GranuLearn Privacy Notice

1. Personal Data We Collect

GranuLearn collects data from you, through our interactions with you and through our Site. You provide some of this data directly, and we get some of it by collecting data about your interactions, use, and experiences with our Site. The data we collect depends on the context of your interactions with us and the choices you make, including your privacy settings and the services and features you use. We also obtain data about you from third parties.

You have choices when it comes to the technology you use and the data you share. When we ask you to provide personal data, you can decline. Many of our services require some personal data to provide you with that service. If you choose not to provide data required to provide you with a service or particular feature, you cannot use that service or feature. Where providing the data is optional, and you choose not to share personal data, features like personalization that use such data will not work for you.

• Data you provide to us: This is personal information about you that you give us directly when you interact with us. You may give it to us by filling out a form on our Site, by corresponding with us by phone, e-mail, or at an in-person event, or through interactions in an GranuLearn sponsored forum. It includes information necessary to register or pay for a subscription or event, to complete your profile, or to place an order for other services we provide. It also includes information shared when you participate in a discussion board, share on social media via our Site, enter a competition or promotion, submit a query, report feedback about or a problem within our Site, or engage with any of the other Interactive Services (defined in the Terms of Use). When you create an account for our Platform, we require you to provide your first name, last name, and email address.

• Payment Processing: When you purchase a subscription, you will need to provide payment and billing information, often including an address and credit card information. Such payment details you provide in the designated checkout page on our Site will be encrypted using the Transport Layer Security (TLS) protocol before they are submitted to us over the internet. Such data is then transmitted directly to our third-party payment and subscription processors and is not within ansrsource’s control. In such cases, this Privacy Notice will not apply, and the use and privacy terms of the third-party payment and subscription processors will apply.

• Data we collect about you from your use of our Site: We will automatically collect information from you each time you visit our Site whether or not you enter the Site as a registered user. This includes technical information, information about your visit, and information about your activity on our Site such as courses searched and viewed, page response times, download errors, length of visit to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), methods to browse to and away from a page, and methods used to contact our sales and support teams. Technical information may also include the internet protocol (IP) address used to connect your device to the internet, unique device identifiers, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating systems, and device platform.
• Data we receive from other sources: This is information we receive about you from third parties that we work closely with to provide, promote, and improve our services. These third parties include business partners, vendors who assist in technical and payment services, advertising networks, analytics providers, and search information providers.

2. How We Use Your Personal Data

GranuLearn uses the personal information you provide in a manner that is consistent with this Privacy Notice as follows:

• Provision of Services: We use your personal information to provide you with our services through our Site, including services arising from any obligations set forth in an agreement between you and us. These services may include providing access to our course library, administration of your account, billing, and notifying you of changes to our service or your account. This data will also be used to allow you to participate in the interactive features of our Site, or to provide you with information you may have requested from us, including but not limited to access to whitepapers and webinars.
• Improvement of Services and Features: We use data to continually improve our Site, including by way of the addition of new content, features, or capabilities.
• Personalization: We use data to enhance the user experience based on prior interactions with our Site.
• Account Activation and Maintenance: Data such as device, network, and subscription identifiers are used to activate and maintain user accounts
• Support: We use your personal data to respond to your requests for assistance including password resets and general troubleshooting.
• Safety Security: We use data to protect the safety and security of our users and our Site. This includes using data to detect malware and malicious activities, and to monitor for violations of our terms of use.
• Communications: We will use your personal data to communicate with you regarding your account and your use of our Site.
• Marketing: We may use your personal data to provide you with information about our services that we feel may interest you and enhance your interaction with our Site. We will communicate with you about these goods and services via email, direct mail, telephone, or through our Site. These communications may include newsletters, promotional emails, or offers to participates in market research requests. We will use your information for this purpose only where you have given your consent to receive such marketing material from us at the point we collect your information, or where you have otherwise consented to receive such marketing material including by way of your selection of marketing preferences in your individual profile, and in accordance with local law.
• Prize Promotions and Events: : We will use your data to administer prize promotions and events where you have consented to participate. For example, we may provide your contact information to a third party that would issue a gift card or other prize
• Reporting and Business Operations: We will use personal data in our legitimate interests (where we have considered that such interests do not override your individual rights), to administer our Site, and for internal operations, including troubleshooting, data analysis, testing, research, statistical survey purposes, and reporting on our performance. We will also use this data for measuring the effectiveness of how we present content and for assessing the effectiveness of content. We use internet protocol (IP) addresses and non-personally identifiable information in our log files to analyze trends, to administer our Site, to track users’ movements in and around our Site, and to gather demographic information about our user base as a whole. We also utilize unstructured machine learning technologies to understand user behaviors in order to provide user-specific recommendations and other personalization of our Site experienc
• Legal Compliance: We process personal data to comply with various laws. For example, we may process your personal data to assist you with exercising your individual privacy rights or to report any prizes or awards to an applicable taxing authority.

3. Reasons We Share Personal Data

We will take reasonable steps to ensure that we only disclose that personal data that is relevant for the purposes for which it is to be used. Furthermore, we will not process your personal data in a way that is incompatible with these purposes.

• Use of Personal Data by GranuLearn Affiliates: GranuLearn affiliates will process your personal data in order to provide you with support and other services. ansrsource’s affiliates can be found on our Website.
• Engagement with GranuLearn Suppliers: We sometimes retain third parties to perform certain business-related functions such as sending email on our behalf, payment processing, or conducting market research. We also share your email address with third parties such as Facebook, LinkedIn, and Twitter in order to provide custom marketing materials for you on their platforms. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. These third parties are not permitted to use your personal information that we share with them for any purpose other than as required for them to provide services to us. ansrsource’s sub-processors can be found on our Website.
• Engagement With Technology Vendor: We also share user engagement information with third parties derived from our Platform. For example, when you view a course related to a specific technology vendor, we share information such as the number of course minutes viewed, Role and Skill IQ levels, hands-on course engagement, and other related data with that technology vendor. We share this information and receive feedback from those third parties in order to improve the content available on our platform and better collaborate with our partners to jointly help companies and individuals address their skill development needs. Unless we specifically ask for and you grant consent, the data we provide to technology vendors does not include personal data.
• Business Plans and Company Partnership Subscriptions: We partner with certain third parties to provide our services to their employees or their group members. As part of such partnerships, a third party may pay for the subscription for its employees or group members or otherwise contract with GranuLearn to make your subscription available to you, and GranuLearn may share information about your use of our services with the third party. If your subscription was provided by your employer or group sponsor (including Company Partnerships as defined in the Terms of Use), we may share information you provide, or information we may otherwise collect through your registration and use of our services, with such third party. This information may include course viewing history, course viewing time, course or assessment completion, course quality ratings and feedback, certifications, performance-related metrics, and other personal information. Your employer or group sponsor can control and administer your GranuLearn subscription. Please Note: If you lose access to your employer or group sponsored account, you will lose access to the services and your data associated with the services, including that which you may have acquired on your own behalf through an individual user account if you used your employer or group sponsored account or email address to register for or to sign into your account. To prevent this from occurring, it is suggested that you include a personal email address as a secondary email in your profile.
• Corporate Mergers and Acquisition Activity: In the event that GranuLearn or its affiliates acquires or is acquired by another business operation, or in the event of a reorganization, merger, or other similar event, your personal data will be shared with the acquiring, acquired, or resulting entities and their affiliates including for the purposes of operating and managing your account as well as for providing you with additional products and services offered by the acquiring, acquired, or resulting entities.
• Legal Requirements: In certain situations, GranuLearn may be required to disclose personal data in response to lawful requests by governmental agencies and supervisory authorities, including to meet security or law enforcement requirements. We reserve the right to disclose your personal information as required by applicable law and when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order, or similar legal process served on us or our Site.

4. How to Access and Control Your Personal Data

You can also make choices about the collection and use of your data by ansrsource. You can control your personal data that we have obtained, and exercise your data protection rights by contacting us or using features we provide. In some cases, your ability to access or control your personal data will be limited, as required or permitted by applicable law or your employer or group sponsor (where applicable).

Control the use of your data for interest-based advertising via the following:

• Select what types of marketing communications you wish to receive in the Communication Preferences section of your profile;
• Utilize the “Unsubscribe” link found in the emails we may send to you; or
• Contact us at support@ansrsource.com. Before helping you with your inquiry, we may ask to verify your identity or the identity of your authorized agent.

Not all personal data processed by GranuLearn can be accessed or controlled via the methods above. Please note that you will not be able to opt-out from our communications that are related to the ongoing service and support of your account. Such communications shall not be considered marketing communications. Additionally, any personal data that you provide to third parties directly, such as our third-party payment and subscription providers, can only be controlled directly by contacting such parties.

5. Cookies and Similar Technologies

GranuLearn and its affiliates use cookies or similar technologies to collect and store certain information. These typically involve pieces of information or code that a website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you. Cookies allow us to create a unique device ID, enable you to be remembered when using that computer or device to interact with websites and online services, and can be used to manage a range of features and content, including storing searches and presenting personalized content.

The Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a feature rich and personalized user experience when you interact with our Site and also allows us to improve our Site. GranuLearn uses third=party services to better understand how you use our platform with the devices you use to access it, and to allow us to deliver tailored recommendations.

Most web browsers automatically accept cookies, but if you prefer, you can change your browser to prevent that. We provide you with information about how to disable cookies in the table below. However, you may not be able to take full advantage of our Site if you do so.

A number of cookies we use last only while you are on our Site and expire when you close your browser or exit our Site. Others are used to remember you when you return to our Site and will remain for a longer period of time. We use these cookies on the basis that they are necessary for the performance of a contract with you, because using them is in our legitimate interests (where we have considered that such interests do not override your individual rights), or where required by law.

We use the following types of cookies:

• Strictly necessary cookies: These are cookies that are required for the operation of our website and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart, or make use of e-billing services
• Analytical/performance cookies: These cookies allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us for our legitimate interests of improving the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies: These are used to recognize you when you return to our website. This enables us, subject to your choices and preferences, to personalize our content, greet you by name, and remember your preferences (for example, your choice of language or region).
• Targeting cookies: These cookies record your visit to our website, the pages you have visited, and the links you have followed. We will use this information subject to your choices and preferences to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose

We may also work with advertising networks that gather information about the content on our Site you visit, and on information on other websites and services you visit. This may result in you seeing advertisements on our Site or our advertisements when you visit other websites and services of third parties. For more information about how to turn this feature off, see below or visit http://optout.networkadvertising.org/ and learn more about opting out of targeted ads. There you will find links for resources specifically for citizens of the United States, Canada, and the European Union.

Disabling Cookies

The effect of disabling cookies depends on which cookies you disable but, in general, our Site may not operate properly if all cookies are switched off. If you only disable third party cookies, you will not be prevented from making purchases on our Site. If you disable all cookies, you will be unable to complete a purchase on our Site.

If you want to disable cookies on our Site, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies for the most popular browsers are set out below:

• For Google Chrome:
  1. Choose Settings> Advanced
  2. Under “Privacy and security,” click “Content settings”
  3. Click “Cookies”

• For Safari:
  1. Choose Preferences > Privacy
  2. Click on “Remove all Website Data”

• For Mozilla Firefox:
  1. Choose the menu “Tools” then “Options”
  2. Click on the icon “Privacy”
  3. Find the menu “Cookie” and select the relevant options

Where you have not set your permissions, we may also separately prompt you regarding our use of cookies on our Site

Except for essential cookies, all cookies used on our Site will expire after two years or sooner.

6. Security of Personal Data

GranuLearn is committed to protecting the security of your personal data. We use a variety of security controls and procedures to help protect your personal data from unauthorized access, use, or disclosure. Our controls include the security measures outlined in Appendix A of our Customer Data Processing Agreement.

7. Access to Third Party Services

This Privacy Notice applies only to our Site. The Site may contain links to other web sites not operated or controlled by us. The policies and procedures described here in our Privacy Notice do not apply to websites or other services that GranuLearn does not operate or control. These links from our Site do not imply that we endorse or have reviewed those websites including their privacy terms. When you leave our Site for a third-party website, you will be subject to the terms of use and privacy terms associated with that third party website.

8. Individuals Subject to the GDPR

If you are subject to the GDPR, the following apply to your personal data.

