Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in NetCE's Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information we collect

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer ("personal information"). In particular, NetCE's product websites, including: NetCE, and NetCE Groups, (collectively, the "Website"), has collected the following categories of personal information from its consumers within the last twelve (12) months:

Personal information under the CCPA does not include:

• Publicly available information, which means (i) information that is lawfully made available from federal, state, or local government records, or information that a business has a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media; or (ii) information made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.
• De-identified or aggregated consumer information.
• Information that is excluded from the CCPA's scope due to the applicability of other laws, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

NetCE obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• From your employer, in cases where your subscription is provided by your employer
• Indirectly from you. For example, from observing your actions on our Website.
• From third-party business partners such as analytics providers.

Use of personal information

We may use, or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns. If you provide your personal information in order to track or complete continuing education or meet licensing or accreditation requirements, we will use your information to provide and report your continuing education credits or report completions of any applicable licensing or accreditation requirements.
• To provide, support, personalize, and develop our Website, products, and services.
• To detect and correct any errors in our Website, products and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests.
• To prevent fraud and help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of NetCE's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by NetCE about our Website users is among the assets transferred.

NetCE will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sale or sharing of personal information

In the preceding twelve (12) months, NetCE has not sold or shared personal information for purposes of cross-context behavioral advertising. We do not sell or share (i) personal information if we have actual knowledge that the consumer is less than 16 years of age; or (ii) Sensitive Personal Information, as defined in the CCPA.

Disclosure of personal information for a business purpose

In the preceding twelve (12) months, NetCE has disclosed the following categories of personal information for one or more of the business purposes described above in Use of Personal Information:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category D: Commercial information.
• Category F: Internet or other similar network activity.
• Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties, as defined in the CCPA:

• Internet service providers
• Data analytics providers
• Continuing education accreditors or reporting entities.

Retention

We will store and use your information only for so long as is necessary for the uses we collected the information for as described in this policy. Unless we are actively using your personal information or have a legal basis for retaining such information, in accordance with this policy and applicable law, we will delete your personal information after 25 years of inactivity with respect to such information.

Your rights and choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to specific information and data portability rights

You have the right to request that NetCE disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion request rights

You have the right to request that NetCE delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes.
3. Debug to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which the consumer provided the information.
8. Comply with a legal obligation.

Correction request rights

You have the right to request that NetCE correct any of your inaccurate personal information that we maintain about you. Once we receive and confirm your verifiable consumer request (see Exercising your rights), we will correct (and direct our service providers to correct) your personal information.

Opt-out request rights

We do not offer a right to opt-out of the selling or sharing of personal information because, within the meaning of the CCPA, we do not sell or share personal information for cross-context behavioral advertising.

Sensitive personal information rights

We do not offer a right to limit the use or disclosure of sensitive personal information because, within the meaning of the CCPA, we do not use sensitive personal information for inferring characteristics.

Exercising your rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us using any of the contact methods listed below in the Contact Information section.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. We may require proof that you have designated the authorized agent to act on your behalf and to verify your identity directly with us. Please contact us using any of the contact methods listed below in the Contact Information section for more information if you wish to submit a request through an authorized agent.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response timing and format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

Please note that once you have submitted a request, we will send you a receipt, acknowledging your request, within 10 days. If, for some reason, you do not receive such a receipt within 10 days of your submitted request, please contact us using any of the contact methods listed below in the Contact Information section, as an error may have occurred.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

The response we provide will explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights, including an employee's, applicant's, or independent contractor's right not to be retaliated against for the exercise of their CCPA rights. We will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California privacy

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. While we do not provide information to third parties for their direct marketing purposes, you may still make such a request. To do so, please contact us using any of the contact methods listed below in the Contact Information section.

Changes to our privacy notice

NetCE reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which NetCE collects and uses your information as described above and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by email, webform, telephone, or US Mail: