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SKILLSOFT PRIVACY POLICY

Last Updated: May 25, 2018

Important information and who we are

Our products and services

The data we collect about you

How is your personal data collected?

How we use your personal data

Disclosures of your personal data

International transfers

Data security

Data retention

Your legal rights

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 as to 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 (“Privacy Policy”).

This privacy notice is provided in a layered format so you can click through to
the specific areas set out below. Please also use the Glossary at Section 11 to
understand the meaning of some of the terms used in this privacy notice.


1. IMPORTANT INFORMATION AND WHO WE ARE

This privacy notice aims to give you information on how Skillsoft Corporation
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, or take part in a
webinar.

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.


CONTROLLER

Skillsoft Corporation is the entity that is the controller and responsible for
the websites located at Skillsoft.com, SumTotalSystems.com, and Vodeclic.com.

We have appointed a data protection officer who is responsible for overseeing
questions in relation to this privacy notice. If you have any questions about
this privacy notice, including any requests to exercise your rights in your
personal data, please contact the Data Protection Officer using the details set
out below.


2. OUR PRODUCTS & SERVICES

Unlike our websites, most of the products and services of Skillsoft, SumTotal,
and Vodeclic – as listed below – are intended for use by our business customers
(“Skillsoft Business Services”), and your use of them is administered by your
company.

Skillsoft Business Services Skillsoft SumTotal Academy (Compliance) Core HR
(HRMS) Books Core Platform Compliance Questionnaires Expense E-Delivery Growth
Edition (Maestro) Mentoring Learn (ELMS) Percipio Pathlore Publisher Payroll
Skillport/OLSA Talent Vodeclic Talent Acquisition



Workforce Management

In such cases, authorized personnel at your company may have access to your
personal information processed by these Skillsoft Business Services, and your
company may have policies applicable to your use of them. Skillsoft is not
responsible for our business customers’ policies and practices related to data
privacy and security, which may be different from this privacy notice and any
applicable notice provide by our business customers.

If your company is administering your use of a Skillsoft Business Service,
please contact your company with any privacy questions related to your use of
that Skillsoft Business Service. If there is a conflict between this Privacy
Policy and an agreement between Skillsoft and its business customer for a
Skillsoft Business Service, then the agreement between Skillsoft and its
business customer will control.


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.

Our full details are:

Full name of legal entity: Skillsoft Corporation Name or 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 March 19, 2018. The data protection laws in the
EU, as well as the UK, will change on 25 May 2018. Although this privacy notice
sets out most of your rights under the new laws, we may not yet be able to
respond to some of your requests (for example, a request for the transfer of
your personal data) until May 2018 as we are still working towards getting our
systems ready for some of these changes.

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. It does not include data
where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about
you which we have grouped together 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), if your company is administering your use of a
Skillsoft Business Service, please contact your company with any privacy
questions related to the personal information processed in connection with 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 (this
includes 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.


IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract
we have with you and you fail to provide that data when requested, we may not be
able to perform the contract we have or are trying to enter into with you (for
example, to provide you with goods or services). In this case, we may have to
cancel a product or service you have with us but we will notify you if this is
the case at the time.


4. HOW IS YOUR PERSONAL DATA COLLECTED?

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

 * Direct interactions. You may share with us some of your Identity and Contact
   Data 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 Data about your equipment, browsing
   actions and patterns. We collect this personal data by using cookies, server
   logs and other similar technologies.
 * Third parties or publicly available sources. We may receive analytics
   andadvertising data about you from the sources listed below, as well as,
   public sources. Please use the following links for more information about how
   Google and Salesforce collect and use data when you visit their partners'
   websites or apps:
   * Google - www.google.com/policies/privacy/partners/
   * LinkedIn -www.linkedin.com/legal/privacy-policy
   * Marketo - documents.marketo.com/legal/privacy/
   * Salesforce.com - www.salesforce.com/in/company/privacy/


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 here to find out more about the types of lawful basis that we will 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 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 updating your email preferences.


