APERIAN GLOBAL^® PRIVACY POLICY

This privacy policy applies to: https://gslearning.aperianglobal.com and https://globesmart.aperianglobal.com (collectively referred to herein as the "Aperian Global"), owned and operated by Aperian Global.^® This privacy policy describes how Aperian Global collects, shares and uses the personally identifiable information you provide on our web sites, consisting of https://gslearning.aperianglobal.com and https://globesmart.aperianglobal.com. This Privacy Policy also describes how we transfer and process your personal information, as well as your rights in determining what we do with the information that we collect or hold about you.

"Personally Identifiable Information" is defined as information that relates directly or indirectly to an identified or identifiable individual that uses our web sites ("you"). Personally Identifiable Information can include information such as your name, street address, email address, cookies, web beacons, and device identifiers, among other things. You are responsible for ensuring the accuracy of the Personally Identifiable Information you submit to Aperian Global. Inaccurate information may affect your ability to use our web sites, the information you receive when using them, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.

INFORMATION COLLECTED AND ITS USE

From our web sites' Registration pages: When a User registers one of our web sites, the following information is collected:

• User's internet protocol ("IP") address is collected for the purpose of system administration, to report traffic patterns through our web sites and their related web tools, and to audit the use of those sites and web tools (e.g. GlobeSmart^®, Global Teaming AssessmentSM, Learning Courses, Webcasts, etc.)
• User's name and email address are collected in order to allow a record of their activities in our websites to be available to them upon subsequent visits. These activities include, but are not limited to:
  • Results from the GlobeSmart ProfileSM
  • List of whom the User has invited to take the GlobeSmart^® Profile
  • Scores from Tests
  • Record of which Case Studies have been read
  • Optional Contributions
  • Password generated by the User is used to enable a secure log in procedure for the User when entering our websites.
  • Organizational Demographics may be collected by Aperian Global to provide Usage Reports to the User's organization broken down by the demographics selected by the organization (e.g. Business Unit, Region, Job Title, etc.)

From My Settings:

The following demographic information is collected either at the point of registration or prior to the use of one of our tools that makes use of demographic information as part of its function, such as the GlobeSmart Profile, GlobeSmart Leadership Assessment, GlobeSmart Teaming Assessment or the Ask a Question/Share My Experience features within GlobeSmart. This information also aids Aperian Global in its ongoing research efforts and is used for improvement of assessment tools.

• Home Country / Culture
• Job Type

Invite a Colleague

If a user chooses to use the Invite Others feature to compare GlobeSmart Profiles with their colleagues, they will be asked to enter their colleague(s) email address(es). An email will then be automatically sent to their colleagues inviting them to visit the site, complete their profile and share it with the user. Aperian Global stores this information for the sole purpose of sending this email and enabling the user to compare their profile with that of their colleagues.

Any individual invited to share their profile can send a request to Aperian Global at support@aperianglobal.com to have their personal information deleted at any time.

Other Information Collected: Aperian Global may also collect certain information about a User's computer hardware and software automatically and store it in log files. This information may include: User's IP address, browser type, device identifiers, domain names, access times and referring Web site addresses.

IP addresses may be used to identify a User whenever Aperian Global or their service providers are required to enforce their terms of use, their terms of service or to protect Aperian Global's service, GlobeSmart, or other Users.

We at Aperian Global and our partners use cookies or similar technologies to identify your device, provide website user authentication, conduct fraud prevention and management services, distinguish you from other visitors, record your IP address, and understand your use of our site. This information is used for fulfilling contracts with our business partners, and to help us serve you better by improving our website design, as well as our products and services. Users can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

Data Retention

Aperian Global will retain your information for as long as your account is active, as needed to provide you services and will use your information as necessary to comply with legal obligations, resolve disputes, and enforce agreements unless a longer retention period is required or permitted by law. Unless requested sooner, Aperian Global will delete all client and associated User information 6 months after the last end date of client's subscription.

THIRD PARTY LINKS: Our site contains several links to third party web sites. If a User clicks on an external link the click will transfer the user off Aperian Global. These third party sites may include sites of the User's organization and/or Aperian Global partners that may use Aperian Global and/or its affiliates' logo as part of a co-branding agreement. These third party sites may send their own cookies, collect data or solicit information. Please note that if you click on social media links that are featured on our site, such links may collect your IP address, which page you are currently visiting on our site, and may set a cookie to function properly.

Please note third party sites that are linked to GlobeSmart are not under the control of Aperian Global. Aperian Global and/or its affiliates are not responsible for the terms of use, policies or contents of any linked site, or any link contained in a linked site. Aperian Global has provided these links as a convenience. Aperian Global and/or its affiliates' inclusion of links to these sites does not imply any endorsement of the material on such sites or any association with their operators. Aperian Global's policy does not extend to any activities that are inherently related to the operation of the Internet (e.g. visiting different websites that are not related with Aperian), which is beyond Aperian Global and its affiliates' control.

Important Aperian Global highlights the importance of Users reviewing the Terms of Use and privacy policy of any linked site before sharing any Personal Information with them as such information can be collected and used by unknown people.

Single Sign-On: You may be able to log in to our web sites using Single Sign-On ("SSO"). These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form.