GranuLearn is acting as a data controller of your personal data when you access our Website and view information about us and our technology, communicate with us, download whitepapers, register for events, and consent to receive marketing communications from us and our affiliates.

When you engage with the Platform because your employer has signed up to a business plan (as described in our Terms of Use at https://www.granulearn.com/terms , the “Terms of Use”) or a Company Partnership Subscription, then;

• Your employer is the data controller with respect to the user information it provides to us. This information typically includes first name, last name, and business email address. Where your employer is the data controller in this way, we act as a data processor under data protection laws, meaning we use the information to provide a service to your employer.
• GranuLearn is the data controller for information provided directly by you or as a result of interacting with the Platform, including assessment data, a secondary email address, additional profile details such as job title, personal website URL, a short bio, social platform handles, and demographic information such as your gender, year of birth, and your work industry. To be clear, none of these additional profile details are required to utilize our Site, but we can offer you an enhanced experience if you provide it

When you sign up as a user of the Platform via an individual plan (as described in the Terms of Use), GranuLearn is the data controller for all personal information provided by that user and collected by the Platform as the user accesses and uses it.

9. Individuals Subject to CCPA

Under California law, California residents are entitled to certain privacy rights concerning their personal information. To learn more about those rights, please visit our CCPA Privacy Notice.

10. Enforcement and Dispute Resolution

We will conduct compliance audits of our relevant privacy practices to verify compliance with this Privacy Notice. Where any ansrsource employee has acted in violation of this Privacy Notice, as determined by us, the employee will be subject to disciplinary action up to and including termination of employment.

Any questions or concerns regarding our use or disclosure of personal data should be addressed to Customer Support at support@ansrsource.com. We will investigate and attempt to resolve any complaints and disputes regarding the use and disclosure of personal information in accordance with the provisions of this Privacy Notice.

11. Retention of Personal Data

Generally we will keep your personal data for the duration of our relationship with you. After our relationship ends, we will retain your personal information for a period of time that permits us to satisfy the following purposes: record retention as may be required by applicable law; for use in a legal claim or proceeding; to address any complaints regarding our services or the Website; or other legitimate interests (where we have considered that such interests do not override your individual rights.

12. Trial or Free Accounts

This Privacy Notice applies to the processing of your personal data in conjunction with a user account of any kind including an account that is offered without charge or on a trial basis, or an account that offers new or limited features.

13. Privacy Shield

Although ansrsource does not rely on the EU-U.S. Privacy Shield Framework as a legal basis for transfers of personal data in light of the judgment of the Court of Justice of the EU in Case C-311/18, ansrsource does adhere to the principles of the EU-U.S. and Swiss-U.S. Privacy Shield frameworks with respect to personal data that is transferred from the European Union and its Member States, the European Economic Area, the United Kingdom and/or Switzerland, to the United States. If there is any conflict between the terms in this Privacy Notice and the privacy shield principles, the principles shall govern. With regard to the Privacy Shield Framework, ansrsource is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. To learn more and view our certification, visit the U.S. Department of Commerce’s Privacy Shield website.

In the context of employee data, ansrsource commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland.

You may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of any complaint under certain circumstances. For further information, please visit the U.S. Department of Commerce’s Privacy Shield website.

14. Changes to this Privacy Notice

We update this Privacy Notice when necessary to provide greater transparency or in response to:

• Feedback from customer, regulators, industry, or other stakeholder
• Changes in our products
• Changes in our data processing activities or policies

When we post changes to this policy, we will provide a version and effective date for the most recent terms. If there are material changes to the policy, such as a change to the purposes of processing of personal data that is not consistent with the purpose for which it was originally collected, we will notify you either by prominently posting a notice of such changes on our Site before they take effect, or by directly sending a notification via email to all registered users of the Platform. We encourage you to periodically review this Privacy Notice to learn how GranuLearn is protecting your information. If you do not agree to abide by this or any future version of the Privacy Notice, you do not have permission to use or access (or continue to use or access) our Site.

15. How to Contact Us

Questions or comments regarding this Privacy Notice should be submitted to ansrsource by e-mail as follows:

ansrsource Content US, LLC
5440 Harvest Hill Road,
Suite 249
Dallas, Texas 75230
Attn: Legal Counsel
Email: support@ansrsource.com