For purposes of this policy, we will use the following definitions:
Personally identifiable information (PII) is information that can identify a user of the Services, including his or her e-mail, name, and address.
De-identified information is information from which personally identifiable components have been removed and a reasonable determination made that an individual is not identifiable.
Student Records are records that are directly related to a student and maintained by Real Frequency on behalf of a parent or guardian, school or other clients and their support organizations..
What Type Of Information Do We Collect And Why?
Information collected during the subscription process: During the registration process for any of our subscriptions, we ask the subscriber to provide us with a name, email address, phone number, and billing information. We may also ask you to provide username and password. We use the information to create and service the account, fulfill the subscription and send you service-related announcements. For instance, we may send emails about routine maintenance, new feature launches or product recommendations related to your subscription. We may also use this contact information to request feedback on our products and services, to inform future customer service and product improvements. If you are registering for a free trial, we will use the information to create a free trial account and to send occasional promotional emails and other marketing campaigns.
We collect students’ full name, class, graduation year/grade, and other information needed to support the student and their college admissions and/or career pursuits. Students will be able to store their activities, and other relevant information in their file.
Children Under Age 13:
In compliance with the Children's Online Privacy Protection Act (COPPA), Real Frequency does not collect personally identifiable information from children under 13, without a parent or guardian's consent, or that of a school if applicable. Parents and guardians of children under 13 who use any of the Real Frequency products have certain rights under COPPA and Real Frequency recognizes those rights. At any time, parents/guardians using Real Frequency Products or Services may request to review the personal information we collected from their child, request that we make no further use of that information or request that we delete it. To exercise your right to delete information, please use the contact information below.
A child's participation or access to Real Frequency information cannot be conditioned on him or her providing more personal information than is reasonably necessary for that activity.
Connecting With Real Frequency:
Contact information for newsletter and surveys: On Real Frequency adult-facing pages of our Services, including pages that do not require log-in, adult users may choose to sign up for newsletters, promotional offerings, or participation in surveys, all of which require contact information. The submitted contact information will be used for promotional purposes, and you may opt-out at any time. An opt-out link or instructions on how to opt-out will be included at the bottom of such messages. Registration for blogs, newsletters, promotional offerings, and surveys participation are not intended for minors.
Information we collect when you contact us: When you send us messages by email or through other online platforms, we collect the information you provide, including your message and any contact information you include. We use and retain such information to respond to your request, facilitate support to you in the future and to optimize our support services.
Feedback: Certain features we offer include an option to provide us with feedback. The feedback feature does not identify the user submitting it. If we receive personally identifiable information through a feedback form we take steps to immediately delete that information. We reserve the right to use feedback for any purpose with no obligation to you.
Information Collected Automatically
We automatically receive and record information on our server logs from a user’s browser. This may include the IP address, pages of Real Frequency visited, the time spent on those pages, and access times and dates. We use this information to better display our Services, maintain a user’s session, identify the country the user is located in, monitor, analyze use of and administer Real Frequency, and to better tailor it to your needs. We may also use this information to serve advertising to adult users.
To collect this information, we use technological tools including:
Cookies. A cookie is a small data file sent from a website or application and stored on your computer or device. Cookies allow us to recognize your browser when you return to Real Frequency. Cookies also allow us to better understand how you interact with Real Frequency’s site and to monitor aggregated usage. You can set your browser to detect some cookies, to stop accepting cookies or to prompt you before accepting a cookie. To learn more about browser cookies, including how to manage or delete them, look in the Tools, Help or similar section of your web browser, or visit allaboutcookies.org.
Pixel Tags. A pixel tag (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one-pixel – that we place in our marketing emails, newsletters, promotional offerings and surveys. We use pixel tags and line tracking to analyze the effectiveness of our marketing campaigns.
By using our Services, you agree to our use of these tracking technologies.
