FranklinCovey Europe Ltd. is committed to protecting the privacy and security of your personal information obtained by reason of your customer relationship with FranklinCovey Europe Ltd. This policy explains the types of customer personal information we collect, how it is used, and the steps we take to ensure your personal information is handled appropriately.

Our policies and practices have been designed to comply with the Data Protection Act 1984 and the versions made in 1998.

Who is FranklinCovey Europe Ltd? For purposes of this Privacy Policy, "FranklinCovey" means FranklinCovey Europe Limited, Products and Training.

What is personal information? Personal information is information that refers to an individual specifically and is recorded in any form. Personal information includes such things as age, income, date of birth, ethnic origin, medical records and credit records. Information about individuals contained in the following documents is not considered personal information:

• public telephone directories, where the subscriber can refuse to be listed
• professional and business directories available to the public
• certain public registries and court records
• certain other publicly available printed and electronic publications

Our commitment to your privacy is governed by the following privacy principles:

1. We are accountable to you
FranklinCovey Europe Ltd. is responsible for all personal information under its control, including any personal information that is transferred to third parties for processing, storage or other purposes. We have employees in each of our business units who are accountable for compliance with these privacy and security principles.

2. We let you know why we collect your personal information
FranklinCovey identifies the purpose for which your personal information is collected. We do this before or at the time the information is actually being collected.

3. We obtain your consent to collect, use or disclose your personal information
FranklinCovey obtains your consent to collect, use or disclose personal information. The method of obtaining consent is appropriate to the type of personal information being collected, used or disclosed:

• FranklinCovey will obtain your express consent (verbal, written or electronic agreement) to collect, use or disclose sensitive personal information.
• FranklinCovey will use implied consent to collect, use or disclose your personal information where one or more of the following apply:
  • a customer relationship already exists
  • express consent has previously been given
  • where the purpose of using the personal information is reasonably apparent to you

You can change your consent preferences at any time by contacting FranklinCovey Europe Ltd's Marketing Department.

4. We limit collection of your personal information
FranklinCovey Europe Ltd. collects only the information required to provide products and services to you. If the personal information we require is collected for a reason other than to provide products and services, your consent will be obtained before or at the time the information is collected. FranklinCovey Europe Ltd. will collect personal information only by clear, fair and lawful means.

Examples of why we collect personal information include:

• Communicating with you generally
• Processing your applications
• Processing and keeping track of transactions and reporting back to you
• Protecting against fraud or error
• Providing product and services requested by you
• Recommending products and services that FranklinCovey believes will be of interest and provide value to you
• To comply with legal and governmental requirements

5. We limit use, disclosure and retention of your personal information
FranklinCovey Europe Ltd. uses and discloses your personal information only for the purposes it was collected. FranklinCovey Europe Ltd. does not sell or rent personal information to any organization or person for any reason. We do not share your personal information with third party organisations except to offer you a product or service. If your personal information is shared with third parties, these third parties are bound by appropriate agreements with FranklinCovey Europe Ltd. to secure and protect the confidentiality of your personal information. FranklinCovey Europe Ltd. retains your personal information only as long as it is required for our business relationship or as required by law.

6. We keep your personal information up to date and accurate
FranklinCovey Europe Ltd. keeps your personal information up to date, accurate and relevant for its intended use. You may request access to the personal information we have on record in order to review and amend the information, as appropriate. In circumstances where your personal information has been provided by a third party, we will refer you to that party (e.g. credit bureaus).

7. The security of your personal information is a priority for FranklinCovey Europe Ltd.
We take steps to safeguard your personal information, regardless of the format in which it is held, including:

• physical security measures such as restricted access facilities and locked filing cabinets
• electronic security measures for computerised personal information such as password protection, database encryption and personal identification numbers,
• organisational processes such as limiting access to your personal information to a selected group of individuals,
• contractual obligations with third parties who need access to your personal information requiring them to protect and secure your personal information.

8. We respond to your questions, concerns and complaints about privacy
FranklinCovey Europe Ltd. responds in a timely manner to your questions, concerns and complaints about the privacy of your personal information and our privacy policies and procedures. How to contact us:

• by calling our UK & Ireland Office on +44 (0) 1295 274100
• by email to solutions@franklincovey.co.uk
• by mail to:

  FranklinCovey Europe Ltd.
  Grimsbury Manor, Grimsbury Green
  Banbury, Oxfordshire, OX16 3JQ
  Attention: Marketing Department