WHAT INFORMATION DO WE COLLECT?

Information You Provide

We collect various types of information from our users to provide and improve our Services. Here are the categories of information we may collect:

• Account Information: This includes your name, email address, telephone/mobile numbers, and any passwords you create when setting up an account on our Site.

• Payment Information: We collect payment and billing information when you make a purchase. This information is provided by you or through our payment service providers, who inform us about the status of your transactions to ensure they are processed correctly. When you make a purchase through our website, your payment information is processed by our third-party payment processors. We do not store your credit card details. These third-party processors have their own privacy policies which you can review at their respective websites. We recommend that you review their privacy policies to understand how they manage your payment information. If you make a purchase offline, we only handle your payment information once to input it securely into our payment gateway. After this initial transaction, we use a non-personally identifiable token for all further processing.

• Commercial Information: Records of the products or services you have purchased, obtained, or considered, as well as other purchasing or consuming histories or tendencies.

• Correspondence and Communication Data: Information you provide when you communicate with us via our customer service channels, including emails, phone calls, or messages to our site chat representatives. This also includes responses to communications we send and interactions with our social media channels.

• Other Information: Any other information you provide directly or indirectly through your use of our Site or Services. This might include data provided during interactions with our Site, additional profile information, or details provided during promotional events.

Automatically Collected Information

When you visit our Site, we automatically collect certain information from your device and the browsers you use. This data helps us understand how you interact with our Site and allows us to improve our services. Here’s what we collect:

• Your device type;

• Internet Protocol (IP) address;

• Application usage information;

• Browser type and version;

• Date and Time of visit;

• Information about the links you click, pages you view, and other information regarding how you interact with the Site;

• Server log information;

• Browser plug-in types and versions; and

• Browsing history and search history within our Site.

We will use this information as described herein, subject to any limitations this Notice sets forth, as well as any applicable law. Information collected from third parties referenced herein may also be subject to their own privacy policies and other rules/ regulations.

HOW WE USE YOUR INFORMATION

We may use and otherwise process each of the categories of information identified above for various business purposes, including:

• Providing products and Services that you purchase, and processing your payments for such purchases;

• Communicating with you;

• Sending you direct marketing and promotional materials relating to our Services and products;

• Verifying your identity and account information;

• Improving our Site and to ensure that the content is presented in the most relevant and effective manner for you and your device;

• Keeping our Services and businesses safe and secure, complying with applicable laws and regulations, and protecting or exercising our legal rights, including defending against legal claims; by way of example only, this includes use of your information to detect, prevent, and investigate fraud and other illegal activity and violations of this Notice and/or or other guidelines/rules; we may monitor chat, and other messages sent through the Services for these purposes;

• As described to you when collecting your information; and

• For any other lawful purpose.

*If we use your information to create aggregate or de-identified information, it will no longer be subject to this Notice.

OUR DISCLOSURE OF YOUR INFORMATION

We do not sell any customer information or share it with anyone who would use it to market to you. However, we may share your information with third party service providers in a way that may be considered a sale of your information under applicable U.S. Privacy Laws. For instance:

• We share your information with third party vendors and service providers who provide services to us for a variety of business purposes, such as payment processing, customer service, e-mail deployment, advertising, marketing, security, performance monitoring, maintaining or servicing accounts, and processing or fulfilling orders and transactions;

• We may share your information with our affiliates;

• We may share your information in connection with corporate transactions, such as sales, mergers, consolidations, an initial public offering, etc.;

• We may disclose your information to respond to subpoenas, court orders, and/or other government/regulatory authority inquires, and to protect and defend the rights, interests, safety, and security of Learniture, our affiliates, and/or the public;

• We may share your information for any other purpose disclosed to you at the time we collect and/or share the information, pursuant to your consent or direction.

• No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

In the preceding 12 months, we have disclosed your information for the following business purposes. The table below describes the categories of information in the left column, examples of data types within the applicable categories in the middle column and the right column states the categories of recipients that receive such information as part of disclosures business purposes.

