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PRIVACY POLICY

WHO ARE WE?
Vector Solutions is a leader in eLearning and performance support, providing
award-winning SaaS solutions. The company delivers continuing education (CE),
training, technology, and performance management solutions to a broad range of
industries, including education, public safety, industrial, IT and architecture,
engineering, and construction (AEC) sectors. Its brands include RedVector,
Convergence Training, TargetSolutions, SafeSchools, SafeColleges, Exceptional
Child, TeachPoint, Not Anymore, Casino Essentials and the Institute for
Certified Gaming Industry Professionals (ICGIP), IndustrySafe, LiveSafe, and
DiversityEdu.

Vector Solutions updated its Privacy Policy effective July 1, 2020 in light of
the California Consumer Privacy Act (CCPA). We appreciate the importance of
privacy and commit to protecting the information you provide us by following the
practices described in this policy.

This Privacy Policy applies to you and Vector Solutions, including its
affiliates and describes our practices for collecting, using, maintaining,
protecting, and disclosing the personal data we may collect from you or that you
may provide when you visit our websites at www.VectorSolutions.com or any other
Vector Solutions websites or forms that link or refer to this Privacy Policy
(collectively referred to as our “Websites”). By visiting, using, and submitting
information to our Websites you are accepting the practices described in this
Privacy Policy and our Agreement of Terms of Use. This Privacy Policy applies to
the personal data collected through our Websites, regardless of the country
where you are located.

Vector Solutions encourages you to provide feedback regarding this Privacy
Policy. If you have questions, comments, or concerns about how we handle your
personal information as described in this Privacy Policy or that Vector
Solutions is not abiding by this Privacy Policy at any time, please contact us
at privacy(at)vectorsolutions.com

Chief Information Officer
4890 W. Kennedy Boulevard, Suite 300
Tampa, FL 33609
813.207.0012
Toll-Free: 1.866.546.1212

This Privacy Policy may change from time to time at Vector Solutions’
discretion. Such changes will be posted on this page. Vector Solutions will not
adopt a change that would limit your rights under this Privacy Policy without
providing notice. You are encouraged to revisit this Privacy Policy each time
you visit www.VectorSolutions.com or any of our Websites, in order to review any
changes that have been made.

WHAT INFORMATION DOES VECTOR SOLUTIONS COLLECT?
Generally, we collect two types of information when you are using our Websites –
information you provide us and information collected by tracking and monitoring,
which may include, for example, training plans, courses taken and completed,
certifications earned, and the like.

The personal information that Vector Solutions requests from you may include
your name, address, email address, telephone number, driver’s license number and
professional license number. Much of www.VectorSolutions.com and our Websites is
accessible to you without your providing personal information.

However, Vector Solutions requires that you register and provide personal
information to enable you to utilize certain features of
www.VectorSolutions.com, including subscribing for Vector Solutions’ courses and
being issued a username or password. The personal information that you provide
must be accurate, complete, and current.

In addition, you submit your personal information to Vector Solutions in order
to receive company updates, press releases, or other special offers from Vector
Solutions and select business sponsors.

Your provision of such information will always be on a voluntary basis. Vector
Solutions will obtain your consent for any use of your personal information not
described in this Privacy Policy or any use beyond the original use for which
you provided it.

HOW DOES VECTOR SOLUTIONS USE THE INFORMATION COLLECTED?
Vector Solutions uses your personal information within Vector Solutions’
internal organization to process any selections that you may make using
www.VectorSolutions.com or any of our Websites and to create, develop, operate,
deliver and improve our products and services.

Vector Solutions may share your personal information with select third parties
for fulfillment of services and features. For example, we will share your
personal information with (i) credit card companies for processing your tuition
if you register for Vector Solutions courses; (ii) state licensing agencies if
you elect to have Vector Solutions report your professional licensing
requirements to those agencies; (iii) select business sponsors; (iv)
professional organizations who refer you to www.VectorSolutions.com or any of
our Websites; (v) vendors whose products you order via www.VectorSolutions.com
or any of our Websites; and (vi) course providers in order to issue you points
and certificates earned by successfully completing coursework.

Vector Solutions may share or disclose your personal information when it
determines, in its sole discretion, that the disclosure of such personal
information is necessary to identify, contact, or bring legal action against you
if you may be: (i) causing intentional or unintentional injury to another; (ii)
interfering with another’s rights or property, including Vector Solutions’
rights or property; (iii) violating any applicable law, rule or regulation; or
(iv) such disclosure is required by any applicable law, rule or regulation.

