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Credly Privacy PolicyRevised: January 22, 2013

Credly, Inc. (“Credly” or "we") provides a badge-based microcredentialing service utilizing various tools, including, but not limited to, the Credly website at https://credly.com and related mobile apps, that allows users to interact online and issue and receive badges (the “Service”). Credly respects your preferences concerning the treatment of information that we may collect from and during your use of the Service. This Privacy Policy lets you know how we may collect, use, and share your information, and the choices available to you to control how we collect, use, or share your information. This Privacy Policy describes the broadest potential use of your information throughout the Service that is consistent with the terms of this policy. However, please note that we may make far less use of your information.

TYPES OF INFORMATION WE COLLECT AND HOW WE COLLECT IT

At the outset, we would like to inform you that the information we collect about you, whether it is supplied directly to us by you or received by us from third-parties (as discussed in more detail below), may include information that identifies you personally or that may not identify you personally. Accordingly, when we refer to information about you in this Privacy Policy it may include both categories of information.

Information That You Give Us. When registering for or using the Service, you may be prompted to give us information about yourself. For example, when you register for an account, you must provide us with your name and e-mail address. When you configure your account settings, you may enter additional information about yourself. You may also select user configuration settings that determine how the Service looks and functions. You may, at times, also send us an e-mail which may contain not only your e-mail address, but other information about you including home or business addresses, telephone numbers, or account details. The information you give us may also include statements you make on the Service or Credly website such as testimonials, services reviews, or other statements. As such, any testimonials, service reviews, or statements you make may identify you personally.

Information about You Received from Third-Party Services or Other Users. If you log in to the Service using credentials associated with your account at third-party services such as Facebook, LinkedIn or Twitter (collectively, “Third Party Service”), you allow Credly to access certain information associated with your account with the Third-Party Service. The information you allow us to access may vary according to the privacy settings you establish at the Third-Party Service. We encourage you to review the privacy policies of any Third Party Services from which you access the Service. In addition, if you utilize a Third-Party Service to log in to the Service, other users to whom you may be connected through such Third-Party Service may be able to see that you are a user of the Service or may be able to view or follow information about you on the Service. Other users of the Service may also make statements about you on the Service or Credly website such as testimonials, services reviews, or other statements. As such, any testimonials, service reviews, or statements made about you by other users may include information about you that identifies you personally.

Electronic Communications Protocols and Web Beacons. We may collect information about you and your use of the Service through electronic communications protocols, web beacons, cookies, embedded URLs, pixel tags and related devices or technologies. As is true when you visit most websites, certain information is automatically generated and stored about your visits to such websites. As such, Credly may automatically receive information from you as part of the communication connection itself between you and Credly or the Service. This type of information may include: network routing information (for example, where you came from); equipment information (for example, device type, operating system, browser type); your internet protocol (“IP”) address, and the dates and times of your visits.

Credly Cookies. Credly's server will query your browser to see if there are "cookies" previously set by the Service. A cookie is a small piece of information sent by a web server that is stored on your computer by a web browser so that it can later be read back from that browser or Credly’s server. The main purpose of cookies is to facilitate and enhance communications and interactions between you and the website, but cookies can be used for other purposes as well. Cookies for the Service may collect a unique identifier, user configuration settings and profile information. Credly also uses cookies to collect general usage and volume statistical information that does not include personally identifiable information. Some cookies may remain on a user's computer after the user leaves the website. While we do not offer an opt-out for cookies, browsers provide you with information on and control over cookies, including a feature to opt-out of the use or storage of cookies. You can set your browser to alert you when a cookie is being used, and accept or reject the cookie. You can also set your browser to refuse all cookies or accept only cookies returned to the originating servers. However, you may not be able to use some features of the Service if you disable cookies.

Third-Party Cookies and Functions. Credly may use third-party advertisers to serve or track advertisements on or within the Service. These third parties may use cookies, pixel tags and other technologies to, among other things, enable themselves to record which ads your browser has loaded and which pages you may have been viewing when the ads were delivered or accessed. The information collected through these functions is subject to the privacy policies of those third parties which you should carefully review.

Location Based Services. The device you use to access the Service may provide your location to the Service. If the feature is enabled, we will automatically receive information about your location when you use the Service.

USE AND SHARING OF YOUR INFORMATION

Credly will use and share information about you consistent with this Privacy Policy. You consent to our use and disclosure of any information submitted to us via the Service, or information collected when you access the Service in any manner, and you acknowledge that you have no expectation of privacy, confidentiality or privilege in such information. Credly uses and, where specified, shares your information for the following purposes:

To issue, process and display Credit. Credly may use your information to determine whether you meet the criteria for receipt of a Credit (as defined in the Terms of Service). For example, the issuance of Credit may be based upon your attendance of an event at a particular time and location. Your information, including location information from your device or the event’s organizer, may be used to confirm whether you meet the criteria for receipt of such a Credit. Credly may also use information that you provide to confirm your identity, and to display Credit that you receive on the Service or on Third Party services, such as through Credly’s or others’ application programming interfaces used by Third Parties, embeds that you may make on Credly’s or Third Parties’ sites, or on social network services you might link to your account.

To provide support or other services. Credly may use your information to provide you with support or other services that you have requested. In addition, Credly may use your information to respond to your inquiries or requests for information.

To engage in transactions. Credly may use your personally identifiable information such as name, physical address, telephone number, e-mail address and/or company/institution to engage in transactions with you, including contacting you about your account or transactions.

To process transactions. Credly may use financial, credit card and payment information that you provide to process your transactions. Credly may need to share some of this information with suppliers, delivery services, credit card clearing houses and other third parties to complete the transactions.