Category of Personal Data	Examples of Personal Data Types Within the Category	Categories of recipients
Identifiers and Contact Information	Contact information (name, email address, & phone numbers), Account Details, Financial Account Information	Software and other business vendors, Marketing Vendors, Affiliates and related entities.
Personal Records	Contact information (name, email address, & phone numbers), Account Details, Financial Account Information	Business Vendors, Marketing Vendors, Affiliates and related entities.
Customer Account Details/Commercial Information	Transaction and Commercial Information,	Business Vendors, Marketing Vendors, Affiliates and related entities.
Internet Usage Information	Transaction and Commercial Information,	Business Vendors, Marketing Vendors, Affiliates and related entities.
Location Data	Location Data	Business Vendors, Marketing Vendors, Affiliates and related entities.
Professional or employment related information	Contact information	Business Vendors, Marketing Vendors, Affiliates and related entities.
Inferences drawn from other information received.	Inferred Information, information received via cookies or analytics.	Business Vendors, Marketing Vendors, Affiliates and related entities.
Sensitive Personal Information	Precise geolocation, and username and password. *Credit or Debit card numbers, financial account numbers (collectively “Payment Information”)	Business Vendors, Marketing Vendors, Affiliates and related entities. *Payment Processors only collect and receive Payment Information. No other vendor receives Payment Information.

U.S. STATE PRIVACY NOTICE

Depending on where you reside, you may be entitled to object to, or request restriction of, certain processing of your information. In addition, you may be entitled to request access to, rectification, erasure, and portability of your information or more information about our privacy practices.

This U.S. State Privacy Notice is designed to provide you with notice of our recent information practices for the 12-month period preceding the “Last Updated” date of this Privacy Notice. This U.S Privacy Notice also applies to our current data practices such that it is also meant to provide you with “notice at collection.”

If you exercise any of the following rights, we will first verify your identity prior to providing any information, which may include the need for you to provide additional information in order for us to properly verify your identity.

You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request related to personal information associated with that specific account. We will only use information provided in the request to verify the requester’s identity or authority to make it.

Depending on your state of residency, you may have the following rights:

• Right to Know and Data Portability: You have the right to request that we disclose certain information to you about our collection and use of your information over the past 12 months, which includes:

  • The categories of information we collect about you.

  • The categories of sources from which we collected information.

  • Our business or commercial purpose for collecting or selling (when applicable) that information.

  • The categories of third parties with whom we share information.

  • The categories of information about you that we disclosed for a business purpose, and the categories of service providers to whom disclosed that information for a business purpose.

Additionally, you may request that we provide the specific pieces of information we collect about you in a portable format.

• Right to Delete: You have the right to request that we delete any of your information that we have collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the information, provide the services you have requested, or take actions reasonably anticipated within the context of our ongoing business relationship.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Enable (internal only) uses that are reasonably aligned with consumer expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify your information not subject to the one of the foregoing exceptions from our records and will direct our service providers to take similar action.

• Right to Correct: You have the right to request correction of any inaccurate information we hold about you.

• Right to opt-out of a sale: You have the right to opt-out of our sale or our use of information for targeted advertising purposes.

• Right to receive notice: You have the right to receive notice of our practices at or before collection of information and you have a right not to receive discriminatory treatment for exercising any of your rights described under this section. We will not discriminate against you based on your exercise of any of your rights.

Depending on your state of residency, you may be limited to the number of free requests you can make in a 12-month period. If you exceed the number of requests allotted under the applicable state law, we reserve the right to charge a reasonable fee to respond to your request.

If you wish to exercise any of your rights, requests should be submitted in writing via email to privacy@learniture.com. If you reside in a jurisdiction that recognizes the ability to use an authorized agent, the authorized agent can submit a request on your behalf to privacy@learniture.com, with the completed authorized agent form.

If you are in a jurisdiction that recognizes your ability to appeal a decision we have made in connection with your attempt to assert a right under any applicable U.S. State Privacy Laws, you may file an appeal of our decision refusing your request to exercise your rights under this Privacy Notice per the instructions provided in our written decision. Requests to change our policies or practices are not grounds for an appeal.

