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Privacy Policy

Privacy Policy (last revised on April 8, 2015)

Introduction

The Declara™ Platform (our “Platform”) is a cloud-based innovative social learning service that you can access

though any internet-connected device, including your laptop, tablet, or smartphone.

The Declara Enterprise Edition™ of the Platform uses machine learning, search, and algorithms to help employees

connect to the right content, groups, and individuals to accelerate learning. Our clients include enterprises,

governments, unions, and other institutions whose users are teachers, students, knowledge workers (like managers,

accountants, consultants, health care professionals, lawyers, scientists, regulators, designers, architects, journalists,

and others), group members, and other constituents.

Our Platform simplifies everyday learning so you can drive your future™.

This Privacy Policy

Thank you for being a user of our services, which include our Platform, applications, beta versions, and websites

(collectively, “Services”), and for reading this Privacy Policy (this “Policy”) of Declara, Inc. (“Declara,” “we,” “us,” “our,”

or the “Company”).

This Policy applies to all of our Services, and describes how we collect, use, and disclose information we obtain

about the Services, and about users of the Services.

This Policy is a part of and is incorporated into our User Agreement (we refer to the User Agreement and the Privacy

Policy as the “Terms of Service” or as this “Agreement”). By using any of our Services, you agree (i) to comply with

the User Agreement, including this Policy, (ii) that your personal information will be handled as described in this

Policy (and the User Agreement); (iii) that the applicable limitations on damages and the resolution of disputes, as

well as other applicable terms of the User Agreement, apply to this Policy; and (iv) that any dispute over privacy is

subject to this Policy (and the User Agreement). You agree that this Policy, like the User Agreement of which it is a

part, applies to you and is effective from the first day you accessed any of our Services.

Information We Collect

We collect information so that we can better serve our users and customers, enhance our Services, create new

products, and benefit our business. You can browse certain portions of our websites without registering. However, to

use many of our Services you must be a registered user. We collect the information in at least three ways:

 Information you share with us. To get the most from our Services, we ask you to create a Profile and

provide your name, user ID, email address, and other personal information. This may include profile

information from social networks through which you create an account or access our Services, and the other

information made available to third parties by those networks. Depending on the Service you are using (and

whether you are using the Declara Enterprise Edition™ of our Platform through your employer or another

entity), we may also ask for your job title, employer, employee ID, government identifiers, education history,

work history, demographic information, and other personal information. We may also collect information that

you provide us when you communicate with us, whether you do so through the Services, send us messages

via a chat feature, email us, or otherwise.

 Information from your use of our Services. Our Platform personalizes your learning journey in a number

of ways. For example, it recommends relevant experts for you to follow based on factors like which other

experts you follow and the searches you conduct. It also learns how you learn, paying attention to whether

you prefer to watch a video, read an in-depth article, or scan a short summary. It does these things by taking

into account how you access and use the Services, which may include collecting information such as:

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 Device information about the devices you use to access the Services, such as your operating

system, hardware, mobile network, phone number, and unique device identifier such as an IMEI

number.

 Log information, which helps us to learn what interests you based on links you click and searches

you conduct, details about your navigation through our Services, the dates and times of your

activity, referral URLs, cookies and similar technology, Flash local shared objects, web beacons,

your IP addresses, browser type, languages, hardware settings, device events like crashes and

system activity, server logs, digital certificates, and certification numbers.

 Location information, such as GPS, WiFi, and satellite signals, location metadata from content

you upload to or share using the Services, such as links, articles, pictures, and so on, and if you

access our Services from a mobile device, we may ask for your location information from that

device.

 Features You Use, such as your collections, courses, questions, answers, insights, posts, chats,

communications, content you create, curate, and share, and related information (including, for

example, metadata associated with that content). When you access our Services via another social

network, that other network may make personal information available to us.

 Information from others. If you’re using Declara Enterprise Edition, you are accessing the Services though

your employer or another entity, which may share with us information like your job title, department,

employee ID number, work-related activities, and advancement opportunities. We may also collect

information from other users who communicate with you through the Services, by posting, commenting,

chatting, or otherwise.

We may combine collected information, both on an aggregated and individualized basis, with other information about

you and/or others from third parties, including for example information from research, marketing, advertising, and/or

similar or related entities, their respective affiliates, and others with whom they do business.

