Privacy Policy and Cookies Statement

Learnexus (“We” or “Company”) are committed to protecting and respecting your privacy.

This privacy statement (together with our terms and conditions and any other policies referred to in it) explains what information we gather about you when you visit the website https://learnexus.com (our “Website”), what and how we use that information, the legal basis for the way in which that information is used and who we give that information to. It also sets out your rights and our obligations in relation to your information and who you can contact for more information or queries.

Who does this apply to and who does it cover?

This privacy statement sets out how we will collect, handle, store and protect information about you when providing services to you or our clients or performing any other activities that form part of the operation of our business, Learnexus.

This privacy statement also contains information about when we share your personal information with other members of our group and other third parties (for example, third parties carrying out due diligence activities on our behalf).

In this privacy statement, your information is sometimes called “personal data” or “personal information”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.

This policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website.
• Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
• Any other sources.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to our privacy statement). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

We understand the importance of protecting children's privacy. Our website is not designed for, or intentionally targeted at children under 18. It is not our policy to intentionally collect or store information about children.

No one under age 18 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at our website.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California privacy rights for more information.

We may collect and process personal data about you because you give it to us, because other people give that data to us (for example, third party service providers that we use to help operate our business) or because it is publicly available.

The personal data that we collect or obtain may include: your name; age; date of birth; gender; gender identity; e-mail address; home address; country of residence; lifestyle and social circumstances (for example, your pastimes); employment and education details (for example, the organization you work for, your job title and your education details); your IP address; your browser type and language; your access times; complaint details; details of how you use our products and services; details of how you like to interact with us and other similar information.

You provide information to us by filling in forms on our website. This information may include information provided at the time of registering, subscribing to any of our services, posting material, sending messages and posting in the Platform, making or receiving payments through your Learnexus User Account or requesting further services.

Details of transactions you carry out via our website.

We may ask you for information when you report an issue or concern, or we have or receive a complaint or query about you (whether or not a formal Dispute is raised). Such information includes:

1. Information you provide to us by filling in forms on our website. This information may include information provided at the time of registering, subscribing to any of our services, posting material, sending messages and posting on the Platform, giving reviews, making or receiving payments through your Learnexus User Account or requesting further services;
2. Details of transactions and projects you carry out via our Website;
3. Information we ask for when you report an issue or concern, or we have or receive a complaint or query about you (whether or not a formal dispute is raised);
4. A record of correspondence between you and us;
5. Information gathered when we ask you to complete wholly voluntary surveys that we use for research purposes;
6. Details of the messages you send and receive using the Platform including without limitation when you sent or received a message and the contents of that message. Messages are not private and are not confidential.

We may collect and process personal data about you from other sources as follows:

1. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website, and Information about your computer and internet connection, including your IP address, operating system, and browser type. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
2. We sometimes supplement the information that you provide with information received from third parties. For instance, credit reference agencies, search information providers, PayPal, other companies (subject to their privacy policies and applicable law), and from other accounts we have reason to believe you control (whether in part or in whole);
3. Where we are provided with personal data about you by any third party such as a service provider, we take steps to ensure that that third party has complied with the privacy laws and regulations relevant to that information. Learnexus may use your personal data to gather feedback regarding your experience you may have with our platform. This helps our business grow by assembling useful information from our end-user;

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics.
• Google Analytics. Our website uses a tool called Google Analytics, which collects user information regarding the activities that users engage in while on the website. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics to improve this site and our outreach efforts.
• Google Ads & Remarketing. We use a tool called "Google Ads" to collect information about the use of this site and use this information to serve you more relevant advertisements ("Retargeting"). You may opt-out of Google's use of cookies by visiting Google's Ads Settings page.
• Facebook Tracking Pixel. We may use the "conversion tracking pixel" provided by Facebook to record the efficacy of Facebook's advertisements and for additional market research purposes.
• Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the website, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third-party service provider, is active only while you are connected to our site and is deactivated or deleted thereafter.

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources, or you provide to us.

Third-party use of cookies and other tracking technologies

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Freelancer data

We collect personal data about our prospective, current and former freelancers (including contingent workers, providers and interns) as follows: basic identification information, such as your name, title, position, professional history, experience, and contract details.

For current employees, we usually collect in addition to the above:

1. Detailed identification information including passport numbers, right to work documentation, private email and/or postal address and country of residence;
2. Electronic identification data (e.g. email address, login information, badge number, online identifiers/cookies, log files, connection time);
3. Education and employment information (e.g. remuneration, bonuses, insurance and other benefits information, employment dates, position information such as title, attendance information including, where relevant, illness or leaves of absence for medical or other reasons, language skills and education details, pensions information including entitlements and recruitment information including job applications, CVs, job history and references);
4. Financial information (e.g. bank account details, and tax-related information);
5. National registry number, social security number or local equivalent;
6. In some cases, the personal data we collect may also include so called 'sensitive' or 'special categories' of personal data, such as details about your: dietary requirements, health (for example, so that we can make reasonable accommodations for you in our buildings, products and services) and sexual orientation (for example if you provide us with details of your spouse or partner); and
7. The types of personal data and special categories of personal data that we collect may vary depending on the nature of the services that we provide to you. In some rare circumstances, we might also gather other special categories of personal data about you because you volunteer that data to us, or we are required to gather that data as a result of legal requirements imposed on us.

We will use your personal data to fulfill your requests and we will ask only for data that is adequate, relevant and not excessive for those purposes. Where we send you information for any purpose, it may be sent by e-mail or post. When we ask you for personal data it may be used for the following purposes:

1. We may contact you occasionally to inform you of new products and services we will be providing;
2. We may send you regular updates on issues we think will be of interest to you;
3. We may send you requested information on our products and services;
4. We may use your personal data for marketing purposes and market research;
5. We may use your personal data internally to provide you with the services offered by us via this website, to administer this website and to help us improve our services;
6. We may use your personal data for managing and making information available to third party service providers (e.g. providers of due diligence services or in order to support our information technology) and our affiliates;
7. We may use your personal data to allow you to participate in interactive features of our service when you choose to do so;
8. We may use your personal data to notify you about changes to our services, terms and conditions, policies or website;
9. We may use your personal data to manage risk, or to investigate, detect, prevent, and/or remediate fraud, suspected fraud or other potentially illegal or prohibited activities;
10. We may use your personal data pursuant to applicable legal or regulatory requirements or to respond to requests and communications from competent authorities (including courts and tribunals);
11. We may use your personal data for the services we receive from our professional advisors, such as lawyers, accountants, and consultants; and
12. We may use your personal data for protecting our rights, those of our clients, or protecting those of our affiliates.

None of the information that we request from you is mandatory. However, where such information is not provided to us, Learnexus may be unable to identify, protect, or return your money or assets.

We are not allowed to process personal information if we do not have a valid legal ground for doing so. Therefore, we will only process your personal information for the purposes outlined above because:

1. Of our legitimate interests in the performance of activities that form part of the operation of our business;
2. Of our legitimate interests in the effective and lawful operation of our business so long as such interests are not outweighed by your interests or fundamental rights and freedoms;
3. Of the legal and regulatory obligations that we are subject to, such as keeping records for tax purposes or providing information to a public body or law enforcement agency; or
4. The information is required in order to carry out the activities that form part of the operation of our business (e.g. the processing is necessary to perform our contractual obligations towards you).

Examples of the ‘legitimate interests’ referred to above are:

1. To benefit from cost-effective services (e.g. we may opt to use certain IT platforms offered by suppliers);
2. To verify the accuracy of information provided by a third party;
3. To prevent fraud or criminal activity;
4. To safeguard the security of our IT systems, architecture and networks, and of our physical premises; and
5. Our freedom to conduct a business and right to property.

To the extent that we process any sensitive personal data relating to you for any of the purposes outlined above, we will do so because either: (i) we are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti money laundering’ obligations (or other legal obligations imposed on us); (ii) the processing is necessary to carry out our obligations under employment, social security or social protection law; (iii) the processing is necessary for the establishment, exercise or defense of legal claims; or (iv) you have made the data manifestly public.

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

California residents may have additional personal information rights and choices. Please see Your California privacy rights for more information.

We may, from time to time, e-mail or post you information to make you aware of our other similar products and services which may be of interest to you. If you do not wish to receive emails or post from us for these purposes, or if you want to be removed from our electronic mailing list you can either select “unsubscribe” from any of the marketing emails that we send or alternatively contact us.

In addition to the information we collect as described above, we use technology to collect anonymous information about the use of our website. For example, our web server automatically logs which pages of our website our visitors view, their IP addresses and which web browsers our visitors use. This technology does not identify you personally, it simply enables us to compile statistics about our visitors and their use of our website.

Our website contains hyperlinks to other pages on our website. We may use technology to track how often these links are used and which pages on our website our visitors choose to view. Again, this technology does not identify you personally — it simply enables us to compile statistics about the use of these hyperlinks.

This website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party websites or any association with their operators. We do not control these websites and are not responsible for their data or privacy practices. We urge you to review any privacy policy posted on any site you visit before using the site or providing any personal data about yourself.

In order to collect the anonymous data described in the preceding paragraph, we may use temporary “cookies” and similar technologies (e.g. web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) that remain in the cookies file of your browser until the browser is closed. For example, we use Google Analytics to help us take and analyze visitor information such as browser usage and new visitor numbers. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited. Please note that the names of cookies, pixels and other technologies may change over time.

Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to your browser and stored on your computer's hard drive. Cookies do not damage your computer. You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. We also use your IP address to help diagnose problems with our server and to administer our website. An IP address is a numeric code that identifies your computer on a network, or in this case, the internet. Your IP address is also used to gather broad demographic information. Cookies are useful because they allow a website to recognize a user's device, preferences and generally help to improve your online experience. You can find more information about cookies at: www.allaboutcookies.org.

By using our website, you agree that we can place cookies on your device. If you want to restrict or block any cookies, you should do this through the web browser settings for each browser you use and on each device you use to access the internet. Please be aware that some areas of our website may not function if your web browser does not accept cookies. However, you can allow cookies from specific websites by making them “trusted websites” in your web browser. The “Help” function within your web browser should tell you how to make these changes.

Find out how to manage cookies on popular browsers:

Our website may also contain plugins and other features that integrate third party social media platforms into our website so that we can improve our offer and make it more interesting for you as a user. You will be able to activate them manually. If you do so, the third-party companies who operate these platforms may be able to identify you, they may be able to determine how you use this website and they may link and store this information with your social media profile. Please consult the data protection policies of these social media platforms to understand what they will be doing with your personal data. If you activate these plugins and other features, you will be doing so at your own risk as we do not have any influence on the data collected and data processing operation, nor are we aware of the full extent of data collection, the purposes and the storage periods.

In connection with one or more of the purposes outlined in the “Use of personal data” section above, we may disclose details about you to: our affiliates; third parties that provide services to us and/or our affiliates, such as our lawyers; competent authorities (including courts and supervisory or other authorities); your advisers or where applicable, your employer; credit reference agencies or other organizations that help us make decisions and reduce the incidence of fraud; and other third parties that reasonably require access to personal data relating to you for one or more of the purposes outlined in the “Use of personal data” section above.

Where you have chosen to connect your Learnexus account to your Facebook or LinkedIn account we may share, disclose, and transfer personal data to Facebook or LinkedIn, as applicable. This permission will be requested when you connect your accounts. If you have given this permission, you may then disable this function at any time by changing your Facebook, LinkedIn or Learnexus account settings (as applicable).

Where appropriate, before disclosing personal data to a third party, we contractually require the third party to take adequate precautions to protect that data and to comply with applicable law.

Where you have consented, we may also share your personal data with other companies within our group of companies who may contact you about their products or services that may interest you.

Please note that some of the recipients of your personal data referenced above may be based in countries outside of the United States whose laws may not provide the same level of data protection. In such cases, we will ensure that there are adequate safeguards in place to protect your personal data that comply with our legal obligations.

All Learnexus personnel accessing personal information must comply with the internal rules and processes in relation to the processing of personal data to protect them and ensure the confidentiality of such information.

We have also implemented adequate technical and organizational measures to protect personal data against unauthorized, accidental, or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. These security measures have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of the personal information, with particular care for sensitive information.

Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect personal data, but we cannot guarantee the security of data transmitted to us or by us.

We will hold your personal data on our systems for the longest of the following periods: (i) as long as is necessary for the relevant activity (which is typically 7 years); (ii) any retention period that is required by law or regulation; or (iii) the end of the period in which litigation or investigations might arise in respect of our activities.

You have various rights in relation to your personal data. In particular, you have a right to:

1. Request a copy of personal data we hold about you;
2. Ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
3. Ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data;
4. Object to our processing of your personal data;
5. Ask that we restrict our processing of your personal data; and
6. Ask for the portability of personal data, that is, to receive the Personal Data you have provided to us in a structured, commonly used and machine-readable form and transmit it to another data controller.

To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact us.

You have the right to complain if you are unhappy with the way we handled your personal information or any privacy query or request you have raised with us. You also have a right to complain to a data protection authority in the place where you live or work, or in the place where you think an issue in relation to your data has arisen.

Our site is operated in the United States and intended for users located in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, processed, stored, and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be shared with third parties for direct marketing purposes and may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using our site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and third parties for marketing purposes and providing contact information for such affiliates and third parties. If you are a California resident and would like a copy of this notice, please email us at hello@learnexus.com. We will make every effort to promptly respond to your request.

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, please review our CCPA Privacy Notice for California Residents.

We may modify or amend this privacy statement from time to time.

To let you know when we make changes to this privacy statement, we will amend the revision date at the beginning of this page. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.

If you have any questions, comments or requests regarding this privacy statement contact us. Our e-mail address is hello@learnexus.com.

1. Information We Collect

Our Website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA's scope, like: health or medical information covered by HIPAA and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, our Website has collected the following categories of personal information from its consumers within the last twelve (12) months:

Our Website obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website.

2. Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, to respond to your inquiry, process your payment and facilitate delivery, or save your information to facilitate new product orders or process returns;
• To provide, support, personalize, and develop our Website, products, and services;
• To create, maintain, customize, and secure your account with us;
• To process your requests, purchases, transactions, and payments and prevent transactional fraud;
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law);
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business;
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• As described to you when collecting your personal information or as otherwise set forth in the CCPA; and
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

3. Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We share your personal information with the following categories of third parties:

• Service providers;
• Marketing agencies; and
• Data aggregators.

4. Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose.

5. Sales of Personal Information

In the preceding twelve (12) months, Company had not sold personal information.

6. Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

7. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; and
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

8. Other California Privacy Rights

California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to hello@learnexus.com.

9. Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

10. Contact Information

If you have any questions or comments about this notice, the ways in which Company collects and uses your information described here and in the Privacy Policy (see above), your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: