It governs the use of data collected by our software platforms, as components of Realityworks products (from now on referred to as “Realityworks product(s)”) as well as our online web platforms within Realityworks.com (from now on referred to as “Realityworks online”).
As used in this Privacy Policy, ‘personal information’ means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person.
FERPA, COPPA and SOPPA Compliance
Realityworks products and Realityworks online are compliant with Family Educational Rights and Privacy Act (FERPA), Children’s Online Privacy Protection Rule (COPPA), and Student Online Personal Protection Act (SOPPA).
- We do not collect or maintain student data or any student education records.
- For more detailed technical information on Realityworks products or Realityworks online, you may contact product support via contact information published on Realitworks.com, or reference product support materials via Realityworks.com support portal.
GDPR Compliance
We comply with the European Union General Data Protection Regulation (“GDPR”). We aim to ensure:
- Transparency regarding the use of data
- That any processing is lawful, fair, transparent and necessary for a specific purpose
- That data is accurate, kept up to date, and removed when no longer necessary
- That data is kept safely and securely
Realityworks processes Personal Information as a Controller or Business, as defined in the EU/UK GDPR and CPRA respectively.
Personal Information We Collect, Why and for How Long
We collect limited personal information only as you engage with both our Educational Content Provision and our Company Website(s).
A. If You Are A Teacher Using Our Educational Content via Realityworks online
- Use of our Educational Content: When you use Educational Content published via Realityworks online, we may automatically collect, through cookies and similar technologies, your internet network activity information (usage data such as dates, times, and details of your browsing activities), and technical data regarding performance (such as page response times, download errors). We may also automatically collect log data including your online identifiers (IP address) and other technical data such as browser type, operating system, device information, and mobile carrier. In addition, we may collect information such as the referring web page, referring search terms, and pages visited. We use this information to create aggregated usage reports, to understand how educators are using our Educational Content Provision and to improve the Educational Content Provision. This is in reliance on our legitimate interests in developing and improving the Service.
- Student links: When you send content links to students, we do not collect any information about the visitors to those links, and students do not require an account to access shared links to content. Please note that we only use necessary cookies to collect session volume information on our Educational Content.
B. If You Are A Website Visitor to Our Company Website(s), This Includes When You:
- Contact us: When you contact us through the website, we collect from you your personal identifiers (name, email address, phone number, country), your professional information (job title), your product interests and any additional information you choose to include. We use this information to respond to your questions or inquiries or to communicate with you about your request.
- Email us: When you email our support team, we collect, from you your personal identifiers (name, email), and any additional information you choose to include in your email message. We use this information to respond to your questions or inquiries.
- Purchase our products: When you purchase a product, we collect from you your personal identifiers (name, email address, shipping address, billing address). Your sensitive financial information (credit or debit card number, CVV, expiration date) is only collected when purchasing products online, during the checkout process, via our company store via our secure payment processor. We use this information to process payments, and to provide your products. Your sensitive financial information used with our third-party payment processor is not accessible to us. This is done to fulfil our contractual relationship with you and/or to comply with a legal obligation. When you purchase a product, you become a Customer. We may also use your information as a customer to send Communications on company updates, offers and resources. This is in reliance with our legitimate interests in developing our products, formation of our marketing strategy and communicate with customers about our business and products.
- Sign up for our email: When you sign up for our email, we collect from you, your personal identifiers (email address, country) and your professional information (job title, school, and postal/zip code). We will use this information to send you Communications about Realityworks products. This is in reliance with your consent.
- Attend our webinars: When you attend one of our webinars, we collect from you, your personal identifiers (name, email address), and your professional information (job title, school, country/region, and postal/zip code). We use Zoom and Microsoft Teams to provide our webinars, which are both associated with Realityworks accounts. Only Realityworks employees have access to content collected from our Webinars. This is in reliance with your consent. We also use this information to send you additional email communications which may be of interest to you, as based on your interaction with our emails and/or Websites.
- Participate in our contests: When you win a contest, we collect from you your personal identifiers (name, email address, mobile number), and your professional information (job title, school, address, postal/zip code). This is in reliance with your consent to ship the prize(s) to you.
- Respond to our surveys: When you respond to a survey, we collect your opinions. We use this information, in combination with the information you have already provided to us, to improve our products and services. This is in reliance with your consent.
- Interact with our Company Website(s): If you provide your affirmative opt-in consent to our use of tracking technologies, we will also collect information from you automatically as you interact with our Websites via non-essential cookies, pixels, and web beacons. Cookies are small pieces of code placed on your device, to enhance your experience on our site and for retargeting purposes. These cookies and pixels allow us to provide a tailored experience for our users and also enable us to retarget our advertisements to you on other platforms.
- Interact with us on social media: When you interact with our social media pages on social networking Websites, such as Facebook, LinkedIn, X (formerly known as Twitter), Instagram, Pinterest, Threads, TikTok, and YouTube, we collect basic engagement metrics and use it to tailor content and marketing and use it to improve user experience as set forth in this section.