Use of Your Information

We use your information, including your personal information, for the following purposes:

 To provide you with our Services;

 To personalize our Services for you and make highly relevant and context-aware the information,

recommendations, and experts we share with and identify for you.

 To communicate with you about your use of our Services (including via email), to respond to your inquiries,

and for other customer relationship purposes.

 To better understand how users access and use our Services, both on an aggregated and individualized

basis, in order to improve our Services; to respond to user desires and preferences; to develop reports for

our customers; and for other research and analytical purposes.

 To tailor the content, information, and recommendations that we may send or display to you, to offer

personalized help and instructions, and to otherwise personalize your experiences while using our Services.

 To develop reports and related analysis regarding user activities.

 To provide you with recommended reading, video and other media, links, information, people (such as

experts), and other learning opportunities we think may interest you, and (unless you are using the

Enterprise Edition) to contact you about products and services, and for other marketing and promotional

purposes.

 As required by law.

Sharing Your Information

We may share your information, including personal information, with others as follows:

 Other Users and Visitors. Any information that you include in your posts, collections, courses, questions,

answers, insights, comments, and other features of the Services, including without limitation your name,

content, and text, all of which may be available to, and searchable by, other users and visitors to our website

and other Services.

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 Your Entity and System Administrator. If you are using Declara Enterprise Edition, we may share

information we collect about you with the institution or other entity with which you are affiliated (e.g., your

employer or university), including without limitation any reports or other analysis. If you are using Declara

Enterprise Edition, your account is managed for you by a domain administrator, who may be able to:

 View statistics regarding your Enterprise Edition account, like statistics regarding applications you

install.

 Change your Enterprise Edition account password.

 Suspend or terminate your Enterprise Edition account access.

 Access or retain information stored as part of your Enterprise Edition account.

 Receive your account information in order to satisfy applicable law, regulation, legal process or

enforceable governmental request.

 Restrict your ability to delete or edit information or privacy settings.

Please refer to your domain administrator’s privacy policy for more information.

 Affiliates. We may disclose the information we collect about you to our subsidiaries, affiliates, and others

with whom we do business. If we do so, their use and disclosure of your personal information will be subject

to this Policy.

 Service Providers. We may disclose the information we collect about you to third-party vendors, service

providers, contractors, and/or agents who perform functions on our behalf.

 Third Parties. We may share information we collect about you with third parties for their research,

educational, and/or similar or related purposes. Unless you are using the Enterprise Edition of our Platform,

we may share such information with third parties for business, marketing, advertising, and other promotional

purposes.

 Business Transfers. If we are acquired by or merged with another company, if substantially all of our

assets are transferred to another company, or as part of any bankruptcy proceeding, we may transfer the

information we have collected about you as part of any such transaction or proceeding.

 Legal Process. We may disclose the information we collect about you in order to comply with the law, a

judicial proceeding, court order, or other legal, quasi-legal, or regulatory process or requirement with which

we reasonably believe we should comply, such as in response to a subpoena or upon advice of our legal

counsel.

 To Protect Us and Others. We may disclose the information we collect about you where we believe it is

necessary to investigate, prevent, or take action regarding situations involving potential threats to the safety

of any person, illegal activities, suspected fraud, violations of our User Agreement (including without

limitation this Policy), or in connection with threatened or actual litigation (or any other mediation or dispute

resolution process) in which we or any of our subsidiaries or affiliates are involved.

 Aggregated and De-Identified Information. We may share aggregated or de-identified information about

users with third parties for research, business, educational, marketing, advertising, promotional, and/or

similar or related purposes.

User-Generated Content

You may be able to post or otherwise share content using our Services, including without limitation your comments,

works of authorship, pictures, and any other information that you would like to be available. If you post content to our

Services, all of the information that you post may become available to all users of our Services, or visitors to our

websites. If you post your own content, your posting may become public and Declara cannot prevent such

information from being used in a manner that may violate this Policy, the law, or your personal privacy.

Third-Party Links

Our Services may contain links to third-party websites. Any access to and use of such linked websites is not

governed by this Policy but instead is governed by the privacy policies of those third-party websites. Declara is not

responsible for the information practices of such third-party websites.

