

Introduction
Skillsoft Corporation is a wholly-owned subsidiary of Skillsoft Limited and is
the entity that primarily controls the website you are visiting. Skillsoft
Limited and its subsidiaries and affiliates (“Skillsoft”) respect your privacy
and are committed to protecting your personal data.

This privacy notice will inform you about how we look after your personal data
when you visit our website (regardless of where you visit it from), handle your
personal data in connection with this website, and tell you about your privacy
rights and how the law protects you.

It also describes your choices regarding use, access and correction of your
personal data. This privacy notice is provided in a layered format so you can
click the numbered links (above) to the specific areas of interest (below).
Please also use our Glossary at Section 11 for definitions of some of the terms
used in this privacy notice.

1. Important Information & Who We Are

This privacy notice aims to give you information on how Skillsoft collects and
processes your personal data through your use of this website, including any
data you may provide through this website when you sign-up to our newsletter,
sign-up for a trial of our products or services, participate in a webinar, or
download a whitepaper.

This website is not intended for children and we do not knowingly collect data
relating to children.

It is important that you read this privacy notice together with any other
privacy notice we may provide on specific occasions when we are collecting or
processing personal data about you so that you are fully aware of how and why we
are using your data. This privacy notice supplements the other notices and is
not intended to override them.


Skillsoft is the entity that is the controller of, and responsible for, the
contact information we collect in connection with our marketing initiatives and
employment opportunities that often originate with our websites located at
Skillsoft.com and SumTotalSystems.com.

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 or would like to exercise your rights in
your personal data, please fill-out our form or contact our DPO using the
details set out below.


2. Our Products & Services

Your use of the products and services of Skillsoft and SumTotal (“Skillsoft
Business Services”) is administered by your employer pursuant to a
business-to-business (“B2B”) contract between Skillsoft and your employer.

It follows that your employer may have access to your personal information
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.

In the context of these Skillsoft Business Services, Skillsoft – as a
‘processor’ of your personal data – is neither responsible for our B2B
customers’ policies and practices related to data privacy and security, nor in a
position to respond to requests concerning personal data processed by Skillsoft
Business Services.

Instead, your employer – as the ‘controller’ of your personal data – administers
your use of each Skillsoft Business Service. Accordingly, please contact your
employer with any privacy questions related to your use of that Skillsoft
Business Service or your employer’s privacy policy governing the same.

Skillsoft Business ServicesSkillsoftSumTotalAcademy (Compliance)Core HR
(HRMS)BooksCore PlatformCompliance QuestionnairesExpenseE-DeliveryGrowth Edition
(Maestro)MentoringLearn
(ELMS)PercipioPathlorePublisherPayrollSkillport/OLSATalentVodeclicTalent
AcquisitionWorkforce Management

Rest assured that there is an agreement between Skillsoft and its business
customer, here, your employer. That agreement will, in every event, take
precedence over conflicting terms in this privacy notice.

In an effort to further clarify the different roles with respect to you and your
personal information as between, for example, you (i.e., a licensed end-user),
your employer (i.e., a Corporate B2B Customer of Skillsoft) and Skillsoft, the
following grid categorizes each entity or person according to its, his, or her
role as articulated by the General Data Protection Regulation 2016/679 (“GDPR”)
of the European Union (“EU”):

Data Subject(s)ControllerProcessorWhat governs the handling and use of the
Personal Data of the Data Subject(s) as between
Controller and Processor?Licensed end-userCorporate (B2B)
CustomerSkillsoftMaster Services/License Agreement together with a Data
Protection Addendum, if one exists.Marketing contacts (e.g., whitepaper
registrants, webinar attendees) and job applicantsSkillsoftSoftware vendors
(e.g., Marketo)Skillsoft’s Privacy NoticeEmployeesEmployersSoftware vendors
(e.g., Skillsoft, SumTotal, and Vodeclic)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.Definitions
under the GDPR‘data subject’ means an identified or identifiable natural
person‘controller’ means the natural or legal person (i.e., corporation)… which,
alone or jointly with others, determines the purposes and means of the
processing of personal data‘processor’ means a natural or legal person, public
authority, agency or other body which processes personal data on behalf of the
controller‘personal data’ means any information relating to a data subject who
can be identified, directly or indirectly, in particular by reference to an
identifier such as a name, an identification number, location data, an online
identifier or to one or more factors specific to the physical, physiological,
genetic, mental, economic, cultural or social identity of that data subject


Contact Details


Please contact us: via e-mail at support@skillsoft.com, by telephone at (866)
754-5435, or by mail to: Skillsoft Corporation, Attn: Legal Department, 300
Innovative Way, Suite 201, Nashua, New Hampshire 03062, U.S.A. with any general
questions about our websites.

