This Privacy Policy governs the manner in which CCKF (T/A, DBA Realizeit) collects, uses, maintains and discloses information collected from users (each, a “User”) of the http://www.realizeitlearning.com website and the Realizeit Application site (“Sites”).

Personal identification information

We may collect personal identification information from Users in a variety of ways in connection with activities, services, features or resources we make available on our Sites. Users may visit our Corporate Site anonymously where we will collect personal identification information from Users only if they voluntarily submit such information. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Corporate Site related activities.

Non-personal identification information

We may collect non-personal identification information about Users whenever they interact with our Sites. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Sites, such as the operating system and the Internet service providers utilized and other similar information.

Web browser cookies

Our Sites may use “cookies” to enhance User experience. User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. Users may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Sites may not function properly.

How we use collected information

Realizeit may collect and use Users personal information to improve our Sites experience. Please see a full description of What Realizeit does with the information it collects in the Privacy Shield section below.

How we protect your information

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Sites. The Company will comply with EU Regulation 2016/679 commonly known as the “GDPR”. GDPR updates will be provided to the Client as is required by the Regulation.

Sharing your personal information

We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined in this policy.

Third party websites

Users may find advertising or other content on our Sites that links to the sites and services of our partners, suppliers, advertisers, sponsors, licencors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Sites. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Sites, is subject to that website’s own terms and policies.

Compliance with children’s online privacy protection act

Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our Sites from those we actually know are under 13, and no part of our website is structured to attract anyone under 13.

Changes to this privacy policy

Realizeit has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Your acceptance of these terms

By using this Sites, you signify your acceptance of this policy and terms of service. If you do not agree to this policy, please do not use our Sites. Your continued use of the Sites following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting us

If you have any questions about this Privacy Policy, the practices of this sites, or your dealings with this site, please contact us at: Realizeit, 220 North Smith Street, Suite 228, Palatine IL 60067 or email us at info@realizeitlearning.com.

EU-U.S Privacy Shield Framework additional policy elements

Realizeit complies with the EU-U.S Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information received from the European Union. Realizeit and its affiliates have certified that they adhere to the Privacy Shield principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability (“Principles”). If there is any conflict between the policies in this Statement and the Privacy Shield Principles, the Principles shall govern. To learn more about Privacy Shield, please visit the U.S. Department of Commerce Privacy Shield website: https://www.privacyshield.gov/. For more information regarding our Privacy Shield certification, please see: https://www.privacyshield.gov/.

The purpose of this Privacy Shield Statement (“Statement”) is to outline how we (Realizeit) comply with the Principles with respect to the personal information we collect. If you would like to obtain additional information regarding our privacy practices in connection with information collected on this website in general, please refer to our Privacy Policy. If there is any conflict between this Statement and the Privacy Policy, this Statement shall prevail.

What Realizeit does with the information it collects

Realizeit makes adaptive learning lessons comments, discussion boards, messaging faciality available in certain areas of the Services. Please remember that any information that is disclosed in these areas becomes public information, and you should exercise caution when deciding to disclose your personal information.

The personal information you supply to Realizeit will not be given, sold, rented, loaned, or otherwise disclosed to any third parties outside of Realizeit and its agents, except when we have your permission and the Institution/corporations permission or under special circumstances, such as when we believe in good faith that disclosure is reasonably necessary to (i) comply with legal process, (ii) enforce the Terms of Use, (iii) respond to claims that any content provided by using the Services violates the rights of third parties, or (iv) protect the rights, property, or personal safety of Realizeit, its users, or the public.

Realizeit may use aggregated personal information to determine the demographic composition of our user base and to distribute statistics/data analytics/usage analytics and general marketplace information about Realizeit. This aggregate information does not identify specific users.

Certain non-personal information regarding users is recorded by the standard operation of the Internet servers hosting the Services and by necessary applications required to deliver the Service. This information is primarily used to provide users of the Services with an enhanced online experience i.e. the adaptive learning experience. Realizeit may disclose aggregated user statistics/analytics in order to describe the Services to prospective partners, advertisers, and other third parties, and for other lawful purposes.

Some features of the Services may be offered in conjunction with a partner company selected by us or by your Institution/Corporation. In order to provide these features, it may be necessary for either you or us to share your personal information with this company. If you do not want your information to be shared, you can choose not to allow the transfer by not using that particular feature.

Also, please be aware that advertisers or Web sites may have linked to Institutional/Corporate sites which link to the Services and they may collect personally identifiable information about you. The information practices of those Web sites linked in this manner are not covered by this Privacy Policy and Realizeit is not responsible for the privacy practices or the content of such Web sites.

