PRIVACY POLICY

OUR POLICY

This Privacy Policy (the “Privacy Policy”) governs Qwiklabs Inc.’s (“Qwiklabs,” "we", "us" and/or "our") use of certain information provided to us in connection with services provided to you under the Qwiklabs Terms of Service (the “Terms of Service”). All capitalized terms in this Privacy Policy shall have the meaning set forth in the Terms of Service, or the meaning set forth in this Privacy Policy if no definition is provided in the Terms of Service. This Privacy Policy sets forth our policies with respect to information including personally identifiable data ("Personal Data") and other information that is collected from you when using or registering for the Service.

BY CLICKING THE "I ACCEPT" BUTTON DISPLAYED AS PART OF THE REGISTRATION PROCESS OR BY USING THE SERVICE OR ANY PORTION THEREOF, YOU ACCEPT AND AGREE TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND THE TERMS OF SERVICE, INCLUDING ALL TERMS INCORPORATED HEREIN BY REFERENCE.

INFORMATION WE COLLECT

When you interact with us through the Service, we may collect Personal Data and other information from you, as further described below:

• We collect Personal Data from you when you voluntarily choose to provide such information such as when you contact us with inquiries, respond to one of our surveys, register for access to the Service or use certain features of the Service. Wherever we collect Personal Data we make an effort to provide a link to this Privacy Policy. By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to us through the Service, you acknowledge and agree that such Personal Data may be transferred from your current location to our offices and servers, or our affiliates and/or contractors located in the United States and other countries. We also collect information about your activity in our Services, which may include details on how you used our Services, Internet protocol address, and the labs and quests you’ve taken, class history and badges earned.
• Non-Identifiable Data: When you utilize the Service, we may receive certain personally non-identifiable information about your use of the Service. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may store such information ourselves or it may be included in databases owned and maintained by our affiliates, agents or service providers. We may use such information and pool it with other information to track, for example, the total number of visitors to the Service, the number of visitors to each page of the Service, and the domain names of our visitors' Internet service providers. It is important to note that no Personal Data is available or used in this process.
• Cookies: In operating the Service, we may use cookies. A cookie is a piece of information that the computer or computers that host our Service give to your browser when you access the Service. Our cookies help provide additional functionality to the Service and help us analyze usage of the Service more accurately. For instance, our Service may set a cookie on your browser that keeps you from needing to remember and then enter a password more than once during a visit to the Service. On most web browsers, you will find a "help" section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some features of the Service.
• Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Services, we may conduct research on our end user's demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregated data with our affiliates, agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

OUR USE OF YOUR PERSONAL DATA AND OTHER INFORMATION

We will use the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide access to such services and to monitor your use of such services. We may also use your Personal Data and other personally non-identifiable information collected through the Service to help us improve the content and functionality of the Service, to better understand our users and to improve the Service. We may use this information to contact you in the future to tell you about services we believe will be of interest to you.

We use information to help improve the safety and reliability of our Services. This includes detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm Qwiklabs, our users, or the public. When we detect spam, malware, illegal content, and other forms of abuse on our systems in violation of our policies, we may disable your account or take other appropriate action. In certain circumstances, we may also report the violation to appropriate authorities.

We may communicate with you through email and notices posted via the Service. These communications may include a series of welcome emails that help inform you about various features of the Service. Please be aware that you may receive certain emails from us related to the proper functioning of your account. We, along with your Lab Sponsor and their affiliates, may send you promotional information unless you have opted out of receiving such information. If you wish to opt-out of receiving promotional emails, please click the "unsubscribe" link at the bottom of the email or send us a communication using the contact information below.

OUR DISCLOSURE OF YOUR PERSONAL DATA AND OTHER INFORMATION

There are certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, including as set forth below:

• With your consent: We will share personal information with companies, organizations or individuals outside of Qwiklabs when we have your consent to do so. We require opt-in consent for the sharing of any sensitive personal information.
• Service Providers, Agents and Related Third Parties: We may hire other companies to perform certain business-related functions. Examples include mailing information, maintaining databases and processing payments. If we employ another company to perform a function of this nature, we may need to provide them with access to certain Personal Data.
• Lab Sponsors, Business Partners and Related Third Parties: We may enter into agreements with business partners and other third parties to make the Services available to you. For example, our Service may be provided to you in conjunction with a Lab Sponsor and/or its affiliates. Accordingly, we may share with such business partners and third parties, including any Lab Sponsor and/or affiliates, information including Personal Data so the business partner or other third party can effectively work with us to manage or operate the corresponding Service or otherwise make the Service available for your use.
• Legal Requirements: We may also disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or property, (iii) act in urgent circumstances to protect the personal safety of users of the Service or the public, or (iv) protect against legal liability.
• Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a sale, merger, reorganization, dissolution or similar event relating to all or a portion of our business, assets relating to the Service, including Personal Data, may be part of the transferred assets.