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Security

We have implemented safeguards to protect the information we collect from loss, misuse, unauthorized access,

disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can

guarantee 100% security.

You should take steps to protect against unauthorized access to your password, mobile devices, and computers by,

among other things, choosing a robust password that nobody else knows or can easily guess, keeping your log-in

and password private, and signing off after using a shared computer. We are not responsible for any lost, stolen, or

compromised passwords or for any activity on your account via unauthorized password activity.

Access to My Information

You may modify the profile information that you have submitted by logging into your account and updating your profile

information. Please note that copies of information that you have updated, modified, or deleted may remain viewable

in cached and archived pages for a period of time, and we may also retain a copy of such information in our systems

and servers.

International Transfers

We may transfer the information we collect about you to other countries, including without limitation the United States

where Declara is located, which may provide a different level of data protection as in your home country. Your data

also may be subject to access by law enforcement and other government entities, including courts and tribunals in

accordance with the laws applicable in those jurisdictions.

Your Choices

We may send periodic promotional or informational emails to you. You may opt out of such communications by

following the opt-out instructions contained in the email or contacting us at privacy@declara.com. Please note that it

may take up to ten (10) business days for us to process opt-out requests. If you opt out of receiving emails about

recommendations or other information we think may interest you, we may still send you emails about your account or

any services you have requested or received from us.

Special Information for California Consumers

California residents may request a list of certain third parties to which we have disclosed personally identifiable

information about you for their own direct marketing purposes. You may make one request per calendar year. In your

request, please attest to the fact that you are a California resident and provide a current California address for your

response. You may request this information in writing by contacting us at: privacy@declara.com. Please allow up to

thirty (30) days for a response.

Children Under 13

Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with

personal information, we will revoke the child’s access and remove such information from our Services.

Tracking

We and our service providers use cookies and other tracking mechanisms to track information about your use of our

Services and may combine this information with other personal information we, or our service providers, collect from

you. Here is some information about tracking:

 Do-Not-Track Signals. We do not track your activities after you leave our Services. While using our

Services, you may disable certain tracking as discussed below (e.g., by disabling cookies), although many of

our Services will not function properly with cookies disabled. So-called “do-not-track” requests are not

recognized.

 Cookies. We or our service providers use cookies to track visitor activity on our platform. A cookie is a text

file that a website transfers to your computer’s hard drive for record-keeping purposes. We or our service

providers use cookies to track user activities on our Services, such as the pages visited and time spent on

our Services. Most browsers allow users to refuse cookies. The Help portion of the toolbar on most browsers

will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you

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when you receive a new cookie, or how to disable cookies altogether. Many of our Services will not function

properly with cookies disabled.

 Local Storage Objects. We may use Flash Local Storage Objects (“Flash LSOs”) to store your preferences

and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and

type of data stored. Typically, you cannot control, delete, or disable Flash LSOs through your web browser.

For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the

Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions

 Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier,

similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear

GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel

tags), in connection with our Services to, among other things, track the activities of users, help us manage

content, and compile statistics about usage. We or our service providers may also use clear GIFs in HTML

emails to our customers, to help us track email response rates, identify when our emails are viewed, and

track whether our emails are forwarded.

 Third-Party Analytics. We or our service providers may use automated devices and applications, such as

Google Analytics, to evaluate usage of our Services. We also may use other analytic means to evaluate our

Services. We use these tools to help us improve our Services, performance, and user experiences. These

entities may use cookies and other tracking technologies to perform their services. We may share your

personal information with these third parties.

 

Contact Us

If you have questions or comments about this Policy or the privacy aspects of our Services, please contact us at:

Declara, Inc.

977 Commercial St.

Palo Alto, CA 94303 USA

Attn: Chief Legal Officer

1-877-216-0604

privacy@declara.com

Changes to this Policy

This Policy is current as of the date it was last modified as set forth above. We may change this Policy from time to

time, so please be sure to check back periodically. We will post any changes to this Policy at

www.declara.com/privacypolicy. If we make any changes to this Policy that materially affect our practices with

regard to the personal information we have previously collected from you, we will endeavor to provide you with notice

in advance of such change by announcing the change on our Services or otherwise notifying you as indicated in the

User Agreement.

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