Skillsoft Privacy Policy and Cookies Statement

Last Updated: October 31, 2014

1. OUR COMMITMENT TO YOUR PRIVACY

TRUSTe European Safe Harbor certification

Skillsoft Corporation is a wholly-owned subsidiary of Skillsoft Limited and is the entity that primarily controls the Web Site. Skillsoft Limited and its subsidiaries and affiliates ("Skillsoft") are committed to respecting your privacy. This privacy policy and statement of cookie use (the "Privacy Policy") discloses our privacy practices and expresses our commitment to keeping you informed of the information we collect and how it is used. We ask that you take time to read it carefully. We may update this Privacy Policy from time to time to reflect new uses, rules, regulations or technologies that impact your privacy. We recommend that users review our Privacy Policy on a routine basis to view any changes. This Privacy Policy will be continuously assessed against new technologies and business practices. This Privacy Policy applies to and governs data collection and usage at www.skillsoft.com, including the content, features, and any microsites, blogs and discussion groups that are a part of www.skillsoft.com (the "Web Site"). The Web Site includes certain pages hosted by third party service providers, which are branded to look like www.skillsoft.com and collect personally identifiable information and perform other tasks on behalf of Skillsoft ("Branded Sites"). These Branded Sites are governed by this Privacy Policy unless indicated otherwise on the Branded Site. Please read this Privacy Policy in its entirety. IF YOU DO NOT AGREE WITH OUR PRIVACY POLICY, THEN DO NOT USE THIS WEB SITE. This Privacy Policy is incorporated into the terms of use for the Web Site www.skillsoft.com/terms.asp.

Skillsoft has received TRUSTe's Privacy Seal signifying that this privacy statement and our practices have been reviewed for compliance with the TRUSTe program viewable on the validation page available by clicking the TRUSTe seal.

The TRUSTe program certification is limited to only that personally identifiable information collected through Skillsoft.com.

Skillsoft complies with the U.S. - E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of data from the European Union and Switzerland, respectively. Skillsoft has certified that it adheres 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 and to view Skillsoft's certification please visit: http://www.export.gov/safeharbor/.

2. THE INFORMATION WE COLLECT AND HOW IT IS USED

You make the decision whether or not to proceed with any activity that requests personally identifiable information, but please be aware that if you choose not to provide the information requested, you may not be able to complete certain transactions with Skillsoft.

Sometimes, such as when you register for a service, order a product or make other requests or inquiries, we will ask for specific information about you in order to provide that product or service to you or respond to your requests or inquiries. We may collect certain personally identifiable information such as contact information, including name, e-mail address, work and home telephone numbers, fax number and a physical postal address. We may also collect information regarding your personal or professional interests, demographics, past experience with Skillsoft products and services, detailed contact preferences or other personally identifiable information. We may use any information that we collect, including personally identifiable information, to tailor subsequent communications to you, including marketing and promotional communications, to administer and operate the Web Site and our business and to provide and continually improve Skillsoft offerings. We may also share information that we collect, including personally identifiable information, with resellers or other third parties in order to market Skillsoft products and/or services to you. We do, however, provide our users a choice as to whether or not they would like to receive marketing or promotional communications. Please see Section 3, Choice.

Users may from time to time receive up-to-date information on products and services via our e-mail newsletter. Users may opt-out at any time from receiving these communications. Please see Section 3, Choice.

We may also periodically conduct business and individual user surveys because they provide us with important information that helps us to improve our products and services. Participation in such surveys is completely voluntary and you, therefore, have a choice whether or not to disclose this information.

Data you submit online may also be combined with other information you provide through other means of communication, such as postal mail.

As is true of most web sites, we gather certain information automatically and store it in log files. This information includes Internet protocol (IP) addresses, browser type, referring pages, date/time stamp and click stream data. We use this information, which does not identify individual users, to analyze trends, to administer the Web Site, to track users' movements around the Web Site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information.

Our Web Site includes social media features, such as the Facebook "Like" button Widgets and the "Share" button. These features may collect your IP address, which page you are visiting on our Web Site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Web Site. Your interactions with these features are governed by the privacy policy of the company providing it.

We provide online training services to employers and individuals through our Skillport training portal. This Privacy Policy does not apply to information collected through the Skillport training portal, which is instead governed by a separate Skillport privacy policy found at http://www.skillport.com/skillport_privacy_policy.html.

A SPECIAL NOTE ABOUT COOKIES

Some pages of the Web Site use cookies. Cookies are small pieces of software which are issued to your computer or device and which store and sometimes track information about your use of the site. Our cookies are not used to collect or store personally identifiable information. By using the Web Site you consent to our use of cookies as explained below.

Most of our cookies are necessary for operation of the Web Site or service that you request as a user of the Web Site, such as to remember text you may have entered when you navigate back to a page in the same session. We also use cookies to provide optional features and functionality that you may access on the Web Site. For example, a cookie can help us identify whether you have downloaded software in the past that allows you to access a white paper so that you won't have to download it again. We use cookies to customize and personalize the Web Site based on preferences you may have expressed either directly by selecting an option or setting or indirectly by your prior use. We also use cookies that collect information about how you use the Web Site to analyze and optimize the performance of the Web Site in order to give you a better user experience. In some cases, particularly with respect to measuring and analyzing performance of the Web Site, cookies may be placed by our third party service providers.

We and our third-party marketing and analytics providers may also employ web beacons or clear gifs (a.k.a. web beacons/web bugs), images and scripts that help better manage content on the Web Site. Web beacons are tiny, clear graphics that are embedded invisibly on web pages. They are used to understand and monitor online movements of users so that we may better understand and improve their experiences on the Web Site. In contrast to cookies, which are stored on a user's computer hard drive, web beacons are not stored on a user's computer or device. We do not tie the information gathered to your personally identifiable information.

We partner with third party ad networks to either display our advertising on our Web Site or to manage our advertising on other sites. Our ad network partners use cookies, scripts, tags and web beacons to collect non-personally identifiable information about your activities on this and other web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking: http://preferences.truste.com/. European Union users may obtain additional information about online behavioral advertising and how to opt-out by clicking: http://www.youronlinechoices.eu/. Please note this does not opt you out of being served advertising, which means that you will continue to receive generic ads.

When you click on a link to an external web site or third party resource (including embedded widgets similar those provided by Facebook and Twitter), the third party may place a cookie from its own site. Skillsoft does not control the dissemination of these cookies. You should check the relevant third party web site for more information about these cookies.

Like other aggregated information from the Web Site that does not identify individual Users, we may analyze and share non-personally identifiable information collected through cookies with Skillsoft subsidiaries, affiliates, and third parties, including our business partners and service providers, and in marketing materials and public disclosures.

Most web browsers automatically accept cookies but, if you prefer, you may take certain steps to control the use of cookies by modifying your browser to reject cookies or to notify you whenever a cookie is sent to your hard drive. You can learn more about cookies and ways to manage them at http://www.allaboutcookies.org/. Please be aware that restricting cookies on the Web Site may impact the functionality and performance of the site.

3. CHOICE

We may use your personally identifiable information for purposes not directly related to products and/or services you have requested or other requests or inquiries you have made, such as to send you e-mail communications, Skillsoft's newsletter, information on new products or offers and information from Skillsoft's partners unless you direct us not to do so by opting-out at the point where the information is collected. Additionally, you may opt-out from use of your personally identifiable information collected online for the purpose of sending such marketing or promotional communications at any time by going to our e-mail preferences page located at http://www.skillsoft.com/email_prefs.asp, sending an e-mail to information@skillsoft.com or by following the unsubscribe instruction contained within each of the newsletters or promotional communications you receive.

We will retain your information for as long as needed for the purposes for which it was collected, and in accordance with our retention policies, as applicable. We will retain and use your information as appropriate to comply with our legal obligations, resolve disputes, and enforce our agreements.

4. SHARING OF INFORMATION

Unless Skillsoft has your permission or is required by law, or except as otherwise set forth in this Privacy Policy, Skillsoft will not sell, rent or lease your personally identifiable information to others, except in order to provide you with the products and services you request. Skillsoft will only share the personally identifiable information you provide online with other Skillsoft affiliates, resellers or other marketers of Skillsoft's products, Skillsoft's partners and/or service providers who may be used to ship products, provide technical support, handle order processing, or otherwise act on Skillsoft's behalf for the purpose of marketing and providing Skillsoft products and services, administering and operating the Web Site and our business and sending marketing and promotional communications. Skillsoft may also share your information with its affiliates so that they may provide you with information about their own products and services and for other marketing and promotional purposes.

Please remember that when you submit information to a discussion group or some other public or online forum, the information submitted will be deemed public information and will not be considered confidential or treated by Skillsoft as other personally identifiable information you specifically provide to Skillsoft, which is subject to this Privacy Policy. To request removal of your personally identifiable information from our blog or community forum, contact us at http://www.skillsoft.com/email_prefs.asp. In some cases, we may not be able to remove your personally identifiable information, in which case we will let you know if we are unable to do so and why.