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 plan
to 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
 1. Identity
 2. Contact

Performance of a contract with you

To manage our relationship with you which will include:

 1. Notifying you about changes to our terms or privacy policy
 2. Asking you to leave a review or take a survey

 1. Identity
 2. Contact
 3. Marketing and Profile

 1. Performance of a contract with you
 2. Necessary to comply with a legal obligation
 3. 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)
 1. Identity
 2. Contact
 3. Technical

 1. 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)
 2. 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
 1. Identity
 2. Contact
 3. Usage
 4. Marketing and Profile
 5. 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
 1. Technical
 2. 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 make suggestions and
recommendations to you about goods or services that may be of interest to you
 1. Identity
 2. Contact
 3. Technical
 4. Usage
 5. 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 use OR the following personal data control mechanisms:


PROMOTIONAL OFFERS FROM 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 group 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.


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 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 Group. This will involve
transferring your data outside the European Economic Area (EEA).

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 Economic Area
(EEA) so their processing of your personal data will necessarily involve a
transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, 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
Europe.

In 2015, Skillsoft certified that it adhered to the Safe Harbor Privacy
Principles of notice, choice, onward transfer, security, data integrity, access,
and enforcement. To learn more about the Safe Harbor program please visit:
http://www.export.gov/safeharbor/. Although the U.S.-E.U. Safe Harbor framework
is no longer considered a valid data transfer mechanism in the European Union,
Skillsoft continues to comply with the relevant principles of the its framework
and will certify compliance with its successor privacy protection framework by
or before the end of the 2018 calendar year.


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

How Long Will You Use My Personal Data For?

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”
in the Glossary at Section 11 below for further information.

In some circumstances we may anonymize 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 LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in
relation to your personal data. If you wish to exercise any of the rights set
out above, please fill-out our form for Personal information requests.


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 or other legitimate circumstances.


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. Occasionally it
may take us longer than a month if your request is particularly complex or you
have made a number of requests.

Finally, we can only act on requests related to the personal information we have
collected through our websites. If you are using any of our Skillsoft Business
Services, please contact your company with any questions or requests related to
your personal information. That said, if we cannot process your request, we will
explain the reason(s) why. For example, a request might impact the rights of
another person or company.


11. GLOSSARY


LAWFUL BASIS

Legitimate Interest means the interest of our business 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 to 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.


THIRD PARTIES


INTERNAL THIRD PARTIES

Other companies in the Skillsoft Group include the following entities and
providing the following services:

Entity Location Services Provided Skillsoft Corporation 300 Innovative Way,
Suite 201
Nashua, NH 03062
USA Skillsoft Business Services; Sales & Marketing Skillsoft UK Limited Compass
House, 2nd Floor
207-215 London Road
Camberley
GU15 3EY
United Kingdom Sales & Marketing Skillsoft Canada, Ltd. 20 Knowledge Park Drive
Fredericton,NB E3C 2P5
Canada

Support for Skillsoft Business Services

SumTotal Systems, LLC

300 Innovative Way
Suite 201
Nashua, NH 03062
USA SumTotal Business Services SumTotal Systems India, LLC 7th Floor, Maximus
Towers
Building 2B, Mindspace
Raheja IT Park
Cyberabad, Hyderabad
Telangana - 500081 India Support for SumTotal Business Services) Vodeclic SAS
102-116, rue Victor Hugo
92300 Levallois-Perret
France Vodeclic Business Services


EXTERNAL THIRD PARTIES

External third parties are limited to Google, LinkedIn, Marketo, and
Salesforce.com as described at further described in Section 4 (above).


YOUR LEGAL RIGHTS

You have the right to:

 * 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.
 * Request the transfer 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.
 * Withdraw consent at any time where we are relying on consent to process your
   personal data. However, this will not affect the lawfulness of any processing
   carried out before you withdraw your consent. If you withdraw your consent,
   we may not be able to provide certain products or services to you. We will
   advise you if this is the case at the time you withdraw your consent.