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LearnQuest Inc. Privacy Policy
Privacy Policy
Last Updated: September 19, 2025
LearnQuest and our subsidiaries and affiliates (“LQ,” “we,” “our,” or “us”) respect your privacy and are
committed to protecting your personal information. This Privacy Policy explains how we collect, use, share,
and safeguard information; describes your rights and choices; and details our compliance with the EU
General Data Protection Regulation (GDPR), UK GDPR, California Consumer Privacy Act/California
Privacy Rights Act (CCPA/CPRA), Children’s Online Privacy Protection Act and Rule (COPPA/COPPA 2.0),
Health Insurance Portability and Accountability Act (HIPAA), and other global data protection laws.
1. Information We Collect
1.1 Directly from You
● When you register for an account, enroll in training, complete forms, make purchases, or
communicate with us.
● Includes identifiers (name, email, phone number), credentials, payment details, and
communications content.
1.2 Automatically Through Technology (Cookies & Tracking)
When you visit our sites or use our services, we automatically collect certain technical and usage data
through cookies, pixels, scripts, and similar technologies. These include:
● Device and browser data (type, operating system, IP address, device ID)
● Usage data (pages visited, time on site, links clicked, training modules accessed)
● Cookie categories:
○ Strictly Necessary: Required for core functionality (login, security, cart).
○ Performance & Analytics: Collect usage statistics to improve services.
○ Marketing & Personalization: Enable targeted advertising and track ad effectiveness.
We manage cookies via a Consent Management Platform. You may adjust preferences at any time through
the Cookie Settings link on every page.
1.3 From Third-Party Sources
We may receive information about you from trusted third parties, including:
● Service providers – e.g., payment confirmations from payment processors, fraud prevention
checks, hosting providers
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LearnQuest Inc. Privacy Policy
● Business partners – e.g., certification status and training completion records from accreditation
partners, course enrollment data from training providers
● Marketing and analytics platforms – e.g., lead capture forms, advertising conversion data, event
registrations
● Publicly available sources – e.g., professional profiles, company directories, industry databases
This data is used only for legitimate business purposes such as fulfilling transactions, validating credentials,
improving services, and ensuring regulatory compliance.
1.4 Combination of Data
Where permitted, we may combine personal and non-personal data to improve accuracy, security, and
personalization.
2. Legal Bases for Processing (GDPR Article 6)
We process personal data only when one or more of the following apply:
● Consent: You have given clear, affirmative consent for specific purposes.
● Contract: Necessary to perform or enter into a contract with you.
● Legal Obligation: Required to comply with laws or regulations.
● Legitimate Interests: Necessary for our legitimate interests, provided your rights do not override
those interests. We document our Legitimate Interests Assessments (LIAs) upon request.
Purpose Data Collected Legal Basis
Payments and transactions Identifiers, payment details Contract
Account creation and Identifiers, credentials Contract
management
Marketing communications Identifiers, usage data Consent
Service improvement & Technical data, cookies Legitimate Interests
analytics
Compliance with legal Payment records, certification Legal Obligation
obligations records
Fraud prevention & security Technical data, account activity Legitimate Interests / Legal
Obligation
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Third-party data integration Professional information, Legitimate Interests
(e.g., enriching profiles with identifiers, and publicly available (documented via Legitimate
publicly available/provided details Interests Assessment – LIA)
data)
3. Cookies, Consent & Tracking
3.1 Cookie Categories
● Strictly Necessary: Required for core functionality; cannot be disabled.
● Performance & Analytics: Require consent to collect usage data.
● Marketing & Personalization: Require consent to deliver targeted content and ads.
3.2 Consent Management & Google Consent Mode
We use a Consent Management Platform to obtain your explicit, informed consent before setting any non-
essential cookies. Until you provide consent, analytics and advertising tags are held back via Google
Consent Mode v2 (signals include ad_storage, analytics_storage, ad_user_data, ad_personalization). You
can change or withdraw consent at any time through the Cookie Settings link available on every page.