We may share or disclose your personally identifiable information if such disclosure is necessary to: (a) comply with legal process (such as a court order) or other legal requirements of any governmental authority; (b) protect our rights or property; (c) protect the interest of users of the Web Site, other than you, or any other person; or (d) operate or conduct maintenance and repair of our services or equipment, as authorized by law.

Notwithstanding the foregoing, Skillsoft may transfer, sell or assign information concerning your use of this Web Site, including without limitation, personally identifiable information, to third parties, as a result of the sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or liquidation of Skillsoft. In the event of such transfer, sale or assignment, notice will be given in accordance with Section 8, Notification of Changes, below.

5. LINKS

Skillsoft may provide you with links to other websites that may be operated by companies not affiliated with Skillsoft. Please be aware that Skillsoft is not responsible for the privacy practices or the content of such websites. Skillsoft does not endorse them or make any representations about them or any information, services, products or materials found on them. Linked websites may have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of any websites that are not affiliated with Skillsoft, any use of those websites, or the privacy practices of those websites.

6. DATA TRANSFER AND SECURITY

We may transfer the personally identifiable information we collect about you to countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Policy and in accordance with applicable law.

We will take steps intended to safeguard personally identifiable information stored on our systems from unauthorized access or disclosure. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot ensure or warrant the security of any information you transmit to us or from our online services, and you do so at your own risk.

7. HOW TO ACCESS AND CORRECT YOUR INFORMATION

Skillsoft strives to keep your personally identifiable information accurate and up-to-date. Should you find inaccuracies in your personally identifiable information and wish to amend, correct or delete the same, please contact us through one of the communication methods described below in Section 12, Contacting Us. To the extent required by applicable law, Skillsoft will respond to requests to update personally identifiable information within 30 days of the reception of the request.

To opt out of all future marketing and promotional correspondence from Skillsoft, please update your e-mail preferences at http://www.skillsoft.com/email_prefs.asp or follow the unsubscribe instructions contained in the e-mail communications you receive. To the extent required by applicable law, your request will be met within 10 business days.

8. NOTIFICATION OF CHANGES

Skillsoft reserves the right to make changes to this Privacy Policy. If we make a material change to this Privacy Policy that results in the use of personally identifiable information that is inconsistent in material respects with the practices described at the time of collection, we will notify you and provide you with the choice as to whether or not you will allow us to use your information in this different manner. In the event there is a material change in our privacy practices that does not affect user information already stored in our database, a notice will be posted on our Web Site notifying all users of the change.

9. CHILDREN

Skillsoft does not knowingly collect personally identifiable information from users under the age of 13. Children under 13 should not send any information about themselves to Skillsoft. If a child under 13 submits information through any part of the Web Site, and Skillsoft becomes aware that the person submitting the information is a child, we will attempt to delete this information as soon as possible.

10. (FOR CALIFORNIA RESIDENTS) CALIFORNIA PRIVACY RIGHTS

California law gives California residents the right to ask us for a notice describing the categories of personally identifiable information we share with third parties or affiliates for their direct marketing purposes. The notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it has been shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please contact us through one of the communication methods described below in Section 12, Contacting Us. Please allow 30 days for a response.

11. ACCEPTANCE OF PRIVACY POLICY

By using the Web Site, you signify your assent to our Privacy Policy. If you do not agree with this Privacy Policy, please do not use our Web Site. Your continued use of this Web Site following posting of changes to these terms will mean you accept those changes.

12. CONTACTING US WITH COMMENTS AND CONCERNS

We welcome your comments. Should you have any questions or concerns about our Privacy Policy, please contact us: via e-mail at support@skillsoft.com, by telephone at (866) 754-5435, or by mail to: Skillsoft, Attn: Skillsoft Legal Department, 107 Northeastern Boulevard, Nashua, NH 03062. If you have any questions or concerns about personally identifiable information with regards to employment applications please contact our human resources department by telephone at (603) 324-3001 extension 3312.

If you feel that Skillsoft is not abiding by this Privacy Policy, you should first contact us by the means listed above. If your inquiry has not been satisfactorily addressed, you should then contact TRUSTe at https://feedback-form.truste.com/watchdog/request. TRUSTe will then serve as a liaison with the Company to resolve your concerns.

Last Updated: October 31, 2014