PRIVACY POLICYFrance-Flag-icon-e1461248835470Germany-Flag-icon-e1461248566766

LRN CORPORATION PRIVACY POLICY

LRN Corporation (“LRN” or “Company”) is committed to protecting your privacy and earning your trust. This Privacy Policy, which is effective as of August 12, 2016, describes LRN’s privacy practices for both the web site located at www.lrn.com, the Customer Web Sites which LRN creates, configures and hosts on behalf of its customers, and any derivative products which are developed to work either remotely or on a mobile/tablet device. The ownership of the data on LRN’s Customer Web Sites or mobile/tablet apps is subject to agreements entered into between LRN and each of its customers.

LRN’s data privacy and data security practices implement best practices for the protection and security of personal information, and also implement the requirements prescribed by the United States and the European Union (“EU”) under the EU/US Privacy Shield Program – which provides compliance guidance for U.S.-based organizations in connection with the European Union’s directives on the protection of the personal information of EU data subjects.

LRN’s COMMITMENTS UNDER THE EU/US PRIVACY SHIELD PROGRAM

LRN adheres to the Privacy Shield principles set forth at www.privacyshield.gov, which are summarized below:

1. Notice: LRN will inform EU data subjects of the Company’s data handling practices, which are set forth in this Policy.

2. Choice: LRN offers individuals the opportunity to opt out if their personal data is to be disclosed to a third party (except agents), or used for a purpose that is materially different from the purpose for which it was originally collected, or subsequently authorized. To be clear, as a matter of strict policy, does not use personal data for any purpose that is not expressly disclosed, and agreed to, by LRN’s customers.
3. Accountability for Onward Transfer: If LRN needs to transfer personal data received from the EU to a third party, LRN will enter into a written contract with that third party which will contain specific provisions for the protection of that personal data.

4. Protection of Personal Data: LRN will take reasonable and appropriate measures to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

5. Data Integrity and Purpose Limitation: LRN will limit its collection and processing of personal information to that which is relevant to the purposes of the processing; will take reasonable steps to ensure that personal data is reliable for its intended use, and is accurate, complete, and current; and will retain personal data only for as long as is necessary to achieve the purpose of the relevant processing.

6. Access: LRN will provide relevant EU individuals with access to the personal data the Company holds about them, as well as the ability to correct, amend, or delete information which is inaccurate, or has been processed in violation of the Privacy Shield.

7. Recourse, Enforcement, and Liability: LRN is subject to the jurisdiction of the US Federal Trade Commission, which has the right to enforce LRN’s compliance with the Privacy Shield Program. In addition, in order to further ensure LRN’s compliance with the Privacy Shield Program, LRN has a contract with an independent recourse mechanism, JAMS (an alternative dispute resolution provider based in the US, with several locations in the EU), which is available – at LRN’s cost, and at no cost to the individual – to address unresolved complaints regarding LRN’s compliance with the Privacy Shield Program.

NOTICE:

Any questions, complaints, access requests, and other issues arising under the Privacy Shield Program, under the US/Swiss Safe Harbor framework (to which LRN has also self-certified), or under LRN’s Privacy Policy more generally, should be directed to LRN Corporation, Legal Department, 745 5th Avenue, 8th Floor New York, NY 10151, Phone 646.862.2049.

LRN has a contract with an independent recourse mechanism, JAMS (an alternative dispute resolution provider based in the US, with several locations in the EU), which is available – at LRN’s cost, and at no cost to the individual – to address unresolved complaints regarding LRN’s compliance with the Privacy Shield Program. Under certain circumstances, the affected individual may invoke binding arbitration.

A citizen of a country within the European Union may also address any privacy-related questions or problems to the appropriate data protection authority in his or her E.U. member state.

LRN may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. LRN may also be liable, under certain circumstances and subject to applicable law, if it transfers personal data to third parties.
LRN has an agreement with Verizon, through Verizon’s Cybertrust Security Certification Verification, to ensure that LRN’s data privacy and data security controls have been assessed, verified, and validated by an industry leader in information security.

Information Collection & Use

Customer Web Sites

LRN provides online knowledge, training, management and other services to employees of LRN’s customers and others designated by LRN’s customers to participate in LRN’s programs (“Users”). LRN’s customers are typically businesses or other organizations. LRN typically provides its services via Customer Web Sites, computer based application, and/or mobile/tablet application that LRN creates, configures, hosts, and supports on behalf of customers. LRN operates its programs and collects and uses data about Users at the direction of, and in accordance with, the instructions of LRN’s customers.

LRN’s arrangements with its customers may require LRN to obtain certain personal information about Users, either from the customer or a User, in order for a User to access the online knowledge, training and other services provided on a Customer Web Site, computer based application, and/or mobile/tablet application. Among other things, LRN may collect the following data: (i) User name; (ii) User identification; (iii) User password; (iv) User email address; and (v) User department(s) and location within the customer organization. LRN may also track the amount of time a User spends on the Customer Web Site, the applications the User employs, the self-tests the User performs, the User’s performance on such tests, and other activities in which the User engages while the User is on the Customer Web Site.

LRN only uses personal information to provide feedback about a User’s activity on a Customer Web Site. For example, LRN may use personal information to inform a User of his or her performance on tests, or the number of training modules that a User has used. LRN may also use personal information to send e-mails to a User, such as reminder e-mails that the User has not completed certain online courses.