3.3 Third-Party Tags
We use the following third-party tags and services:
● Google Analytics 4 and Conversion Linker (analytics and conversion measurement)
● Google Ads Remarketing and Conversion Tracking (advertising and attribution)
● LinkedIn Insight Tag (advertising and conversion measurement)
● YouTube embeds (video playback and analytics)
● HubSpot forms (lead capture)
● Google reCAPTCHA (bot detection and security)
These providers may process online identifiers (including IP addresses), device information, page URLs,
referrers, and event metadata. Transfers outside your jurisdiction are protected by Standard Contractual
Clauses with Transfer Impact Assessments and supplemental safeguards per Schrems II guidance.
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4. Sharing and Disclosure
4.1 Service Providers
We share data with third-party processors under Data Processing Agreements that enforce GDPR- and
CCPA/CPRA-compliant safeguards. Categories include payment processors, IT hosting, analytics, event
management, marketing platforms, and security services.
4.2 Cross-Context Behavioral Advertising (CPRA)
For California residents, we may “share” personal information for cross-context behavioral advertising via
platforms such as Google Ads and LinkedIn to measure conversions and deliver relevant ads. We honor
Global Privacy Control (GPC) signals as valid opt-out requests.
4.3 Legal Requirements
We may disclose personal data to comply with legal obligations, respond to lawful requests, or protect
rights, property, or safety.
4.4 No Sale of Personal Information
We do not sell personal data.
However, under the California Privacy Rights Act (CPRA), certain uses of data for cross-context behavioral
advertising (for example, using Google Ads or LinkedIn Insight Tag) are classified as “sharing.”
California residents may therefore exercise their right to opt out of such “sharing” by:
● Clicking the “Do Not Sell or Share My Info” link in the site footer,
● Sending an email request to Privacy.Compliance@learnquest.com, or
● Using a browser that sends a Global Privacy Control (GPC) signal, which we honor automatically.
This ensures compliance with CPRA while reaffirming our position that LearnQuest does not engage in the
sale of personal data.
5. International Data Transfers
For transfers outside the EU/EEA and UK, we implement:
● Standard Contractual Clauses (SCCs) with Transfer Impact Assessments and supplemental
measures per Schrems II guidance
● Adequacy decisions adopted by the European Commission or the UK authorities
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● Binding Corporate Rules, where applicable
Privacy Contact (and EU/EEA Representative):
Jonathan Elinsky
LearnQuest Incorporated
1900 Market Street, Suite 800
Philadelphia, PA 19103, USA
Tel: +1 (610) 206-0101
LearnQuest appoints a Privacy Contact rather than a mandatory DPO, as our core activities do not involve large-
scale sensitive data processing or systematic monitoring requiring a GDPR-mandated DPO.
6. Data Retention
We retain personal data only as long as necessary to fulfill the purposes described and to comply with
legal obligations. We maintain documented operational procedures for retention and secure deletion of
data, which are reviewed by our audit and compliance teams to ensure adherence to these timeframes.
Data Category Retention Period Legal Justification
Payment & transaction records 7 years Tax/legal obligations
Certification/educational 10 years Accreditation & compliance
records
Account data (inactive) 5 years of inactivity Legitimate interest / business
need
Marketing data Deleted 24 months after the Consent
later of the last marketing email
engagement (e.g., link click) or
most recent consent renewal
Support inquiries 24 months Legitimate interests
Analytics & advertising event GA4 default (14 months); Platform settings & de-
data aggregated de-identified identified use
metrics retained longer where
permissible
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LearnQuest Inc. Privacy Policy
7. Your Rights and Choices
7.1 EU/EEA & UK GDPR Rights
You may:
● Access, correct, or delete your personal data
● Restrict or object to processing
● Receive your data in a portable format
● Withdraw consent at any time
● Lodge a complaint with a supervisory authority
7.2 U.S. State Privacy Rights
Residents of California, Virginia, Colorado, Connecticut, Utah, and other U.S. states with applicable
consumer data protection laws have rights similar to those outlined under the GDPR and CCPA/CPRA.
