(Updated 14 May 2018)

Freeformers Holdings Limited is committed to protecting and respecting your privacy.

This Privacy Notice aims to give you information about how and what personal data we collect, and how and
why we process it. It also describes your rights regarding personal information we process about you.

When we refer to “Freeformers”, “we”, or “us” in this policy, we mean Freeformers Holdings Limited, which
controls the information collected when you use our website or one of our learning and assessment products.
In this policy we refer to our website and our learning and assessment products as “Services”.

HOW WE COLLECT INFORMATION

We collect information when you provide it directly to us:

• Account information - we collect information (including name and email address) when you register for an
  account for one of our learning and assessment products.
• Content you provide through our learning and assessment products - we collect and store information about
  your progression through learning courses, such as responses to learning assessment questions, submitted
  learning tasks and feedback, inferred scores in skills areas (“Future Workforce Model”) based on progress
  and assessment, contact information for notifications and assignment of learning and assessment tasks and
  anonymised data for research and tuning of our products.
• Content you provide through our website - we collect your email address when you subscribe to receiving
  our newsletter.
• Customer support - we collect your contact information when you correspond with us through our website or
  by phone, email or other contact methods..

We also use cookies and similar technologies on our Services to track your browsing behaviour, links clicked,
your device type, and to collect data, including analytics, about how you use and interact with our Services.
For more information see sections on cookies and analytics.

HOW WE USE INFORMATION

We will only use the information you give us for the following purposes:

• To provide services and to personalize your experience - we use information about you to provide our
  services to you, including to authenticate you when you log in, provide customer support, and operate
  and maintain our Services.
• Our learning and assessment products include features that use your information to measure your progression
  through learning courses, by analyzing your responses to learning assessment questions, submitted learning
  tasks and feedback.
• To provide customer service - we use your information to provide you with the information, products, and
  services that you request from us.
• To send you our newsletters - with your consent, we use your contact information to send you our weekly
  newsletter by email. You can opt-out of receiving these emails by clicking the unsubscribe link at the
  end of the email.

We will use information about you that we collect automatically for the following purposes:

• To administer our Services - including troubleshooting, data analysis, testing and research purposes.
• To improve our Services - to ensure that content is presented in the most effective manner for you and
  for your device.
• As part of our efforts to keep our Services safe and secure.

SECURITY AND DATA RETENTION

We take appropriate technical and organisational measures to ensure that the information we collect is kept
secure, accurate and up to date.

We will keep your personal information only for as long as necessary to fulfil the purposes for which we are
processing your personal information.

DISCLOSURE OF YOUR INFORMATION

Freeformers does not sell or share your personal information with third parties.

TRANSFERRING INFORMATION OUTSIDE OF EUROPE

Freeformers will not transfer your data outside of Europe. If you are based outside of the EU when providing
data (such as a response to a learning assessment question), be aware that your data will be transferred into
the EU.

YOUR RIGHTS

You have certain rights in relation to your personal information, including the right to:

• Request access to and obtain a copy of your personal information.
• Rectification of your personal information if it is no longer accurate or erasure of your personal
  information if our retention is no longer necessary for the purposes for which it was collected.
• Restrict or object to the processing of your information in certain circumstances.
• Data portability. You can obtain some of your information in a format you can move from one service provider
  to another (for instance, when you transfer your mobile phone number to another carrier). Depending on
  the context, this applies to some of your information, but not to all of your information. Should you
  request it, we will provide you with an electronic file of your information.

In addition, where you have provided your consent to our processing of personal data, you can withdraw this
at any time.

If you wish to exercise any of your rights in relation to your personal information please send your request
to us using details set out in the “Contact Us” section below. We may need to verify your identity before
granting access or otherwise changing or correcting your information.

If you wish to obtain a copy of your information, please complete Data Subject Access request form and send
it by email to privacy@freeformers.com.

You also have the right to complain to the Information Commissioner or to your local data protection
supervisory authority if you are unhappy with our privacy practices notified under this Privacy Notice.

COOKIES

We use cookies on our Services to provide users with more user-friendly services, collect anonymous
information and for security purposes.

What is a cookie?

It’s an online technology to collect information about you and to store your online preferences. Cookies are
small pieces of information sent by a web server to a web browser which allows the server to uniquely
identify the browser on each page.

Types of cookies

• Session cookies. These expire when you close your browser and do not remain on your computer.
• Persistent cookies. These are stored on your computer until they expire or you delete them from your cache.
  They are normally used to make sure the site remembers your preferences.

Categories of cookies

• Strictly necessary cookies. These cookies are essential for you to move around our Services and use their
  features. Without these cookies, we cannot provide features you have asked for, such as access to secure
  areas.
• Performance cookies. These cookies collect anonymous information on how people use our Services.
• Functionality cookies. These cookies remember choices you make, such as your last action, language and
  search preferences. We can use these to provide you with a better experience based on your preferences.
  The information from these cookies is anonymous and they cannot track your browsing activity on other
  websites.

How to delete cookies

• Go to the help and support area on your internet browser for instructions.
• Information on deleting or controlling cookies is also available at www.allaboutcookies.org
• If you delete or disable our cookies you may not be able to access certain areas or features of our site.

GOOGLE ANALYTICS

We use Google Analytics to analyse the use of our Services. Google Analytics gathers information about
service’s use, by means of cookies. The information gathered is used to evaluate the use of our Services
and to provide online reports, which show the activities on our Services.

LINKS TO OTHER WEBSITES

Our Services contain links to third-party websites. We are not responsible for the privacy practices or the
content of third-party sites. Please read the privacy policy of any website you visit.

OUR POLICY TOWARDS CHILDREN

Our services are not directed to individuals under 16. If we obtain actual knowledge that any information we
collect has been provided by an individual under the age of 16, we will promptly delete that information.

CHANGES TO OUR PRIVACY POLICY

We may update this Privacy Notice from time to time. We will always include the date of a new version so
that you know when there has been a change.

CONTACT US

If you have any questions, concerns or complaints about our Privacy Policy, our practices or our Services,
you may contact our Office by email hello@freeformers.com or our Data Protection Officer (DPO) and
team by email privacy@freeformers.com. Alternatively, you may contact us by either of the following
means:

• By mail: Freeformers Holdings Limited, 21 Hatton Garden, EC1N 8BA, London, United Kingdom
• By Phone: +44 203 691 7940

We will respond to all requests, inquiries or concerns within 28 days.