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Privacy Notice

Learning Technologies Group Plc. its subsidiaries, and its associated businesses
(“LTG”, “we” or “us”) are committed to protecting and respecting your privacy.
The Learning Technology Group companies includes the following entities:
Preloaded, Affirmity, Gomo Learning, Rustici Software [including SCORM Cloud,
and Rustici Managed Hosted products (Rustici Engine, Content Controller)],
PeopleFluent, Watershed, VectorVMS, Breezy, Instilled, Open LMS, and GetBridge.
We provide this privacy notice (“Privacy Notice”) to explain how we collect, use
and disclose certain personal information online via our group websites, and our
SaaS or Subscription Services (as listed below, collectively referred to as
“Sites”).

This policy sets out the basis on which personal data is collected from you
either through our Sites or our Subscription Services (collectively “our
Sites”). Please read the policy carefully to understand our practices regarding
our collection and use of your personal information and how it will be treated.

If you have any questions regarding our privacy practices or this Privacy
Notice, please contact us using the contact details given below. 

Table of contents:

 * Who are “You”?
 * Your Information
   * Customer Information
   * End-user information
 * Visitor Information
 * Cookies and Other Tracking Technologies
   * Types of Cookies
   * Purposes of Cookie use
 * Your Rights
   * GDPR
   * CCPA
   * COPPA
 * Third Party Websites
 * Corporate and Contact Details
 * Changes to this Privacy Notice


WHO ARE “YOU”?

This Privacy Notice describes how we use “your” information. To understand which
of our uses of information are actually applicable to you and your information
see the following useful definitions.

You may be a(n): 

Customer – an entity, or person representing an entity that has an agreement in
place with LTG or one of its subsidiaries under which we provide you with SaaS
or Subscription Services, or is visiting our Site to purchase SaaS or
Subscription Services via an online payment system.

End-User – a person with a user account to one of our Customer’s instances of
our SaaS or Subscription Services. For example, you may be a user of your
workplace or educational institution’s Learning Management System, of which we
are the provider. Or you may be an applicant to your employer or prospective
employers recruitment system, of which we are the provider. 

Visitor – a person who is visiting our website, or has expressed an interest in
our products or services by filling in a contact form or sign-up sheet in
relation to an event or webinar, or has had conversations about our products
with our sales team and provided them with your details.


YOUR INFORMATION

Please select the correct option based on the above definitions to access the
information applicable to you and your information.


CUSTOMER INFORMATION

Our Agreement with you is the best source of information on which personal data
we process for you and how we use and protect that personal data. We encourage
you to familiarize yourself with the terms of our agreement and reach out to
your account manager if you have any questions. 


ONLINE PURCHASES

If you make a purchase via one of our Sites, or by clicking the “Pay by Debit or
Credit Card” link in one of our emails or invoices (“Online Payments”), this
section shall apply. 

When you click the “Pay” or “pay by credit or debit card link, you will be taken
to another site, managed by our payment processor in order for your payment to
be processed. Your personal data will be securely encrypted and for further
information upon this details of the privacy policy of our payment processor(s)
are set forth below, and if applicable, in the email informing you of how to pay
by credit or debit card. When you click on this link we will receive details of
your IP address. You will be required to provide your payment details, which
will be made available to a third party payment gateway and merchant bank to
process the transaction. We will not receive and/or store your payment details,
but once you have made payment we will receive confirmation that your payment
has been processed and with certain details regarding the transaction including
the amount paid you will be required to provided your payment details We are
required to retain a copy of the transaction details for up to 7 years; however,
this does not include card data. 

For further information regarding the payment providers used on each of our
sites, please see below. Please note that we are not responsible for the privacy
practices or the content of such web sites, and this Privacy Policy does not
apply to such sites. We encourage our users to be aware when they leave our site
and to read the privacy statements of each and every site that collects
personally identifiable information.

