Digital Learning Services Privacy Notice

• Where your consent is required we will obtain your permission before sending you promotional material about Pearson or accessing information on your device relating to your use of our websites and apps. You can withdraw that consent at any time.
• We use your personal information to enable you to register with Pearson and to provide you with the Services that you request, or which are requested on your behalf by educational institutions, parents or guardians.
• Some of our Services provide interactive features that engage with third party sites such as social media sites or those of educational institutions. If you use those features those sites will send us information about you.
• Our Services may use artificial intelligence and machine learning to provide you with a personalised experience and educational tools and material that are likely to be most useful to you. Where that is the case such uses will be clearly signposted and additional information will be provided to you.
• We use cookies and other technologies to track the use of our websites and apps and to improve and personalise our services. This varies by site and app and details are available on product specific website and app cookie policies and preference centres.
• We transfer personal information to the United States and to other countries which may be outside the country in which you live. Where that is necessary, we do so in accordance with applicable law and rely on established mechanisms (such as the European Commission’s Model Contract Clauses) to protect personal information.

This Privacy Notice is designed to help you understand how we and other companies in our group collect and use your personal information. We want you to make informed decisions when using our websites and any features on them, including any registration and ecommerce services.

This Privacy Notice applies to all Services linking to this Privacy Notice and any features of them and any ecommerce, purchasing or other areas which require registration on our sites. However, it won’t apply to any third-party sites which are linked to our sites. We recommend that you read the privacy notice of any such sites that you visit as we are not responsible for them.

We have included full details of who we and our group companies are at the end of this Privacy Notice.

If your access to the Services was purchased for you by an institutional customer, then the institutional customer will, together with Pearson, be a data controller for any personal information which is uploaded to or accessed by the Services.

This does not mean that Pearson ceases to be responsible to you for its handling of your personal information. Pearson needs to process your personal information to maintain the account that you register for in order to access the Services. Institutional customers will also need access to information about your engagement with Services that they purchase for your use and, as a result, Pearson and institutional customers will be joint data controllers for the information relating to your use of any services purchased by an institutional customer and you can exercise your rights over your personal information by contacting either Pearson or the relevant institutional customer.

However, please note that if you have any queries that relate specifically to maintenance of your Pearson account rather than a specific product purchased by an institution (for example, if you are a learner and want to confirm how many different institutions have purchased products for your use), you will need to raise that query with Pearson directly.

We collect your information in three ways:

1. When you, your parent/carer or your institution (including your teacher) disclose your information through using the Services, registering you to use the Services (including when an institutional customer instructs us to register you to use the Services), contacting us (online or offline), ordering Services from us.
2. When you interact with the Services, our website, our mobile applications or when you open our email communications. We use cookies to collect this information. To find out more, please visit our Cookie Policy.
3. From specified third parties if you use Services which incorporate or link to third party products. For example, if you use a Service to obtain a personalised learning pathway that includes courses from third party providers, those third party providers may provide Pearson with limited information relating to your activity on that course including whether course checkout/onboarding is completed, start and end dates, what was charged for the course, whether or not it was completed and if a certificate was provided upon completion. If this data sharing takes place that will be made clear as part of the Services and before any data sharing takes place.

In a separate automatic operation we may collect application and system logs data which could include data such as your IP address, internet service provider and browser type, type of computer/device, and details of the website, application or email communication you came from before entering the Services. This information is used to:

• work out how many times the Services are visited;
• record which parts of the Services have been visited so we can improve the content and layout of the Services;
• understand the effectiveness of our email communications;
• monitor the health of the Services, detect unauthorised access and fraudulent activity, prevent and respond to security incidents and appropriately scale the computing resources for the Services.

We may from time to time supply third parties with an anonymised form of this data for uses in connection with our Services.

We will never sell users' personal information. We may disclose and share personal information:

• with our service providers (for example, suppliers who develop or host our Services) in which case we will require them to implement appropriate technical and organisational measures to meet the requirements of applicable law; and/or
• if required or permitted by law; and/or
• with relevant third parties (such as law enforcement agencies, your employer or educational institution) if we reasonably believe a user may be in breach of the law (e.g. if a user has posted defamatory content on our Services) or may have engaged in any academic dishonesty or misconduct, or may be in breach of any terms of use or end user licence agreement which apply to the Services, or in breach of any other contract with the user or the user's educational institution or employer; and/or
• with an institutional customer (on a limited basis and only with your knowledge and where it is necessary to provide the Services) or parent/carer where the institutional customer or parent/carer has purchased access to the Services on the user's behalf; and/or
• with our group companies who may use the information in accordance with the Marketing communications and opting out section below. Please note information on learners aged under 16 will not be shared with group companies for marketing purposes; and/or
• in connection with a sale, joint venture or other transfer of some or all of our company or assets, subject to the commitment of the acquiring entity to comply with this Privacy Notice; and/or.
• to protect the security and safety of the user and other persons, data, assets and systems, consistent with applicable law; and/or
• in other situations with the user's consent.

