Effective May 25, 2018
This Policy applies to the processing of personal information collected in connection with the digital learning environments (each a “DLE”) Remote-Learner hosts on behalf of our clients, the R-L website (rlwebsite2017.wpengine.com), R-L’s client information portal Learning Spaces (www.learningspaces.remote-learner.com), and the normal business operations and communications conducted with clients, end-users, and visitors (collectively, our “Service”). By using the Service, you consent to the privacy practices described in this Policy as well as the terms of any agreement you have entered into with R-L (each an “Agreement”). Capitalized terms used but not defined in this Policy have the meaning given to them in such Agreement.
This Policy applies to R-L’s collection, use, and disclosure of the personal information in the following categories:
- Attendees: Individuals who provide their information to R-L representatives when they attend or register to attend R-L-sponsored events or other events at which we participate.
- Website Visitors: Individuals who visit R-L’s websites (rlwebsite2017.wpengine.com) or Learning Spaces (www.learningspaces.remote-learner.com). For clarity, “websites” does not include any sites owned or operated by R-L’s clients, partners, or services providers.
- Clients: Entities or organizations that have entered into agreements with R-L for the Service.
- End Users: Individuals who visit a Client DLE and whose information we process in order to provide the Service to our Clients pursuant to our agreements with them.
- Data Sources: Encompasses Attendees, Website Visitors, Clients, and End Users.
This Policy does not apply to our partners and service providers who may have their own terms and privacy policies. Our Clients are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, including those relating to the collection of personal information in connection with the use of our Service by End Users with whom our Clients interact.
Personal Information Collected
For the purpose of this Policy, “personal information” means any information relating to an identifiable person who can be directly or indirectly identified, in particular by reference to an identifier such as a name or email address. In connection with the Service, R-L obtains personal information from various sources described below.
Information Attendees Provide
R-L may ask for and collect personal information such as name, email address, or organization when Attendees register for or attend a sponsored event or other events at which R-L (and/or its representatives) participates.
Information Website Visitors Provide
R-L requests – at the discretion of Website Visitors – personal information via a contact form including name, email, phone number, and company. R-L may also ask Website Visitors to submit similar personal information if they choose to use interactive features of the Website, including participation in surveys, promotions, webinars, requesting email notifications or otherwise communicating with us. R-L sends such communications in accordance with applicable law.
As is standard practice with most websites, R-L collects information provided by the Website Visitor’s browser including the visitor’s IP address, operating environment (such as browser type and version, browser plugins installed, operating system version, regional and language settings, screen size and/or resolution, windows size, and page size), access dates and times, and referring websites. Additionally, R-L automatically collects information about Website Visitors such as the pages, features, and other materials accessed, the amount of data transferred, the links clicked, the amount of time the spent interacting with each page, and other information about the Website Visitor’s interactions with the website.
Website Visitors should be aware that websites offers many interactive elements including forums, search fields, login data, and course activities. If Website Visitors choose to participate in any of these interactive elements, please be aware that any information posted or provided might be read, collected, and used by others who access it. If Website Visitors wish to remove their personal information from any of our interactive areas, please see the section below entitled “Data Rights.”
Information Clients Provide
Information End Users Provide
R-L has no direct relationship with End Users of a Client’s DLE. It should be understood that as a data processor, R-L does not dictate the nature of the personal information collected nor is it responsible for the access to that information. The responsibility for information collection, types of information collected, and access to that information lies with R-L’s Clients. R-L is responsible for site-level access security and notifications to Clients. R-L relies upon Clients to comply with the legal requirements that apply to subject access requests. Clients are solely responsible for ensuring compliance with all applicable laws and regulations with respect to their DLE End Users.
As is standard practice with most sites, R-L collects information provided by the End User’s browser including the End User’s IP address, operating environment (such as browser type and version, browser plugins installed, operating system version, regional and language settings, screen size and/or resolution, windows size, and page size), access dates and times, and referring websites. Additionally, R-L automatically connects information about the End User’s visit to a Client’s DLE such as to the pages, features, and other materials accessed by the End User, the amount of data transferred by the End User, the links the End User clicks, the amount of time the End User spends interacting with each page, and other information about the End User’s interactions with the website.
How Personal Information is Used
- R-L only stores and uses personal information as is reasonably necessary or appropriate in connection with the use of the Service, including: (a) to contact Clients in connection with the use of the Service, including to respond to Client inquiries; (b) for authentication and identification purposes; (c) to enable R-L to provide the Service; (d) to process payments and to provide Clients with notices about their accounts and subscriptions; (e) to fulfill any other purpose for which Data Subjects provide such information to R-L; (f) in any other way R-L may describe when Data Subjects provide the information; (g) to carry out R-L’s business and legal obligations and enforce R-L’s rights related thereto; (h) to provide Data Subjects with relevant advertising and promotions; (i) to ensure compliance with the Agreements and/or to investigate any potential breach of the Agreements; and (j) to protect R-L’s networks, data, software, or business interests.
