INTRODUCTION

Welcome to the Taylor Associates (“Taylor Associates”) privacy notice.
Taylor Associates respects your privacy and is committed to protecting your personal data. This privacy notice
will inform you as to how we look after your personal data when you visit our website at www.readingplus.co.uk
(regardless of where you visit it from) or enter into discussions with us regarding the purchase of a
subscription to our Reading Plus application and tell you about your privacy rights and how the law protects
you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out
below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS & PRIVACY SHIELD
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice aims to give you information on how Taylor Associates collects and processes your personal
data through your use of this website, including any data you may provide through this website when you complete
a contact form or in the course of discussions regarding the purchase of a subscription to our Reading Plus
application. This website is not intended for children and we do not knowingly collect data relating to children
via this website.

It is important that you read this privacy notice together with any other privacy notice or fair processing
notice we may provide on specific occasions when we are collecting or processing personal data about you so that
you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and
is not intended to override them. In particular, if you wish to understand how we collect and process personal
data when you use our Reading Plus Application please refer to our Reading Plus Application Privacy Policy
https://privacy.readingplus.com.

Controller

Taylor Associates Communications, Inc (referred to as “Taylor Associates”, “we”,
“us” or “our” in this privacy notice) is the data controller and is responsible for the
personal data we collect through your use of the website or through our discussions with you regarding the
purchase of a subscription for our Reading Plus application.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy
notice. As a US based company, we have also appointed an EU Representative to ensure you have a local point of
contact to which you can address questions about this privacy notice. If you have any questions about this
privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager or
our EU Representative using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Taylor Associates Communications, Inc

Name or title of data privacy manager: Roger Harris

Email address: privacy-manager@readingplus.com

Postal address: 110 W. Canal St. Suite 301 Winooski, VT 05445 USA

Telephone number: +1 800 732-3758

Our EU representative’s full details are:

Full name of EU Representative: Reading Solutions UK Ltd

Email address: info@readingsolutionsuk.com

Postal address: Enterprise House, Kingsway N, Gateshead, NE11 0SR

Telephone number: 0191 389 6078

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) which is
the UK supervisory authority for data protection issues. The ICO’s website is located at www.ico.org.uk. We
would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact
us in the first instance. We will investigate and seek to resolve any complaints as soon as reasonably possible.

Please also refer to the section on International Transfers & Privacy Shield to understand about your rights
to refer complaints to an independent dispute resolution body and, in some cases, to invoke binding arbitration.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on August 22, 2018 and historic versions are archived here
https://live-www-readingplus-co-uk.pantheonsite.io/privacy-policy-2017.

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 relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or
enabling those connections may allow third parties to collect or share data about you. We do not control these
third-party websites and are not responsible for their privacy statements. When you leave our website, we
encourage you to read the privacy notice of every website you visit.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be
identified. It does not include data where the identity has been removed (anonymous data).

You may visit our website, and we may capture your personal data, because you are: a current or potential
individual or corporate client (or an employee of one of our corporate clients or potential corporate clients);
a parent whose child uses our Reading Plus application; a supplier to our company; a business partner of our
company; an individual with a personal or professional interest in the research we undertake; or a current,
former or potential future employee of our company.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together
follows:

• Identity Data includes first name and last name, username or similar identifier, title,
  employer and personal or professional role e.g. teacher or parent.
• Contact Data includes postal address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone
  setting and location, browser plug-in types and versions, operating system and platform and other technology
  on the devices you use to access this website.
• Usage Data means information about how you use our website.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of
  products and services you have purchased from us.
• Profile Data includes your username and password, purchases or orders made by you, your
  interests, preferences, feedback and survey responses.

We also collect, use and share Aggregated Data such as statistical or demographic data for any
purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as
this data does not directly or indirectly reveal your identity. For example, we may aggregate
your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we
combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you,
we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about
your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions,
trade union membership, information about your health and genetic and biometric data). Nor do we collect any
information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to
provide that data when requested, we may not be able to perform the contract we have or are trying to enter into
with you (for example, to provide you with services). In this case, we may have to cancel a product or service
you have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling
  in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you
  provide when you:
  • enter into discussion with us to purchase a subscription for our Reading Plus application;
  • enter a competition, promotion or survey; or
  • give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may
  automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this
  personal data by using cookies, and other similar technologies. Please see our cookie policy https://live-www-readingplus-co-uk.pantheonsite.io/cookies/ for further
  details.
• Third parties or publicly available sources. We may receive personal data about you from
  various third parties and public sources as set out below:
  • Technical Data from the following parties:
    • analytics providers such as Google based outside the EU;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services
    such as Salesforce, LiveAgent and Hubspot, based outside the EU.
  • Identity and Contact Data from our UK reseller, Reading Solutions UK Ltd.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral
    Register.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in
the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and
  fundamental rights do not override those interests
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data. Should we wish to use
your data for a purpose that requires your consent in the future we will contact you to explain the purpose for
which consent is required and to seek your consent.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and
which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where
appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for
which we are using your data. Please contact us if you need details about the specific legal ground we are
relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, client relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of clients for our products and services, to keep our website updated and relevant and to develop our business)

Marketing

We do not undertake any marketing activities in the UK or aimed at individuals in the UK.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access
cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible
or not function properly. For more information about the cookies we use, please see our cookie policy
https://live-www-readingplus-co-uk.pantheonsite.io/cookies.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider
that we need to use it for another reason and that reason is compatible with the original purpose. If you wish
to get an explanation as to how the processing for the new purpose is compatible with the original purpose,
please contact us.

Should we wish to use your personal data for a purpose that is materially different from the purposes for which
we collected it, we will contact you to notify you about the new purpose and will only begin processing your
personal data for that new purpose where you have consented to our doing so.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes outlined in the table in
paragraph 4 above:

• External Third Parties as set out in the Glossary.

We have data processing agreements in place with External Third Parties which do not allow those External Third
Parties to use your personal data for their own purposes and only permit them to process your personal data for
specified purposes and in accordance with our instructions. Our External Third Parties are required to adhere to
the same standards of data protection as we follow and we have measures in place to monitor our External Third
Parties’ compliance. In some circumstances, we will remain liable to you for the actions of our External Third
Parties.

• Reading Solutions UK Ltd, our UK reseller.

Reading Solutions UK Ltd is our UK reseller and a data controller in its own right. We may transfer your personal
data to Reading Solutions UK Limited if you contact us because you wish to become a client (or are representing
a corporate entity that wishes to become a client), because you are an existing client (or are representing a
corporate entity that is an existing client) and you have misdirected a query or question regarding your account
to us. We have a written agreement in place with Reading Solutions UK Ltd under which Reading Solutions UK Ltd
commits to applying the same data protection standards as we apply ourselves. You may ask us not to transfer
your personal data to Reading Solutions UK Limited but please note that if you do so you may not be able to
subscribe to our Reading Plus application.

• Other third party data controllers.

We may share your personal data with other third party data controllers to whom we may choose to sell, transfer,
or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge
with them. If a change happens to our business, then the new owners may use your personal data in the same way
as set out in this privacy notice.

• Disclosures for national security or law enforcement purposes or to meet legal requirements

In some circumstances we may be required to disclose your personal data in response to valid requests from public
authorities or governmental departments, both in the United Kingdom and in the United States. This may be in
order to meet legal obligations we are subject to (for example, we will disclose information to HM Revenue &
Customs in the UK in relation to paying tax) or to meet national security or law enforcement obligations.

INTERNATIONAL TRANSFERS & PRIVACY SHIELD

Taylor Associates is a US company. Our servers, offices and staff are all located in the United States. All
personal data that we collect (as described in this Privacy Policy) will be transferred to the United States,
and all of the processing of that personal data (as described in this Privacy Policy) will take place in the
United States.

Whilst the data protection laws in the United States may not be as comprehensive as those in force in the United
Kingdom, as a supplier of services to individuals in the European Union, Taylor Associates is directly subject
to, and required to comply with, the General Data Protection Regulation.

In addition, because we transfer your personal data to the United States, we have registered under the EU–U.S
Privacy Shield and are committed to complying with the principles of the Privacy Shield including notice,
choice, accountability for onward transfer, security, data integrity and purpose limitation, access and
recourse, enforcement and liability.

For the purposes of enforcing compliance with the Privacy Shield, Taylor Associates is subject to investigatory
and enforcement authority of the U.S. Federal Trade Commission.

To learn more about the Privacy Shield Framework, and to view our certification, you can visit the U.S.
Department of Commerce’s Privacy Shield website at https://www.privacyshield.gov/welcome. A list of Privacy
Shield participants is maintained by the Department of Commerce and is available at https://www.privacyshield.gov/list.

As stated at the beginning of this Privacy Policy, you can direct any questions or complaints about the way we
process your personal data to us or to our EU Representative Reading Solutions UK Ltd, via email: info@readingsolutionsuk.com, postal mail: Enterprise
House, Kingsway N, Gateshead, NE11 0SR, telephone: 0191 389 6078.

We will seek to resolve any complaints addressed directly to us within 45 days. If we have not resolved your
complaint successfully within 45 days, we have agreed to co-operate with the EU data protection authorities. If
you are unsatisfied with the resolution of your complaint you may contact the EU data protection authorities at
https://ico.org.uk/concerns/eu-us-privacy-shield/ for further information and assistance. This service will be
provided at no cost to you.

You may have the option of selecting binding arbitration for the resolution of your complaint under certain
circumstances, provided you have: (1) raised your complaint directly with Taylor Associates (or our EU
Representative) and provided us with the opportunity to resolve the issue; (2) made use of the independent
dispute resolution mechanism described above; and (3) raised the issue through the Information Commissioner’s
Office and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For
more information on binding arbitration, see the US Department of Commerce’s Privacy Shield Framework: Annex 1
at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

Your personal data will also be processed outside of the EEA by data processors acting on our instructions as
follows:

Name/nature of processor	Description of processing activities	Country/countries in which processing takes place	Safeguards implemented
Amazon Web Services, Inc	Provision of data centre facilities, servers, networking equipment and host software systems	United States	Standard Contractual Clauses & EU-US Privacy Shield
Google Cloud	Provision of cloud computing services	United States	EU-US Privacy Shield
Cloudflare	Provision of content delivery network services, DDoS mitigation, Internet security and distributed domain name server services	United States	Standard Contractual Clauses & EU-US Privacy Shield
Salesforce	Provision of cloud computing services	United States	Standard Contractual Clauses & EU-US Privacy Shield
Citrix	Provision of secure file sharing	United States	Standard Contractual Clauses & EU-US Privacy Shield
HubSpot	Provision of marketing and communication services	United States	Standard Contractual Clauses & EU-US Privacy Shield

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost or
used or accessed, altered or disclosed accidentally or in an unauthorised way. In addition, we limit access to
your personal data to those employees, agents, contractors and other third parties who have a business need to
know. They will only process your personal data on our instructions and they are subject to a duty of
confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any
applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

How long will you use my personal data for?

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 unauthorised 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.

Details of retention periods for different aspects of your personal data are available in our retention policy
which you can request from us by contacting us.

In some circumstances you can ask us to delete your data; see Your Legal Rights below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for
research or statistical purposes in which case we may use this information indefinitely without further notice
to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You
have rights to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

Please refer to the Glossary at the end of this policy to find out more about these rights or visit the
Information Commissioner’s Office website at www.ico.gov.uk.

If you wish to exercise any of the rights set out above, please contact us.

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 is clearly unfounded, repetitive or excessive. Alternatively, we may
refuse to comply with your request in these circumstances.

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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that
personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you
for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if
your request is particularly complex or you have made a number of requests. In this case, we will notify you and
keep you updated.

GLOSSARY

Legitimate Interest means the interest of our business in conducting and managing our business
to enable us to give you the best service/product and the best and most secure experience. We make sure we
consider and balance any potential impact on you (both positive and negative) and your rights before we process
your personal data for our legitimate interests. We do not use your personal data for activities where our
interests are overridden by the impact on you (unless we have your consent or are otherwise required or
permitted to by law). You can obtain further information about how we assess our legitimate interests against
any potential impact on you in respect of specific activities by contacting us or our EU Representative.

Performance of Contract means processing your data where it is necessary for the performance of
a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is
necessary for compliance with a legal or regulatory obligation that we are subject to.

External third parties

• Service providers acting as data processors based in the United Kingdom or the United States who provide IT
  and system administration services.
• Professional advisers acting as data processors or joint data controllers including lawyers, bankers,
  auditors and insurers based in the United Kingdom or the United States who provide consultancy, banking,
  legal, insurance and accounting services.

Your legal rights

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 data we hold about you corrected, though we may need to verify the accuracy of
  the new data you provide to us.
• 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 successfully exercised your right to object to
  processing (see below), where we may have processed your information unlawfully or where we are required to
  erase your personal data to comply with local law. Note, however, that we may not always be able to comply
  with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the
  time of your request.
• 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 as you feel it impacts on your fundamental rights and freedoms. You also
  have the right to object where we are processing your personal data for direct marketing purposes. In some
  cases, we may demonstrate that we have compelling legitimate grounds to process your information which
  override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to
  suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the
  data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c)
  where you need us to hold the data even if we no longer require it as you need it to establish, exercise or
  defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have
  overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to
  you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable
  format. Note that this right only applies to automated information which you initially provided consent for
  us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data.
  However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
  If you withdraw your consent, we may not be able to provide certain products or services to you. We will
  advise you if this is the case at the time you withdraw your consent.