Kaplan North America, LLC (“Kaplan,” “we” or “us”), a company that empowers access to education, offers coaching and career development skills (the “Service”) for the career success of Amazon employees. This Privacy Policy (or “Policy”) explains how we use, share and protect your personally identifying information (“Personal Data”) when we deliver the Service, when you access https://go.kaplan.com/amazon and other Service sites (collectively the “Site”), when you otherwise interact with us or receive a communication from us related to the Service, and when you permit us to receive data about you from Amazon.

Transfer of Data Outside of Your Home Country: Your Personal Data will be held in the United States. Your Personal Data may also be stored, processed and accessed in other countries where Kaplan has facilities or where you are located. You consent to the transfer of your Personal Data outside your country, including to the United States.

This Privacy Policy covers the following:

Information We Collect or May be Provided to Us

Personal Data is any information about an individual from which that individual can be identified. Your name, address and phone number are examples of Personal Data. We collect Personal Data that you choose to provide to us or that Amazon may provide to us related to the Service, including when you

• Submit an Interest Form
• Contact Information such as your name, personal e-mail address, phone number and address.
• Book an Appointment such as your phone number.
• Demographic Information such as month and day only of birthdate, city and state
• Professional Information such as Employee ID (if known), Amazon Alias, Amazon Building (e.g., MIA3).
• Eligibility for the Career Choice program such as part-time or full-time hourly
• Communication Preferences such as preferred method (video chat, cell phone and times available.
• Education such as level of education completed or currently attending school.
• Share Number for Mobile Devices, Phone Calls and SMS. If you provide us with a telephone number in the Interest Form or when interacting with the Site and consent to be contacted at that number, we may contact you by telephone and/or text message utilizing automated technology at such telephone number(s). You understand that you do not need to provide consent to receive or purchase goods or services from us.
• Interact with the Site. When you visit the Site or interact with emails that we send to you, we may passively collect information from you and store that information on our server logs, including your internet protocol address (“IP address”), browser type, operating system, device identifier, device model, software version, or mobile or ISP carrier information. We also use Cookies and other technologies to collect information about your visit to the Sites, such as the date and time of your visit, the information you searched to find the Sites, or your activity on the Sites. “Cookies” are small files which may be stored on your computer during your use of the Sites and contain data about your use of the Sites. We may use session Cookies (which expire when you close your browser) or persistent Cookies (which stay on your computer until you delete them). We and our service providers may also use so-called "pixel tags", "web beacons", "clear GIFs" or similar means (collectively, "Pixel Tags") in connection with some Site pages and HTML-formatted email messages to, among other things, compile aggregate statistics about Site usage and response rates. A pixel tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to Site visitors and may be associated with cookies on the visitors’ hard drives. Pixel Tags allow us to count users who have visited certain pages of the Site, to deliver branded services, and to target our promotional or advertising campaigns and determine their effectiveness.

How We Use Information

We may use your Personal Data in the following ways and in accordance with applicable laws.

• For the purpose we received your Personal Data and to deliver the Service, for example to setup coaching sessions or respond to a specific inquiry;
• To send reports requested by Amazon related to the Service and your participation;
• To add you as a user to the Service, allow you access to the Service and to post content and communicate with others;
• To customize, improve and personalize your learning experience;
• To administer, support, improve and develop our business;
• To enhance and understand your progression;
• To perform data analytics alongside other data about you that we may collect outside the Amazon Career Choice program to improving product effectiveness, learning experience, and quality services to Amazon;
• To send you information about the Service;
• To fulfill the obligations of Amazon Career Choice program;
• To send you information about other Kaplan products and services that align with your participation in the Amazon Career Choice and only if you separately expressed interest and opted-in to receive communications from Kaplan.
• And as otherwise described to you at the point of collection.

How We Share Information

We may share your Personal Data with:

• Authorized service providers that perform certain services on our behalf (e.g. processing credit card payments, delivering packages, providing assessments, customer service and marketing assistance, performing business and sales analysis, supporting our website functionality, and supporting other features offered through our website);
• The businesses or organizations which we partner to offer you coaching and the Service, such as other Kaplan companies, to provide you with services that you participate in or request;
• Government agencies, courts of law and law enforcement in connection with a subpoena or similar investigative demand, a court order, or a request for cooperation; or to establish or exercise our legal rights or defend against legal claims or as otherwise required by law;
• Your employer, Amazon, that has paid for your access to the Service.
• Other Parties in Connection with a Corporate Transaction: We may also disclose Personal Data in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, internal reorganization, or in the unlikely event of bankruptcy.
• Aggregated Data: We also may share other information with third parties in a manner that does not identify particular users, including, for example, aggregated data about how users are using the Service.

Third-Party Websites and Links

You may be able to link from the Site to third-party websites and third-party websites may link to the Site ("Linked Sites"). This Privacy Policy governs collection and use of Personal Data by Kaplan. This Privacy Policy does not govern those third parties’ content, services, or use of your information. Kaplan makes no representation about their data practices or policies.

California Residents Additional Privacy Rights

If you are a resident of the State of California you have additional privacy rights, which supplement this privacy policy.

California Consumer Privacy Act:

The California Consumer Privacy Act (“CCPA”) provides California residents with rights, upon a verifiable consumer request, to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as to request information pursuant to rights to know/access, delete, and limit the sale of Personal Information. The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the all or part of the CCPA because it is considered public information (i.e., it is made available by a government entity), covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act, aggregated or deidentified, or employment-related or B2B-related information.

To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.

Right to Notice at Collection Regarding the Categories of Personal Information Collected: You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. This notice should be provided at or before the time of collection. The categories we use to describe the information are those enumerated in the CCPA.

Identifiers: We collect identifiers such as your name, phone number, contact address and e-mail address when you engage with our website. We use this information to manage and provide the Services that you request, respond to your requests, and to communicate with you about the Services.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): In addition to the identifiers in the above section, we collect your credit card number to provide you with requested Service. We may also collect information regarding your education and occupation to optimize additional products and services that may be of interest to you.

Protected classification characteristics under California or federal law. In addition to the variables listed above, we may also collect age, gender, marital status, and ethnicity to further understand our customers, and personalize offerings of products or services.

Internet or other similar network activity. We automatically collect information about your browsing history and your interaction with the content of our Services to measure activity, determine the effectiveness of our Services, and improve them.

Sensory Data: We collect your audio or voice recordings to provide you with Services.

We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected.

We may share any of the above-listed information with Service Providers, as described above. Service Providers are restricted from using Personal Information for any purpose that is not related to our engagement. The types of Service Providers with whom we share information and the services they provide are described in the Privacy Policy section titled “Disclosure of Your Personal Data.”

We do not sell personal information and in the preceding twelve (12) months, we have not sold any personal information.

Right to Know/Access Personal Information: You have the right to request access to Personal Information collected about you over the past 12 months and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. You may submit such a request as described below. To protect our users’ Personal Information, we are required to verify your identity before we can act on your request.

Right to Request Deletion of Personal Information: You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. You may submit such a request as described below. To protect our users’ Personal Information, we are required to verify your identity before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

How to Submit a Request: You may submit a request to exercise your rights to know/access or delete your Personal Information through any of the following means:

1. By filling out a Consumer Data Request Form available at this link: CCPA Data Privacy Form
2. By sending us an email at careerchoice.privacy@kaplan.com
3. By calling us at 877-450-0013

Only you or your authorized agent may make a verifiable consumer request related to your personal information. If you use an authorized agent to submit a request on your behalf, we may require that you (1) provide the authorized agent written permission to do so, and (2) provide a copy of the authorization or provide a copy of a power of attorney that complies with California Probate Code sections 4000 to 4465 so that we can verify the identity of the authorized agent.

