Last Updated: 2/6/2023

We at Degreed, Inc. (“Degreed”, “we”, “us” or “our”) are committed to respecting the privacy of our users. We strive to provide a safe, secure online experience. This privacy policy sets forth the online data collection, usage, maintenance, disclosure and protection policies and practices that apply whenever you visit or your personal information is disclosed in connection with the Degreed.com website (together: “Site“) and functionality provided through or in connection with it, such as our Degreed social media channels, emails, events, forms and served ads (“Services“). We are not responsible for the privacy policies or practices of other websites to which links are included on this Site.

This privacy policy does not set forth the online data collection, usage, maintenance, disclosure that apply to users of the Degreed or LearnIn applications. This information is presented in the privacy policies available when accessing the respective applications.

What Types of Information Do We Collect?

When you visit our Site and use our Services we may receive personal information relating to you. “Personal Information” is information that can directly or indirectly identify you or could reasonably be linked with you or your household, such as your first name, last name, business email address, social media handles, telephone number or payment information (if you register for a paid event that we run).

We may also receive other information relating to you or your device used to access our Site or Services which may also be considered Personal Information, such as your IP address, device type, operating system, browser type, and other technical information.

How Do We Get Information About You?

If you provide us with information about another person then you must make sure you are authorized to provide this information to us.

How Do We Use the Information We Collect?
Here are the ways in which we use the information we collect:

In general, we will only use your Personal Information for the purposes described in this privacy policy or for purposes that we explain to you at the time we collect your Personal Information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you if and where this is permitted by applicable law.

Legal basis for processing Personal Information

Our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

Whenever applicable laws require a specific legal basis for collecting or processing Personal Information, and in particular if you are in the European Economic Area or the United Kingdom, we will only collect Personal Information from you where the processing is in our or in a third party’s legitimate interests and not overridden by your rights, where we have your consent to do so or whenever it is necessary for the performance of a contract with you or to take the steps necessary to enter in such contract. In some cases, we may also have a legal obligation to collect Personal Information from you or may otherwise need the Personal Information to protect your vital interests or those of another person. If we rely on our legitimate interests, this interest is related to the performing of the processing activities identified above.

How Do We Share Your Information?
Degreed will not share Personal Information with third-parties except in limited circumstances and where this is permitted by applicable law.

Cross border transfers of your Personal Information

We will ensure that any overseas recipient will process your such Personal Information in a way that is consistent with our obligations under applicable laws.

We use third party service providers, many of whom process your Personal Information overseas. We may use one or more third party service providers to perform the same or similar services for us in the future.

Where your data is transferred between Degreed and its affiliates or other third parties, we take appropriate safeguards to ensure that your Personal Information will remain protected in accordance with this Privacy Policy and applicable laws. For transfers of personal data from the European Economic Area or the United Kingdom) data is transferred relying on the European Commission’s Standard Contractual Clauses (for EEA data) as well the International data transfer addendum to the European Commission’s standard contractual clauses for international data transfers(for UK data), which require Personal Information transferred outside the EEA or the United Kingdom to be processed in accordance with EU and/or UK data protection law. We may also rely on another appropriate mechanism according to applicable laws for the transfer of data internationally, such as adequacy decisions by competent authorities which authorizes transfers of data to certain countries or territories.

How Can You Change Your Information Collection Preferences?
You can choose not to provide certain data to us, but you may not be able to use certain features of our Services.

• To stop receiving email communications from us, you can opt out by using the unsubscribe mechanism in the footer section of the email you have received. Note that you may still receive transactional messages regarding our Site and Services from us, including administrative confirmations, order confirmations, important updates about our Services, and notices about our policies.
• For Personal Information received through cookies or other similar technologies the browser or device you use may allow you to control cookies and other types of local data storage. Your wireless device may also allow you to control whether location or other data is collected and shared. You can manage the Degreed cookies through the Osano Cookie Consent tool on the bottom-right side of our website. For further information about how you can control Cookies, please see our Cookie Notice.

How Long Is Your Information Retained?
Degreed retains user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the category of user to whom the data relates, the type of data, and the purposes for which we collected the data.

We retain Personal Information data collected through our Site for up to 3 years.

Users may request deletion of their Personal Information at any time by emailing privacy@degreed.com.

Cookies
We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use Personal Information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice.

How Do We Secure and Protect Your Information?
When you submit information to Degreed, we do our utmost to ensure that information is protected against loss, misuse, alteration, destruction or unauthorized access. Degreed implements technical and organizational measures to protect information, which include appropriate privacy and security policies, training and awareness initiatives, strong access control, up-to-date anti-virus software and industry standard authentication methods for accessing the data. Degreed also uses standard encryption tools such as SSL (Secure Socket Layer) to help protect Personal Information and to keep information collected secure.

Children Under 18 Years of Age
Our Site and Services are intended for adult professionals. Our Site and Services and materials featured on them are not intended for, and we do not intend to collect information from, children under the age of 18. If we learn we have collected or received Personal Information from a child under the age of 18, we will delete that information. If you believe we might have any information from or about a child under the age of 18, please contact us at privacy@degreed.com.

Notice to EU Citizens
For users located in the European Economic Area, Switzerland or the United Kingdom (collectively, “European Users“), If a European User accesses or uses our Site or Services, Degreed is the “data controller” of their Personal Information and we perform any processing of your Personal Information in accordance with this privacy policy.

European Users have data protection rights. These rights include:

• Right of access: The right to obtain access to your Personal Information.
• Right to rectification: The right to correct or update inaccurate or incomplete Personal Information.
• Right to erasure: The right to obtain the erasure of your Personal Information in certain circumstances.
• Right to portability:* The right to move, copy, or transfer your Personal Information.
• Right to restrict processing: The right to restrict processing of your Personal Information.
• Right to object to processing: The right to object to processing of your Personal Information for certain purposes.
• Right to withdraw consent: The right to withdraw your consent to the processing of your Personal Information where we have relied upon your consent to do so.

To exercise any of the rights outlined above, please contact us at privacy@degreed.com.

Please be advised, we may need to request specific information from you to confirm your identity before processing your request.

If we are unable to satisfactorily resolve your request you have the right to lodge a complaint with a supervisory authority. If you are in the European Economic Area you may contact your local data protection authority. You can find details for your local data protection authority by visiting https://edpb.europa.eu/about-edpb/board/members_en, telephoning +32 2 299 11 11, or writing to Directorate-General for Justice and Consumers | European Commission at 1049 Bruxelles/Brussel, Belgium.

If you are in the United Kingdom you may contact the Information Commissioner’s Office by visiting https://ico.org.uk/global/contact-us/, telephoning +44 (0) 303 123 1113 or writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Notice to California and Virginia Residents
If you are a California or Virginia resident, the following information also applies to you and supplements the information contained elsewhere in this privacy policy.

Information we collect and sources of Personal Information

This privacy policy already describes the Personal Information we collect and the sources of Personal Information – see the sections above “What Types of Information Do We Collect?” and “How Do We Get Information About You?”.

In the past 12 months, we have collected the following information for the following purposes:

• Identifiers: This includes, for example, your first name, last name, business email address, social media handles, telephone number and Internet Protocol address, as well as account username or screen name and other online identifiers. We obtain this information when you provide it to us or otherwise automatically in the course of your interactions with our Services.
• Internet or other electronic network activity information: This includes, for example, device type, operating system, browser type, and other technical information. We obtain this information automatically in the course of your interactions with our Services.
• Demographic information: This includes information such as age and gender. We obtain this information when you provide it to us or otherwise automatically in the course of your interactions with our Services.
• Commercial Information: This includes records of products purchased or considered, or other similar consuming histories. This allows us to provide technical functionality, develop new products and services, and analyze your use of them. We obtain this information directly from you or otherwise automatically in the course of your interactions with our Services.
• Geo-location data: This includes, for example, your locale, zip code, and general geolocation information (based on your IP address). We obtain this information when you provide it to us or otherwise automatically in the course of your interactions with our Services.

We collect Personal Information directly from you, automatically from your use of our Services and from certain third-party sources, as described in the section above “How Do We Get Information About You?”.

How we use and share your Personal Information

We use Personal Information for the business and commercial purposes as described in the section above “How Do We Use the Information We Collect?”. We do not share your Personal Information except as approved by you or as otherwise described in this privacy policy. You can find more information in the section above “How Do We Share Your Information?”.

