Privacy & Policy

Privacy Policy

General

Apex Learning Inc. (““Apex Learning”),
wants to offer you the best experience through its service; For this reason, we are interested in taking care of
the privacy of our users, making this document (the “Policy“)
available to inform about the policies and procedures related to the treatment of information and personal data
that it collects from users through the site. Apex Learning’s web and/or virtual platforms (hereinafter jointly,
the “Platform“).

Apex Learning is committed to ensuring all data collected is protected across all
aspects of our organisation, as per the General Data Protection Regulation (GDPR) as it applies in the UK,
tailored by the Data Protection Act 2018.

Users who access our services through the Platform, agree to be bound by the
provisions of this Policy, accept that their personal information be collected through questionnaires, records,
electronic forms, among others granted and/or virtually required on the Platform, and authorise Apex Learning to
use and process all the information provided to Apex Learning. It is worth mentioning that this Policy is an
integral part of the Terms and Conditions in (LINK UPDATE)

Apex Learning reserves the right to modify the Privacy Policy, which will be
communicated via email with reasonable anticipation of its entry into force.

Definitions

Without prejudice to the terms defined in various sections of this document, the
terms used here with the first capital letter and that are not defined differently will have the meaning
attributed to them below and may be used in masculine, feminine or neutral, as well as singular or plural,
indistinctly and according to the context:

Cookie : It is the data file
that is stored on the user’s device when the user has access to the site.
Responsible for Treatment :
Natural person or legal entity that collects, stores, conserves, uses, blocks or deletes personal data
of Users on behalf of Apex Learning, by virtue of a legal relationship that binds them with it and
defines the scope of performance.
User and/or
Users : That natural person, a natural person with a
business, or legal person who registers on the Platform to acquire the products and/or services offered
on the Platform.
Platform : Includes: (i) the
Internet website www.Apex Learning .com and, (ii) the corresponding applications for mobile devices. The
Privacy Policy applies only to the information that Users provide us through the Platform.
External Servers : We use
other companies, agents or contractors to provide external services. For example, payment processing and
other payment forms provide customer service, analyse and improve data (including information regarding
our users’ interaction with our service).
Personal Information : Allows
to identify and/or make the user identifiable; such as their names, surnames, ID number, telephone
number, email, among others, that Apex Learning deems appropriate to request, in order to be able to
provide the services and/or products offered on the Platform appropriately.
General Information : By
itself, it does not allow the user to be identified, but it may be required by Apex Learning to provide
its services.

From now on, it will be understood that the expression “Personal Data” will refer to
Personal Information and General Information provided by Users.

What information do we collect?

If the user wishes to access the Platform’s services, they must register by
completing the registration form with their Personal Information; including your phone number, email address,
full names, a username, a password.

Likewise, we collect information from the user related to (i) content shared within
the Platform, (ii) course data (behaviour and use of the product, comments and projects created), (iii) payment
data, (iv) data about shopping. Apex Learning may request other Personal Data that it deems appropriate at the
time.

Without prejudice to the above, for security reasons, Apex Learning does not collect
or store: (i) confidential data of the cardholder (such as all credit card numbers or card authentication data),
( ii) data of the instructors, (iii) data about the user’s accounts in other services, unless they are connected
to the Apex Learning account.

We use different international gateways to be able to charge for the Courses, which
process all this information and By accepting the Privacy Policy, you agree to share your information with the
payment gateways indicated above. We do not have access to credit card details or information within a Paypal
account.

We give the user the option to add more information to their profile. The user can
include a profile photo, a brief description, the country and city where he comes from, his date of birth and a
cover image.

What do we use user data for?

Apex Learning will use the information it collects to (i) present the Platform and
its contents; (ii) provide and coordinate with the user the information of the services they request; (iii)
notify the user of changes to the Platform; (iv) allow the user to participate in interactive functions of the
Platform; (v) provide support to the user; (vi) validate the integrity of the information provided; (vii) update
and consult contact details and other relevant information; (viii) answer the user’s inquiries and requests;
(ix) manage User preferences regarding their accounts, (x) carry out statistical studies necessary to enhance
Apex Learning services and improve the User experience; as well as trends and traffic, and keep track of
purchases and usage data. (xi) guarantee compliance with the information security protocols; among other
purposes related to the service provided by Apex Learning to the user; and (xii) facilitate the technical
operation of the services, including troubleshooting, the security of the services, and the prevention of fraud
and misuse.

Unless otherwise indicated in this section of our Policy, we will not share your
Personal Information with any third party without your authorisation, unless it is necessary to execute the
contractual relationship and for the updates that may be given on the Platform.

Likewise, the User’s Personal Data will be used, including, but not limited to, in
the following cases:

System Administration: We may use User Personal Data for the purposes of
administering our systems, assisting in diagnosing problems with servers, monitoring the performance and traffic
of our systems, and gathering demographic information.