Your personal information may be accessible to the United States government,
courts or law enforcement or regulatory agencies through the laws of the United
States.

Vector Solutions may also share or disclose your personal information (i) with
necessary third parties in connection with, or during negotiations for, an
acquisition, merger, asset sale, or other similar business transfer that
involves all or substantially all of our assets or functions where personal
information is transferred or shared as part of the business assets; and (ii)
with persons of your choosing and at your discretion, should the product you are
subscribed to allow for that functionality.

If you transmit, submit or post information to www.VectorSolutions.com or any of
our Websites that is not, or does not contain, personal information, you
automatically grant Vector Solutions the royalty-free, non-exclusive right and
license to use, copy, format, adapt and/or to incorporate the same in other data
and content viewable on, contained in, or downloadable from,
www.VectorSolutions.com or any of our Websites.

WHAT IS VECTOR SOLUTIONS’ OPT-OUT POLICY?
You may at any time request a copy of the personal information that you provided
and elect to revoke (“opt-out”) the information provided. We reserve the right
to review and in our sole discretion decline your request or deny it as
permitted by law.

In order to opt-out, you may contact your employer, your System Administrator,
or Vector Solutions at support.lms(at)vectorsolutions.com. Vector Solutions will
accordingly furnish you with a copy of your personal information or change its
records to remove your personal information.

If you opt-out of providing your personal information, Vector Solutions will no
longer use your personal information or share it with third parties. However,
keep in mind that your opting-out of providing personal information may inhibit
or cancel your ability to fully utilize www.VectorSolutions.com or any of our
Websites to subscribe for Vector Solutions courses and to access or use some
other features.

HOW CAN INFORMATION BE CORRECTED OR UPDATED
You may correct, update or change your personal information or change any
selections you have made with regard to our use of that information after you
have provided such information or selections to Vector Solutions via
www.VectorSolutions.com, by contacting your employer, your System Administrator
or Vector Solutions at support.lms(at)vectorsolutions.com.

DOES VECTOR SOLUTIONS USE COOKIES?
Yes, Vector Solutions uses “cookies.” Cookies are small files that are written
to the user’s hard drive or device through your Web browser (if you allow). This
enables the site’s or service provider’s systems to recognize your browser and
capture and to track and store preferential information about you as you use
www.VectorSolutions.com or any of our Websites. Cookies can be used so that
users do not have to re-enter data with each visit to our Websites. Cookies
track your personal preferences and activities and to compile aggregate data
about how our service is used, but in no way contain or refer to any personal
information.

This information, oftentimes anonymous or aggregated, helps Vector Solutions
serve you better by compiling user preferences to improve the features of
www.VectorSolutions.com or any of our Websites. Vector Solutions may also share
this aggregated information to third parties, but keep in mind that the
aggregated information contains absolutely no personal information.

If you do not want www.VectorSolutions.com or any of our Websites’ cookies to be
inserted into your hard drive, you can disable your hard drive’s ability to
accept and receive cookies through your web browser. However, keep in mind that
if you disable your hard drive’s ability to accept and receive cookies, you may
not be able to fully utilize all of the convenience features of
www.VectorSolutions.com or any of our Websites. For instance, you may have to
log in your username or password more than once per session. To find out more
about cookies, visit http://www.allaboutcookies.org/.

Note, we do not process or respond to web browsers’ “do not track” signals or
other similar transmissions that indicate a request to disable online tracking
of users who use or visit our websites. To find out more about “do not track,”
please visit http://www.allaboutdnt.com.

DOES VECTOR SOLUTIONS ISSUE USERNAMES AND PASSWORDS?
You may be issued a username or password by Vector Solutions to utilize certain
features of www.VectorSolutions.com or any of our Websites. In order to receive
a username or password from Vector Solutions for use on www.VectorSolutions.com,
you will be required to submit personal information. You are responsible for
keeping your usernames and passwords, if any, confidential.

You are responsible for any access, use or activities on www.VectorSolutions.com
of any of our Websites under your username or password. For that reason, be sure
to log off when you are finished using a shared computer.

WHAT KIND OF SECURITY DOES VECTOR SOLUTIONS USE?
The security of your personal information is very important to us. We use
physical, electronic, and administrative safeguards designed to protect your
personal data from loss, misuse and unauthorized access, use, alteration or
disclosure. Where we have given you (or where you have chosen) a password for
access to certain parts of our Websites, you are responsible for keeping this
password confidential. We ask you not to share your password with anyone. We
urge you to take care when providing information in public areas of our Websites
like message boards, which any website visitor can view.