We also use personal information in aggregate form (so that no individual user is identified by name) to identify types of user, audit and analyse how our Services are used, to help with the strategic development of our Services, to conduct educational research, and to develop new products and services. When doing so we remove any direct identifiers so that the data is no longer considered personal data for the purposes of data privacy laws and regulations.

Marketing will not be sent to any learners aged under 16 registered to use the Services unless consent has been provided on behalf of the learners, in which case such consent may be withdrawn at any time.

Contact details for teachers, learners who are 16 or over, and adult subscribers to the Services may be used for these purposes:

1. to contact the user with more information about our products and services and those of our group companies, except where the user has told us not to;
2. to invite the user to participate in surveys, discussions and prize draws and ask for the user's views on our Services via online surveys and discussion forums.

Participation in surveys and discussion forums is entirely voluntary. Users may unsubscribe from being contacted for these purposes at any time. Survey information will be used for market research with the aim of improving our Services.

We will not send marketing emails to a user who has opted out of receiving them. Any marketing communications we send will include an unsubscribe link at the end of the email.

We will keep your personal information only for as long as necessary to fulfil the purposes for which we are processing your personal information unless the law permits or requires longer. For example, we might need to keep your personal data for quality assurance of the service we have provided, or we might need to keep it to defend future legal claims.

If you are under 16, please be sure to read this Privacy Notice with your parent or guardian and ask them questions about anything you don’t understand.

In some regions such as the EEA (European Economic Area) you may have certain rights in relation to your personal information including the right to:

• request access to and obtain a copy of your personal information
• rectification of your personal information if it is no longer accurate or erasure of your personal information if our retention is no longer necessary for the purposes for which it was collected
• restrict or object to the processing of your personal information in certain circumstances
• data portability (if applicable)

If you or your parents or guardians wish to exercise any of your rights in relation to your personal information please send your request to us using the details set out in the "Contacting Pearson" section below. We will consider and act upon any request in accordance with applicable data protection laws.

You may also have the right to complain to the Information Commissioner (if you are in the UK) or to your local data protection supervisory authority if you are unhappy with our privacy practices notified under this Privacy Notice.

If you have any questions about our Privacy Notice, please do not hesitate to contact us at:

Data Protection Officer
Pearson
80 Strand
London
WC2R 0RL
United Kingdom

You may also email us at dataprivacy@pearson.com.

This Privacy Notice is provided on behalf of Pearson plc and its group companies. This means all companies owned or controlled by Pearson plc (registered office 80 Strand, London, WC2R 0RL, United Kingdom, registered number 53723).

Limited personal information is collected during the registration process for Services. As a guide, we normally request the following data fields for users who are learners: First Name, Last Name and email address. In addition, where relevant, we may also collect: Year Group, date of birth, gender, a learner's institution and course identifier. The limited personal information we collect during the registration process for teachers typically is: First Name, Last Name and Email address, and where relevant, the teacher's institution and course identifier.

Institutional customers are responsible for ensuring that any information they upload to the Services is accurate.

For some Services, a user may register using an alias name (pseudonym) and email address that is not otherwise associated with personal information provided to Pearson. This alias registration may not be available if the user account is established through integration with a third party service or if the institutional customer establishes the account for a user or otherwise prohibits the use of this option. If a user establishes a user account through alias registration in an institutional customer setting, the user must notify the institutional customer and the teacher for each educational course or learning program in which the Services are used so that the teacher and educational institution can recognize the user account as belonging to that user.

As users of the Services, learners and teachers may also generate personal information when using the Services. For example, the Services may record assignments, student coursework, responses to interactive exercises, scores, grades and instructor comments, details of the books the learner has read or activities the learner has completed. Users may also generate personal information if they post in a community or forum, or use a communication tool provided through the Services. Pearson is not responsible for use or disclosure of these postings or communications by community or forum members, or by anyone else who receives your communications.

Other personal information that we collect may include your credit card or billing information, shopping selections and data about the pages you visit and your other activity on our site, as well as any other personal information relating to you that you supply to us or which is provided to us with your knowledge and permission.

When we say "users" we mean the individuals who use the Services. Users could include an institutional customer's learners, teachers and administrators, or individual subscribers who purchase access to the Services for themselves or for a child in their care.