C. If You Visit Us at An Event, This Includes When You:
- Are in photos/videos: When you interact with us at an event, photos may be taken. We will ask for your consent and outline how long we will keep the photos at the time. We will use the photos, if we have your permission, to promote Realityworks products and services. We may share the photos on social media.
Data Retention
Realityworks will also use the personal information we collect as described in this section to comply with the law, to efficiently maintain our business, to prevent issues and abuse of both our Educational Content Provision and our Company Website(s) and for other limited circumstances as described in HOW WE SHARE YOUR PERSONAL INFORMATION.
Unless otherwise stated in this Privacy Policy, we retain your personal information for as long as the relevant Realityworks account exists or until we no longer need your information to fulfill the purposes for which we collected it. You can delete your accounts in our systems at any time, by contacting us and submitting a request to remove your information. However, we may need to use and retain personal information for a period if any of the following scenarios exist:
- Compliance with legal and ethical obligations. For example, retaining personal information where we are legally required to do so or required by our professional ethics rules.
- Meeting our safety and security commitments. For example, keeping our properties secure and preventing fraud.
- Exercising or defending legal claims. We also may need to retain personal information for longer than the periods indicated above in order to respond to legal process or enforceable governmental requests, or to enforce our contracts or Terms of Use, including investigation of potential violations.
How We Share Your Personal Information
A. General Sharing
Realityworks shares personal information in the following ways:
- Within Realityworks platforms: We share your personal information within Realityworks, as appropriate, to provide our Educational Content, manage our sales, marketing and financial systems, in order maintain our business.
- With our affiliates: We share information with subsidiary companies and internal brands within our parent company (RW Thrive) as part of our regular reporting activities on company performance. Shared reports use aggregated information and personal information is not reidentified.
- In the event of a corporate reorganization: In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We will also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
- For legal purposes: We share your personal information where we are legally required to do so, such as in response to court orders, governmental/regulator bodies, law enforcement or legal process, including for national security purposes. We may share your information with our legal advisors or auditors to establish, protect, or exercise our legal rights or as required to enforce our terms of service or other contracts or to defend against legal claims or demands. We also share this information with third parties as necessary to: detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; to comply with the requirements of any applicable law; or to comply with our legal obligations.
- With your consent: Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time and may do so by contacting us via methods published on our company website(s).
B. Sharing in The Last Twelve (12) Months
For a business purpose: In the preceding twelve (12) months, Realityworks has disclosed the following categories of personal information for a business purpose to the following categories of parties:
- We have disclosed your personal identifiers to internal functions that allow us to provide and support our products and services. These include the following: information technology (“IT”) support; Product/customer support, Quality and product management, R&D, data hosting; customer relationship management; mailing; email delivery; professional services (lawyers, bankers, insurers, auditors, accountants); purchase and payment; error reporting; video/phone system; web analytics; and similar services.
- We have disclosed your personal identifiers to Shopify, our online store platform.
- We have disclosed your internet or other electronic network activity information collected by cookies to our cookie management system.
Employees and third parties are contractually prohibited from using collected Personal Information for any other purpose than providing the service used by us, for the purposes described in this Privacy Policy. This ensures all employees and Third-Party Providers will provide the same or higher level of protection for your Personal Information. We only permit Third Party Service Providers to process Personal Information for specified purposes and in accordance with our instructions.
International Transfers
Your information is stored and processed in our headquarters in the United States. To ensure your Personal Information receives an adequate level of protection, we require our Service Providers to protect it in a way that respects the EU GDPR and the UK GDPR.
If you are based in the UK or EU, we will transfer your Personal Information out of the UK or EU and we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will transfer your Personal Information to countries that have been deemed to provide an adequate level of protection or Personal Information by the UK or the EU.
- We will transfer your Personal Information to certain Service Providers protected by specific contracts approved for use in the UK or EU which give Personal Information the same protection it has in the UK and EU.
- We will transfer your Personal Information to certain Service Providers covered by the EU-U.S. Data Privacy Framework and/or the UK Extension to the EU-U.S. DPF.
These safeguards are monitored in accordance with the appropriate laws and are kept up to date. If you require further information about these protective measures, please write to our Data Protection Officer.
If you are based in the USA, some of your Personal Information will be transferred out of the USA to the EU and the UK. If you require further information about this, please write to our Data Protection Officer.
How We Keep Your Personal Information Safe
Realityworks respect the trust placed in us to properly protect your information and we take all appropriate steps to maintain a reasonable security program designed to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
Our security measures include, but are not limited to, the use of access-controlled data centers, data encryption in transit, brute force controls, firewalls, multi factor authentication for systems, regular staff training and physical access controls.
In addition, we limit access to your personal information to those employees, agents, contractors and other Third Parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Users of our Educational Content are responsible for using their best efforts to select and protect any provided details, including restricting access to any accounts you may create with us.