Unfortunately, the transmission of information via the internet is not
completely secure. Although we do our best to protect your personal data, we
cannot guarantee the security of your personal data transmitted to our Websites.
Any transmission of personal data is at your own risk. We are not responsible
for the circumvention of any privacy settings or security measures contained on
our Websites.

DOES VECTOR SOLUTIONS USE LINKS TO OTHER INTERNET WEBSITES?
As part of our routine business operations, our Websites contain links to third
party websites, plug-ins, services, social networks or applications. Clicking on
those links or enabling those connections may allow the third party to collect
or share data about you. Vector Solutions does not control these third-party
websites, and we encourage you to read the privacy notice of every website you
visit, as its privacy policy may differ substantially from that of this Privacy
Policy.

CALIFORNIA RESIDENT
If you are a California resident, please refer to our California Privacy Policy
for additional information about your rights related to the personal information
we collect, use, and disclose. We do not share information that identifies you
personally with non-affiliated third parties for their own marketing use without
your permission.

WHAT IS VECTOR SOLUTIONS’ CHILDREN’S ONLINE PRIVACY POLICY?
With respect to minors, www.VectorSolutions.com and any of our Websites are not
intended to be accessed or utilized by persons under the age of 18, except as
provided in the “Vector Solutions Privacy Policy for Children Under the Age of
13 Section” below. We do not specifically market to children under 13. Vector
Solutions does not intend or purposefully attempt to gather information from
children under the age of 13.

The following applies to Scenario Learning, LLC Clients only:

FERPA
Scenario Learning, LLC and its Clients are subject to the Family Educational
Rights and Privacy Act (“FERPA”). As such, Scenario Learning, LLC acknowledges
that: (a) Scenario Learning, LLC and its Clients are each providing educational
services to the other that they would otherwise have to provide for themselves
using faculty and staff; (b) each has a legitimate educational interest in the
student education records that may be disclosed; and (c) Scenario Learning, LCC
will be under the direct control of each Client User with respect to the use and
maintenance of information from student education records. Scenario Learning,
LLC acknowledges that the student education record it may receive is
confidential and will use the information only for the purposes for which the
disclosure was made. Scenario Learning, LLC will not re-disclose the information
to any third party without prior written consent from the student and client.
Scenario Learning, LLC works together with its Clients to share student
education records in a manner that protects such records from disclosure.

The following applies to Not Anymore Client and Client’s Users only:

Limited Reporting
In addition to the security provided by the Client/Server technical design,
Scenario Learning, LLC has a feature designed to prevent Not Anymore Client
users from uniquely identifying the personal information from any individual
user. For each Client (e.g., each school), an administrator is provided with
access to an online portal that provides information about that Client’s User’s
progress. The administrator has access to a Progress Report, which includes
user-specific information as discussed above. Not Anymore Clients have access to
a raw data report that includes all of the de-identified data. The de-identified
data does not become available to the Client until at least 100 men and 100
women have completed the program. In addition, each time the full raw data
report is opened the information is randomized. These protections ensure that a
Client is not able to review the Users that have completed the program each day
and try to match it up with data in the raw data report, thereby identifying the
personal data from any individual User. Should a Not Anymore Client not meet the
100 men and 100 women minimum, they are not provided access to the raw data
until after all Not Anymore Client Users have completed the program, and if the
number of completions is still too low at that time, either the demographic data
is removed from the raw data file altogether or with very small populations, the
raw data is not provided at all.

Vector Solutions Privacy Policy for Children Under the Age of 13 – SafeSchools
Alert Service and SafeSchools Alert Mobile Application
Vector Solutions’ Websites and related services are not intended for use by
children under the age of 13; however, we are committed to protecting children
who make use of our SafeSchools Alert Service or SafeSchools Alert Mobile
Application for reporting, managing, tracking and resolving incidents in
compliance with applicable regulations in our efforts to keep children safe.

The Children’s Online Privacy Protection Act of 1998 and its rules
(collectively, “COPPA”) require us to inform parents and legal guardians (as
used in this Section of our Privacy Policy), (“parents”) about our practices for
collecting, using, and disclosing personal information from children under the
age of 13 (”children”). It also requires us to obtain verifiable consent from a
child’s parent for certain collection, use, and disclosure of the child’s
personal information. Children may access and use our SafeSchools Alert Service
and SafeSchools Mobile App to track, manage and resolve incidents in our
web-based system.

