Supplemental Privacy Statement

Effective Date: January 1, 2023

Introduction

This Privacy Statement explains Pearson’s commitment to comply with California, Colorado, and Virginia law and applies to personal information collected through the Educational Products and Services that link to this Privacy Statement (the Services). Please read this Supplemental Privacy Statement in conjunction with the Privacy Notice that linked here.

Definitions

Business Purposes as defined under California law includes the following:

Audit means auditing compliance with the Terms of Use, this Privacy Statement, the U.S. Digital Learning Services Privacy Notice and applicable law. It also means auditing current interaction with a User and concurrent interactions with others, such as auditing access to particular content or features.
Debugging means identifying and repairing errors that impair existing intended functionality.
Evaluation means undertaking internal research to assess the effectiveness of the Services and for technological development and demonstration.
Maintenance and Improvement means undertaking activities to verify or maintain the quality or safety of the Services, and to improve, upgrade or enhance the Services.
Provide the Services means delivering and providing the Services, including, but not limited to, providing educational content and learning services, maintaining accounts, providing customer service, fulfilling orders and verifying customer information.
Security means detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity and taking appropriate action for those responsible for that activity.
Short-Term Use means short-term, transient use related to a current interaction with a California resident, such as the contextual customization of ads shown as part of the same interaction. In Short-Term Use, the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction.

Personal Information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or their household. Categories of Personal Information include the following:

Identifiers means information used to identify a particular user, such as name, email address, user name, IP address or other online identifier.
Customer Records means categories of customer personal information described in California Civil Code 1798.80, including name, address and education information.
Protected Class Characteristics means characteristics identified under California and/or federal law such as race, ethnicity, national origin, disability, veteran or military status.
Commercial Information means information about products or services purchased, used or considered by a User.
Biometric Information means genetic or biological characteristics, such as information derived from fingerprint, iris or retina scans.
Internet or Other Similar Network Activity means information generated from interaction with a website or the internet.
Geolocation Data means information about the geographic location from where a user accessed the Services.
Sensory Data includes audio, electronic and visual information
Professional or Employment-Related Information means current or past job history.
Non-Public Education Information means personally identifiable Education Information that is not publicly available, as defined in the Family Educational Rights and Privacy Act (FERPA).
Inferences Drawn from Other Personal Information means inferences that create a profile about User’s preferences, characteristics, intelligence, abilities and aptitudes.
Sensitive Personal Information means Personal information that reveals certain information about a consumer that are generally considered to be sensitive in nature, including:

Any communications you have with a third party (ie, somebody outside our business)
Biometric data processed to identify an individual
Data about sexual orientation or sex life
Financial account details in a combination (for example card number and password) that gives access to an account
Genetic data
Government-issued numbers (such as a social security number or a number on a passport, or driver's license)
Health data
Philosophical or religious beliefs
Precise geolocation
Racial or ethnic origin
Union membership
Information from a known child

Personal Information Collected and Disclosed within the Last 12 Months

Within the last 12 months, Pearson collected and disclosed categories of Personal Information through the Services, as follows:

Category	Source	Purpose	Disclosures to Third-Party Businesses
Identifiers	Users, Educators, and Institutions.	Provide the Services.	Service Providers, Educators, and Institutions for auditing, debugging, evaluation, maintenance and improvement, providing the services, security and short-term use. Law Enforcement in very limited circumstances, when required for security.
Customer Records	Users, Educators, and Institutions.	Audits, Evaluation, Provide the Services, Security, and Short-Term Use.	Service Providers, Educators, and Institutions for auditing, debugging, evaluation, maintenance and improvement, providing the services, security and short-term use. Law Enforcement in very limited circumstances, when required for security.
Protected Classes Characteristics	Users (only certain Career Success products)	Provide the Services.	Service Providers in order to provide the Services.
Commercial Information	Users	Audit, Evaluation, Maintenance and Improvement, Provide the Services, Security, Short-Term Use.	Service Providers, Educators, and Institutions for auditing, debugging, evaluation, maintenance and improvement, providing the services, security and short-term use. Law Enforcement in very limited circumstances, when required for security.
Biometric Information	Not applicable	Not applicable	Not applicable
Internet or Other Similar Network Activity	Users	Audit, Debugging, Evaluation, Maintenance and Improvement, Provide the Services, Security, and Short-Term Use.	Service Providers, Educators, and Institutions for auditing, debugging, evaluation, maintenance and improvement, providing the services, security and short-term use. Law Enforcement in very limited circumstances, when required for security.
Geolocation Data	Users (Country of location)	Audit, Debugging, Evaluation, Maintenance and Improvement, Provide the Services, Security, and Short-Term Use.	Service Providers for auditing, debugging, evaluation, maintenance and improvement, providing the services, security and short-term use. Law Enforcement in very limited circumstances, when required for security.
Sensory Data	Users	Debugging, Evaluation, Maintenance and Improvement, Provide the Services and Security.	Service Providers for debugging, evaluation, maintenance and improvement, providing the services, and security.
Professional or Employment-Related Information	Users	Provide the Services, Evaluation.	Service providers. Educators and Institutions to provide the Services and for evaluation.
Non-Public Education Records	Users, Educators and Institutions.	Provide the Services. Evaluation.	Service providers. Educators and Institutions to provide the Services.
Inferences	Users, Student Users’ Instructors and Educational Institutions.	Provide the Services. Security. Evaluation.	Service Providers, Educators, and Institutions for providing the Services, security and evaluation. Law Enforcement in very limited circumstances, when required for security.
Sensitive Personal Information	Users, Student Users’ Instructors and Educational Institutions.	Provide the Services.	Service Providers, Educators, and Institutions for providing the Services

