1. INTRODUCTION Kairos Cognition ("us," "we," “kairos® ,” or "Company") is committed to respecting the privacy rights of its customers, visitors, and other users of the Company Website (the "Site"). We created this Website Privacy Policy ("Privacy Policy") to give you confidence as you visit and use the Site, and to demonstrate our commitment to fair information practices and the protection of privacy. 2. INFORMATION COLLECTION PRACTICES 2.1. TYPES OF INFORMATION COLLECTED ​ (a) TRAFFIC DATA COLLECTED We automatically track and collect the following categories of information when you visit our Site: (1) IP addresses; (2) domain servers; (3) types of computers accessing the Site; (4) types of web browsers used to access the Site; (5) referring site; (6) pages visited on the Site; and (7) the duration of your visit to the Site (your "Session") (collectively "Traffic Data"). Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes or for improving your experience on the Site. We also use "cookies" to customize content specific to your interests, and to store your password so you do not have to re-enter it each time you visit the Site. (b) PERSONAL INFORMATION COLLECTED In order for you to access certain premium services and to purchase products that we offer via the Site, we require you to provide us with certain information that personally identifies you ("Personal Information"). Personal Information includes the following categories of information: (1) Contact Data (such as your name, mailing address, and email address); (2) Financial Data (such as your account or credit card number); and (3) Demographic Data (such as your zip code, age, and income). If you communicate with us by email, post messages to any of our chat groups, bulletin boards, or forums, or otherwise complete online forms, surveys, or contest entries, any information provided in such communication may be collected as Personal Information. 2.2. USES OF INFORMATION COLLECTED ​ (a) USE OF INFORMATION We do not share user-identifiable results with anyone outside of OpenBook Learning, Inc. without your permission. Inside OpenBook Learning, Inc. and its subsidiaries, GTD Focus and Kairos Cognition, user-identifiable results are only shared with those responsible for client development and the maintenance of our servers, databases, and other customer records. We do not share user-identifiable results with any third parties. We may use result data, stripped of identifiable information, for OpenBook Learning, Inc. research and development purposes. We may use Contact Data to send you information about the Company or our products or services, or promotional material from some of our partners, or to contact you when necessary. We may use your Demographic Data to customize and tailor your experience on the site, and for displaying content that we think you might be interested in and according to your preferences. Third party vendors, including Google, show our ads on the internet, and use cookies to serve ads based on a user’s prior visits to this Site. (b) SHARING OF PERSONAL INFORMATION We share certain categories of information we collect from you in the ways described in this Privacy Policy. We reserve the right to share Contact Data and Financial Data with business partners to assist us by performing core services (such as hosting, billing, fulfillment, or data storage and security) related to our business activities and/or operation of the Site. If we do share any such data with business partners, we will require those business partners to agree to uphold the same standards of security and confidentiality that we have promised to you in this Privacy Policy, and they will only use your Contact Data and other Personal Information to carry out their specific business obligations to the Company. By choosing to provide us with Personal Information for a particular purpose, such as providing us with Contact Data and/or Financial Data to make a purchase from the Site, you authorize us to share such information with business partners to the extent this is necessary to carry out the purpose for which you shared the information. If you do not want us to share your Contact Data with any third parties, please email us at, but please understand that such a request will likely limit your ability to take advantage of all of the features and services we offer on the Site. In addition, we maintain a procedure for you to review and request changes to your Personal Information; this procedure is described in Section 3.1, below. If you link to another website through our Site, or purchase a product or service from a third party through an advertisement on our Site, you authorize us and such third party to track your usage and/or exchange any Personal Information you may provide directly or indirectly through your use of the Site. (c) USER CHOICE REGARDING COLLECTION, USE, AND DISTRIBUTION OF PERSONAL INFORMATION You may choose not to provide us with any Personal Information. In such an event, you can still access and use much of the Site; however, you will not be able to access and use those portions of the Site that require your Personal Information. You may opt out of Google's use of cookies by visiting the Google advertising opt-out page, or you can opt out of Google and other third-party vendor's use of cookies by visiting the Network Advertising Initiative opt out page. 3. CONFIDENTIALITY AND SECURITY OF PERSONAL INFORMATION Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties unless you authorize us to do so, or unless such disclosure is necessary to: (a) comply with a court order or other legal process; (b) protect our rights or property; or (c) enforce our Terms of Use. We take commercially reasonable precautions to protect your Personal Information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. Your Personal Information is stored on secure servers that are not accessible by third parties. We transmit sensitive information, such as credit card information, via secured channels. 3.1. USER ABILITY TO ACCESS, UPDATE, AND CORRECT PERSONAL INFORMATION We maintain a procedure in order to help you confirm that your Personal Information remains correct and up-to-date. At any time, you may visit your personal profile at the LOGIN LINK. Through your personal profile you may review and update your Personal Information that we have already collected, and choose whether or not you wish us to send you information about our company. In the event we wish to send you promotional material from some of our partners or share your Personal Information with third parties, we will also give you the opportunity to choose whether or not you wish for us to do so. If you wish to contact us regarding your Personal Information, you may do so by emailing us at 3.2. LOST OR STOLEN INFORMATION Please notify us promptly at if your credit card, user name, or password is lost, stolen, or used without permission. In such an event, we will remove that credit card number, username, or password from your account and update our records accordingly. 3.3. PUBLIC INFORMATION The Site may contain links to other websites. We are not responsible for the privacy practices or the content of such websites. We may also make chat rooms, forums, message boards, and news groups available to you. Please understand that any information that is disclosed in these areas becomes public information. We have no control over its use and you should exercise caution when deciding to disclose your Personal Information. 4. UPDATES AND CHANGES TO PRIVACY POLICY We reserve the right, at any time and without notice, to add, change, update, or modify this Privacy Policy, simply by posting such change, update, or modification on the Site and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Site.

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