1. OUR COMMITMENT TO YOUR PRIVACY

SkillSoft and its subsidiaries and affiliates (“SkillSoft”) are committed to respecting your privacy, and providing a secure environment in which you can participate in on-line activities is important to us. This Policy discloses our privacy practices and expresses our commitment to keeping you informed of the information we collect and how it is used. We ask that you take time to read it carefully. We may update this Policy from time to time to reflect new uses, rules, regulations or technologies that impact your privacy. We recommend that users review our Policy on a routine basis to view any changes.

SkillSoft is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent, non-profit organization whose mission it is to build user trust and confidence in the Internet. Because SkillSoft wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and to have its privacy practices reviewed for compliance by TRUSTe. By displaying the TRUSTe trustmark, SkillSoft has agreed to notify you of: what personally identifiable information is collected; the organization collecting the information; how the information is used; with whom the information may be shared; what choices are available to you regarding collection, use and distribution of the information; the kinds of security procedures in place to protect against the loss, misuse or alteration of information under SkillSoft’s control; and how you can correct any inaccuracies in the information.

SkillSoft complies with the safe harbor privacy framework as set forth by the U.S. Department of Commerce.

2. THE INFORMATION WE COLLECT AND HOW IT IS USED

You make the decision whether or not to proceed with any activity that requests personal information, but please be aware that if you choose not to provide the information requested, you may not be able to complete certain transactions with SkillSoft.

Sometimes, such as when you register for a service, order a product, or make other inquiries, we will ask for specific information about you in order to provide that product or service to you. We will need certain personally identifiable information such as name, contact and billing information.

In order to tailor subsequent communications to you and to continually improve SkillSoft offerings, we may also ask you to provide information regarding your personal or professional interests, demographics, past experience with SkillSoft products and services, and detailed contact preferences. We do, however, provide our users a choice as to whether or not they would like to receive these communications. Please see our Choice and Opt-In section.

Users may from time to time receive up-to-date information on products and services via our e-mail newsletter. Again, out of respect for your privacy, we give users the choice to opt-in to receiving these communications. Please see our Choice and Opt-In section.

We may also periodically conduct business and individual user surveys because they provide us with important information that helps us to improve our products and services. Participation in such surveys is completely voluntary and you, therefore, have a choice whether or not to disclose this information. Any personal information submitted in response to a survey will remain strictly confidential.

Data you submit online may also be combined with other information you provide through other means of communication, such as postal mail.

Some SkillSoft Web pages use cookies. Cookies are small data files that are transferred from a Web server to your browser. This file contains information that may later be read back by the Web server for record keeping purposes. Use of cookies is standard on the Web and can improve the service a Web site provides to you because content can be prepared to suit your preferences. Cookies are useful, for example, to facilitate a regular visitor’s use of a site by eliminating the need to repeatedly type in a password, and to store preferences on a personalized site. This type of information is not used to personally identify an individual, and you remain anonymous. You may modify your browser to reject cookies or to notify you whenever a cookie is sent to your hard drive. If you reject a cookie sent by SkillSoft, you may still access the site, but such access may be limited.

3. CHOICE/OPT-IN

We will not use your personal information for purposes not directly related to products and services you’ve requested unless you direct us to do so by opting-in at the point where the information is collected. Additionally, if after agreeing to any particular secondary uses of your information, you change your mind, you may opt-out in the “Personalize My e-Learning” area of the site or by contacting us through one of the methods described in section 9 below.

4. SHARING OF INFORMATION

Unless SkillSoft has your permission or is required by law, SkillSoft will not sell, rent, lease or otherwise provide your personally identifiable information to others, except in order to provide you with the products and services you request. SkillSoft will only share the personal data you provide online with other SkillSoft entities and/or outside contractors who may be used to ship products, provide technical support, handle order processing, or otherwise act on SkillSoft’s behalf for the purpose of providing products and services.

Please remember that when you submit information to a discussion group or some other public forum, the information submitted will be deemed public information and will not be considered confidential.

5. LINKS

SkillSoft may provide you with links to other sites. Please be aware that SkillSoft is not responsible for the privacy practices of these sites. SkillSoft does not endorse them or make any representations about them or any information, services, products or materials found on them. If you decide to access any of the third party sites through links, we strongly encourage you to read their privacy statements.

6. DATA SECURITY

SkillSoft is committed to ensuring the security of your information. We use encryption technology, privacy protection controls and restrictions on employee access in order to safeguard your personal information.

Because SkillSoft is a global company, we may provide company information to our worldwide offices. The personal information you provide may be transferred to other SkillSoft offices around the world. Also, in certain countries, SkillSoft’s outside contractors might undertake the collection, transferring and storage and processing of your information.

Every SkillSoft employee must abide by our Privacy Policy. Only authorized employees will have access to your personal information and such access is limited to a need-to-know basis. If, for example, you call us with a concern or complaint, the SkillSoft representative is allowed to access the personal information that s/he requires to address your particular concern.

7. HOW TO ACCESS AND CORRECT YOUR INFORMATION

SkillSoft strives to keep your personally identifiable information accurate and up-to-date. Should you find inaccuracies in your personally identifiable information, please contact us through one of the communication methods described below in Section 9.

8. NOTIFICATION OF CHANGES

SkillSoft reserves the right to make changes to this privacy policy. If we make any changes that result in the use of personally identifiable information in a manner different from that stated at the time of collection, we will first notify you via e-mail and provide you with the choice as to whether or not you will allow us to use your information in this different manner. In the event there is a material change in our privacy practices that does not affect user information already stored in our database, a notice will be posted on our web site notifying all users of the change.

9. CONTACTING US WITH COMMENTS AND CONCERNS

We welcome your comments. Should you have any questions or concerns about our Privacy Policy, please contact us: via e-mail at support@skillsoft.com, by telephone at (866) 754-5435, or by mail to: SkillSoft, Attn: SkillSoft Contracts Department, 107 Northeastern Boulevard, Nashua, NH 03062.

If you feel that SkillSoft is not abiding by this privacy policy, you should first contact us by the means listed above. If your inquiry has not been satisfactorily addressed, you should then contact TRUSTe at http://www.truste.org/watchdog.html. TRUSTe will then serve as a liaison with the Web site to resolve your concerns.