Payment Provider or GatewayPrivacy / Security
PolicyAdyenhttps://www.adyen.com/policies-and-disclaimer/privacy-policyAuthorize.nethttps://www.authorize.net/company/privacy/Cheddarhttps://www.getcheddar.com/privacyPinnacle
Bankhttps://www.pnfp.com/learning-center/fraud-and-security/how-pinnacle-protects-you/Recurlyhttps://recurly.com/security/Shopifyhttps://www.shopify.com/legal/privacyStripehttps://stripe.com/gb/privacy


END-USER INFORMATION

We have been provided with your information, and handle your information subject
to an agreement with one of our clients. Our client may be your employer (or an
affiliate of your employer), a prospective employer to whom you have submitted a
job application or resume, your educational institution, or another company
which has either given you or asked you to sign up for an account with one of
our Sites. Our client acts as ‘data controller’ for your information, and we act
as ‘data processor’. This means that we do not determine how we collect or use
your data. Our client determines how we collect or use your data, and provides
us with instructions on what to do with it in our agreement with them. We only
collect and use your data in accordance with the agreement between us and our
client. Further to this, 

Our client is responsible for the management of your account on our Site. If you
have any questions or concerns regarding our use or collection of your data, or
if you wish to make a request to exercise your rights as a data subject or a
consumer (as explained below), please reach out to our client as they are best
placed to assist you. 


HOW DO WE COLLECT YOUR INFORMATION?

Your information will either have been provided to us by our client if they have
set your account up for you, or provided to us by you where our client has
invited you to set up an account or submit information such as a resume. 


WHICH TYPES OF INFORMATION DO WE COLLECT?

This depends upon which of our Sites you are using, and how our client is using
our Site to collect your information. Broadly, the types of data we collect may
include: 

 * Account details (username, password, log-in data, profile data)
 * Contact details (name, work/institution phone or email, personal phone or
   email (for recruitment Sites only))
 * Education or Training related data (for LMS Sites only) (course enrollment,
   course completion, course information, quiz scores, results, class/training
   schedules, and other training related information determined by our client)
 * Employment and performance related data (for workforce management, and D&I
   Sites) (job roles or descriptions, performance reviews, length of service,
   feedback, job title, division, development goals or plans, performance plans,
   salary data). 
 * Recruitment related data (for Recruitment sites only) (home address,
   qualifications, work history, resume/CV data, job application data)

If you require more information about which of your information we use, please
contact our client as they can advise you on which of your information they have
used our Site to collect. 


HOW DO WE USE YOUR INFORMATION?

We only use your information to provide our services to our client in accordance
with the agreement between us and our client. Our services to our client include
the routine activities of providing cloud based services such as hosting,
support, and maintenance. The majority of the time we have no need to access any
individual’s information to provide these Services. There are only certain
scenarios in which we would ever need to access your information. These
scenarios largely are based around providing technical support to your or our
client, in which case we may need to access your information to identify or
resolve a technical issue. We will only ever access your information to the
extent required, and with the permission of our client. 

For more information about how we or our client use your information, please
contact our client as they are best placed to provide you with this information.


WHERE WE STORE YOUR INFORMATION AND FOR HOW LONG

All of your information is stored on secure servers, with layers of security to
keep your information protected. The location of the server on which your
information is stored depends on which of our Sites you are using, and also on
what we have agreed with our client. The length of time for which we store your
information is also determined by our agreement with our client. Our client as
the ‘data controller’ is responsible for determining both of these things.

For more information about where and for how long we store your information,
please contact our client as they are best placed to provide you with this
information.


VISITOR INFORMATION


HOW DO WE COLLECT YOUR INFORMATION?

You directly provide us with the data that we collect. We collect data and
process data when you:

 * Complete a form on our website or via online advertising;
 * Provide us with your personal data at an event;
 * Sign up to a newsletter, contest, webinar, event, or other service;
 * Register online or place an order for any of our products or services.
 * Voluntarily complete a customer survey or provide feedback on any of our
   Sites or via email.
 * Use or view our website via your browser’s cookies.

Data collected via online forms will advise which fields are mandatory and which
are optional.


WHICH TYPES OF INFORMATION DO WE COLLECT?

The types of information we may collect through our Sites includes:

 * Contact Details (e.g. name, address, email address, phone and fax numbers,
   institution, title or job position), 
 * Your interest in LTG’s (or its subsidiaries’) products or services;
 * Information about your interest in newsletters, webinars, events, or other
   services that we provide (solely or jointly with others); and 
 * Any other data you provide. 

A visitor to our Sites who is not seeking employment or expressing interest in
purchasing products or services is not required to reveal any personal
information, provided that the applicable Site Cookie policy applies to all
visitors.


HOW DO WE USE YOUR INFORMATION?

We use information in the following ways:

 * To provide you with information via post, email or phone about products or
   services you requested or we feel may interest you;
 * To manage any query you have raised;
 * To allow you to participate in interactive features of our services, when you
   choose to do so;
 * To administrate our newsletters, surveys, and contests;
 * To arrange and manage events and webinars;
 * To administer our Site, and for internal operations (including
   troubleshooting, data analysis, testing, research, statistical purposes, and
   as part of our efforts to maintain the safety and security of our Sites)

Once we receive your information, it is subject to strict security measures in
accordance with applicable law. We may transfer personal information to
companies that help us to provide our Services and that we believe offer a
secure solution that improves our Service delivery. We may also transfer
personal data to our affiliates and partners. 

If you are a system user of one of our customers and have questions regarding
the processing of your personal information, please contact our respective
customer directly as they control the handling of your data.


COOKIES AND OTHER TRACKING TECHNOLOGIES

Our site uses cookies to distinguish you from other visitors to provide you with
a better experience and to help us improve our site. A cookie is a small data
file placed on the hard drive of your computer when you visit a website. 


TYPES OF COOKIES

Our site may use session cookies, persistent cookies, and web beacons. A
“session cookie” expires when you end your session (i.e. close your browser).  A
“persistent cookie” stores information on your hard drive so when you end your
session and return to the same website at a later date, the cookie information
is still available. A “web beacon” is a small string of code that represents a
clear graphic image, a redirect URL or JavaScript and is used in conjunction
with a cookie. The cookies we place on our server are readable only by us, and
cookies cannot access, read or modify any other data on your computer. We may
use web beacons alone or in conjunction with cookies to compile information
about your usage of our site and interaction with emails from us. For example,
we may place web beacons in marketing emails that notify us when you click on a
link in the email that directs you to our site, in order to improve our site and
email communications.


PURPOSES OF COOKIE USE

We use Cookies for several purposes. Please see information below on each of
these purposes.


PREFERENCE COOKIES

We use preference cookies to collect information about your choices and
preferences, and to allow us to remember language or other local settings and
customize our site accordingly.


ANALYTICS COOKIES

We also use analytics cookies to collect information about your use of our site,
and to enable us to improve the way our site works. For example, analytics
cookies show us which are the most frequently visited pages on our site, help us
record any difficulties you have with our site, and show us whether our
advertising is effective or not. This allows us to see the overall patterns of
usage on our site, rather than the usage of a single person. We use the
information to analyse the site traffic, but we do not examine this information
for individually identifying information. 


MARKETING COOKIES

We use Remarketing with Google Analytics to advertise online. Third party
vendors, including Google, may show our ads on sites across the internet. 

We, and third party vendors, including Google, use first-party cookies (such as
the Google Analytics cookie) and third-party cookies (such as the DoubleClick
cookie) together to inform, optimize, and serve ads based on someone’s past
visits to our website. Remarketing cookies used by us expire after 30 days. To
opt out of Remarketing or to control your ad preferences, please click here.


CONTROLLING COOKIES

Most web browsers have a “help” menu where you can review how to prevent your
browser from accepting new cookies, how to have your browser alert you when you
receive a new cookie or how to fully disable cookies on your browser. You can
learn more about cookies at sites like www.aboutcookies.org. If you use your
browser settings to block all cookies, you may not be able to access all or
parts of our site.


THIRD PARTY COOKIE PROVIDERS

In addition to the cookies that we own, we may also use third-parties cookies on
our Sites for the purposes detailed above. 

As the owners of these cookies, you are entitled to information from these third
parties regarding their privacy and security policies, and on how to opt-out
from their cookies. You can find more information on our third party cookie
providers below:

Name of providerLinkBusiness
UnitAddThishttps://datacloudoptout.oracle.com/Breezy HRAmazon Web Services
(AWS), CloudFronthttps://aws.amazon.com/privacy/Gomo
LearningAppcueshttps://www.appcues.com/privacyOpen LMSBrighter
IRhttps://www.brighterir.com/gdpr-privacy-cookie-policy/LTG
PlcDrifthttps://www.drift.com/privacy-policy/Open LMSEvidon
(Crownpeak)https://www.crownpeak.com/privacy-policyBridge,
InstilledFacebookhttps://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0Breezy
HRFull
Storyhttps://help.fullstory.com/hc/en-us/articles/360020624254-Security-OverviewBreezy
HR, BridgeGoogle services: Google tag manager, Google Analytics, DoubleClick,
Google Optimize, etc.https://policies.google.com/privacy?hl=enAffirmity, Bridge,
Gomo Learning, Instilled, Learning Technologies Group, LEO, OpenLMS,
PeopleFluent, Preloaded, Rustici Software, VectorVMS, WatershedGrowSumo
(PartnerStack)https://partnerstack.com/policiesBreezy
HRHotJarhttps://www.hotjar.com/policies/do-not-track/Affirmity, Gomo Learning,
Learning Technologies Group, LEO, OpenLMS, Preloaded, Rustici Software,
VectorVMSInspectlethttps://www.inspectlet.com/optoutBreezy
HRIntercomhttps://www.intercom.com/legal/privacyBreezy
HRLeadFeederhttps://www.leadfeeder.com/privacy/HCT/Effective
PeopleLinkedInhttps://www.linkedin.com/legal/privacy-policyAffirmity, Breezy HR,
Bridge, Gomo Learning, Instilled, Learning Technologies Group, LEO, OpenLMS,
PeopleFluent, Preloaded, Rustici Software, VectorVMS, WatershedMicrosoft
Clarityhttps://privacy.microsoft.com/en-US/privacystatementBridge, PeopleFluent,
Open
LMSMixpanelhttps://mixpanel.com/legal/privacy-policy/OpenLMSOneTrusthttps://www.onetrust.com/privacy/Bridge,
Instilled,
PeopleFluentPardothttps://www.salesforce.com/company/privacy/full_privacy/Affirmity,
Breezy HR, Bridge, Gomo Learning, Instilled, Learning Technologies Group, LEO,
OpenLMS, PeopleFluent, Preloaded, Rustici Software, VectorVMS,
WatershedPendohttps://www.pendo.io/legal/privacy-policy/Bridge,
ReflektiveStatCounterhttps://statcounter.com/about/cookies/Affirmity, Gomo
Learning, OpenLMS, VectorVMSStripehttps://stripe.com/privacyBreezy HRX
(previously Twitter)https://twitter.com/en/privacyAffirmity, Gomo Learning,
Learning Technologies Group, OpenLMS, Preloaded, Rustici Software, VectorVMS,
WatershedUser
Zoomhttps://www.userzoom.com/privacy-policy/BridgeUnbouncehttps://unbounce.com/privacy/Rustici
SoftwareWeePie pluginshttps://www.weepie-plugins.com/cookies/Affirmity, Gomo
Learning, Learning Technologies Group, OpenLMS, Preloaded, VectorVMSWootric
(InMoment)https://inmoment.com/privacy-policy/Breezy HR


WHAT ARE YOUR CHOICES REGARDING COOKIES?