In the preceding 12 months, we have disclosed the following categories of Personal Information for a business purpose:

• Identifiers, as set forth above.
• Internet or other electronic network activity information.
• Demographic information.
• Commercial Information.
• Geo-location data.  

We do not your sell your Personal Information. However, we permit certain third-party advertising and analytics partners to collect information about you through our Services for purposes of serving ads that are more relevant and for ad campaign measurement and analytics. For more information or to opt out of the use of your Personal Information for advertising purposes, please see the section above “How Can You Change Your Information Collection Preferences?”.

Your Privacy Rights

As California or Virginia resident you have certain rights. These rights have certain specificities such as timeframes and limitations according to each local law, but in general include, where applicable:

• Right to access: You have the right to request to know more about the categories and specific pieces of Personal Information that we have collected about you and access a copy of your Personal Information.
• Right to erasure: You have the right to request deletion of Personal Information that we have collected about you.
• Right to opt-out: You have the right to opt-out of the processing of your personal data in certain situations as provided by the applicable laws of each state.
• Right to data portability: You have the right to receive a copy of your personal data in a portable, and to the extent technically feasible, readily usable format that permits you to transmit the data to another entity of your choice.

If you are a resident of California or Virginia you also have the right to rectification, meaning the right to correct eventual inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data.

Finally, if you are a resident of California or Virginia, you have the right not to be subject to automated decision-making, whenever it produces legal effects or significantly affects you.

If you choose to exercise any of your rights described above, Degreed will treat you like all other users. In other words, there is no penalty for exercising your rights.

To exercise any of these rights, please email privacy@degreed.com or write to us at the physical address listed in the Contact Details section below. You may designate an authorized agent to make these requests on your behalf. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify you and/or your authorized agent’s identity before fulfilling your request.

You also have the right to request certain details about what Personal Information we share with third parties for those third parties’ direct marketing purposes. To submit your request, send an email to privacy@degreed.com.

Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to “Do Not Track” signals. However, we provide you with the ability to opt-out of the use of tracking technologies to send you interest-based advertising as explained above.

Notice to Australia Residents
If you are a resident of Australia and you have a complaint, you may refer it to the office of the Australian Information Commissioner (“OAIC”). You can contact OAIC by visiting www.oaic.gov.au, forwarding an email to enquiries@oaic.gov.au, telephoning 1300 363 992, or writing to OAIC at GPO Box 5218, Sydney NSW 2001.

Notice to Users in Brazil
For users located in Brazil (collectively, “Brazilian Users”), If a Brazilian User accesses or uses our Site or Services, Degreed is the “data controller” of their Personal Information and we perform any processing of your Personal Information in accordance with this privacy policy. The purposes, form and duration of the processing of Personal Information are already described in this privacy policy, as well as information regarding how information is shared.

Brazilian Users have certain data protection rights. These rights include:

• Confirmation that processing of Personal Information exists
• Access to Personal Information processed
• Correction of incomplete, inaccurate, or outdated Personal Information
• Anonymizing, blocking, or deleting Personal Information
• Data portability
• Exclusion of Personal Information
• Information about sharing of Personal Information with other companies
• Information about the possibility of not providing Personal Information
• Withdrawal of consent

To exercise any of the rights outlined above, please contact us at privacy@degreed.com.

Please be advised, we may need to request specific information from you to confirm your identity before processing your request.

Revisions to this Privacy Policy
We may revise this privacy policy from time to time as we add new features or as laws change that may affect our Site or Services. If we make material changes to this privacy policy, we will let you know in an appropriate manner and we will post a new version number at the beginning of this privacy policy, consisting of the date (year and month) the privacy policy was last revised, so that you will be able to tell when the privacy policy was last changed. 

Contact Details 

If you have any questions about this privacy policy or any questions, complaints or claims, please contact us at:
Email: privacy@degreed.com
Address: 4305 Hacienda Drive Suite 300 Pleasanton, CA 94588
Phone: 1-800-311-7061

You can contact Degreed’s Data Protection Officer, Victor Neamt, at privacy@degreed.com.

We always enjoy hearing from you and appreciate your business. Should you nonetheless have unresolved concerns, you have the right to lodge a complaint with your local data protection authority.