Other Covered Entities

KtoAct Limited


  • Education
  • Adult Education and Training


Swiss-U.S. Privacy Shield Framework: Active

Original Certification Date: 12/4/2019
Next Certification Due Date: 1/15/2021
Data Collected: NON-HR

EU-U.S. Privacy Shield Framework: Active

Original Certification Date: 2/5/2019
Next Certification Due Date: 1/15/2021
Data Collected: NON-HR

Purpose of Data Collection

Adeption processes two primary types of data. 1) User profile data - Personal Data: (Name, email, phone number, country, city, job title, organization, team). This information is used to contact users via notifications and also to provide a profile to other participants on the learning platform who are in their network of learners. 2) Learning data - Activity Data: (Answers to questions and actions that users set to progress their learning). Adeption processes this data to provide a record of learning objectives and actions for the users to reflect on, and it uses this data to match learning tools and content to their specific requirements. This data is only visible to the users, and their manager and coach who are aligned to the program and other users who are in their selected 'peer' group or are a part of their learning network. Adeption also aggregates user data into meta-level data which provides generalized insights on overall trends of learners. This meta-level data is not user specific and is anonymous. The meta-level data may be shared with the organizations that the user may be employed as data insights. This is used to make decisions about future learning experiences that the organization provides to aid its learners (users). The meta-data may also be used for research into learning trends and improve the prediction of matching content to key phrases that users provide. It is important to note that the meta-level data is not user-specific and therefore is not personal data.

Privacy Policy

Non-HR Data


Adeption Privacy policy and use of data

Effective Date: 11/28/2019

Verification Method


Dispute Resolution

Questions or Complaints?

If you have a question or complaint regarding the covered data, please contact KtoAct Limited at:

Tim Winstone
Chief Operating Officer
KtoAct Limited
1 Belvedere Drive Suite 200
Mill Valley, California 94941

Privacy Shield organizations must respond within 45 days of receiving a complaint.

If you have not received a timely or satisfactory response from KtoAct Limited to your question or complaint, please contact the independent recourse mechanism listed below


Appropriate statutory body with jurisdiction to investigate any claims against KtoAct Limited regarding possible unfair or deceptive practices and violations of laws or regulations covering privacy Federal Trade Commission