In verifying requests, we employ reasonable measures to detect fraudulent requests and prevent unauthorized access to your personal information. To meet our obligations, we are required to verify your identity, and the identity of your authorized agent, if the request is submitted via an agent, by associating the information provided in your request to personal information previously collected by us.

If we suspect fraudulent or malicious activity on or from the password-protected account, we may decline a request or request that you provide further verifying information.

You may only make a verifiable consumer request twice within a 12-month period. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request.

Right to Opt Out of Sale of Personal Information to Third Parties: You have the right to opt out of any sale of your Personal Information by Kaplan to third parties. We do not sell information to third parties.

Right to Information Regarding Participation in Data Sharing for Financial Incentives: You have the right to be free from discrimination based on your exercise of your CCPA rights. We do not discriminate against anyone who chooses to exercise their CCPA rights.

Residents of the European Union Or United Kingdom Additional Privacy Rights

If you are a resident of the European Union (EU) or United Kingdom (UK) you have additional privacy rights, which supplement this privacy policy.

Data Protection Officer

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy policy.

Email: careerchoice.privacy@kaplan.com

If you are an EU national or resident in an EU country, and wish to contact our EU Representative: Kaplan Ireland Education Limited, 13/14 Aungier Street, Dublin 2, D02 WC04 Ireland

If you are a UK national or resident in the UK, and wish to contact our UK Representative: Kaplan UK Limited, UK Data Protection Representative, Palace House, 3 Cathedral St, London SE1 9DE, England

If you are located in the EU, EEA, Switzerland or UK you have the right to lodge a complaint with an EU or the UK Supervisory Authority. We would, however, appreciate the opportunity to address your concerns before you approach the ICO, so please contact us in the first instance.

Storage and Retention of Personal Data

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. Please contact us at careerchoice.privacy@kaplan.com if you would like more information.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your working relationship with us.

In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Your Rights as a Data Subject

Under certain circumstances, by law you have the right to:

• Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
• Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
• Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your Personal Data to another party.

If you want to review, verify, correct or request erasure of your Personal Data, object to the processing of your Personal Data, or request that we transfer a copy of your Personal Data to another party, please contact us at careerchoice.privacy@kaplan.com.

What We May Need from You

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

No Fee Usually Required

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Your Right to Withdraw Consent

In circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. You have the right to withdraw consent to marketing by following the opt-out links on any marketing message. To withdraw your consent for another circumstance, please contact us at careerchoice.privacy@kaplan.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data Security

We employ physical, electronic and managerial procedures to protect your information both online and offline from access by unauthorized persons and against unlawful processing, accidental loss, destruction and damage. However, as effective as these security measures are, no security system is impenetrable. We cannot guarantee the security of our systems, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the Internet.

Children’s Privacy

We do not knowingly collect any personal information from children under the age of 16 without parental consent, unless permitted by law. If we learn that a child under the age of 16 has provided us with personal information, we will delete it in accordance with applicable law.

Changes to this Privacy Policy

We may modify this Privacy Policy from time to time. We will notify you of changes by posting changes here, or by other appropriate means. Any changes to the Privacy Policy will become effective when the updated policy is posted on the Services. Your use of the Services or your provision of information to us following such changes indicates your acceptance of the revised Privacy Policy.

Your Ability to Choose

If you do not wish to continue receiving emails from us about the Service, you may unsubscribe by clicking on the unsubscribe link in our emails and following directions. If you do not wish to continue receiving SMS messages from us, you may stop messages by replying “STOP” to any message. You may also direct us to stop marketing to you by emailing us at careerchoice.privacy@kaplan.com.

Contact: Comments, queries and requests relating to this Privacy Policy are welcomed and should be addressed as follows:

By mail: Kaplan North America, LLC 1515 W Cypress Creek Road, Fort Lauderdale, FL 33309
By email: careerchoice.privacy@kaplan.com

Rev. March 2022