MANAGING AND DELETING YOUR INFORMATION

Reviewing, and Updating Your Information

When you’re signed into your Qwiklabs account, you can always review and update information by visiting your account profile.

Exporting, Removing & Deleting Your Information

You can export a copy of content in your Qwiklabs account if you want to back it up or use it with a service outside of Qwiklabs by contacting us. You may update, correct, or delete your profile information and preferences at any time by accessing your account settings page or editing your Qwiklabs account profile through the Services.

You can also delete your labs by using the available tools in our Services. If desired, you can delete your entire Qwiklabs account, including all information associated with your account such as lab and quest progress, class history, and badges earned by choosing that option in your account settings page.

Please note that while your deletions are reflected promptly in active member databases, in some cases, we retain data for limited periods when it needs to be kept for legitimate business or legal purposes. See “Data Retention” below for more information.

There are other ways to control the information Qwiklabs collects whether or not you’re signed in to a Qwiklabs account, including configuring your browser to indicate when Qwiklabs has set a cookie in your browser. You can also configure your browser to block all cookies from a specific domain or all domains. But remember that our Services rely on cookies to function properly.

DATA RETENTION

Information Retained Until You Remove It

As we describe above, you can delete your entire Qwiklabs account, including all information associated with your account such as lab and quest progress, class history, and badges earned by using the available tools in our Services. In some cases, rather than provide a way to delete data, we store it for a predetermined period of time. For each type of data, we set retention timeframes based on the reason for its collection.

Information Retained For Extended Time Periods for Limited Purposes

Sometimes business and legal requirements require us to retain certain information for specific purposes for an extended period of time. Reasons we might retain some data for longer periods of time include:

• Security, fraud & abuse prevention
• Financial record-keeping
• Complying with legal or regulatory requirements
• Ensuring the continuity of our services

YOUR CHOICES

When you sign up for the Service, we ask you to provide Personal Data. If you do not wish to provide such Personal Data, you may not use the Service. If we want to use Personal Data in a manner different than the purpose for which it was collected, we will ask for your consent prior to doing so. If we propose to use Personal Data for any purposes other than those described in this Policy and/or in the specific notice provided through the Service, we will offer you an effective way to opt out of our use of your Personal Data for those other purposes.

EXCLUSIONS

This Privacy Policy shall not apply to any unsolicited information you provide to us through this Service or through any other means. This includes, but is not limited to, information posted to any public areas of the Service (collectively, "Public Areas"), any ideas for new products or modifications to existing services, and other unsolicited submissions (collectively, "Unsolicited Information"), including all Content as that term is defined in the Terms of Service. All such Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution. Please also note that any Personal Data or other information you provide to be displayed in your publicly available online profile will be displayed for others to see and thus will not be subject to the terms of this Privacy Policy. We cannot and will not be responsible for what third parties do with any Personal Data or other information that you choose to make publicly available. As such, we advise that you exercise great care in determining what information you choose to make publicly available through the Service.

CHILDREN

We do not knowingly collect Personal Data from children under the age of 16, or the age of consent in your country, and do not target the Service to children under such age. If you are under the relevant age of consent in your country, please do not submit any Personal Data through the Service. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children to never provider Personal Data on the Service without their permission. If you have reason to believe that a child under the age of consent has provided Personal Data to us through the Service, please contact us, and we will endeavor to delete that information from our databases.

LINKS TO OTHER WEBSITES

This Privacy Policy applies only to the Service. The Service may frame or contain references or links to other websites not operated or controlled by us (the "Third Party Sites"). The policies and procedures we describe here do not apply to the Third Party Sites. The links from the Service do not imply our review or endorsement of the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

SECURITY

We take reasonable steps to protect the Personal Data provided via the Service from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. These steps include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store Personal Data. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from the Service may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Data to us via the Internet.

DATA INTEGRITY

We process Personal Data only for the purposes for which it was collected and in accordance with this Privacy Policy or any applicable service-specific privacy notice. We review our data collection, storage and processing practices to ensure that we only collect, store and process the Personal Data needed to provide or improve our Services. We take reasonable steps to ensure that the Personal Data we process is accurate, complete, and current, but we depend on our users to update or correct their Personal Data whenever necessary.

COMPLIANCE & COOPERATION WITH REGULATORS

We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.

Data Transfers

Your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this Privacy Policy. We also comply with the EU-US and Swiss-US Privacy Shield Frameworks relating to the transfer of data.

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

European Requirements

If European Union (EU) data protection law applies to the processing of your information, you can exercise your right to request access to, update, remove, and restrict the processing of your information. You also have the right to object to the processing of your information or export your information to another service. Please contact us to exercise these rights.