Necessary cookies, which are required for the core functionality of the website,
are enabled by default automatically when you access the Site.

For all other categories of cookies used, which are not necessary for the site
to operate, you can expressly consent to their use by clicking “accept” on the
cookie banner which is set on the Site. If you do not wish to consent to the use
of these cookies, you can opt out by returning to the Site and changing your
cookie settings.

Additionally you can also decide whether or not to accept cookies through your
internet browser’s settings. Most browsers have an option for turning off the
cookie feature, which will prevent your browser from accepting new cookies, as
well as (depending on the sophistication of your browser software) allow you to
decide on acceptance of each new cookie in a variety of ways. You can also
delete all cookies that are already on your computer. If you do this, however,
you may have to manually adjust some preferences every time you visit a site and
some of the Services and functionalities may not work.

By continuing to browse our Site, you are agreeing to our use of cookies. 


SECURITY

We understand that the security of any data we collect is of great importance.
We therefore make sure it is well protected. We have appropriate physical,
electronic, and managerial procedures to safeguard and secure the personal
information we process. We follow generally accepted industry standards to
protect personal information submitted to us both during transmission and once
received. While we strive to protect your personal information, we cannot
guarantee its absolute security and any transmission of personal information is
therefore at your own risk. 

If you are a Customer, and you require more information regarding our security
measures, please refer to our agreement. If you are an End-User, please reach
out to our client who controls your account. If you are a Visitor, please
contact us using the methods detailed below for more information.


DISCLOSURE OF YOUR INFORMATION

Personal information may be disclosed to our ultimate holding company and its
direct and indirect subsidiaries. Our employees are responsible for the internal
security of confidential or proprietary information, and are only given access
in accordance with the principle of least privilege, meaning they are only given
access to your information when necessary and to the extent necessary for our
operations to continue. Employees receive regular data protection and cyber
security training, and are subject to LTG’s data protection and security
policies. Employees who violate the data protection and security policies are
subject to disciplinary action including, but not limited to termination. 

Our general policy is not to disclose your personal information to any
third-party without your prior consent. However, we may disclose your personal
information to third parties in the following scenarios:

 * We may use third-party vendors and hosting partners to provide the necessary
   hardware, software, networking, and other technology and services required to
   operate and maintain our Sites. As part of this, we may be required to
   transfer some of your personal information to these vendors and partners.
   Where we use third-party service providers, we choose vendors that enhance
   our services or practices and follow any legal requirements that apply to
   securing your data.
 * If we sell or buy any business or assets in which case your personal
   information may be disclosed to the prospective seller or buyer.
 * If we, or substantially all of our assets, are acquired by a third party,
   personal information held by us will be transferred as assets.
 * We also reserve the right to disclose your personal data as required by law
   or in the good faith that disclosure is necessary to protect our rights. This
   may include exchanging information with other organizations for the purposes
   of fraud protection and credit risk reduction.

We do not share, sell, rent, or trade personal information with third parties
for their promotional or other purposes. If this practice should change, we will
update this policy to identify how individuals can opt-out.


YOUR RIGHTS

Please see the sections below for further information about your rights in
accordance with applicable law.  


GDPR AND THE DATA PROTECTION ACT 2018 FOR EU/UK RESIDENTS

The General Data Protection Regulation (GDPR) is a regulation in the European
Union (EU) and EEA on data protection and privacy and is applicable to all EEA
residents. The Data Protection Act 2018 is the UK’s enactment of the GDPR, and
applicable to all UK residents. You have the right to contact your local data
protection authority and can request details of how to do this by contacting us
at privacy@ltgplc.com. 


LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

We process your personal data on the following legal bases:

Type of ProcessingLawful BasisSending marketing information (to you as an
individual)ConsentCarrying out our contractual obligations to our
ClientsPerformance of a contractSetting cookiesConsentSending marketing
information to existing customers and business prospectsLegitimate interests


DATA SUBJECT RIGHTS – EU AND UK RESIDENTS

As a EU or UK data subject, being a person resident in the EEA or UK, you are
entitled to the following rights in regard to your personal data: 

The right to access – You have the right to request that we provide you with
copies of your personal data which we hold on record. In some scenarios, as
permitted by law, we may charge you a small fee for this service.