How long will Pearson hold onto my personal information?

We will keep each category of your personal information, as identified in the table above, only for as long as necessary to fulfil the purposes for which we are processing that category of your personal information and to meet legal and audit requirements, or as long as you continue to engage with the Services, or longer with your consent.

Sale or Sharing of Personal Information

We do not sell or share, and have not sold or shared, any Personal Information collected through the Services within the last twelve (12) months.

Privacy Rights

Where Pearson is a service provider to an educational institution, your request for access, deletion or correction of your education records or course data should be directed to your school or University. Pearson cannot modify or delete education records or other records collected or processed by, or on behalf of, an educational institution unless directed to do so by the educational institution directly.

FERPA Privacy Rights. FERPA provides students with privacy rights and protection for educational personally identifiable information collected and processed on behalf of educational institutions receiving government funding from the U.S. Department of Education. FERPA provides students with rights to obtain from these educational institutions access to their educational records, as well as correction and amendment of their educational records, even though the CCPA does not apply to non-profit and public educational institutions.

Residents of California, Colorado and Virginia have certain rights related to their personal information collected by and on behalf of a business. Depending on where you live and Pearson’s role in collecting and/or processing your personal information, you may have the following rights:

To request access to your information including a request to receive a written report of the categories and sources of information and/or the specific personal information held by Pearson. Your request may be limited to information collected within the previous twelve (12) months;
to update or correct your personal information;
to ask that we remove or delete your personal information with some exceptions. For example your request for deletion of your personal information may not interfere with an in process transaction, investigation or legal obligation;
to appeal a decision in response to a request regarding your personal information;
to withdraw your consent to the processing of your personal information;
to ask that we limit or restrict the processing of your personal information;
to ask that we transfer your information to another service provider;
to object to our processing of your personal information;
to opt out of automated processing which has a significant impact (such as profiling);
To opt out of the sale or sharing of their Personal Information or to require affirmation authorization to sell or share personal information if you are under the age of 16;
To limit the use or disclosure of sensitive personal information which is not necessary for the Services provided;
to complain to a regulator about the handling of your personal information; and
To not be discriminated against for exercising any of your rights related to your data.

Pearson will not use or disclose your Sensitive Personal Information, collected through the Services, without your consent. Pearson does not use or disclose Sensitive Personal Information for any purpose other than that which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services, or as otherwise permitted by law.

How to Make a Request to exercise your rights

You may be able to exercise the above rights via the controls within your account here

To request access to a report of your data or deletion of your personal information, please click here for additional information: https://www.pearson.com/en-us/legal-information/california-consumer-rights.html

We will not require a California resident to set up an account in order to make a request or receive the requested information. In order to respond to a request, however, we must be able to reasonably verify, understand and fulfill the request. We will not be able to respond to the request if we are unable to verify identity or the authority to make the request. In conducting verification, we generally will use personal information previously collected by us. If the request is made on behalf of another individual, we may require additional verification and documentation of the individual’s authority to make the request. In responding to requests, we may limit the information provided for privacy and security reasons, as permitted by law.

We will process your request within the time required by the law or inform of the basis for any unexpected delays.

To request correction of incorrect information associated with you, please contact support@pearson.com or call the toll free phone number located here.

For any other questions about your rights associated with your personal information or to appeal a decision in response to a request to exercise any of the above privacy rights, contact dataprivacy@pearson.com.

Changes to this Supplemental Privacy Statement

We may update this Privacy Statement from time to time in the same way that we update the Privacy Notice that linked to it.

Contact Information

If you have any questions or comments about this Privacy Statement or your rights under California law, please contact us at dataprivacyUS@pearson.com.