This Section only applies to children under the age of 13 and supplements and is
a part of the general Vector Solutions Privacy Policy. The remainder of this
Privacy Policy applies to teens and adults.

Terms that are defined in the Vector Solutions Privacy Policy have the same
meanings as used in this Section for Children Under the Age of 13.

Information We Collect from Children
Your child’s School District has chosen to make the Safe Schools Alert Service
and associated SafeSchools Alert Mobile Application (the “App”) available to its
students (collectively referred to in this Section as the “Service”). Based on
the School Districts’ authorization, this Service is made available on the
premise that the School District has obtained any requisite parental consent.
Children can access many parts of the SafeSchools Alert Service via the Mobile
Application and our Websites and they can use its tip and incident reporting
feature anonymously and without providing us with any personal information. We
do not require sensitive or otherwise protected data about the user; however, we
have no way to restrict users from entering information in the free form text
areas of the App or via the Website. While children may voluntarily include
personal information when they visit our Website or use the App to report an
incident, Vector Solutions has no control over this. If the child chooses to
share personal information when submitting a tip or reporting an incident, such
information will be shared with the School District.

We only collect as much information about a child as is reasonably necessary for
the child to participate in providing a tip or reporting an incident, and we do
not condition his or her participation on the disclosure of any personal
information or other information than is reasonably necessary. Your child, at
his or her option, can elect to remain anonymous. The App only allows users to
communicate with their School District’s administration and DOES NOT allow users
to communicate with each other.

Information We Collect Directly
When first using the App, a child will be requested to provide us with the
Organization Code provided by the child’s School District and the child’s
confirmation that he/she is associated with the School District.

When your child uses the App, we may automatically collect information such as
the IP address, browser type, operating system and device/hardware, general
location, and other log in information, including the date and time of any
reports made through the App.

Automatic Information Collection and Tracking.
We use technology to automatically collect information from our users, including
children, when they access and navigate through the App or the Website and use
certain of its features. The information we collect through these technologies
may include a unique identification for the user’s device for installation of
the App and the tip or report data provided by the user.

How We Use Your Child’s Information
We use the information we collect from your child to transmit the incident
report to your child’s School District by an “anonymous user,” unless the child
has elected to include personal information. Your child may voluntarily provide
information in a report or when using the Service or the App, that allows the
School District to identify them, but the Service and the App do not require or
encourage children to provide personal information. Any information provided by
the child is used to manage, track, and resolve reported incidents for the
purpose of keeping children safe.

Our Practices for Disclosing Children’s Information
We do not use or share children’s personal information other than as described
in this section.

We may disclose aggregated information about many of our users, and information
that does not identify any individual or device. In addition, we may disclose
children’s personal information:

If we are required to do so by law or legal process, such as to comply with any
court order or subpoena or to respond to any government or regulatory request.
If we believe disclosure is necessary or appropriate to protect the rights,
property, or safety of Vector Solutions, our customers or others, including to:
- protect the safety of a child;
- protect the safety and security of the App or our Services or
- enable us to take precautions against liability.

To law enforcement agencies or for an investigation related to public safety.
In addition, if Vector Solutions is involved in a merger, divestiture,
restructuring, reorganization, dissolution, or other sale or transfer of some or
all of Vector Solutions’ assets, whether as a going concern or as part of
bankruptcy, liquidation, or similar proceeding or event, we may transfer the
personal information we have collected or maintain to the buyer or other
successor.

‌Accessing and Correcting Your Child’s Personal Information
The Service and the App are designed to be used anonymously so parents may not
be able to review reports. If the child has voluntarily submitted personal
information as part of a report, parents may contact the School District
directly to review such information. Parents have the right to refuse to permit
further use or collection of their child’s personal information.

You may contact your child’s School District Administrators directly if you have
any questions regarding how your child’s data is collected and used or if you
would like to correct or remove your child’s information or to change or
withdraw your consent to use such information.

Contact Information for the Vector Solutions Children’s Privacy Policy
You may contact Vector Solutions at:

Vector Solutions
4890 W. Kennedy Boulevard, Suite 300
Tampa, FL 33609
Attention: Chief Information Officer
email: privacy(at)vectorsolutions.com
813.207.0012
Toll Free: 1.866.546.1212


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