Service Providers: Aperian Global's computer servers are hosted by third party providers, which are SOC2 compliant and are prohibited from using personal information for any purpose. A complete list of Aperian Global's sub-processors can be found here: GlobeSmart Subprocessors and Subsidiaries

International Transfer

To facilitate our operations, we may transfer, store and process your personal information in jurisdictions other than where you live. Laws in these countries may differ from the laws applicable to your country of residence. For instance, if you are a European Economic Area (EEA) data subject and your personal information is shared with our affiliates, partners, or third-party service providers acting on our behalf outside of the EEA, then it is done so pursuant to necessary means to ensure an adequate level of protection.

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

Aperian Global participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. While Privacy Shield is no longer considered adequate by the EU Courts, we have elected to continue our certification to the US Department of Commerce because the framework helps to protect our users' personal information. We therefore remain committed to subjecting all personal data received from the European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework's applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce's Privacy Shield List.

Aperian Global is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and for subsequent transferring that data to third parties acting as agents on its behalf. Aperian Global complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, UK, and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Aperian Global is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the Privacy Shield Principles, Aperian Global commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Aperian Global at: privacydept@aperianglobal.com.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

SECURITY OF USERS' INFORMATION: The security for all Information associated with the users of our web sites is of utmost importance to Aperian Global. Once Aperian Global receives personally identifiable information from a User, it uses industry standard physical, technical and administrative measures to safeguard the confidentiality of the User's information. For example, Aperian Global stores and protects the personal information Users provide using computer systems with restricted access, located in controlled facilities using standard safeguards such as firewalls and secure socket layers.

Aperian Global and its service providers also exercise reasonable care in providing for secure transmission of information between a User's device and Aperian Global's servers. Aperian Global cannot, however, guarantee that data transmission over the Internet is 100% secure. If you have questions about the security of your personal information, or if you have reason to believe that the personal information that we hold about you is no longer secure, please contact us immediately as described in this Privacy Policy.

SHARING AND CONTROLLING USERS' INFORMATION: Aperian Global does not use and disclose personal information for purposes that are materially different from the purposes for which it was collected. We will share your Personal Data with third parties only in the ways that are described in this privacy statement. Aperian Global will provide individuals with reasonable mechanisms to exercise their choices. We do not sell your personal information to third parties. Aperian Global does not share personal information about Learning Portal and related web tool Users with parties outside the User's organization, Aperian Global and/or its affiliates and service providers. Aperian Global believes that Users should have control over the collection and use of their personal information. Therefore, Users have access to their information in the following areas of GlobeSmart:

• Account Settings: The Account Settings page in GlobeSmart allows Users to view and change their account information. On this page, Users can change their email, password, demographic- and other information collected in the Registration process. Aperian Global will respond within thirty days to all requests to provide access to personal information.
• GlobeSmart Profile: The GlobeSmart Profile page allows the User to re-take the survey at any time and share the resulting Profile with whomever the User chooses. Unless the User grants permission, their Profile will not be shared with anyone.
• Choice/Opt-out: Wherever users are provided the opportunity to 'opt-in' to receiving specific Aperian Global emails (e.g. newsletters), Users can opt-out of these emails at any time from My Settings / Account Settings or by following the Unsubscribe link at the bottom of the emails. There are certain system emails for which Users may not opt-out. These include the account activation email and invitations from colleagues or team members inviting them to share GlobeSmart Profiles.

Disclosure: In certain situations, Aperian Global may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We reserve the right to disclose your personal information as required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our web sites. If Aperian Global is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our web sites of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

ACCESS RIGHTS (EU/EEA data subjects): Upon request Aperian Global will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at privacydept@aperianglobal.com.

Upon request and within 30 days, Aperian Global will respond to individuals seeking reasonable access to personal information that it holds about them.

You also have the right to amend or update inaccurate or incomplete personal information, request deletion of your personal information, or request that we no longer use it. Aperian Global will take reasonable steps to permit individuals to correct, amend, or delete information unless we are exempted from doing so. If we deny your request, we will provide an explanation supported by an exception. Please contact support@aperianglobal.com to change your personal information gathered on our websites covered by this privacy policy. We will reply to your request in a reasonable time.

WHOM TO CONTACT: If Users have any questions about this Privacy Policy, they may contact Aperian Global at privacydept@aperianglobal.com.

CHANGES TO THIS POLICY: Aperian Global will occasionally update this Privacy Policy to reflect company and customer feedback, as well as evolving legal requirements. When Aperian Global posts changes to this Policy, you will see the word "updated" next to the Privacy policy link on the front page of the Aperian Global Learning Portal. If there are material changes to this Policy or in how Aperian Global will use your personal information, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. Aperian Global encourages you to periodically review this Policy to be informed of how Aperian Global is protecting your information. A User's continued use of our web sites following the posting of changes to these terms will mean that that User accepts those changes.

Please Note Nothing in the terms of this Privacy Policy or the act of engaging with our website services shall form a contract between Aperian Global and any of the Users. Aperian Global further confirms that it does not provide any warranties and does not accept any liability to any Users with respect to any advice provided in any part of the Aperian Global Learning Portal and related web tools.

Company Contact Information Attn: Privacy Officer, Aperian Global, 414 Fayetteville Street, 4th Floor, Raleigh, NC 27601 privacydept@aperianglobal.com