- R-L will not sell or lease personal information to any third party, and R-L will not knowingly disclose personal information to a third party unless specified in subsections A and C of this section. R-L may use the information it has collected to enable it to display advertisements to its advertisers’ target audiences. Even though R-L does not disclose personal information for these purposes without consent, if a recipient interacts with an advertisement, the advertiser may assume that the recipient meet its target criteria.
- to any person, entity or organization which has a Data Subject’s consent for R-L to disclose personal information to;
- to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of R-L’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by R-L about its users is among the assets transferred;
- to any of its business partners and agents who provide hosting services, and website and technical support providers, as is necessary or required in connection with the operation, maintenance, and support of the Service;
- to any person, entity or organization in order to facilitate the provision of the Service, such as providing name and payment information to R-L’s third party payment processors;
- to comply with any legal requirements, subpoena, discovery requests, or court orders, to defend any legal or administrative proceedings, or as R-L believes in good faith is necessary to comply with any laws or legal requirements;
- as R-L believes is necessary or appropriate in an emergency situation, including without limitation, to prevent criminal activity, personal injury or property damage;
- to law enforcement, financial institutions or other appropriate authorities in connection with any investigation of suspected criminal or fraudulent activity by any person or entity; and
- if R-L believes it is necessary or appropriate to protect the rights, property, or safety of itself, its business partners, its users, or third parties (including, without limitation, to facilitate the enforcement of R-L’s rights under the Agreements).
Use of Non-Personal Information
R-L may use non-personal information (including, for example, aggregated information about its users or information that does not identify any individual) for any purposes whatsoever (including without limitation, advertising, marketing, enhancing, designing, or developing products and/or services, and research), and R-L may share non-personal information with others, including its partners, affiliates, and service providers.
How Personal Information is Kept Safe
R-L takes the security of personal information very seriously. R-L has established and maintains administrative, physical, and technical measures to secure and protect personal information in our possession against accidental or illegal destruction, loss, theft, alteration, disclosure, access, misuse or any other form of data processing. R-L also restricts access to personal information to employees who require it to provide Services and it takes measures to delete personal information when the information is no longer necessary for the purposes for which it was processed unless required by law or by an Agreement to keep the information for a longer period.
However, R-L cannot guarantee that information will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of R-L’s security measures. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. Any transmission of personal information is at Client’s own risk. R-L is not responsible for circumvention of any privacy settings or security measures contained in the Service.
If Data Subjects have any questions about the security of personal information, contact firstname.lastname@example.org.
Attendees and Website Visitors
Subject to applicable law, Attendees and Website Visitors have the right to access, correct, update, export, restrict, anonymize, or delete their personal information. To make such a request, they may email R-L at email@example.com and R-L will respond within thirty (30) days. Please note that these rights may be limited in some circumstances by local law.
Device operating systems or browsers may include settings, options, or add-on components to control the placement and presence of cookies. If Attendees and Website Visitors choose to delete, modify, or alter cookies, they may not be able to utilize the full set of Service features and functionalities.
Please be aware that it may take up to ten (10) business days to process a request to opt out of receiving commercial email from R-L or otherwise modify the nature or frequency of promotional communications to be received.
Subject to applicable law, Clients have the right to access, correct, update, export, restrict, anonymize, or delete personal information. To make such a request, Clients may email firstname.lastname@example.org and R-L will respond within thirty (30) days. In addition, Clients also have the right to lodge a complaint with a competent supervisory authority subject to applicable law. Please note that these rights may be restricted and subject to conditions under applicable law.
Device operating systems or browsers may include settings, options, or add-on components to control the placement and presence of cookies. If Clients choose to delete, modify, or alter cookies, they may not be able to utilize the full set of Service features and functionalities.
Third Party Sites
R-L is an international organization with affiliates, partners, and service providers in the United States and Canada. R-L stores information in these regions but may transfer and/or access that information from around the world for the purposes of storage and processing of data, fulfilling Data Source requests, and otherwise operating the Service as described in this Policy, as is customary and unavoidable for cloud-hosted solutions transmitting data on the public Internet.
If Data Sources choose to use the Service from regions of the world with laws governing data collection and use that may differ from the laws in the United States or Canada, they acknowledge that they may be transferring personal information outside of those regions to the United States or Canada for storage and processing. By using the Service or otherwise providing information to R-L, Data Sources agree to the transfer of personal information to the United States or Canada.
R-L does not deliberately collect the personal information of minors. If R-L discovers that the personal information of a minor has been inadvertently acquired, it will take all necessary steps to remove and erase that information within ten (10) days.
Remote-Learner US, Inc.
1550 Larimer Street, Suite 785
Denver, CO 80202 USA
Attention: Data Protection Officer
Remote-Learner Canada, Inc.
180 Northfield Drive West, Suite 4
Waterloo, ON N2L 0C7
Attention: Data Protection Officer