LRN’s arrangements with its customers require LRN to provide all User information in LRN’s possession, including a User’s personal information, directly to the customer with which the User is associated (i.e., the User’s employer). If a User corresponds with LRN, LRN may keep a record of that correspondence. LRN may also forward correspondence to the customer with which the User is associated. We will share your personal information with third parties only in the ways that are described in this privacy policy. We do not sell your personal information to third parties. LRN does not transfer any personal User information to any third party (other than to the LRN customer with which the User is associated) unless it is authorized to do so by the customer with which the User is associated, in connection with the services that LRN provides to the customer, or required to do so by applicable law such as to comply with a subpoena, or similar legal process – or 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 may provide your personal information to companies that provide services to help us with our business activities such as shipping your order or offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us.

LRN actively collects information from visitors to its website at www.lrn.com both by asking specific questions on the site and by permitting visitors to communicate directly with LRN via e-mail. Some of the information that visitors to the website submit may be personally identifiable (that is, information that can be uniquely identified with an individual, such as name, address, e-mail address, phone number, etc.). LRN uses this information to send visitors to its website further information regarding LRN. LRN does not provide, sell, or otherwise make available to third parties personal information that is collected from visitors to the website.

LRN may collect, store or accumulate certain non-personally identifiable information concerning visitors’ use of this site, such as information regarding which pages are most often visited. LRN may share with or transfer to third parties such non-personally identifiable information for the purpose of maintaining the site, responding to direct inquiries, or measuring traffic and traffic trends at this site. LRN does not otherwise provide or sell any of this information to third parties.

Data Integrity & Data Security

LRN has taken commercially reasonable and appropriate steps to protect personal information that LRN collects, processes or maintains. These steps include, among other things, limiting the number of people who have physical access to LRN’s database servers, utilizing electronic security systems, and using password protections which guard against unauthorized access. LRN employs these and other safeguards and practices to provide for the security of personal information in its possession, but cannot guarantee that such measures will be infallible. LRN also requires its vendors to take commercially reasonable and appropriate steps to protect personal information in their possession.

Correcting & Updating Personal Information

LRN is committed to ensuring that the personal information it collects, processes, and maintains is accurate. At the direction of, and in accordance with, the instructions of LRN’s customers, LRN allows Users of LRN’s Customer Web Sites to access their personal information in LRN’s possession and to correct, amend, or delete inaccurate information. Users of LRN’s Customer Web Sites who have questions about personal information on file with LRN may, if the customer so provides, access the Customer Web Site to make such corrections or may contact LRN at the address below.

Visitors to LRN’s website may update, or request the deletion of, previously submitted personal information via the Contact page. We will respond to your request to access within 30 days.

Analytics / Log Files

As is true of most web sites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

We may combine this automatically collected log information with other information we collect about you. We do this to improve the services we offer you, and to improve marketing, analytics, or site functionality.

Tracking Technologies

Technologies such as: cookies, beacons, tags and scripts are used by LRN and our customers, affiliates, or analytics or service providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use cookies to allow users to access and track their training Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

Local Storage Object

Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use local shared objects (LSOs) such as HTML 5 to collect and store information.

Links

LRN web sites may contain links to other web sites. LRN is not responsible for the privacy practices of, or the content on, such other sites.

Widgets

Our Web site includes Widgets, which are interactive mini-programs that run on our site to provide specific services from another company (e.g. displaying the news, opinions, music, etc). Personal information, such as your email address, may be collected through the Widget. Cookies may also be set by the Widget to enable it to function properly. Information collected by this Widget is governed by the privacy policy of the company that created it.

Disclaimers

The services provided by Customer Web Sites do not constitute the rendering of legal services, and no attorney-client relationship is formed between LRN and any customer, or between LRN and any User, by virtue of such services. The information contained in Customer Web Sites is not intended to constitute legal advice or to substitute for obtaining appropriate legal advice.

This Privacy Statement describes LRN’s privacy practices only. It does not describe, and LRN makes no representations about, the privacy practices of any other parties, including LRN’s customers, who may receive personal information from LRN about Users associated with that customer in the course of LRN’s performance of services for the customer.

Opt-out

Recipients may unsubscribe from future email communications from LRN by following the instructions in such communications.

Questions & Complaints

Any questions, complaints, access requests, and other issues arising under the Privacy Shield Program, under the US/Swiss Safe Harbor framework (to which LRN has also self-certified), or under this LRN Privacy Policy more generally, should be directed to LRN Corporation, Legal Department, 745 5th Avenue, 8th Floor New York, NY 10151, Phone 646.862.2049.

In order to further ensure LRN’s compliance with the Privacy Shield Program, LRN has a contract with an independent recourse mechanism, JAMS (an alternative dispute resolution provider based in the US, with several offices in the EU), which is available – at LRN’s cost, and at no cost to the individual – to address unresolved complaints regarding LRN’s compliance with the Privacy Shield Program.

A citizen of a country within the European Union may also address any privacy-related questions or problems to the appropriate data protection authority in his or her E.U. member state.

Business Transfers

In the event of a sale, assignment, liquidation or other transfer of all or substantially all of the stock, assets or business of LRN, personal information may be transferred to a relevant successor entity, subject to the applicable privacy policy. In these events, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Changes to this Privacy Policy

If we decide to change our privacy policy, we will post those changes to this privacy statement, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page prior to the change becoming effective.

This Privacy Policy was last reviewed on August 11, 2016.