If you have any questions, you may contact us. If you have concerns regarding your rights under local law, you can contact your local data protection authority. Qwiklabs has appointed Google Ireland Ltd. to act as its local representative under Article 27 of the EU General Data Protection Regulation. Google Ireland Ltd.’s address is Gordon House, Barrow Street, Dublin 4, Ireland.

We process your information for the purposes described in this Privacy Policy, based on the following legal grounds:

With your consent

We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time.

When we're pursuing legitimate interests

We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like:

• Providing, maintaining, and improving our Services to meet the needs of our users
• Developing new products and features that are useful for our users
• Understanding how people use our Services to ensure and improve the performance of our Services
• Customizing our Services to provide you with a better user experience
• Marketing to inform users about our Services
• Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our Services
• Protecting against harm to the rights, property or safety of Qwiklabs, our users, or the public as required or permitted by law
• Performing research that improves our Services for our users and benefits the public
• Fulfilling obligations to our partners like lab sponsors
• Enforcing legal claims, including investigation of potential violations of our Terms of Service

When we're providing a service

We process your data to provide a service you’ve asked for under a contract. For example, we process your information in connection with labs and trainings provided by your Lab Sponsor.

When we’re complying with legal obligations

We’ll process your data when we have a legal obligation to do so, for example, if we’re responding to legal process or an enforceable governmental request.

CHANGES TO OUR PRIVACY POLICY

We change this Privacy Policy from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We always indicate the date the last changes were published and you can contact us if you would like to access a previous version of this Privacy Policy. If changes are significant, we’ll provide a more prominent notice.

ACCESS TO INFORMATION

We strive to keep your Personal Data accurately recorded. Through the Service, we provide you with access to update your profile and revise Personal Data previously submitted to the Service.

CONTACTING US

Please contact us with any questions or comments about this Privacy Policy, your personal information, our use and disclosure practices, or your consent choices.

Last Updated: May 25, 2018

PRIVACY SHIELD POLICY

Qwiklabs Inc. ("Qwiklabs") is committed to upholding the highest ethical standards in its business practices and strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business. This Privacy Shield Policy sets forth the privacy principles that Qwiklabs follows with respect to personal consumer information transferred from the European Economic Area (EEA) (which includes the twenty-eight member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and Switzerland to the United States.

This Privacy Shield Policy applies to all Personal Information received from consumers by Qwiklabs in the United States from the European Economic Area and Switzerland, in any format including electronic, paper or verbal.

Qwiklabs complies with the EU-US Privacy Shield and Swiss-U.S. Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Information from European Union member countries and Switzerland. Qwiklabs has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov.

The Federal Trade Commission has jurisdiction with enforcement authority over Qwiklabs’ compliance with the EU-US Privacy Shield Framework.

DEFINITIONS

For purposes of this Privacy Shield Policy, the following definitions shall apply:

"Agent" means any third party that collects or uses Personal Information under the instructions of, and solely for Qwiklabs or to which Qwiklabs discloses Personal Information for use on Qwiklabs' behalf or in partnership with Qwiklabs. Examples of Agents may include service providers and related third parties that Qwiklabs may hire to perform certain business-related functions. Other examples of Agents may include lab sponsors, business partners and related third parties with which Qwiklabs may enter into agreements to make its services available to users.

"Personal Information" means any information or set of information that identifies or is used by or on behalf of Qwiklabs to identify an individual. This includes first name, last name, email address and company name. Personal Information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public Personal Information. We use this information to give the individual access and personalization to the Qwiklabs service.

"Sensitive Personal Information" means Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, Qwiklabs will treat as Sensitive Personal Information any information received from a third party where that third party treats and identifies the information as sensitive.

INFORMATION WE COLLECT

When you interact with us through the services provided by Qwiklabs, including the website(s) we operate (the "Services"), we may collect the following types of Personal Information and other information from you, as further described below. This information is being collected under the EU-US Privacy Shield and Swiss-U.S. Privacy Shield Frameworks. We will collect and use the information for the purposes noted below.

Personal Information That You Provide Through the Services: We collect Personal Information from you when you voluntarily choose to provide such information such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services or use certain features of the Services. If you provide Personal Information in order to obtain access to the Services, we will use your Personal Information to provide access to such Services and to monitor your use of such Services. Also, if you contact us by e-mail, we will use the Personal Information you provide to answer your question or resolve your problem. We may also use your Personal Information and other information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services. We may also use this information to contact you in the future to tell you about services we believe will be of interest to you.