The full contact details of our Data Protection Officer are:

Full name of legal entity: Skillsoft Corporation
Title of DPO: Data Protection Officer
Email address: contactdpo@skillsoft.com

Postal address:
300 Innovative Way, Suite 201,
Nashua, New Hampshire 03062, U.S.A.

Telephone number: 866-754-5435

If you have an unresolved privacy or data use 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.

Changes to this Privacy Notice and Your Duty to Inform Us of Changes


This version was last updated on August 18, 2021. As you may already be aware,
significant changes to the data protection laws in the EU, as well as the UK,
went into effect on May 25, 2018, with similar changes having gone into effect
for Californians on January 1, 2020. This privacy notice outlines, or provides
mechanisms for exercising, most of your rights under these legal frameworks
including timelines for when you should expect to hear back from us.

We may update this privacy notice and its last updated date to reflect changes
to our data governance practices. If we propose to make any material changes, we
will notify you by means of a notice on this page prior to the change becoming
effective. We encourage you to periodically review this page for the latest
information on our privacy practices.

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.

Third-party Links
This website 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 statements. When
you leave our website, we encourage you to read the privacy notice of every
website you visit.

3. The Data We Collect About You

Personal data, or personal information, means any information about an
individual from which that person can be identified. We may collect, use, store
and transfer different kinds of personal data about you which we have grouped
together as follows:

Identity Data includes first name, last name, username or similar identifier,
title, your employer.

Contact Data includes business address, corporate or personal email address and
telephone numbers.

Technical 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 our website, products and
services.

Marketing and Profile Data includes your interests and preferences in receiving
marketing from us and select third parties, your communication preferences and
survey responses.

As noted in Section 2 (above), in the likely event your employer is
administering your use of a Skillsoft Business Service, please contact your
employer with any privacy questions related to the personal information
processed in connection with your company’s license of that Skillsoft Business
Service.

We also collect, use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data may be derived from your
personal data but is not considered personal data in law as this data does not
directly or indirectly reveal your identity. For example, we may aggregate your
Usage Data to calculate the percentage of users accessing a specific website
feature. However, if we combine or connect Aggregated Data with your personal
data so that it can directly or indirectly identify you, we treat the combined
data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you. Special
Categories of Personal Data include details about your race or ethnicity,
religious or philosophical beliefs, sex life, sexual orientation, political
opinions, trade union membership, information about your health and genetic and
biometric data. Nor do we collect any information about criminal convictions and
offences.

4. How Is Your Personal Data Collected?

We use different methods to collect personal data from and about you including
through:

Direct interactions. You may share with us some of your Identity and Contact
information by filling in forms or by corresponding with us by post, phone,
email or otherwise. This includes personal data you provide when you: inquire
about our products or services; apply for a job opening; request marketing to be
sent to you; enter a competition, promotion or survey; or give us some feedback.

Automated technologies or interactions. As you interact with our website, we may
automatically collect Technical information about your equipment, browsing
actions and patterns. We collect this personal data by using cookies, server
logs and other similar technologies. Please learn more about the cookies we use
and about setting your preferences at the Cookie Preferences at the bottom of
this page.

Third parties or publicly available sources. We may receive analytics and
advertising data about you from the sources listed below, as well as, other
vendors and public sources. Please use the following links for more information
about how these third parties collect and use personal data: Google – LinkedIn –
Marketo – Pendo – Salesforce.com




5. How We Use Your Personal Data


We will only use your personal data when the law allows us to. Most commonly, we
will use your personal data in the following circumstances:

 * Where we need to perform the contract we are about to enter into or have
   entered into with you.
   
 * Where it is necessary for our legitimate interests (or those of a third
   party) and your interests and fundamental rights do not override those
   interests.
   
 * Where we need to comply with a legal or regulatory obligation.

