Last Updated: November 8, 2023
By using RealResponse, you agree to the terms of this Policy. If you do not agree with this Policy, then do not use RealResponse.
1. INFORMATION WE COLLECT
We collect the information you provide to us directly or that is provided to us on your behalf by your institution or organization that purchase a license for you to use RealResponse.
Depending on how you interact with RealResponse, the personal information we collect from you may vary. Some examples of instances in which you may decide to provide personal information to us include:
- Creating an account;
- Signing up for alerts;
- Interacting with other RealResponse users;
- Filling out forms, questionnaires, and/or surveys, and by submitting information on the RealResponse web-based portal;
- Submitting reviews related to one of our products or services; and
- Contacting us for technical support or customer service.
1.1 Personal Information That We Request.
1.1.1 Required Information. To create login credentials, we will collect:
- your first and last name;
- an email address and a password of your choosing for logging in;
- your institution or organization; and
- the team(s) (if any) with which you are affiliated.
1.1.2 Voluntary Information. You may also have the opportunity to provide optional information to use in connection with your account.
1.1.3 Free-Form Text Entry. RealResponse also allows users to submit information through the entry of free-form text. Informaion you provide in any free-form text field is also collected by RealResponse and will be collected and stored on our servers.
2. INFORMATION WE COLLECT BY AUTOMATED MEANS
2.1 Individuals typically access RealResponse through their computer, laptop, mobile device, tablet, or other internet-enabled device (each a “Device”). When you use RealResponse, your Device automatically provides information to us so we can respond and customize our response to you. The information we collect by automated means may vary, but generally includes technical information about your Device, such as your IP address or other Device identifier. We may also collect information relating to usage information and statistics about your interaction with RealResponse. Such information may include the URLs of our web pages that you visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, location data, and other information about how you used RealResponse.
2.2 Automated means of data collection include the following:
2.2.1 IP Address, Web Browser, and Device Information. When you visit a RealResponse website, your Device automatically sends us your Internet protocol (“IP”) address so that the web pages you request can be sent to and accessed on your Device. An IP address is a number that is automatically assigned to the Device that you are using by your Internet Service Provider. We use your IP address to determine additional information, such as whether the Device has ever been used to visit RealResponse before, which RealResponse features were used the most often, and how much time was spent on a page.
2.2.2 Web Beacons and Log Files. RealResponse may, from time to time, use a variety of “web beacons,” including “pixel tags,” “web beacons,” “clear GIFs,” or similar means in connection with RealResponse and HTML-formatted email messages to, among other things, track the actions of users, record the IP address of your Device, the URL of the web page, the date and time the page was viewed, and the type of Device and/or browser used, to determine the efficacy and utilization of and to compile aggregate statistics about RealResponse usage and response rates. This information is typically collected in “log files,” which we use to track traffic to, from, and on RealResponse. We use this information for a variety of purposes, including the management and maintenance of our RealResponse.
2.2.3 Location Data. If you access RealResponse using a mobile Device, we will collect your physical location if you have enabled this feature. Even if you are not using a mobile Device, information about your general location may be discernable from your Device’s IP address or the URLs we receive.
3. HOW WE USE INFORMATION
We may use the information we collect:
- to provide you with our services;
- to analyze use of RealResponse and customize and improve the features, performance, and support of RealResponse;
- to manage and protect RealResponse;
- for internal operations, including troubleshooting, data analysis, testing, research, and service improvement;
- to communicate with you regarding our services and to answer your questions or requests;
- to provide you with information about the services we offer (including details of any products which we believe may be of interest to you) in accordance with your preferences as indicated when you entered into any agreement with us, including any marketing consent preferences;
- to comply with any legal or regulatory obligations (including in connection with a subpoena, warrant, or other court order);
- for other purposes that you separately authorize as you interact with RealResponse.
4. HOW WE SHARE INFORMATION
4.1 RealResponse allows users to communicate with their teams, institutions, and/or organizations – both (1) actively and directly, and (2) also through the submission of anonymous information. While such information and/or content is created by you, RealResponse intends to– and frequently does – share with other users, particularly when such information addresses or suggests circumstances involving physical and/or emotional harm, criminal activity, ethical lapses, and other instances that require the attention and/or a response of your team, institution or organization. Among others, we may disclose information you submit to RealResponse as follows:
- Your team, institution, or organization may set up internal permissions for coaches, faculty, administrators, employees or staff members to review the information you submit;
- RealResponse personnel may review your information as part of their development, support, quality control, and/or risk response functions;
- Law enforcement and or emergency responders may be granted access to information if necessary in investigating crimes or responding to emergencies.
RealResponse collects and records the following information which may be shared:
- Date and time stamps for when comments, content, or information are submitted to RealResponse;
- Survey data;
- Data submitted by you and other users;
- Realtime usage reports; and
- Personnel documentation.
RealResponse allows administrators, faculty, staff and/or others to read, print, and respond to the content you submit depending on the service offering you are using. RealResponse also allows teams, institutions, and organizations to establish their data retention and purge policies consistent with their own institutional or governmental obligations. All content categorized as educational or personnel records shall remain the property of the organization and be held confidential in accordance with applicable federal, state or local privacy or intellectual property law. Contact your organization’s administrator to learn the specific details about how your institution or organization uses and retains the information you submit.
We reserve the right to transfer any information we have about you in connection with a sale, merger, consolidation, change in control, transfer of assets, reorganization, or liquidation of our business. We reserve the right to disclose any personal information as needed if that information is requested by law enforcement agencies or if we are required to do so by law, treaty, regulation, subpoena, court order, or by a government entity. We also may disclose your personal information to third parties if we have reason to believe that disclosing such information is necessary to conduct investigations of possible breaches of law, to cooperate in any legal investigation, or to identify, contact, or bring legal action against someone who may be violating any agreement with us.
4.2 Except as set forth in Section 4.1 above, RealResponse generally does not disclose your individual account information, content, or usage data to third parties. However, we may disclose your personal information as follows:
- With your consent;
- We use affiliated and unaffiliated service providers all over the world that help us deliver our service and run our business, including Amazon Web Services (“AWS”) for storing and supporting RealResponse and, accordingly, any data you provide is also subject to AWS’ Customer Agreement and Service Terms;
- We share aggregated usage statistics that cannot be used to identify you individually;
- In a reorganization or sale of our company or assets, your data may be transferred;
- If you submit a direct message or report through RealResponse, we may disclose your personal information to the intended or necessary recipient.
4.3 In small communities, such as schools, athletic teams and clubs, or organizations, others may be able to identify you even if we protect your personal information. Details about your experiences, circumstances, activities, involvements and relationships may make it possible for another person to identify you. RealResponse cannot and will not attempt to prevent other users from identifying you if you reveal personal details in the content you submit.
5.3 What types of Cookies do we use? We use two types of Cookies on RealResponse: “session cookies” and “persistent cookies.” Session Cookies are temporary Cookies that remain on your device until you leave RealResponse. A persistent Cookie remains on your device for much longer until you manually delete it (how long the Cookie remains will depend on the duration or “lifetime” of the specific Cookie and your browser settings).
5.4 What are Cookies used for? Cookies may transmit information about you and your use of RealResponse, such as your browser type, search preferences, and the date and time of your use. The data stored in Cookies is anonymous and is not linked to your personally identifiable information without your permission. Cookies may link to certain unique, non-personally identifiable information such as the information that you entered at time of registration or on your profile, but this is not linked to your name or any personally identifiable information.
5.4.2 Managing Cookies.
We work with third parties, such as AWS for storing and supporting RealResponse and, accordingly, AWS may use the Cookies set on your device to measure the performance and track traffic to RealResponse generally.
You may be able to opt out of AWS’ placement of Cookies by following opt-out instructions provided by AWS, to the extent such instructions are provided.
You may also be able to disable placement of some Cookies other than necessary cookies by setting your browser to decline cookies, though this may worsen your user experience. If you delete your browser cookies, then you will need to reset your settings to decline cookies again. Additionally, if you change computers or web browsers, you will need to opt out again. For more information about deleting and controlling cookies visit AboutCookies.org.
6. Choices Regarding Your Personal Information
6.1 You can manage your account settings in the “Account Settings” page on RealResponse. For individuals located in the European Economic Area or the United Kingdom, please also see “Your GDPR and UK GDPR Rights” below in Section 7. Please note that we may not be able to correct or update your personal information previously provided to us by third parties.
6.2 If you receive any promotional e-mail communication from us, you will be given the option to “unsubscribe” from receiving further e-mail communications from us at any time. Your option not to receive promotional and marketing material will not preclude us from corresponding with you, by email or otherwise, regarding your existing or past business relationships with us, and will not preclude us from accessing and viewing your personal information in the course of maintaining and improving RealResponse.
7. Your GDPR and UK GDPR Rights
If you are an individual in the European Economic Area or the United Kingdom, then this section applies to you.
Who Is the Data Controller? RealRecruit, LLC is the data controller for customers and potential customers and visitors to RealResponse. If you are a Member of an Institutional User, then we are a data processor for the Institutional User and the Institutional User is the data controller.
What Are Our Legal Bases for Processing? For each of the purposes of processing purposes, we have set out the legal basis on which we use your personal information.
- To provide RealResponse and the services that you request – For our legitimate business interests (i.e., the provision of RealResponse) and, depending on the circumstances, to perform a contract between you and us
- To communicate with you about RealResponse and to respond to your questions or requests – For our legitimate business interests (i.e., the provision of RealResponse)
- To manage and protect RealResponse – For our legitimate business interests (i.e., the provision of RealResponse)
- To enforce our terms, conditions, and policies – For our legitimate business interests (i.e., the provision of RealResponse)
- To improve the quality of RealResponse – For our legitimate business interests (i.e., the provision of RealResponse)
- To provide you with information about RealResponse we offer (including details of any products which we believe may be of interest to you) in accordance with your preferences as indicated when you entered into any agreement with us, including any marketing consent preferences – With your consent
- To comply with any legal or regulatory obligations (including in connection with a subpoena, warrant, or other court order) – For compliance with legal obligations to which we are subject
Where we rely on the legitimate interests of RealRecruit, LLC or those legitimate interests of a third party to justify the purposes for using your personal information, this will include the commercial interests of RealRecruit, LLC relating to improvement and development of our business operations and service offerings, or those of a third party; or protection of our business, employees, or those of a third party.
Categories of Recipients. View Section 4 (How We Share Information) for the categories of recipients with whom we share personal information.
Data Retention. We will retain your personal information for as long as is necessary for purposes for which it was collected. The precise period will depend on the reason why it was collected. Those periods are also based on the requirements of applicable laws, applicable legal and regulatory requirements and periods relating to the commencement of legal actions.
Data Transfers. If we transfer personal information outside the European Economic Area or the United Kingdom, we will implement appropriate and suitable safeguards to ensure that such data will be protected as required by applicable data protection law. For further information as to the safeguards we implement please contact firstname.lastname@example.org.
Your GDPR and UK GDPR Rights. The following is a summary of the data protection rights available to individuals in the European Economic Area and the United Kingdom in connection with their personal information for which RealRecruit, LLC is a controller; for requests about your account information, please direct those requests to your organization. RealRecruit, LLC will follow the instructions of the Institutional User regarding data subject requests for account information.
- Right of access to your personal information – You have the right to receive a copy of your personal information that we hold about you, subject to certain exemptions.
- Right to rectify your personal information – You have the right to ask us to correct your personal information that we hold where it is incorrect or incomplete.
- Right to erasure of your personal information – You have the right to ask that your personal information be deleted in certain circumstances. For example (i) where your personal information is no longer necessary in relation to the purposes for which they were collected or otherwise used; (ii) if you withdraw your consent and there is no other legal ground for which we rely on for the continued use of your personal information; (iii) if you object to the use of your personal information (as set out below); (iv) if we have used your personal information unlawfully; or (v) if your personal information needs to be erased to comply with a legal obligation.
- Right to restrict the use of your personal information – You have the right to suspend our use of your personal information in certain circumstances. For example (i) where you think your personal information is inaccurate and only for such period to enable us to verify the accuracy of your personal information; (ii) the use of your personal information is unlawful and you oppose the erasure of your personal information and request that it is suspended instead; (iii) we no longer need your personal information, but your personal information is required by you for the establishment, exercise, or defense of legal claims; or (iv) you have objected to the use of your personal information and we are verifying whether our grounds for the use of your personal information override your objection.
- Right to data portability – You have the right to obtain your personal information in a structured, commonly used and machine-readable format and for it to be transferred to another organization, where it is technically feasible. The right only applies where the use of your personal information is based on your consent or for the performance of a contract, and when the use of your personal information is carried out by automated (i.e. electronic) means.
- Right to object to the use of your personal information – You have the right to object to the use of your personal information in certain circumstances. For example (i) where you have grounds relating your particular situation and we use your personal information for our legitimate interests (or those of a third party); and (ii) if you object to the use of your personal information for direct marketing purposes.
- Right to withdraw consent – You have the right to withdraw your consent at any time where we rely on consent to use your personal information.
- Right to complain to the relevant data protection authority – You have the right to complain to the relevant data protection authority where you think we have not used your personal information in accordance with data protection law.
8. SECURITY SAFEGUARDS
We employ reasonable physical, electronic, and managerial measures designed to safeguard the information we collect online. However, no company can fully eliminate security risks, so we cannot make guarantees about any part of our services. You are responsible for keeping your username and password secret. Once you have registered with us, we will never ask you for your password. Please create a unique password for RealResponse and do not use it for any other web services or applications. Do not share your password with anyone else.
9. Do-Not-Track Requests; Third-Party Tracking
Unless your browser settings are configured to make your online activities and information about your online activities (such as traffic data as described above) invisible to usage analytics tools, we do not presently have the capability to omit you from usage analytics to the extent your browser only sends us a “do not track” message and does not otherwise screen you from tracking without any action on our part. To learn more about browser tracking signals and “Do Not Track”, please visit http://allaboutdnt.org. Third parties, other than our vendors (such as our website analytics provider), do not have authorization from us to track which websites you visited prior to and after visiting RealResponse. Please note, however, that we cannot control third-party tracking and there may be some third-party tracking that occurs without our knowledge or consent.
Anyone under 14 years of age is expressly prohibited from using RealResponse or providing any personal information. If you become aware that anyone under 14 years of age has provided us with personal information without parental consent, please contact us at info@RealResponse.com. If we become aware that a minor under 14 has provided us with personal information without parental consent, we will remove such information and terminate the account.
RealResponse is based in the U.S., and the Company’s offices are headquartered in the U.S. Information you provide to RealResponse and that RealResponse obtains as a result of your use of RealResponse may be processed and transferred to the U.S. and be subject to U.S. law. The privacy and data protection laws in the U.S. may not be equivalent to such laws in your country of residence. See section 7 above for more information about RealResponse’s processing of any data subject to GDPR.
12. CHANGES TO THIS POLICY
13. CONTACT US