In addition, we and our third party partners may use tracking technologies to deliver targeted advertisements and marketing messages to adult users on our or unaffiliated websites and online services. We also occasionally source information about groups of adults to generate a "lookalike audience" or similar audience of prospective customers through advertising platforms. This allows us to target prospective customers with advertisements on their networks who appear to have shared interests or similar demographics to our existing customers, based on the platforms' own data. We do not have access to the identity of anybody in the lookalike audience, unless they choose to click on the ads, and this information is only used for customer prospecting.
To learn about interest-based advertising, “lookalike audiences” and how you can opt-out of these features, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the Digital Advertising Alliance (DAA) resources at http://www.aboutads.info/choices. Note that if you wish to opt out, you will need to do so separately for each of your devices and for each web browser you use. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at http://www.youronlinechoices.eu/. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
How We Share Your Information
We may provide Personally Identifiable Information to our partners, business affiliates, and third party service providers who work for Real Frequency and operate some of its functionalities. These may include hosting, streaming, credit card processing services and companies that provide marketing emails on our behalf. A current list of these third parties service providers is available to our subscribers upon request through info@Real Frequency.com. These third parties service providers are bound contractually to practice commercially reasonable security measures and to use your Personally Identifiable Information solely as it pertains to the provision of their services. They do not have the independent right to share your Personally Identifiable Information or use it for any unrelated purposes.
We reserve the right to disclose personally identifiable information if we are required to do so by law, or if we believe that disclosure is necessary to protect our rights, protect your safety or others' safety, investigate fraud, and/or comply with a judicial proceeding, court order, subpoena, or legal process.
We may share administrators’ and parents’ email addresses collected when registering to free trials or other services with third parties business partners for marketing purposes when the individual has opted in to receive such communication. You may opt out of promotional messaging at any time as described in the Opt Out section below.
We strive to maintain security policies and procedures that are designed to protect your information.
Our application servers which are third party, are located in a secured, locked, and monitored environment to prevent unauthorized entry or theft, and are protected by a firewall. The servers are located in a data center in the United States and backed up daily to a secure, U.S.-based, off-site data center.
We apply a Secure Sockets Layer (SSL or HTTPS) encrypting technology to encrypt data in transit between the server and the browser remains encrypted. We also encrypt the data at rest.
Governance policies and access controls are in place to ensure that the information of each district, school, or other subscriber is separated, and all subscribers can only access their own data.
Only limited Real Frequency personnel and partner developers have access to the database, and personnel only access it when necessary to provide services. Personnel with access to Student Records pass criminal background checks and undergo periodic privacy training.
We follow standardized and documented procedures for coding, configuration management, patch installation, and change management for all applicable servers.
While we strive to maintain industry-standard privacy and security practices, it should be noted that no industry system is fail proof, and we are not responsible for security incidents not reasonably foreseeable or reasonably within our control. In the event of unauthorized access to Personally Identifiable Information, we will notify the affected subscriber(s) in accordance with applicable law, and as appropriate, coordinate with the subscriber to support notification of affected individuals, students, and families.
Links To Third Party Sites
If you have subscribed to receive marketing messaging from us, or if you receive an unwanted email from us, you can opt-out of receiving future emails by clicking the opt-out link in the email or alternatively by sending an email to info@Real Frequency.com, with “Opt out” in the subject line. We will process your request within a reasonable time after receipt. Note that you will continue to receive operational emails regarding the products or services you are subscribed to.
For California Residents
As a California resident, you have certain rights regarding your personal information. These rights include:
In order to prevent unauthorized access to your information, we are required by law to verify your identity before we may address your request.
To Exercise Your Rights
Real Frequency is used by students at the direction of our clients. As such, we are obligated under FERPA to remain under the direct control of our Customers with respect to our use and maintenance of student personal information that is part of the education record.
All other Real Frequency users and visitors may exercise these rights by emailing us at info@Real Frequency.com
Your exercise of the above rights is subject to certain exemptions to safeguard the public interest and our interests. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. Where required by applicable law, we will notify you if and why we are unable to fulfill your request.