Communication and Advertising: We will use Personal Data to
periodically send the user to his email address advertisements, offers and send him advertising about
the products offered on the Platform. In case the user expresses his consent to the sending of
unsolicited advertising material, he will click on the check box “I expressly accept the sending of
advertising and/or commercial material by Apex Learning “, which is located at the end of the Policy.
Without prejudice to this, in case you accept the sending of advertising, but after that, you want to
withdraw the consent, the user may request that the sending of advertising be omitted through email
info@apexlearning.com.
Service Providers: In case we decide to request the services of third
parties in which the User’s Personal Data is involved (for example, security services, payment gateway,
data management and storage, call centres, among others), we will transfer the Data User’s personnel
that are necessary for the providers to carry out their services, either to national or international
service provider companies. In this case, the latter is obliged to maintain the confidentiality of the
information they have or could have access, including their employees or suppliers. It should be noted
that Apex Learning will not be responsible for the obligations that correspond to the Service
Providers.
Other types of disclosure : Without prejudice to any provision to the
contrary, contained in this Policy, we reserve the right, and the user hereby expressly authorised us,
to share their Personal Information or General Information: (1) in response to subpoenas, court orders or legal or administrative
processes of any nature, or to establish, protect or exercise our legal rights or defend against
lawsuits, administrative proceedings and investigations of any nature; (2) if we believe it is necessary
to investigate, prevent or take action regarding potentially illegal activities, fraud, or situations
that involve potential threats to the safety of any person or property; (3) if we believe it is
necessary to investigate, prevent or take action regarding significant abuse of the Platform’s
infrastructure, denial of service attacks, or attempts to compromise the security of the information);
and (4) if we were acquired or merged with another entity, and in the cases of corporate
reorganisations,
Surveys: We can send to your email and/or through text messages or any
other available means, surveys on the services we provide through the Platform, and/or on any other
topic of interest to guarantee the improvement of our services.

By virtue of the aforementioned, Apex Learning transfers Personal Information at the
national and international level of the Users for the purposes detailed in this point, for which the Users give
their informed, prior and express consent.

Rights of Users

Users may access, rectify, oppose and cancel their Personal Data (“Arco Rights”), as
well as the other rights granted by law, which may be exercised by request addressed to the following email:
info@apexlearning.com.

The procedure of Apex Learning before the exercise of the Arco Rights by the user is
subordinate to the provisions and terms established by the Normative Framework for the Protection of Personal
Data.

Notwithstanding the foregoing, Apex Learning may keep certain information of the user
requesting the cancellation, in order to serve as evidence against a possible claim against Apex Learning for
responsibilities derived from the processing of said information. The duration of said conservation may not
exceed the legal limitation period of said responsibilities.

Treatment by third parties:

Whenever Apex Learning entrusts the processing of personal data to a third party or
allows third parties access to its data banks for the provision of a specific service (“”), Apex Learning will
take into account the following specifications:

1.1 Any processing of Personal Data carried out by a third party other than Apex
Learning must be regulated in an agreement with the (“Agreement with the “) that, in which it is expressly
established that the treatment of Personal Data is will be carried out following the instructions of Apex
Learning and under the regulation of the Data Regulatory Framework. Likewise, Apex Learning will establish that
only the Personal Data will be processed for the purposes authorised or established in the contract, so that the
Treatment Manager will not use them for a different purpose, nor will they improperly communicate them to other
people.

1.2 The Agreement must stipulate the security measures that the Treatment Manager
will be obliged to implement, such as the protection of Personal Data, the return or destruction of Personal
Data, once the order has been completed.

1.3 The Agreement with the must establish that, in the event of non-compliance by
the Treatment Manager, the offender will respond to Apex Learning and the authorities for any unauthorised
treatment or use of Personal Data.

1.4 If the Person in Charge of Treatment needs to subcontract with third parties the
services that he was obliged to offer, he must have the prior authorisation of Apex Learning, and this will only
proceed as long as the subcontractor assumes the same obligations as the Person in Charge of Treatment.

1.5 The Agreement must also establish confidentiality obligations regarding the
information accessed by the Treatment Manager, keeping said obligations in force even after the term of the
contract has expired.

Incorporation of Personal Data in a Data Bank

In accordance with the provisions of the Regulatory Framework for the Protection of
Personal Data, Apex Learning informs the Users of the Platform that the User’s Personal Information will be
incorporated into the data banks owned by Apex Learning.

The data banks will be stored by means of External Servers, and the data conservation
time will be according to the purpose of their storage. Without prejudice to this, Apex Learning is hereby
authorised to keep certain information after the fulfilment of the purpose; In order for it to serve as evidence
against a possible claim against Apex Learning for responsibilities derived from the treatment of said
information.

In that sense, through this Policy, the user gives his express consent for the
inclusion of his Personal Information in the aforementioned data banks.

