LRN works in collaboration with EthicsPoint, Inc. to make GEMS™ Helpline™ available to its customers. For purposes of this Privacy Policy, the term “Service Provider” means both LRN and EthicsPoint.

The Service Provider is committed to protecting your privacy through a variety of ways including using industry accepted security measures to protect against the loss, misuse and alteration of data contained in our system. The Service Provider Privacy Policy is designed to ensure the safety and accuracy of our customers' and visitors' personal information. Any information given to us will never be sold, rented, traded, or leased.

The Service Provider does not publish text, images, or multimedia content that portray nudity, foul language, violence or other information not suitable for children. Web sites maintained by Service Provider are not directed to children under the age of 13. Service Provider will not knowingly collect or maintain personally identifiable information from or about anyone under 13. The Service Provider is committed to assisting its clients in complying with privacy laws and adhering to the highest industry standards on privacy.

The Service Provider is not responsible for content that is saved to any Service Provider system by reporters or client company representatives

No personally identifying information is automatically collected from reporters using GEMS™ Helpline™ systems. Personally identifying information is stored only when a reporter voluntarily gives this information for use by a client company.

All communications between the Helpline™ site and a user’s web browser are accomplished using 128 bit SSL encryption and Verisign certificates to protect confidential data. The Service Provider does not allow users to transfer or receive confidential information unless they are using a validated 128 bit encrypted session.

All communications between the Helpline™ site and a user's web browser are accomplished using 128 bit SSL encryption and Verisign certificates to protect confidential data. The Service Provider does not allow clients to transfer or receive confidential information unless they are using a validated 128 bit encrypted session.

Session Variables may be used temporarily in your system cache to create ease-of-use during your transaction. All Session Variables are deleted when you log off of Helpline™. Examples of such information are automatically produced alphanumeric numbers held during your session on our site to facilitate page-to-page transactions. Your name, email, phone, address, company name or any other identifying information is not stored at any time.

The Service Provider does not share your personal information with partner companies unless given your expressed permission in writing.

Usernames and passwords are stored in our database for use in our reporting system. This information is kept secure on our private servers and is only used to assist you in accessing your account as a client. No information is released outside of the Helpline system.

The Service Provider provides communications via email to its customers regarding product and service information, system status and upgrades. Additionally, the Service Provider enables customers to submit personally identifying information through completion and submission of inquiry forms related to our provision of services and subscription forms associated with newsletters and seminars. When the Service Provider collects personally identifiable information from opt-in participants, such information is used by Service Provider only to respond to visitors’ requests. In instances where opt-in participants' requests concern Service Provider partners, Service Provider will provide personally identifiable information only to respond to that request. The Service Provider does not sell, rent, lease, trade or share visitors' personally identifiable information. The Service Provider communicates only to users who affirmatively express an interest in receiving e-mails relevant to their interests, and customers may "opt-in" and "opt-out" of receiving email communications from Helpline™ through selections available on emails received.

The Service Provider contracts with third parties for Web-based services that include email delivery and content streaming, that may collect non-personally identifiable visitor data including IP address of their server and pages visited.

No company other than the Service Provider is allowed to access information stored on our servers, unless expressly authorized by the Service Provider. Unauthorized access to this information is a violation of the law. The Service Provider has placed security measures and firewalls on all network servers in an attempt to prevent outside parties from accessing private information. In the event of a breach of security, the Service Provider will press charges to the fullest extent against those parties illegally accessing information on our servers.

If you have reason to believe the Service Provider has breached your confidentiality or privacy, please contact our outside independent director Carl Liggio, Esq. at cliggio@mcandl.com.

The Service Provider utilizes Cookie technology for purposes of web site traffic analysis such as the time/date of the visit, the time/date of last visit, the page viewed, the referrer, transaction information for eCommerce pages, and other data. The Service Provider tracks click behavior in the e-mails it sends out. This data is used to update specific user-profile information, ascertain the areas of most interest to opt-in e-mail recipients, and to personalize e-mail messages to them.

The Service Provider enables visitors to submit personally identifying information from visitors to its Web sites through visitors’ completion and submission inquiry forms related to our provision of services and subscription forms associated with newsletters and seminars. When Service Provider collects personally identifiable information from opt-in participants, such information is used by Service Provider only to respond to visitors’ requests. In instances where opt-in participants’ requests concern Service Provider partners, The Service Provider will provide personally identifiable information only to respond to that request. The Service Provider does not sell, rent, lease, trade or share visitors’ personally identifiable information. The Service Provider communicates only to users who affirmatively express an interest in receiving e-mails relevant to their interests, and visitors may "opt-in" and "opt-out" of receiving email communications through selections available on emails received.

The Service Provider contracts with third parties for Web-based services that include email delivery and content streaming, that may collect non-personally identifiable visitor data including IP address of their server and pages visited.

If you have received unwanted, unsolicited email sent by the Service Provider or from any Service Provider system or purporting to be sent via Service Provider, please forward a copy of that email with your comments to info@ethicspoint.com or info@lrn.com for review.