Click to find out more about the lawful basis that we may rely on to process
your personal data.

Generally we do not rely on consent as a legal basis for processing your
personal data other than in relation to sending our own or third party direct
marketing communications to you via email or text message. You have the right to
withdraw consent to marketing at any time by checking or unchecking relevant
boxes to adjust your marketing preferences or by following the “Unsubscribe”
link in any marketing message sent to you.


Purposes For Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we may
use your personal data, and which of the legal bases we rely on to do so. We
have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground
depending on the specific purpose for which we are using your data.


Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer or contact

(a) Identity(b) Contact

Performance of a contract with you

To manage our relationship with you which will include:(a) Notifying you about
changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity(b) Contact

(c) Marketing and Profile

(a) Performance of a contract with you(b) Necessary to comply with a legal
obligation

(c) Necessary for our legitimate interests (to keep our records updated and to
study how customers use our products/services)

To administer and protect our business and this website (including
troubleshooting, data analysis, testing, system maintenance, support, reporting
and hosting of data)

(a) Identity(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision
of administration and IT services, network security, to prevent fraud and in the
context of a business reorganisation or group restructuring exercise)(b)
Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or
understand the effectiveness of the advertising we serve to you

(a) Identity(b) Contact

(c) Usage

(d) Marketing and Profile

(e) Technical

Necessary for our legitimate interests (to study how customers use our
products/services, to develop them, to grow our business and to inform our
marketing strategy)

To use data analytics to improve our website, products/services, marketing,
customer relationships and experiences

(a) Technical(b) Usage

Necessary for our legitimate interests (to define types of customers for our
products and services, to keep our website updated and relevant, to develop our
business and to inform our marketing strategy)

To improve your experience in furtherance of our legitimate interests (or where
needed, with consent), including through the use of automated systems that
analyze data using machine learning and other analytic techniques

To make suggestions and recommendations to you about goods or services that may
be of interest to you

(a) Identity(b) Contact

(c) Technical

(d) Usage

(e) Marketing and Profile

Necessary for our legitimate interests (to develop our products/services and
grow our business)


Marketing
We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising. We have established an Email
Preference Center where you can view and make certain decisions about your
personal data. If you have any other questions about this privacy notice or
would like to exercise your rights in your personal data, please fill-out our
form or contact our DPO using the details set out above.

Promotional Offers Us


We may use your Identity, Contact, Technical, Usage and Profile Data to form a
view on what we think you may want or need, or what may be of interest to you.
This is how we decide which products, services and offers may be relevant for
you (we call this marketing).

You will receive marketing communications from us if you have requested
information from us or purchased products or services from us or if you provided
us with your details when you entered a competition or registered for a
promotion and, in each case, you have not opted-out of receiving that marketing.

Third-Party Marketing


We will get your express opt-in consent before we share your personal data with
any company outside the Skillsoft family of companies for marketing purposes.

Opting 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 as a result of a product/service purchase, warranty
registration, product/service experience or other transactions.

Cookies


You can set your browser to refuse all or some browser cookies, or to alert you
when websites set or access cookies. If you disable or refuse cookies, please
note that some parts of this website may become inaccessible or not function
properly. To learn more about the cookies we use, please click the Cookie
Preferences link at the bottom of this page.

Change of Purpose


We will only use your personal data for the purposes for which we collected it,
unless we reasonably consider that we need to use it for another reason and that
reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify
you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or
consent, in compliance with the above rules, where this is required or permitted
by law.

6. Disclosures of Your Personal Data

We may have to share your personal data with the parties set out below for the
purposes set out in the table in paragraph 4 above.

 * Internal Third Parties as set out in the Glossary.
   
 * External Third Parties as set out in the Glossary.
   
 * Third parties to whom we may choose to sell, transfer, or merge 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.
   
 * 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.

We require all third parties 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.

7. International Transfers

We share your personal data within the Skillsoft family of companies. This will
involve transferring your data outside the European Union, the United Kingdom,
and Switzerland.

We ensure your personal data is protected by requiring all our group companies
to follow the same rules when processing your personal data. These rules are
binding company policies. Many of our external third parties are based outside
the European Union, the United Kingdom, and Switzerland, so their processing of
your personal data will necessarily involve a transfer of data outside the
European Union, the United Kingdom, and Switzerland. Whenever we transfer your
personal data out of the European Union, the United Kingdom, and Switzerland, we
ensure a similar degree of protection is afforded to it by using specific
contracts approved by the European Commission which give personal data the same
protection it has in the European Union.