Non-discrimination: We shall not discriminate or otherwise penalize anyone for exercising their rights.
Categories of Personal information we collect
For adult users, we also collect:
Categories of sources from which the Personal Information is collected
Business or commercial purpose for collecting or selling Personal Information
We collect your Personal Information to provide the services and for the following business purposes:
Categories of third parties with whom we share Personal Information
We share personal information with service providers who support us in delivering the Services as described above.
For our adult users, we also share personal information with "third parties" as the term is defined in CCPA for targeted marketing purposes.
Specific pieces of Personal Information we have collected:
Connecting with Real Frequency: name, email address, other contact information, IP address
Website visitors: IP address, pseudonymous end user identifiers
Authorized Agent: California residents may use an authorized agent on their behalf to exercise a privacy right discussed above. If you are an authorized agent acting on behalf of a California resident to communicate with us or to exercise a privacy right discussed above, you must be able to demonstrate that you have the requisite authorization to act on behalf of the resident and have sufficient access to their laptop, desktop, or mobile device to exercise these rights digitally. If you are an authorized agent trying to exercise rights on behalf of a Real Frequency client or user, please contact the user's school or district with supporting verification information, which includes a valid Power of Attorney in the State of California, proof that you have access to the user’s device, and proof of your own identity.
Using Real Frequency Products and Services Outside The US
If you are using the Services outside the United States, you consent to having your information and data transferred to the United States. If you are in any jurisdiction with laws or regulations governing internet use, including collection, use, and disclosure of personal data, different from those of the United States, you may only use the Services in a manner that is lawful in your jurisdiction. If your use of the Services may be unlawful in your jurisdiction, please do not use them. If your use of the individual accounts may be unlawful in your jurisdiction, please do not use it.
Using Real Frequency From The EU
Real Frequency processes your information in one of two capacities, either: (i) as a Data Controller for our own internal business operations, such as sales, marketing, administration etc., or (ii) as a Data Processor when carrying out our Services for our customers using individual accounts.
As a Data Controller, Real Frequency processes your personal data, in accordance with applicable law, for the following purposes:
The bases for processing of your personal data for the purposes described above will include:
Your personal data will be retained as long as is reasonably necessary for the purposes listed above or as required by applicable local law. Retention periods can vary based on the type of information and how it is used.
What Are Your Rights Under the GDPR?
Parents/guardians of children using Real Frequency should contact us to exercise their rights and we will work with the parent/guardian to facilitate those requests.
When we are operating as a Controller, we provide you with certain rights related to your personal data. To exercise your rights, please contact us at info@Real Frequency.com. We will respond to your request within a reasonable time frame.
Please note that the rules in your country may provide you with additional rights or may limit the rights noted below. In all cases, we will comply with the applicable laws.
Right of access
You may have the right to obtain confirmation about whether or not we process your personal data, and when we do, to request access to that personal data. The access information includes the purposes of processing, the categories of personal data involved, and the recipients or categories of recipients to whom the personal data have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access.
You may have the right to obtain a copy of the personal data undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
Right to rectification
You may have the right to rectify inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure
Under certain circumstances, you may have the right to obtain from us the erasure of personal data concerning you and we may be obliged to erase that personal data.
Right to restriction of processing
Under certain circumstances, you may have the right to restrict processing your personal data. In this case, the respective data will be marked and may only be processed by us for certain purposes.
Right to data portability
Under certain circumstances, you may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit those data to another entity without hindrance from us.
Right to object
Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, or where Personal Data are processed for direct marketing purposes at any time to the processing of your Personal Data by us and we can be required to no longer process your Personal Data.
Moreover, if your Personal Data is processed for direct marketing purposes, you have the right to object at any time to the processing of Personal Data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your Personal Data will no longer be processed for such purposes by us. If you have concerns or complaints you may have a right to lodge a complaint with a supervisory authority.
If you wish to report a security breach, please contact us at info@Real Frequency.com.
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