Published on 19 October 2015

This Policy will be reviewed from time to time to take account of new or amended laws, new technology and/orchanges to our operations and practices and the changing business environment. A copy of this policy can be obtained through our website www.pearson.co.za or by contacting the General Counsel: South Africa, Legal and Compliance. All personal information held by us will be governed by the most recently updated policy.

This policy sets out:

• What information we collect;
• How we collect it;
• Why we collect it;
• How we use it;
• How we disclose it;
• Opting in or opting out;
• How we hold it - Management and security; and
• Accessing and updating or correcting your information and how to contact us.

What information we collect

1. In general, we collect personal information in order to conduct our business, to provide and market our goodsand services and to meet our legal and regulatory obligations. The personal information we collect about you includes (but is not limited to) your name, contact details (including phone numbers and addresses), gender, date of birth, occupation and other information which may assist us in conducting our business, and providing and marketing our goods and services. In certain circumstances we collect financial information, including your credit card information where appropriate.
2. We also collect information about you that is not personal information. For example, we may collect datarelating to your activity on our websites (including the type of internet browser you use, your operating system, address of referring site, and your IP address and clickstream information) via tracking technologies such as cookies, or we may collect information from you in response to a survey, promotion or competition. We generally use this information to report statistics, analyse trends, administer our services, diagnose problems and target and improve the quality of our products and services. Cookies allow your browser to utilise some of the features of our sites. We use both session ID cookies and persistent cookies. Most web browsers are set by default to accept cookies. If you reject cookies you will be unable to take advantage of some of the features of our websites.
3. We generally advise that you do not publish or communicate personal information, or at least limit thepersonal information that you publish or communicate, to the public via our services, such as in any forums, blogs or anywhere that user generated content can be uploaded ("Non-Confidential Information"). We cannot control any third party collection or use of your Non-Confidential Information that is publicly available.

How we collect it

1. We may collect your personal information from a variety of sources, including from you, advertisers, mailinglists, recruitment agencies, contractors and business partners.
2. We will generally collect personal information by way of forms filled out by people, face-to-face meetings, interviews, business cards, electronic attachments, telephone conversations and from third parties (representatives, agents or credit reporting agencies). In addition, we collect personal information from our websites through receiving subscription applications, job applications and emails.
3. We may collect your personal information when you request or acquire a product or service from us, registerwith us as a subscriber or member, provide a product or service to us, complete a survey or questionnaire, enter a competition or event, contribute in a fundraising event, participate in our services (including blogs and forums) or when you communicate with us by email, telephone or in writing (for example if you make a complaint or provide feedback).
4. If, at any time, you provide personal or other information about someone other than yourself, you warrant thatyou have that person's consent to provide such information for the purpose for which you provide it to us.

Why we collect it

1. The primary purpose for which we collect information about you is to conduct our business, provide andmarket our products and services to you, meet our legal or regulatory obligations, and also for the management of business transactions entered into with us and the administration of any accounts you have with us. We may state a more specific purpose at the point we collect your information (including but not limited to any law that requires or authorises the particular information to be collected).
2. If you do not provide us with the information that we request, we may not be able to provide you with ourproducts or services. For example, if you do not register as a member of a website, you will not be able to access features or services that are reserved for members or subscribers only.

How we use it

1. In addition to the primary purpose outlined above, we may use the personal information we collect, and you consent to us using your personal information:
2. to provide you with news and information about our products and services, and opportunities that we believe you may be interested in;
3. for purposes necessary or incidental to the provision of goods or services to you;
4. to personalise and customise your experience purchasing or using our goods or services;
5. to manage and enhance our products and services;
6. to communicate with you, including by email, mail or telephone;
7. to conduct competitions or promotions;
8. to verify your identity;
9. to investigate any complaints about or made by you, or if we have reason to suspect that you are in breach ofany of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity;
10. as part of any investigation in relation to you or your activity, including:
    1. if we have reason to suspect that you have committed a breach of any of our terms and conditions, orhave otherwise been engaged in any unlawful activity, and we reasonably believe that disclosure is necessary to any relevant authority or enforcement body, or your Internet Service Provider or network administrator;
    2. where there is actual, alleged or suspected fraud or unlawful activity (including actual, alleged orsuspected fraudulent use by any person other than you of your credit or debit card details to make any purchase from us) and we reasonably believe that disclosure is necessary to, or we have been requested to make disclosure by, any relevant authority or enforcement body.