Skillsoft is responsible for the processing of personal data it receives and
subsequently transfers to a third party acting as an agent on its behalf.
Skillsoft complies applicable data protection laws for all onward transfers of
personal data from the EU and the United Kingdom and Switzerland, including the
onward transfer liability provisions of applicable data protection laws.

With respect to personal data received or transferred pursuant to, among other
data protection law, the GDPR. In certain situations, we may be required to
disclose personal data in response to lawful requests by public authorities,
including to meet national security or law enforcement requirements.

8. Data Security

We have put in place appropriate security measures to prevent your personal data
from being accidentally lost, used or accessed in an unauthorized way, altered
or disclosed. 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.

We have put in place procedures to deal with any suspected personal data breach
and will notify you and any applicable regulator of a breach where we are
legally required to do so.

9. Data Retention


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, “Request erasure”
(below) for further information.

In some circumstances we may aggregate your personal data (so that it can no
longer be associated with you) for research or statistical purposes in which
case we may use this information indefinitely without further notice to you.

10. Your Rights in Your Personal Data

Under certain circumstances, you have rights under data protection laws in
relation to your personal data. If you wish to exercise any of these rights set
out below, please fill-out our form and help us help you by specifying which
right(s) outlined below you are asserting.

 * 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 and to check that we are lawfully processing it.
   
 * Request correction of the personal data that we hold about you. This enables
   you to have any incomplete or inaccurate data we hold about you corrected,
   though we may need to verify the accuracy of the new data you provide to us.
   
 * Request erasure of your personal data. This enables you to ask us to delete
   or remove personal data where there is no good reason for us continuing to
   process it. 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.
   
 * 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 also have the right to 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.
   
 * 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.
   
 * Requesttransfer of your personal data to you or to a third party. 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.

As noted elsewhere in this privacy notice, if you are using any Skillsoft
Business Services, please contact your employer with any questions or requests
related to your personal information.

It follows that we are only able to act on requests related to the personal
information that we have collected through our website(s). 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.

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 for these or other legitimate reasons.

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). 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.

Time Limit To Respond


We try to respond to all legitimate 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.

Rights for California Residents


Certain rights outlined above may be available to you if you reside in
California. Please review our California Privacy Notice to learn more about your
rights and how to exercise them.

11. GLOSSARY

Lawful Basis means the interest of our organization in conducting and managing
our business to enable us to give you the best service/product and the best and
most secure experience. We make sure we consider and balance any potential
impact on you (both positive and negative) and your rights before we process
your personal data for our legitimate interests. We do not use your personal
data for activities where our interests are overridden by the impact on you
(unless we have your consent or are otherwise required or permitted by law).

Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your
request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data
where it is necessary for compliance with a legal or regulatory obligation that
we are subject to.

Internal Third Parties means other companies in the Skillsoft family including
the following entities that provide the following services:

Entity

Location

Services Provided

Skillsoft Corporation

300 Innovative Way, Suite 201
Nashua, NH 03062 USA

Skillsoft SaaS; Sales & Marketing

Skillsoft UK Limited

Compass House, 2nd Floor
207-215 London Road
Camberley
GU15 3EY
United Kingdom

Sales & Marketing

Skillsoft Digital (France) SAS (f/k/a Vodeclic SAS)

102-116, rue Victor Hugo
92300 Levallois-Perret
France

Sales & Marketing

Skillsoft Canada, Ltd.

20 Knowledge Park Drive
Fredericton, NB E3C 2P5
Canada

Support for Skillsoft SaaS

SumTotal Systems, LLC

300 Innovative Way, Suite 201
Nashua, NH 03062 USA

SumTotal SaaS

SumTotal Systems India LLC

7th Floor, Maximus Towers
Building 2B, Mindspace
Raheja IT Park
Cyberabad, Hyderabad
Telangana – 500081 India

Support for SumTotal SaaS




External Third Parties include, but are not limited to, Google, LinkedIn,
Marketo, Pendo, and Salesforce.com as further described in Section 4 (above).

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