CALIFORNIA SHINE THE LIGHT LAW

California residents may opt out of the sharing of personal information (as defined by California’s “Shine the Light law”), with third parties for their own direct marketing purposes. California residents may opt out and/or request for an accounting of what third parties we have shared your personal information with. This right is in addition to and different than rights granted to California residents pursuant to the California Consumer Privacy Act (CCPA). California residents exercising their Shine the Light rights should mail requests to our address identifying the request as a Shine the Light Request and include a statement attesting to your California residency.

CANADA (PIPEDA)

If you are a user in Canada, you are afforded specific rights regarding your information. You can make any of the following requests, and we will respond to your request as soon as possible, and in any event, no later than thirty (30) days after receipt, unless we notify you otherwise.

• Right to Know. You have the right to request that we disclose certain information about our collection and use of your information, including:

  • The information we collected about you,

  • Where the information was obtained from, and

  • How the information is or has been used and who it has been disclosed.

• Portability. Upon request, and when possible, we can provide you copies of your information. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Notice, which include withdrawing your consent (resulting in deleting your account and any associated information). Where applicable, we will ensure such changes are shared with any trusted third parties.

• Correction. If any of your information is incorrect, you may change or request that your information be corrected by submitting a request as described below. Where applicable, we will ensure such changes are shared with any trusted third parties.

• Deletion. If you wish to cease use of your account and have your information deleted from our Services, please notify us at privacy@learniture.com. We will confirm receipt and erase your information (and delete your account and any associated information). Where applicable, we will ensure such changes are shared with any trusted third parties. We may refuse to provide information in the event; we cannot confirm your identity or you fail to provide information necessary for us to locate your information, for situations in which searching for and providing your information is prohibitively costly, where the information contains references to other individuals, or when information cannot be disclosed for legal, security, or commercial proprietary reasons.

SUBSCRIPTIONS AND ACCOUNT INFORMATION

At any time, you can review and modify the information you have given us during your account registration process, via your account page.

If you would like to receive emails that feature our products, specials and other information we think you might find useful, select the “Subscribe” box when you create your account. You may subscribe or unsubscribe at any time by logging into your account and clicking “Edit Account.”

COOKIES

By using our Site and Services, you consent to our use of Cookies and other similar technologies. A cookie is a small file that our web server sends to your device (computer, tablet, mobile phone, etc.) when you visit our Site. It is stored as a text file on your hard drive so we can access it when you visit us again. Cookies contain information that identifies you to our Site, so you don't have to reenter your information every time you visit. This helps us personalize your shopping experience and gives you easy access to your online shopping account.

First-Party and Third-Party Cookies

Cookies on our website can be categorized as first-party or third-party:

First-Party Cookies: These are cookies that are set directly by our website when you visit it. They help us understand your preferences and provide a smoother experience on our site.

Third-Party Cookies: These cookies are set by entities other than our website, such as technology providers like Google or social media platforms like Facebook. We collaborate with these third parties to enable their cookies on our site, which helps us understand how you interact with our content and tailor our services to better suit your needs. Such third-party cookies may also enable targeted advertising on other platforms you visit, potentially leading to personalized ads based on your interests.

Persistent and Session Cookies

Session Cookies: These cookies are temporary and only exist for the duration of your visit to our website, disappearing when you close your browser. They help maintain security and ensure smooth navigation during your session.

Persistent Cookies: These cookies remain on your device beyond a single session and will stay until they expire or you delete them. They remember your preferences and actions across multiple visits, enhancing convenience but also enabling tracking activities over time. Because they can collect data across different websites and sessions, they are often used for more extensive tracking and personalization efforts.

Types of Cookies We Use

Essential Cookies: These cookies are necessary for our website to function properly. They enable you to move around the site and use its features, such as accessing secure areas.

Performance Cookies: These cookies collect information about how you use our website, like which pages you visited and which links you clicked on. None of this information can be used to identify you. It is all aggregated and, therefore, anonymized. Their sole purpose is to improve website functions.