Realizeit utilizes other companies to provide limited services on its behalf, including but not limited to customer support, web analytics, coordination of mailings and event management. These companies are permitted to access only the information they require to perform those services. Realizeit requires these companies to maintain the confidentiality of any personal information and prohibits them from using the information for any other purpose than the purpose for which it was collected.

Realizeit’s transfer of Personal/Student Data to a third party in the event of a company transaction is governed by our agreements with our educational institutions and applicable law.

Scope

This Statement applies to any personal information received by Realizeit and its affiliates from the European Union in reliance on Privacy Shield.

Realizeit Data Processing Activities

Realizeit at times acts as a data processor or a data controller when processing personal data transferred from the EU, depending on the Realizeit product or service. Though the types of data Realizeit collects and processes may vary depending on the product and our customers’ preferences, data we collect typically includes personal information relating to students and other end users of our products and services and educational institutions/corporations, billing and payments information, web browsing behaviour and other information relating to a user’s device used to access the services, and other information as described in our Privacy Policy. Realizeit processes this data for the purpose of providing our business and consumer services; billing and payments; customer service and product support; communications and marketing; analytics to inform and improve our services; other internal purposes.

Principles

1. Notice. We will provide individuals with notice of our data collection and processing practices in our Privacy Policy, describing what personal information we collect, the purpose and use of personal information, the categories of third parties with whom we may share such information (and the purposes for which we do so), the individual’s right to access such information, the choices and means through which the individual may limit the use and disclosure of personal information, and other disclosures consistent with the Notice Principle. Where we process personal information on behalf of an educational or other institution (each an “Institution”) with which you have a direct relationship, we will work with them to help them provide appropriate notice to you.

2. Choice. We offer individuals the opportunity to opt-out of providing PII, personal identifiable information, (we presently do not gather sensitive personal information, SPI). We do not disclose PII to a third party (other than to a service provider, the users educational institution/corporation or pursuant to lawful request as set forth below), or use PII for a purpose materially different from the purpose for which it was originally collected (as set out in our Privacy Policy) or subsequently authorized by you if such circumstances arise. You also have the ability to opt out at any time from the use of your personal information for direct marketing purposes, by following the unsubscribe procedures indicated in the mailing and use the designated functionality. If you have further questions related to the above, you can also contact us at info@realizeitlearning.com. Where we process personal information on behalf of an Institution, we will work with that Institution/corporation to comply with any individual’s choices for limiting use or disclosure of personal.

3. Onward Transfers (Transfer to Third Parties). Realizeit may transfer personal information to certain third parties (as described above). Where we transfer personal information to a third party, will take reasonable and appropriate steps to ensure the third party processes personal information for limited and specified purposes and in a manner consistent with Realizeit’s Privacy Shield obligations. Where the transfer is to a third-party agent acting on our behalf, Realizeit may be liable if such third parties fail to meet those obligations, and we are responsible for the event giving rise to the damage.

4. Security. We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have implemented appropriate physical, electronic and managerial procedures to help safeguard and secure personal information from loss, misuse, unauthorized access or disclosure, alteration or destruction.

5. Data Integrity and Purpose Limitation. We will process personal information in a manner that is compatible with and relevant to the purpose for which it was collected or authorized by individuals. Where we receive personal information from an Institution, it shall be the Institution that determines those purposes. To the extent necessary for those purposes, we will take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use.

6. Access. EU individuals have the right to reasonable access to the personal information about you that we hold. On request, we will also take reasonable steps to correct, update, amend or delete any information that is demonstrated to be inaccurate, except where the burden or expense of doing so would be disproportionate to the risks to your privacy in the case in question or where the rights of third parties would be violated. Where we process personal information on behalf of an Institution, we will direct any individual requests for access or to limit use or disclosure to the Institution, and we will work with such Institution in complying with such requests in accordance with applicable law and our obligations under Privacy Shield.

7. Jurisdiction and Enforcement. As part of our participation in Privacy Shield, we are subject to the investigatory and enforcement powers of the US Federal Trade Commission.

8. Lawful Requests. Realizeit may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

9. Contact Realizeit and Recourse
In compliance with the Privacy Shield Principles, Realizeit commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact (your organization name) at:

info@realizeitlearning.com or write to:

Privacy and Security

Realizeit

220 N Smith St., Suite 228

Palatine, IL 60067

USA

Realizeit has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.