The right to rectification – You have the right to request that we correct any
information we have on record that you believe is inaccurate. You also have the
right to request that we complete any information we have on record that you
believe is incomplete.

The right to erasure – You have the right to request that we erase your personal
data, under certain conditions.

The right to restrict processing – You have the right to request that we
restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to our
processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that we transfer
the data that we have collected to another organization, or directly to you,
under certain conditions.

You can verify whether we hold any of your personal data, or make a data subject
request by submitting a request via the Data Subject Request Form. We may need
to verify your identity before we are able to respond to the inquiry.


AUTHORIZED REPRESENTATIVE EEA

All LTG subsidiaries (defined above) based outside of the EEA have, to the
extent  that the GDPR is applicable with regard to any data processing
performed, appointed Learning Technologies Group GmbH to act as their designated
representative within the EEA.

Name: Learning Technologies Group GmbH

Address: Dieningholt 9, 59387 Ascheberg

Email: privacy@ltgplc.com


AUTHORIZED REPRESENTATIVE UK

All LTG subsidiaries (defined above) based outside of the UK have, to the extent
that the Data Protection Act 2018 is applicable with regard to any data
processing performed, appointed Learning Technologies Group (UK) Limited to act
as their designated representative within the UK. 

Name: Learning Technologies Group (UK) Limited

Address: Projects The Lanes, Nile House, Nile Street, Brighton, East Sussex BN1
1HW.

Email: privacy@ltgplc.com 


DATA PRIVACY FRAMEWORK – FOR EU, UK AND SWISS INDIVIDUALS WHOSE DATA IS
TRANSFERRED INTO THE US

As applicable, we comply with the EU-US Data Privacy Framework program (EU-U.S.
DPF), UK Extension to E.U.-U.S. DPF (UK-US DPF), and Swiss-US Data Privacy
Framework program (Swiss-U.S. DPF) as developed by the United States Department
of Commerce, European Commission, UK Government and Swiss Federal
Administration. Learning Technologies Group and its US affiliates included in
its certification have certified to the U.S. Department of Commerce that it
adheres to the DPF Principles with regards to transfers to the US of personal
data received from the European Union, in reliance on the EU-U.S. DPF and with
regard to transfers to the US from the United Kingdom (and Gibraltar) in
reliance on the UK Extension to the EU-U.S. DPF. We certify adherence to the
Swiss-U.S. DPF Principles with transfers to the US of personal data received
from Switzerland in reliance on the Swiss-U.S. DPF. If any conflict shall arise,
the Data Privacy Framework Principles shall govern. To learn more about the Data
Privacy Framework program and to view our certification page, please
visit www.dataprivacyframework.gov/. 

Pursuant to the Data Privacy Framework Principles, we are obligated to inform
EU, UK, and Swiss individuals whose data is transferred to the United States
that we may be required to release that information in response to lawful
requests by public authorities including to meet national security and law
enforcement requirements. We remain responsible and liable under the Data
Privacy Framework Principles if third-party agents that we engage with process
the personal data in a manner inconsistent with the Data Privacy Framework
Principles, unless we can prove we are not responsible for the event giving rise
to the damage.

We  are committed to cooperate with EU Data Protection Authorities (DPAs), the
UK Information Commissioner’s Office and the Swiss Federal Data Protection and
Information Commissioner (FDPIC) and comply with the advice given by such
authorities with regard to human resources data transferred from the EU, UK and
Switzerland in the context of the employment relationship. EU individuals with
HR complaints should refer to https://edpb.europa.eu/about-edpb/board/members_en
for the list of Data Protection Authorities.