Non-Identifiable Data: When you utilize the Services, we may receive certain personally non-identifiable information about your use of the Services. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may store such information ourselves or it may be included in databases owned and maintained by our affiliates or Agents. We may use such information and pool it with other information to track, for example, the total number of visitors to websites providing the Services, the number of visitors to each page, and the domain names of our visitors' Internet service providers. It is important to note that no Personal Information is available or used in this process.

Cookies: In operating the Services, we may use cookies. A cookie is a piece of information that the computer or computers that host our Services give to your browser when you access the Services. Our cookies help provide additional functionality to the Services and help us analyze usage of the Services more accurately. For instance, our Services may set a cookie on your browser that keeps you from needing to remember and then enter a password more than once during a visit to the Services. On most web browsers, you will find a "help" section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some features of the Services.

Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Services, we may conduct research on our end user's demographics, interests and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregated data with our affiliates, Agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes.

PRIVACY PRINCIPLES

The privacy principles in this Privacy Shield Policy are based on the Privacy Shield Principles.

NOTICE: Where Qwiklabs collects Personal Information directly from individuals in the EEA and Switzerland, it will inform them about the purposes for which it collects and uses Personal Information about them and the choices and means, if any, Qwiklabs offers individuals for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to Qwiklabs, or as soon as practicable thereafter, and in any event before Qwiklabs uses or discloses the information for a purpose other than that for which it was originally collected or discloses information to a non-Agent third party.

CHOICE: For Personal Information, Qwiklabs offers individuals the opportunity to choose (opt-in) whether their Personal Information is (a) to be disclosed to a non-Agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. To choose, individuals can check the box with the title "Opt-in: Send me valuable promos or updates about new hands-on learning" on the "My Account" page.

For Sensitive Personal Information, Qwiklabs will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-Agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Qwiklabs will provide individuals with reasonable mechanisms to exercise their choices.

ACCOUNTABILITY FOR ONWARD TRANSFER: Qwiklabs may provide Personal Information to Agents to perform tasks on behalf of and under our instructions. Such Agents must agree to use such Personal Information only for the purposes for which they have been engaged by Qwiklabs.

Qwiklabs also may disclose Personal Information for other purposes or to other third parties when the individual has consented to or requested such disclosure. Please be aware that Qwiklabs may be required to disclose an individual's Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. Qwiklabs remains responsible for any of your Personal Information that is shared with third parties under the Onward Transfer Principle, for external processing on our behalf.

SECURITY: Qwiklabs will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

DATA INTEGRITY AND PURPOSE LIMITATION: Qwiklabs will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Qwiklabs will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current. We will only collect and store Personal Information that is relevant to fulfill the purpose of the request and will retain such information no longer than appropriate to fulfill the purpose of the request.

ACCESS AND RECOURSE: Qwiklabs acknowledges the right of individuals access to their personal data. Upon request, Qwiklabs will grant individuals reasonable access to Personal Information that it holds about them. In addition, Qwiklabs will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. These requests can be made by contacting Qwiklabs by mail at 355 Main Street Cambridge MA 02142 USA.

ENFORCEMENT AND LIABILITY: Qwiklabs will conduct compliance audits of its relevant privacy practices to verify adherence to this Privacy Shield Policy. Any employee that Qwiklabs determines intentionally violates this policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION

In compliance with the EU-US Privacy Shield and Swiss-U.S. Privacy Shield Principles, Qwiklabs commits to resolve complaints about your privacy and our collection or use of your Personal Information. EEA and Swiss individuals with inquiries or complaints regarding this Privacy Shield Policy should first contact Qwiklabs at support@qwiklabs.com. You may also refer a Privacy Shield complaint to your local data protection authority and we will work with them to resolve your concern. In certain circumstances, the Privacy Shield Frameworks provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Privacy Shield Principles.

PRIVACY POLICY

Qwiklabs's Privacy Policy, which can be found at https://qwiklabs.com/privacy_policy (the "Website Privacy Policy"), contains information regarding how Qwiklabs collects and personal information and other information of consumers on our website generally. This Privacy Shield Policy is intended to provide additional information about our practices with respect to Personal Information that is transferred from the EEA and Switzerland to the U.S. In the event of any inconsistencies with the Website Privacy Policy and this Privacy Shield Policy with respect to such information, this Privacy Shield Policy shall govern.

CONTACT INFORMATION

Questions or comments regarding this Privacy Shield Policy should be submitted to Qwiklabs by mail at 355 Main Street Cambridge MA 02142 USA.

CHANGES TO THIS PRIVACY SHIELD POLICY

This Privacy Shield Policy may be amended from time to time, with or without notice, consistent with the requirements of the Privacy Shield Principles. Please review this Privacy Shield Policy periodically, and especially before you provide any Personal Information. This Privacy Shield Policy was last updated on the date indicated above.

Last Updated: September 21, 2017