Our Service Providers that handle payment data maintain the relevant Payment Card Industry (PCI) compliance levels. Please note if Realityworks displays links to third-party websites, our Privacy Policy will not apply. Please refer to the third-party Privacy Policy for how your Personal Information may be processed.
Do We Allow Advertising within Our Educational Content Provision or Share Personal Data for Advertising?
Realityworks does not carry paid advertisements for anyone else on either our Company Website(s) or our Educational Content. We do not share data for advertising or marketing purposes on our Educational Content Provision only. For how we share data for advertising purposes on our Company Website(s) please see ‘How we Share Your Personal Information’ above.
Automated Decision-making
Automated decision-making is used as part of our Company Website(s). This helps us customize the email journey, ensuring what you receive is relevant to you. Automated decision-making is not used as part of our Educational Content Provision. We do not anticipate the automated decisions on our Company Website(s) will impact you in a legal, or similarly significant manner.
Do Not Track
We do not respond to Do Not Track requests. Do Not Track is a preference you can set in your web browser to inform websites and mobile applications that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.
Rights of California Residents Only
A. General Sharing
The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, “CPRA”) entitles California residents to certain rights. To the extent the CPRA applies to our processing of your personal information, you are entitled to the following rights:
- Right to Access/Know: You have the right to request what personal information we have collected, used, disclosed, and sold about you, unless doing so proves impossible or would involve disproportionate effort. You may only make a request for access twice within a 12-month period.
- Right to Deletion: You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions. For example, if we are required by law to retain the information that you are asking to be deleted, we would not be able to delete the information until we are legally permitted to delete it.
- Right to Correct: You have the right to correct inaccurate personal information that we collect or maintain.
- Right to Opt Out of Sale/Sharing: You have the right to opt out of the sale or sharing of your personal information to third parties.
- Right to Non-Discrimination: You have the right to not receive discriminatory treatment if and when you exercise your privacy rights under the CPRA.
- Right to Limit Use of Sensitive Personal Information: You have the right to limit the use of your sensitive personal information when such use goes beyond that which is necessary for providing the Services or certain other permissible purposes like fraud, customer service or quality control. Sensitive information includes Social Security number, driver’s license number, biometric information, precise geolocation, and racial and ethnic origin. However, Realityworks does not process sensitive personal information in a manner which gives rise to this right.
If you are a California resident and wish to exercise your privacy rights, you may submit a request via contact information published on our website(s). Please indicate your state of residence upon submission of your request. You may opt in or out of non-essential cookies at any time by using the toggles in Your Privacy Rights.
For requests submitted via telephone, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. In doing so, we will take steps to verify your request by matching information provided by you with the information we have in our records. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information. We will ask you for your school name, school zip code, and your role.
Only you, or a person that you authorize to act on your behalf may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.
We will try to act on your request within one month or quicker if local law requires. You will be notified of receipt of your request within 10 days. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Rights of Nevada Residents
If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of certain personal information of yours. We do not currently sell any of your personal information under Nevada law, nor do we plan to do so in the future. However, you can submit a request to opt-out of future sales, as defined by Nevada law, by contacting us via methods published on our website(s). Please include “Opt-Out Request Under Nevada Law” in the subject line and body of your message.
Rights of EU and UK Residents
Where the UK GDPR and the EU GDPR apply, by law you have the right to:
- Request access to your Personal Information. This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we have processed your information unlawfully or where we are required to erase your Personal Information to comply with law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a Third Party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request the restriction of your Personal Information. This enables you to ask us to suspend the processing of Personal Information about you, (i) if you want us to establish its accuracy or (ii) where our use of the data is unlawful but you do not want us to erase it, (iii) where you need us to hold the data even if we no longer require it as you need to establish, exercise or defend legal claims or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your Personal Information to you or another party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Right to withdraw your consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose (such as electronic marketing or photographs), you have the right to withdraw your consent for that specific processing at any time. We will then no longer process your information for the purpose(s) you originally agreed to, unless we have another legitimate basis for doing so.
- Right to lodge a complaint about how we handle your Personal Information with IMY (Sweden EU) or the ICO (UK).
If you are a resident in any of the jurisdictions above and wish to exercise your data protection rights, please contact us via methods published on our company website(s).
Only you, or a person that you authorize to act on your behalf may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Information is not disclosed unlawfully. We will try to act on your request within one month or quicker if local law requires. You will be notified of receipt of your request within 10 days. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Changes to This Privacy Policy
We may amend this Privacy Policy at our sole discretion at any time. If we do, we will post the changes to this page, and will indicate the date the changes go into effect. We encourage you to review our Privacy Policy to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on the Websites and/or via email, and obtain your consent, if required.
Contact Information
You can also reach us by mail at our headquarters:
Realityworks Inc., 2709 Mondovi Road, Eau Claire, WI 54701.