While the Swiss Federal Administration has not yet approved the Swiss-US DPF, we
are committed to complying with the Swiss-US DPF once it is approved by the
Swiss Federal Administration as a lawful data transfer mechanism for transfers
of personal data from Switzerland to the United States and have self-certified
for Switzerland under the Data Privacy Framework.

In compliance with the EU-US Data Privacy Framework Principles and the UK-US
Data Privacy Framework, we commit to resolve complaints about your privacy and
our collection or use of your personal information transferred to the United
States pursuant to the DPF Principles. EU/EEA, Swiss and United Kingdom
individuals with Data Privacy Framework inquiries or complaints should first
contact us via the methods detailed below under the heading “Exercising Your
Rights”.

If your  DPF complaint cannot be resolved through the above channels, under
certain conditions, you may invoke binding arbitration for some residual claims
not resolved by other redress mechanisms. 
See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2

You may request a copy of, correct or amend incorrect data or request deletion
of personal information that has been processed in violation of the Data Privacy
Framework Principles. To seek access, correct, amend, or delete inaccurate data
transferred to the United States under Data Privacy Framework, please complete
this Data Subject Request Form. We will respond to the inquiry within 30 days.

Individuals with general Data Privacy Framework inquiries or complaints should
contact us via the methods detailed below under the heading “Exercising Your
Rights”.


CCPA 

The California Consumer Privacy Act (CCPA) is a law in the State of California
on data protection and privacy and is applicable to all California residents. 


NOTICE OF COLLECTION AND PROCESSING ACTIVITIES

Under the CCPA, you are entitled to certain information so that you are informed
about how we collect your data, and how and why we use that data after
collection. We encourage you to read this policy in full to get the clearest
understanding, but we have summarized this information here:

Categories of personal information collectedAs listed under the heading “Which
Types of Data Do We Collect?” aboveHow personal information is collectedAs
listed under the heading “How Do We Collect Your Data” above.Categories of
sources from which the personal information is collectedWe only collect personal
information provided by you to us, either directly (e.g. by contact form, by
email) or indirectly (e.g. via cookies). We may also collect your personal
information from our partners when running joint webinars or events which you
have signed up to. We do not collect personal information from any other
sources. Purpose of collectionFor our legitimate and lawful sales and marketing
operations, and as further detailed under the heading “How Do We Use Your Data?”
aboveCategories of third parties with whom the data has been sharedYour personal
data may be shared with our subsidiaries and associated businesses, our third
party providers (e.g. our hosting and analytics providers), and where we host a
joint event with a partner which you sign up to, we may share you data with that
partner. Specific pieces of informationWe can provide this information on
request, in accordance with the procedure set out below. 


CONSUMER RIGHTS – CALIFORNIA RESIDENTS

As a Consumer, being a person resident in California, you are entitled to the
following rights regarding your personal data:

Right to Opt-out – You have the right to opt out of an organization selling your
information to third parties. We do not sell information to third parties at
this time, but should this change we would update this policy to provide further
information on our practices and the exercising of this right. 

Right of notice – You have the right to be notified of which personal data we
are collecting from you, the reasons why, and how it would be used. This policy
provides you with this information. 

Right of Disclosure – You have the right to request that we disclose certain
information to you about our collection and use of your personal information
over the past 12 months. 

Right of Deletion – You have the right to request that we delete any personal
information we have collected from you in the last 12 months, in certain
circumstances.

Right to Equal Services and Prices  – You have the right to exercise your rights
under the CCPA free of discrimination, and we will never deny you goods or
services, charge you a different price, provide you with a different level or
quality of goods or services based on your exercising your rights to your data.

You may only make a request to exercise your rights of disclosure within a
twelve (12) month period. 


COPPA

In accordance with the Children’s Online Privacy Protection Act (“COPPA”) and
the GDPR, our Sites are not intended for use by children. We do not knowingly
request, solicit, access, or receive personally identifiable information from
anyone under the age of 13 and 16 respectively. 

Where we are aware of any personal information submitted through our Sites
belonging to a child, we will delete this data from our records.