When we say "institutional customers", we mean learning providers such as schools, colleges, local education authorities, private language schools, education agencies or any other organisations that purchase access to the Services for use by users in its organisation.

We and our group companies use your personal information for a variety of business purposes which are in our legitimate interests ("Business Purposes"), and/or in order to enter into or perform a contract with you ("Contractual"), and/or with your consent ("Consent"), and/or compliance with our legal obligations ("Legal Reasons"). For example, we may use your personal information:

• to provide you with the relevant services through our applicable site, for Contractual Reasons
• to process your online purchases, for Contractual Reasons
• to inform you about and provide more information on products and services offered by us and our group companies, for our Business Purposes or with your Consent
• to invite you to participate in surveys, discussions and prize draws and ask for your views on our services via online surveys and discussion forums, for our Business Purposes and/or with your Consent
• to improve the products and services offered to you for our Business Purposes
• for marketing for our Business Purposes and/or with your Consent
• for statistical or analytical purposes for our Business Purposes
• to detect, prevent or investigate security breaches or fraud for our Business Purposes and/or Legal Reasons
• to otherwise to better meet the needs and preferences of our customers for our Business Purposes

We will not allow unrelated third parties to use your personal information for marketing without your consent. Where we rely on your consent, you have the right to withdraw it at any time.

We also use personal information to identify types of user, audit how our sites are used, and to help with the strategic development of our sites. When doing so, we remove any direct identifiers.

Participation in surveys and discussion forums is entirely voluntary. You may unsubscribe from being contacted for these purposes at any time. Survey information will be used for market research with the aim of improving our services.

We will show your username on any content you submit or post on our sites (including discussions, bulletin boards and forums).

The personal information that is collected will be used by Pearson to provide the Services (including to communicate with users regarding service updates) and in accordance with this Privacy Notice. In addition, where an institutional customer has purchased access to the Services, personal information will also be used by Pearson in accordance with our contract with that institutional customer.

This may include analysis of users' use and progress across a variety of Services so that we can help learners make progress with their learning - for instance to evaluate the educational efficacy and effectiveness of the Services and to make appropriate recommendations to users and institutional customers based on this evaluation.

Email addresses for learners are collected in order to be able to issue passwords securely through our systems and to send out service messages where necessary. Please also refer to the section headed Marketing communications and opting out to see how else email addresses may be used.

Some Services may have the capability to connect to your Google Drive so that you can upload or download documents directly from or into your Google Drive. Before they do so, you will receive a prompt asking you to click "Allow" to enable the Services to connect to your Google Drive. You may remove this connection in the My Account settings for your Google account at any time. Pearson will use this connection to access your Google Drive only for the purpose of uploading or downloading documents that you specifically select with limited metadata to allow identification and retrieval, so that you can access and use the documents within the Services or download them to Google Drive. Pearson will use, process and store these documents and associated personal data in accordance with this Privacy Notice.

We seek to protect the safety of all your personal information by implementing appropriate technical and organisational measures. For example, provided your browser accepts HTTPS (Hyper Text Transfer Protocol) Secure encryption, we seek to protect your payment information against unauthorised access through a secure server. Where we use third parties to process personal information, we require them to ensure the safety of your information.

Any personal information that you voluntarily post on a public area of our site, such as a bulletin board or discussion forum, or an interactive area requiring registration and/or subscription, may be collected and used by others. Please be careful what personal information you disclose in this way. You understand that we cannot control the actions of other users.

We may transfer your personal information to other countries around the world, including countries outside of the European Economic Area ("EEA"), which may not have the same data protection laws as those of the country where you access our sites. Where we transfer your personal information to countries outside of the EEA we will take appropriate steps to ensure your personal information is afforded the same level of protection as described in this Privacy Notice.

We have entered into an intercompany data processing agreement using the European Commission standard contractual clauses (in the absence of an adequacy decision) for data transfers to our group companies located outside of the EEA. We rely on adequacy decisions or any adequate data transfer mechanisms adopted by the European Commission or a supervisory authority from time to time for transfers to third parties located in countries outside of the UK or the EEA.

Any improper collection or misuse of personal information is in violation of this Privacy Notice and of our Legal Notice or terms of use. Please report it by emailing dataprivacy@pearson.com.

You agree not to misuse any personal information available on our sites or to gather it or use robots or other automated scripts, codes or functionalities to do so.

We may immediately suspend or terminate your access to our site without notice if we become aware that you are in breach of applicable terms and conditions of use or of this Privacy Notice.

We may update this Privacy Notice from time to time. We will always include the date of a new version so that you know when there has been a change.