Functionality Cookies: These cookies allow our website to remember choices you make (such as your user name, language, or the region you are in) and provide enhanced, more personal features.

Advertising Cookies: These cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share that information with other organizations or advertisers.

Managing Your Cookie Preferences

How to Block Cookies

You can configure your web browser to block cookies if you prefer not to accept them. However, please be aware that blocking cookies might affect the functionality of many websites. Here are instructions for common browsers:

• Google Chrome: Go to "Settings" > "Privacy and security" > "Site settings" > "Cookies and site data." From here, you can toggle on "Block all cookies."

• Mozilla Firefox: Open "Menu" > "Options" > "Privacy & Security." Under "Cookies and Site Data," click "Block cookies and site data."

• Safari: Go to "Safari" > "Preferences" > "Privacy," then choose "Block all cookies."

• Microsoft Edge (formerly Internet Explorer): Click on "Settings" > "Privacy, search, and services," scroll to "Clear browsing data," and then select "Choose what to clear."

How to Delete Existing Cookies

If you wish to remove cookies that have already been stored on your device, you can do so using your browser’s settings. Here are the steps for the same browsers:

• Google Chrome: Navigate to "Settings" > "Privacy and security" > "Clear browsing data." Choose "Cookies and other site data" and then hit "Clear data."

• Mozilla Firefox: Click "Menu" > "Options" > "Privacy & Security." Under "Cookies and Site Data," click "Clear Data."

• Safari: Go to "Safari" > "Preferences" > "Privacy," then click on "Manage Website Data" and "Remove All."

• Microsoft Edge (formerly Internet Explorer): Go to "Settings" > "Privacy, search, and services," under "Clear browsing data," click on "Choose what to clear," then select "Cookies and other site data" and click "Clear now."

Please note that if you choose to disable cookies, some areas of our website may not work properly.

Analytics:

We use various service providers to help analyze how people use our Site. These service providers use cookies and similar technologies to collect information pertaining to how you use our Site. We use the information we get from these service providers to improve our Site and Services. Some of these service providers and more specifically items we track include:

• Learniture uses a third-party tool to record visitor sessions to the site. A session recording allows us to track a visitor's browser and device type, mouse movements and clicks, form completions, and key site events like purchases and chat conversations. We use this data to further optimize the look, function and content of our site and improve your shopping experience. However, we respect your right to control the data that is collected about you. To opt out of our data collection, visit  https://mouseflow.com/opt-out/.

• Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy.

Some mobile and web browsers transmit “do not track” signals, which send a signal to websites visited by you about your browser’s do not track preference settings. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of their existence. Our Site is not currently configured to alter its behavior or respond to “do not track” signals, or other mechanisms that may allow you to opt out of the collection of your information across websites.

CHILDREN’S INFORMATION

We do not intend for our Site to knowingly collect or solicit any information from anyone under the age of 18 or knowingly allow minors under the age of 18 to disclose their personal information to use through our Site. Our Site and Services are directed to individuals who are 18 years of age and older. If you are a parent or guardian and believe that we might have any information about your child who is under the age of 18, please contact us.

RETENTION, SECURITY, INTEGRITY

We only retain information for as long as reasonably necessary, and for the purposes set out herein, and in accordance with applicable law. We will maintain security measures to safeguard your information from loss, theft, interference, misuse, unauthorized access, disclosure, alteration, and/or destruction. However, no data storage system or transmission of data over the internet or any other public network can be guaranteed to be 100% secure, accurate, complete, and/or current. Information collected by third parties may not have the same security protections and we are not responsible for protecting the security of such information.

CHANGES TO OUR NOTICE

We reserve the right to modify our Privacy Notice at any time, so please review it frequently. We will post any changes here, on our homepage and in other appropriate places so you'll always know what information we collect, how we keep it safe and under what circumstances we share it. If we make material changes to our Notice, we will notify you here, by email or by means of a notice on our homepage.

CONTACT INFORMATION

Learniture
3736 Regent Ave., Cincinnati Ohio 45212
Phone: 1-866-619-1776
Email: privacy@learniture.com.