EXERCISING YOUR RIGHTS

To exercise your rights under the GDPR, the Data Protection Act 2018, or the
CCPA, you may make a request via the Data Subject Request Form, or by calling
+44(0) 20 7832 3440.

To enable us to process your request, we may require you to:

 * Provide sufficient information that allows us to reasonably verify you are
   the person about whom we collected personal information or an authorized
   representative.
 * Describe your request with sufficient detail that allows us to properly
   understand, evaluate, and respond to it.

Please note that we would be unable to respond to your request, or provide you
with any personal data if we are unable to verify your identity or authority to
make the request and confirm the personal information relates to you.

We endeavor to respond to a request within thirty (30) days of receipt. If we
require more time (up to 90 days), we will inform you of the reason and
extension period in writing.

We do not charge a fee to process or respond to your verifiable consumer request
unless it is excessive or onerous, repetitive, or manifestly unfounded. If we
determine that the request warrants a fee, we will tell you why we made that
decision and provide you with a cost estimate before completing your request.


THIRD PARTY WEBSITES

Our Sites may contain links to and from websites of our partner networks,
clients, and/or affiliates. Please note that these websites are subject to their
own privacy policies and we do not accept any liability for these sites and
policies. Please check these policies before you submit any personal data to
these websites.


CORPORATE AND CONTACT DETAILS

Our global privacy team act as our main point of contact for all privacy
matters. You can contact them by submitting a request via Data Subject Access
Form, or by calling +44(0) 20 7832 3440.

SiteLTG company with responsibility for the SiteAddresswww.ltgplc.comLearning
Technologies Group Plc15 Fetter Lane, London, EC4N 1BWbreezy.hrBreezy HR,
Inc.1534 Oak St #301,Jacksonville, FL 32204www.affirmity.comLearning
Technologies Group, Inc. through its division Affirmity434 Fayetteville St.,
Suite 900, Raleigh, NC 27601www.ecreators.com.auLearning Technologies, Inc.
through its division Open LMS434 Fayetteville St., Suite 900, Raleigh, NC
27601www.getbridge.comLearning Technologies, Inc. through its division getBridge
LLC434 Fayetteville St., Suite 900, Raleigh, NC 27601www.gomolearning.comGomo
Learning LimitedProject The Lanes, Nile House, Nile Street, Brighton East Sussex
BN1 1HWwww.instilled.com/Learning Technologies Group, Inc. through its division
PeopleFluent434 Fayetteville St., Suite 900, Raleigh, NC
27601www.openlms.comLearning Technologies, Inc. through its division Open LMS434
Fayetteville St., Suite 900, Raleigh, NC 27601www.peoplefluent.comLearning
Technologies Group, Inc. through its division PeopleFluent434 Fayetteville St.,
Suite 900, Raleigh, NC 27601www.preloaded.comPreloaded LimitedThe Arts Building,
Morris Place, Finsbury Park, London N4 3JGwww.reflektive.comLearning
Technologies, Inc. through its division getBridge LLC434 Fayetteville St., Suite
900, Raleigh, NC 27601www.rusticisoftware.comRustici Software LLC210 Gothic Ct
#100Franklin, TN 37067www.vectorvms.comLearning Technologies Group, Inc. through
its division Vector VMS434 Fayetteville St., Suite 900, Raleigh, NC
27601www.watershedlrs.comWatershed Systems Inc210 Gothic Court, Suite
100,Franklin, TN 37067

privacy@ltgplc.com, or at:

Learning Technologies Group Plc
15 Fetter Lane
Attention: Privacy Team
London, UK EC4A 1BW

Phone: +44(0) 20 7832 3440


CHANGES TO THIS PRIVACY NOTICE

We reserve the right to modify this Privacy Notice at any time, so review it
frequently. If material changes are made, it will be reposted and made available
from our homepage so you are aware of what personal information we collect, how
we use it, and under what circumstances (if any) we disclose it. 

Last Updated: January 2024



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