These rights may include:
● Requesting disclosure of personal data categories and specific pieces collected, shared, or sold in
the past 12 months
● Requesting deletion or correction of personal data
● Opting out of targeted advertising and sale/sharing of personal data
● Limiting use of sensitive personal information (e.g., financial account, precise geolocation, racial or
ethnic origin)
● Designating an authorized agent to exercise these rights
Requests may be submitted via Privacy.Compliance@learnquest.com, and we will verify your identity
before processing.
If you would like LearnQuest to remove your personal information from our systems, please fill out this
form and send it to our Privacy Compliance Team.
Ongoing Compliance: LearnQuest actively monitors new and emerging state privacy laws (currently more
than 19 across the U.S.) and updates our practices and disclosures as additional regulations take effect.
We extend comparable rights and protections to residents of any state with an active consumer data
protection law, ensuring consistency and compliance nationwide.
7.3 Opt-Out Mechanisms
● Use the “Do Not Sell or Share My Personal Information” link in the site footer
● Send an opt-out request to Privacy.Compliance@learnquest.com
● Global Privacy Control (GPC) signals sent from your browser will be honored as valid opt-out
requests
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8. CCPA/CPRA 12-Month Disclosure Table
Category Collected Disclosed to Service Shared for Targeted
Providers Ads
Identifiers Yes Yes Yes
Commercial Yes Yes No
Information
Internet/Network Yes Yes Yes
Activity
Geolocation Data Yes Yes Yes
Professional Yes Yes No
Information
Inferences Yes Yes Yes
9. Children’s Privacy
For minors, we implement robust parental consent verification methods, such as credit-card verification,
parental email confirmation, or other industry-standard age verification processes. We apply strict data
minimization principles, and provide an “eraser button” for easy deletion. These procedures are designed
to ensure compliance with COPPA, COPPA 2.0, and applicable child data protection standards globally. If
you believe we have collected data from a minor, contact Privacy.Compliance@learnquest.com for prompt
deletion.
10. Automated Decision-Making & Profiling
We do not currently engage in automated decision-making that produces legal or similarly significant
effects. Should we implement algorithmic training recommendations, learner risk scoring, or similar
profiling features in the future, we will update this Policy, explain the logic involved, and provide a clear
opt-out mechanism.
11. Data Minimization & Accuracy
We collect only the minimum personal data necessary for specified purposes. We take reasonable steps to
ensure data accuracy and update it upon request. We conduct quarterly data minimization reviews and
automatically remove or anonymize data that is no longer required for our stated purposes. These reviews
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and automated controls ensure compliance with GDPR Article 5(1)(c) and other global minimization
standards. Our documented procedures also define the specific workflows, responsibilities, and audit logs
for data deletion and anonymization, ensuring full accountability and regulatory traceability.
12. Data Security
We maintain administrative, technical, and organizational measures—encryption at rest and in transit,
access controls, role-based permissions, secure development practices, and regular audits/penetration
testing—to protect personal data. We continuously review and enhance our security posture.
13. Data Breach Notification
In the event of a data breach affecting personal data:
● We will notify the relevant supervisory authority within 72 hours if required under GDPR.
● We will inform affected individuals without undue delay if there is a high risk to their rights and
freedoms.
● Notifications will include the nature of the breach, categories of data involved, likely
consequences, and measures taken to mitigate harm.
14. Email Marketing (CAN-SPAM Compliance)
All commercial emails comply with the CAN-SPAM Act and include:
● Accurate sender identification and subject lines
● Our valid physical mailing address
● Clear unsubscribe instructions; opt-out requests processed within 10 business days
Transactional and service-related emails are not subject to unsubscribe requests.
15. Changes to This Policy
We may update this Policy periodically. Material changes will be communicated via email or a prominent
notice on our website. Continued use of our services after updates indicates acceptance of the revised
Policy.
16. Contact Us
For questions or to exercise your rights:
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LearnQuest Inc. Privacy Policy
● General inquiries: info@learnquest.com
● Privacy & compliance: Privacy.Compliance@learnquest.com
Privacy Contact & EU/EEA Representative:
LearnQuest Incorporated
1900 Market Street, Suite 800
Philadelphia, PA 19103, USA
Tel: +1 (610) 206-0101
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