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Privacy Statement
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LRN CORPORATION
LRN Corporation ("LRN") is committed to protecting your privacy and earning your trust. This Privacy Statement describes LRN's privacy practices for both the web site located at www.lrn.com and the Customer Web Sites which LRN creates, configures and hosts on behalf of its customers. These practices implement the requirements prescribed by the United States-European Union "Safe Harbor" arrangement for compliance by U.S.-based organizations with the provisions of the European Union's Directive regarding the protection of personal information.

Information Collection & Use
Customer Web Sites
LRN provides online knowledge, training, management and other services to employees of LRN's customers and others designated by LRN's customers to participate in LRN's programs ("Users"). LRN's customers are typically businesses or other organizations. LRN typically provides its services via Customer Web Sites that LRN creates, configures and hosts on behalf of customers. LRN operates its programs and collects and uses data about Users at the direction of, and in accordance with, the instructions of LRN's customers.

LRN's arrangements with its customers may require LRN to obtain certain personal information about Users, either from the customer or a User, in order for a User to access the online knowledge, training and other services provided on a Customer Web Site. Among other things, LRN may collect the following data: (i) User name; (ii) User identification; (iii) User password; (iv) User email address; and (v) User department(s) and location within the customer organization. LRN may also track the amount of time a User spends on the Customer Web Site, the applications the User employs, the self-tests the User performs, the User's performance on such tests, and other activities in which the User engages while the User is on the Customer Web Site.

LRN only uses personal information to provide feedback about a User's activity on a Customer Web Site. For example, LRN may use personal information to inform a User of his or her performance on tests, or the number of training modules that a User has used. LRN may also use personal information to send e-mails to a User, such as reminder e-mails that the User has not completed certain online courses.

LRN's arrangements with its customers require LRN to provide all User information in LRN's possession, including a User's personal information, directly to the customer with which the User is associated (i.e. the User's employer). If a User corresponds with LRN, LRN may keep a record of that correspondence. LRN may also forward correspondence to the customer with which the User is associated. LRN does not transfer any personal User information to any third party (other than to the LRN customer with which the User is associated) unless it is authorized to do so by the customer with which the User is associated , in connection with the services that LRN provides to the customer, or required to do so by applicable law.

www.lrn.com

LRN actively collects information from visitors to its website at www.lrn.com both by asking specific questions on the site and by permitting visitors to communicate directly with LRN via e-mail. Some of the information that visitors to the website submit may be personally identifiable (that is, information that can be uniquely identified with an individual, such as name, address, e-mail address, phone number, etc.). LRN uses this information to send visitors to its website further information regarding LRN. LRN does not provide, sell, or otherwise make available to third parties personal information that is collected from visitors to the website.

LRN may collect, store or accumulate certain non-personally identifiable information concerning visitors’ use of this site, such as information regarding which pages are most often visited. LRN may share with or transfer to third parties such non-personally identifiable information for the purpose of maintaining the site, responding to direct inquiries or measuring traffic and traffic trends at this site. LRN does not otherwise provide or sell any of this information to third parties.

Data Integrity & Data Security
LRN has taken commercially reasonable and appropriate steps to protect personal information that LRN collects, processes or maintains. These steps include, among other things, limiting the number of people who have physical access to LRN's database servers, utilizing electronic security systems, and using password protections which guard against unauthorized access. LRN employs these and other safeguards and practices to provide for the security of personal information in its possession, but cannot guarantee that such measures will be infallible. LRN also requires its vendors to take commercially reasonable and appropriate steps to protect personal information in their possession.

Correcting & Updating Personal Information
LRN is committed to ensuring that the personal information it collects, processes, and maintains is accurate. At the direction of, and in accordance with, the instructions of LRN's customers, LRN allows Users of LRN's Customer Web Sites to access their personal information in LRN's possession and to correct, amend, or delete inaccurate information. Users of LRN's Customer Web Sites who have questions about personal information on file with LRN may, if the customer so provides, access the Customer Web Site to make such corrections or may contact LRN at the address below.

Visitors to LRN's website may update, or request the deletion of, previously submitted personal information via the Contact page.

Cookies & Session IDs
LRN uses cookies to authenticate visitors to certain pages on www.lrn.com. LRN also uses cookies and session IDs to authenticate Users as they navigate various parts of Customer Web Sites. For example, cookies may be used to enable a User to move through a Customer Web Site without having to retype the User's password. Cookies and session IDs may also be used to automate certain data entry functions associated with Customer Web Sites. LRN does not obtain personal information via cookies or session IDs, and does not link any data collected through cookies or session IDs to any personal information.

Links
LRN web sites may contain links to other web sites. LRN is not responsible for the privacy practices or the content of such other sites.

Disclaimers
The services provided by Customer Web Sites do not constitute the rendering of legal services, and no attorney-client relationship is formed between LRN and any customer, or between LRN and any User, by virtue of such services. The information contained in Customer Web Sites is not intended to constitute legal advice or to substitute for obtaining appropriate legal advice.

This Privacy Statement describes LRN's privacy practices only. It does not describe, and LRN makes no representations about, the privacy practices of any other parties, including LRN's customers, who may receive personal information from LRN about Users associated with that customer in the course of LRN's performance of services for the customer.

Opt-out
Recipients may unsubscribe from future email communications from LRN by following the instructions in such communications.

Questions & Complaints
If anyone has any questions or complaints about this Privacy Statement, the practices of, or his or her dealings with, any of LRN's web sites, he or she should contact LRN at the following address:

Webmaster
LRN Corporation
1100 Glendon Avenue, Suite 700
Los Angeles, California 90024

A citizen of a country within the European Union may also address any privacy-related questions or problems to the appropriate data protection authority in his or her E.U. member state.

If an individual covered by this Privacy Statement has a complaint about the processing or use of that individual's personal information, and the complaint is not resolved to the individual's satisfaction through LRN's internal procedures, then LRN will make arrangements to offer an independent, third-party dispute resolution mechanism to resolve the complaint.

Business Transfers
In the event of a sale, assignment, liquidation or other transfer of all or substantially all of the stock, assets or business of LRN, personal information may be transferred to a relevant successor entity, subject to the applicable privacy policy.

Changes to this Privacy Statement
This Privacy Statement may be amended from time to time. When we do update the Privacy Statement, we will also revise the "Last Updated" date at the bottom of this document. Any changes to this Privacy Statement will be posted on LRN's website.

This Privacy Statement was last updated on October 26, 2006.

 
 
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LRN is a leading provider of solutions that foster corporate ethics and responsibility in the workplace. Our mission is to help companies establish and achieve the highest set of conduct standards through a comprehensive suite of ethics training programs.

Business ethics have become a major issue in contemporary business, and adherence to principled standards can help a company maintain the public trust. In the course of day-to-day business, challenges to an organization's code of conduct ethics can be numerous. At LRN, we know that an effective, business code of ethics must not only reflect the values of an organization, but manifest in each employee's individual actions and communications. For a code of conduct to remain relevant, it must reflect the latest business practices, legal research, and offer solutions to issues that threaten corporate ethics.

LRN specializes in removing the barriers to instituting an abiding code of conduct by providing informative seminars and online ethics courses on a variety of topics from an introduction to business ethics to corporate governance and accountability. For ethics-conscious organizations, a corporate compliance programs by LRN can inspire honorable conduct and a lasting, ethically sound, corporate culture.

LRN has provided ethics training programs to the world's largest organizations for over two decades. Our expertise also extends to OSHA compliance training, sexual harassment in the workplace prevention, enterprise risk management and HIPPA training.