To interact with Third-Party Services. If you choose to log in using an account from a Third-Party Service, Credly may contact you via an e-mail address associated with your account at the Third-Party Service and post status updates, notes, photos, videos and other materials to the Third-Party Service on your behalf pursuant to the permissions that you grant.

To tailor advertising to your needs and respond to your requests. Credly may use your information to provide you with notices regarding new product releases and service developments and serve advertisements that may be of interest to you. Credly may also use your information to respond directly to your requests for information, including registrations for newsletters or other specific requests.

To provide online forums and social networks. The Service allows users to participate in interactive discussions and post comments and other content. You should carefully consider whether you wish to submit personal information in these settings because any information you share may become publicly accessible. You should tailor any content you submit accordingly.

To improve quality and facilitate use of the Service. Credly may use your information, including the information gathered as a result of site navigation and electronic protocols and cookies (including third-party cookies), to improve the quality of the Service, to better serve you and enhance your experience with the Service, and to track marketing campaign responsiveness and evaluate page response rates. The foregoing uses may include our having to modify or copy the information you provide, such as, for example, textual or narrative content, images, or video content.

To operate the Service through the assistance of third parties. Credly may use third-party services, such as hosting services and software developers, in support of its operation of the Service. When doing so, we will take steps to ensure that such service providers comply with this Privacy Policy and implement appropriate measures to safeguard against the unauthorized disclosure of your information.

To comply with legal requirements. Credly may disclose your information to comply with laws, court orders, litigation or other legal requirements or processes, and/or in response to requests from governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our rights or protect our operations or users.

To provide investors and others with aggregated information. We may provide our investors, partners, affiliates and others with aggregated information (information that does not identify users personally) concerning users of the Service. Such aggregate information may include number of users, countries of residence, average page views per session and average length of time as a member.

To facilitate a merger or acquisition. Credly may disclose your information to a successor or acquiring entity as part of a merger, acquisition, reorganization or other transaction involving all or substantially all of Credly’s assets.

PRIVACY PREFERENCES

The Service provides tools for you to customize the information about yourself that is made accessible to others. You can set global values that apply generally, or you can customize selections to fine tune your preferences. Note, however, that the Service applies default settings when you establish an account, and those default settings will apply unless you change them. Default settings will also apply when the Service introduces new features. Certain information about yourself, such as your full name, is always available to others on the Service, and your use of the Service indicates your acceptance of these settings. You should review your privacy preferences regularly to ensure that the settings match your preferences.

SECURITY

We use reasonable efforts to secure access to your information in our possession, but will not be liable for any failure to safeguard such information, whether inadvertent or otherwise. Your information may, at times, be stored with third parties who have informed us that they also use reasonable efforts to secure access to individuals’ information, but we will not be liable for the failure of any third party to safeguard such information, whether inadvertent or otherwise.

We protect the security of your information during transmission by using Secure Sockets Layer (SSL) software or other encryption technology, which encrypts information you input. Wherever appropriate, we obfuscate and/or encrypt information in our systems and/or during information transfer.

It is important for you to protect against unauthorized access to your password to the Service and to your computer. Be sure to log off the Service when finished using a shared computer.

GENERAL

Your California Privacy Rights. Under California Civil Code Section 1798.83, if you are a California resident and your business relationship with Credly is primarily for personal, family or household purposes, you may request certain data regarding Credly’s disclosure, if any, of personal information to third parties for the third parties’ direct marketing purposes. To make such a request, please send an e-mail message to privacy@credly.com with "Request for California Privacy Information" in the subject line of your email. You may make such a request up to once per calendar year. If applicable, we will provide you, by e-mail, a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the third parties' names and addresses. Please note that not all personal information sharing is covered by Section 1798.83's requirements.

Third-Party Sites. The Service may provide links to third-party sites. Those sites are beyond our control. Your interactions with those third parties are subject to their privacy policies and terms of use.

Transfer of Information to Other Countries. Credly’s processing and storage of the information about you that it collects may involve the transfer of that information to various countries around the world, including countries other than the one in which you reside. By submitting your information to Credly via the Service, you consent to such transfers and to the processing and storage of that information in various countries around the world, including countries other than the one in which you reside.

No Use by Minors. The Service is intended for use by adults only. In connection with the Service, Credly does not promote online to children and does not intentionally collect any personally identifiable information from children under the age of thirteen (13). If you believe that a person under the age of thirteen (13), has disclosed personally identifiable information through the Service, please report this to us immediately by emailing us at: privacy@credly.com with “Notice of Underage Person” in the subject line of your email.

Applicable Law and Jurisdiction. This Privacy Policy shall be governed by, construed and entered in accordance with the laws of the State of New York applicable to contracts deemed to be made within such state, without regard to choice of law or conflict of law provisions thereof. All disputes with respect to this Privacy Policy shall be brought and heard either in the New York State Courts located in the county of New York, New York, or the federal district court for the Southern District of New York. You consent to the in personam jurisdiction and venue of such courts. YOU HEREBY WAIVE YOUR RIGHT TO A TRIAL BY JURY WITH RESPECT TO ANY CLAIM, ACTION OR PROCEEDING, DIRECTLY OR INDIRECTLY, ARISING OUT OF, OR RELATING TO, THIS AGREEMENT TO THE FULLEST EXTENT PERMITTED BY LAW.

Policy Updates. We may, in our sole discretion, update this Privacy Policy from time to time, and the updated version of this Privacy Policy will be effective upon posting. Please check this page periodically to review the most up-to-date version of this Privacy Policy. By continuing to use the Service after an updated version has been posted, you agree to be bound by the new Privacy Policy.