California Privacy Disclosure Notice

This notice describes the rights of Californians under the California Consumer Privacy Act of 2018 (CCPA).

We fully describe our privacy policy and practices in our Privacy Policy, which we ask you to read in conjunctions with this notice.

The four subjects discussed in this notice are:

1. we do not sell your personal information;

2. your rights under the CCPA;

3. categories of personal information we collect and the sources; and

4. categories of personal information we share for a ‘business purpose.

1. We do not sell your personal information

The CCPA requires us to disclose whether we sell your personal information. We do not sell your personal information.

2. Your rights under the CCPA

2.1 Requests for information

If you have a learning account with us, you can correct inaccuracies or update or add information yourself. Additionally, you can request us, via [email protected], for copy of your personal information. In our Privacy Policy, we discuss the kinds of personal information we collect and why and how we collect, use, share and secure that information.

Under the CCPA, you can also request that we disclose how we have collected, used and shared your personal information over the past 12 months, including the categories of personal information we collected and our purposes for doing so; the categories of sources for that information; the categories of third parties with whom we shared it for a business purpose and our purposes for doing so.

2.2 Your right to opt out of sales

As mentioned above, we do not sell personal information, so we don’t have an opt-out facility.

2.3 Your right to notification

We cannot collect new categories of personal information or use them for materially different purposes without first notifying you.

2.4 Non-discrimination for exercising your CCPA rights

The CCPA prohibits businesses from discriminating against you for exercising your rights under the law. Such discrimination may include denying services, charging different prices or rates for services, providing a different level or quality of products or services, or suggesting that you will receive a different level or quality of services as a result of exercising your rights. As mentioned in our Privacy Policy, you need to be aware that, without certain basic personal information, your access to and use of our products and services will be less than optimal.

2.5 Your right to delete personal information

You can delete your personal information by closing your account with us or by requesting that specific information be deleted via [email protected]. We will comply with your request unless we need the information and we are allowed to retain it under the CCPA, e.g. if we need the information:

• to complete a transaction or contract for which the information was collected; or
• when the information is being used to detect, prevent or investigate security incidents, comply with laws, identify and repair bugs or ensure another consumer’s ability to exercise their right to free speech or other rights provided by law; or
• for internal uses that are reasonably aligned with your expectations, based on your relationship with us or compatible with the context in which you provided the information.

3. Categories of Personal Information we collect and the sources

Our Privacy Policy describes the information we collect and its sources. This notice organises that information around the personal information categories set out in the CCPA.

CCPA Personal Information Category → Sources of this Information

• Identifiers (e.g., name, address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers) → Information you provide directly or through your interactions with our Services (as defined in our User Terms)
• Characteristics of protected classifications under California or Federal law (e.g., your gender or age) (“Characteristics of Protected Classifications”) → Information you provide to us directly and inferences we make based on that information
• Commercial information (e.g., information regarding products or services purchased, obtained or considered) → Information you provide to us directly, such as if and when you buy a Premium Subscription Your interactions with our Services Information from our affiliates (as defined at the beginning of our Privacy Policy)
• Internet or Other Electronic Network Activity Information (e.g., browsing history, search history and information regarding your interactions with our Services) → Your interactions with our Services
• Geolocation Data → Information you provide to us directly or through your interactions with our Services (e.g. if you use our Services from a mobile device, that device may send us data about your location based on your phone settings)
• Professional or Employment-Related Information → Information you provide to us directly Information from our Customers (i.e. your employer) or affiliates
• Inferences → Information you provide to us directly or through your interactions with our Services Information from our Customers (i.e. your employer) or affiliates
• Personal information described in Cal. Civ. Code §1798.80(e)(such as name, address, telephone number, education, employment history) → Information you provide directly or through your interactions with our Services Information from our Customers (i.e. your employer) or affiliates
• Audio, electronic, visual or similar information → Information you provide directly or through your interactions with our Services, Customers (i.e. your employer) or affiliates

We use your personal information for the purposes outlined in our Privacy Policy.

4. Categories of Personal Information we share for a ‘business purpose’

While we do not sell your personal information, we may share it to support our own operational purposes in providing Services to you, as described in our Privacy Policy. Examples of these operational purposes, known as ‘business purposes’, are repeated below.

• our course content providers may have access to names of learners enrolled in the providers’ courses;
• our distribution partners, who offer our content for sale through their own platforms or who otherwise integrate with our software, may collect and handle the same enrolment information as we do, as well as other information concerning the learning activities and course completion progress of learners in relation to courses that have been accessed via our distribution partners’ websites; and
• our implementation partners may have access to the information we collect for the purpose of assisting us and our distribution partners to develop our systems to offer and deliver our products and services.

If you have any questions about this notice, please send them to [email protected].