About security measures

Apex Learning guarantees the protection of the User’s Personal Data and avoids its
alteration, loss, treatment and/or unauthorised access, taking into account the nature of the stored data and
the risks to which they are exposed, all in accordance with the provisions of the Regulatory Framework for the
Protection of Personal Data.

Apex Learning employs various security measures to prevent unauthorised access,
misuse or disclosure with technology and processes used in the industry. Notwithstanding this, Apex Learning is
not responsible for illegal interceptions or violation of its systems or databases by unauthorised persons, as
well as the improper use of the information obtained by those means, or for any illegitimate interference that
escapes the control of Apex Learning and that it is not attributable to it.

Apex Learning is not responsible for possible damages that may arise from
interferences, omissions, interruptions, computer viruses, telephone breakdowns or disconnections in the
operational functioning of the electronic system, delays or blockages in the use of the Platform, motivated by
causes unrelated to Apex Learning.

Likewise, Apex Learning does not assume any responsibility for possible damages,
fines or legal actions that could be caused due to the breach of the obligations of the External Servers hired
for the Platform.

Additionally, the Apex Learning Platform may contain links to other websites.
However, it does not assume responsibility for the content of the privacy policies and/or practices of other
websites. When a User accesses a link that redirects him to another website, he must accept and abide by the
privacy policy of the said website.

Cross-border data flow

The servers, providers and/or computers used by Apex Learning to provide its services
may be located outside the country or under another government jurisdiction. The user authorises Apex Learning
to transfer, store and process their Personal Data internationally (“Cross-Border Flow”) in accordance with the
provisions established in the Normative Framework for the Protection of Personal Data, for which they express
their prior, informed, free consent, express and unequivocal.

On the Veracity of Personal Data

Each user is responsible for the veracity, accuracy, validity and authenticity of the
information provided, and undertakes to keep it duly updated. Notwithstanding the foregoing, the user authorises
Apex Learning, if it considers it pertinent, to verify the veracity of the Personal Data provided, through
information obtained from publicly accessible sources or entities specialised in providing said
information.

Personal information requested by public authorities

Apex Learning undertakes not to disclose or share the User’s Personal Data, without
the user having given due consent to do so, with the exception of requests for information from public
authorities in the exercise of their functions and the scope of their powers; by virtue of court orders and/or
legal provisions.

Cookies and other information

We use the user’s IP address to identify problems, administer the Platform and
identify patterns of traffic behaviour. Cookies or similar technology are also used to be able to offer content
according to your interests and to store your password so that the user does not have to enter it again each
time he returns to the Platform. It is essential to mention that we use different types of cookies, tools of
data collection, profiling and online advertising. In this sense, in order for you to have detailed information,
we ask you to review Apex Learning’s Cookies Use Policy. (LINK UPDATE)

Consent

Users declare to have previously read and provide their free, express, unequivocal
and informed consent for Apex Learning to process their Personal Data; Likewise, they declare that they have
been informed about what information is collected, the way in which it will be carried out and the purpose of
collecting Personal Data.

Minors

In the event that Apex Learning collects and processes the Personal Data of minors,
necessary and indispensable for the development of the contractual relationship with the underage User; Apex
Learning will inform the owner of the personal data and/or their legal guardian, about the purposes of the
processing of Personal Data, in accordance with the provisions of article 14 of the Law on Protection of
Personal Data.

Policy Update

Apex Learning expressly reserves the right to modify and/or update this Policy at any
time, in accordance with the modifications or requirements of the regulation or due to adjustments inherent to
the service made at Apex Learning’s criteria.

Any modification and/or update produced in this Policy will come into effect from its
publication on the Platform.

Likewise, Apex Learning will make its best effort to notify Users of said
modifications through their registered email or by publishing the Platform.

Assignment of contractual position

The user expressly authorises the transfer of this Policy and the Personal Data in
favour of any person who (i) is bound by this Policy; and/or (ii) that it is the new person in charge of the
data banks that contain the Personal Data.

After the transfer has been produced, Apex Learning will not have any responsibility
with respect to any event that occurs from the date of the transfer. The new data bank manager will assume each
and every one of Apex Learning’s obligations established in this Policy regarding the treatment, safeguarding
and conservation of Personal Data.

Applicable law

The Privacy Policies are governed and interpreted in accordance with the laws in
force in the United Kingdom, subject to the competence and jurisdiction of the Judges and Courts of the United
Kingdom.

Contact

Apex Learning accepts all types of doubts, complaints or comments regarding the
Privacy Policies. Send us an email info@apexlearning.com or write to us at the following address: Apex Learning
Inc.

I declare that after having read the Privacy Policy, I expressly accept all the terms
contained therein and also authorise Apex Learning to send me advertising and/or commercial material. As a sign
of agreement, I proceed to fill out the visiting user purchase form.