2. as part of a sale (or proposed sale) of all or part of our business; and/or

3. as required or permitted by any law or regulation.

How we disclose it

1. We may disclose personal information, and you consent to us disclosing your personal information, to othermembers of the Maskew Miller Learning Group (in which case, your personal information will be collected, used, disclosed, managed and stored in accordance with this Privacy Policy). Due to the Global nature of Maskew Miller Learning’s organisation, personal information may be transmitted, stored and processed in a country other than South Africa, including primarily in the United States of America, the European Union and India, and you explicitly consent that the personal information you provide may be transferred, processed and stored in countries outside South Africa.
2. We may also disclose personal information, and you consent to us disclosing your personal information, tothird parties:
   
   1. engaged by us to perform functions or provide products and services on our behalf, such as processing ofcredit card information, debt collection, marketing, research and advertising;
   2. that are our agents, business partners or joint venture entities or partners;
   3. that sponsor or promote any competition that we conduct or promote via our services;
   4. authorised by you to receive information held by us;
   5. as part of any investigation in relation to you or your activity, including:
      
      1. if we have reason to suspect that you have committed a breach of any of our terms and conditions, orhave otherwise been engaged in any unlawful activity, and we reasonably believe that disclosure is necessary to the Police, any relevant authority or enforcement body, or your Internet Service Provider or network administrator; or
      2. where there is actual, alleged or suspected fraud or unlawful activity (including actual, alleged orsuspected fraudulent use by any person other than you of your credit or debit card details to make any purchase from us) and we reasonably believe that disclosure is necessary to, or we have been requested to make disclosure by, the Police or any relevant authority or enforcement body.

2. including but not limited to our external advisers or potential or actual bidders or their external advisers aspart of a sale (or proposed sale) of all or part of our business; and/or

3. as required or permitted by any law or regulation.

Opting in or opting out

1. At the point we collect information from you, you may be asked to "opt in" to consent to us using or disclosingyour personal information for purposes other than those that are expressly stated in this policy. For example, you may be asked to opt-in to receive further information or communications from our advertisers or supporters.
2. You will generally be given the opportunity to "opt out" from receiving communications from us or from thirdparties that send communications to you in accordance with this policy. For example, you will be given the option to unsubscribe to emails or newsletters sent by us.

How we hold it - management and security

1. Once the Protection of Personal Information Act comes into effect, we will appoint an Information Officer tooversee the management of personal information in accordance with this policy and the applicable law and regulations. Until such time, the General Counsel: South Africa, Legal and Compliance, shall fulfil this role.
2. Other than in relation to Non-Confidential Information, we will take all reasonable steps to protect thepersonal information that we hold from misuse, loss, or unauthorised access, including by means of firewalls, password access, secure servers and encryption of credit card transactions.
3. However, you acknowledge that the security of online transactions and the security of communications sentby electronic means or by post cannot be guaranteed. You provide information to us via the internet or by post at your own risk. We cannot accept responsibility for misuse or loss of, or unauthorised access to, your personal information where the security of information is not within our control.
4. If you suspect any misuse or loss of, or unauthorised access to, your personal information, or any otherprivacy breach please let us know immediately.

Accessing and updating or correcting your information and how to contact us

1. You may seek access to, or seek to update or correct, the personal information we hold about you. Thisaccess shall become subject to the Protection of Personal Information Act (once it comes into effect).
2. We will require you to verify your identity and to specify the information to which require access or updating orcorrection. A fee may be charged for providing access, however, we will advise you of the likely cost in advance.
3. Subscribers or members of our websites will generally be able to access and update their membership andcontact details online.
4. We request that you keep your information as current as possible so that we may continue to improve ourservice to you.
5. If you would like to seek access or request updating or correction to personal information we hold about you,or if you have any questions or complaints about how we collect, use, disclose, manage or store your personal information, you can contact the department that collected your personal information in the first instance, or write to: