At RECOFTC, we care about the confidentiality and security of your personal information. We will use commercially reasonable efforts to keep your Personal Information secure in compliance with this Privacy Policy. "Personal Information" is defined below. As used in this Privacy Policy, "we," "us," and "our" refer to RECOFTC.

This Privacy Policy only applies to information that we collect through the e-learning at RECOFTC website (the "Site,"), which consists of all content and pages located within the learning.recoftc.org web domain. This Privacy Policy does not apply to information that we may collect from you in other ways on other RECOFTC channels or information that you may provide to us over the phone, by fax, or through conventional mail. In addition, your learning records are protected by the Family Educational Rights and Privacy Act ("FERPA") to the extent FERPA applies.

Usernames and postings

Comments or other information posted by you to our forums, wikis or other areas of the Site designed for public communication or communication among registered course members may be viewed and downloaded by others who visit the Site. For this reason, we encourage you to use discretion when deciding whether to post any information that can be used to identify you to those forums (or other public or course-wide areas).

Consent to processing outside home country

By using or providing information to our Site, you understand and unambiguously consent to the collection, use, disclosure and retention of information in the United States and other countries and territories, for the purposes set forth in this Privacy Policy. You hereby consent to the collection, use, disclosure and retention by e-learning at RECOFTC of your Personal Information as described under this Privacy Policy, including but not limited to the transfer of your personal data between RECOFTC and the third parties, affiliates and subsidiaries described in this Privacy Policy. For further certainty, any consent relating to a right to transfer information referred to in this paragraph shall be deemed to include your consent to the transfer of the applicable Personal Information to a jurisdiction which may provide a different level of privacy protection than that available in your own country.

If you do not agree with these terms, then please do not access, browse or register for the Site. If you choose not to provide us with certain information required to offer you the services on this Site, you may not be able to establish a user account and we may not be able to provide you with those services.

Personal information

As used in this Privacy Policy, "Personal Information" means any information about yourself that you may provide to us when using the Site, such as when you sign up for a user account through the Site, which may include (but is not limited to) your name, contact information, gender, date of birth, occupation.

We endeavor to limit the collection of Personal Information to what we need with respect to specific Site activities in order to satisfy business, legal or regulatory requirements. This Site does not currently collect financial information from you.

Information we collect and how we use it

We collect information, including Personal Information, when you sign up for a user account, participate in online courses, send us email messages and participate in our public forums. We also collect certain usage information about learners’ performance and patterns of learning. In addition, we track information indicating, among other things, which pages of our Site were visited, the order in which they were visited, when they were visited and which hyperlinks and other user interface controls were used.

We may log the IP address, operating system and browser software used by each user of the Site, and we may be able to determine from an IP address a user's Internet Service Provider and the geographic location of his or her point of connectivity. Various web analytics tools are used to collect this information. Some of the information is collected through cookies (small text files placed on your computer that store information about you, which can be accessed by the Site). You should be able to control how and whether cookies will be accepted by your web browser. Most browsers offer instructions on how to reset the browser to reject cookies in the "Help" section of the toolbar. If you reject our cookies, many functions and conveniences of this Site may not work properly.

Use and disclosure to third parties

Among other things, we and the educational institutions and other leading global members that provide courses through the host of this Site (the "Members") may use the information about you collected through the Site (including your Personal Information) in connection with the following. In cases where we share or disclose your Personal Information: (1) the third party recipients are required to handle the Personal Information in a confidential manner and to maintain adequate security to protect the information from loss, misuse, unauthorized access or disclosure, alteration and destruction; and (2) we will only disclose and share the Personal Information that is required by the third party to fulfill the purpose stated at the time of collection.

• To enable the Members to provide, administer and improve the courses.
• To help us and the Members improve e-learning offers at RECOFTC, both individually (for example by course staff when working with a learner) and in aggregate, and to individualize the experience and to evaluate the access and use of the Site and the impact of e-learning at RECOFTC on the worldwide educational community.
• For purposes of scientific research, particularly, for example, in the areas of cognitive science and education.
• For the purpose for which you specifically provided the information, for example, to respond to a specific inquiry or provide you with access to the specific course content and/or services you select.
• To track both individual and aggregate attendance, progress and completion of an online course, and to analyze statistics on learner performance and how learners learn.
• To monitor and detect violations of the Honour Code for e-learning at RECOFTC as well as other misuses and potential misuses of the Site.
• To publish information, but not Personal Information, gathered about e-learning at RECOFTC access, use, impact and learner performance.
• To send you updates about online courses offered by e-learning at RECOFTC or other events, to send you communications about products or services of /or e-learning at RECOFTC, /or e-learning at RECOFTC affiliates, or selected business partners that may be of interest to you, or to send you email messages about Site maintenance or updates.
• To archive this information and/or use it for future communications with you.
• To maintain and improve the functioning and security of the Site and our software, systems, and network.
• For purposes described elsewhere in this Privacy Policy (including Sharing with Third Parties).
• As otherwise described to you at the point of collection or pursuant to your consent.

We will share information we collect with the Members, and we and the Members may share this information (including Personal Information) with third parties as follows:

• With service providers or contractors that perform certain functions on our or the Members' behalf, including processing information that you provide to us on the Site, processing purchases via third party providers, and other transactions through the Site, operating the Site or portions of it, providing or administering courses, or in connection with other aspects of e-learning at RECOFTC or Member services.
• With other visitors to the Site, to the extent that you submit comments, course work, or other information or content (collectively, "Postings") to a portion of the Site designed for public communication; and with other members of the RECOFTC class of e-learners of which you are a member, to the extent you submit Postings to a portion of the Site designed for viewing by those class members. We may provide your Postings to learners who later enroll in the same classes as you, within the context of the forums, the courseware, or otherwise. If we do re-post your Postings originally made to non-public portions of the Site, we will post them without your real name and email (except with your express permission), but we may use your username without your consent.
• For purposes of scientific research, particularly, for example, in the areas of cognitive science and education. However, we will only share Personal Information about you for this purpose to the extent that doing so complies with applicable law and is limited to the Personal Information required to fulfill the purposes stated at the time of collection.
• To provide opportunities for you to communicate with other users who may have similar interests or educational goals. For instance, we may recommend specific study partners or connect potential learner mentees and mentors. In such cases, we may use all information collected about you to determine who might be interested in communicating with you, but we will only provide other users your username, and not disclose your real name or e-mail address to your contact.
• To respond to subpoenas, court orders, or other legal process; to investigate, or prevent, or take action regarding illegal activities, suspected fraud, or security or technical issues, or to enforce our honour code, or this privacy policy; as otherwise may be required by applicable law; or to protect our rights, property, or safety or those of others.
• With affiliates of this Site or the Members, or with successors in the event of a merger, acquisition or reorganization, for their use consistent with this Privacy Policy.
• As otherwise described to you at the point of collection or pursuant to your consent.
• For integration with third party services. For example, videos and other content may be hosted on YouTube and other websites not controlled by this Site.

In addition, we may share aggregated information that does not personally identify you with the public and with third parties, including but not limited to researchers and business partners.

Use for personalization and pedagogical improvements

Our goal is to provide current and future visitors with the best possible educational experience. To further this goal, we sometimes present different users with different versions of course materials and software. We do this to personalize the experience to the individual learner (assess the learner's level of ability and learning style, and present materials best suited to the learner), to evaluate the effectiveness of our course materials, to improve our understanding of the learning process and to otherwise improve the effectiveness of our offerings. We may publish or otherwise publicize results from this process, but, unless otherwise permitted under this Privacy Policy, those publications or public disclosures will not include Personal Information.

Links to other websites

This Site contains links to websites published by third parties, including other content providers as well as certain service providers, such as those who process payments on behalf of RECOFTC. These other websites are not under our control, and you acknowledge and agree that we are not responsible for the collection and use of your information by such websites, unless we have otherwise indicated in this Privacy Policy. We encourage you to be aware when you are redirected to a third party website and to review the privacy policies of each website you visit and use.

Security

This Site has a program designed to protect Personal Information in its possession or control. This is done through a variety of privacy and security policies, processes, and procedures, including administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the Personal Information that it creates, receives, maintains, or transmits. Nonetheless, no method of transmission over the Internet, or method of electronic storage, is 100 percent secure and therefore, RECOFTC cannot guarantee its absolute security.

Changing our privacy policy

Please note that we review and may make changes to this Privacy Policy from time to time. When changes are made, the Privacy Policy link will include a notation "Revised (date)." indicating that you should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. The notation will be included in the Privacy Policy link for at least seven (7) days after the update has been made. By accessing this Site after any changes have been made, you signify your agreement on a prospective basis to the modified Privacy Policy and any changes contained therein. In case you miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

Privacy concerns

If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the information we maintain about you, please contact us at app.elearning@recoftc.org

Effective date: 1 September 2020