Rustici Software, LLC Privacy Policy

We respect your privacy and want you to know how we handle the information we receive via our website and through our online applications, including Content Controller and SCORM Cloud.

Information We Collect

We collect the email addresses and other contact information of people who correspond with us. We maintain records of our correspondence. We collect aggregate information on the web pages and application functionality users access or visit. We maintain all user submitted data required for proper operation of Content Controller and SCORM Cloud. This data is collected to deliver and improve the services that we offer and includes eLearning content and the tracking data generated by learners experiencing their training (such as quiz scores, time spent in training and other SCORM data). Content Controller and SCORM Cloud services may be directly accessed through other web sites. Personal information that you provide to those sites may be sent to Content Controller or SCORM Cloud in order to deliver the service. We process such information under this Privacy Policy. You may access your personal information at any time to correct, amend or delete it, where it’s inaccurate. When you register for a SCORM Cloud account or take a course within SCORM Cloud we ask for information such as your name, company name and email address. If you sign up for a free SCORM Cloud account you are not required to enter a credit card until you upgrade to a paid plan. Users of paid plans are required to enter their credit card number. Rustici Software uses a third party intermediary to manage credit card processing. This intermediary is not permitted to store, retain or use your billing information except for the sole purpose of credit card processing on Rustici Software’s behalf.

Cookies

A cookie is a small piece of data that includes an anonymous unique identifier, that is sent to your browser from a web site’s computers and stored on your computer’s hard drive. We use cookies to track current session information and to streamline your login process. We do not require permanent cookies.

Information Usage

Rustici Software uses your information for the following general purposes: products and services provisioning, billing, identification and authentication, services improvement, contact and research.

Information Sharing

Except as described in this policy, Rustici Software will not give, sell, rent or loan any personal information to any third party, unless:

  • It is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Terms of Service of the specific application, or as otherwise required by law.
  •  Rustici Software is acquired by or merged with another company. In this event, Rustici Software will notify you before information about you is transferred and becomes subject to a different privacy policy.

If our Information Sharing policy changes in the future, Rustici Software will offer individuals an opt-in or opt-out choice regarding the sharing of their personal data. Please be aware that Rustici Software may be required to disclose an individual’s personal information in response to lawful request by public authorities, including to meet national security or law enforcement requirements.

Data Storage

Rustici Software uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage and other technology and services required to operate and maintain our services which may require that your personal information be transferred to these vendors and partners. Although Rustici Software owns the code, databases and all rights to the Rustici Software applications, you retain all rights to your data. Rustici Software maintains reasonable security measures to protect your information from loss, destruction, misuse, unauthorized access or disclosure. These technologies help ensure that your data is safe, secure, and only available to you and to those you provided authorized access. However, no data transmission over the Internet or information storage technology can be guaranteed to be 100% secure. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU/US Privacy Shield, Rustici Software is potentially liable.

Access

Rustici Software acknowledges the right of individuals to access their information. Requests to access personal information should be submitted to support@scorm.com, with the subject line “Personal Information Access Request”

Children’s Personal Information

In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we do not knowingly request, solicit, access or receive personally identifiable information from anyone under the age of 13. Our customers who use the Content Controller product to run their training programs and store personal data may, however, collect personal data from children under the age 13 using this platform. Such parties are the “operators” of their respective websites as defined by COPPA. While it is our customers’ responsibility, not ours, to ensure compliance with COPPA, in the event we have actual notice that a customer has collected personal information in violation of COPPA, we will require such customer to take measures to comply with COPPA. Rustici Software disclaims all liability related to the collection and use of personal information by its customers.

Changes to Privacy Policy

Rustici Software may update this policy from time to time. You can review the most current version of this privacy policy at any time at http://www.scorm.com/privacypolicy. Your continued use of the site or service constitutes your agreement to be bound by such changes to the privacy policy. Your only remedy, if you do not accept the terms of this privacy policy, is to discontinue use of the site and service.

Terms of Service

When you access and use the SCORM Cloud service, you are subject to the SCORM Cloud Terms of Service . When you access and use the Content Controller or Hosted SCORM Engine services, you are subject to the Terms of Service enumerated in your company’s Service Agreement.

California Statutory Rights.

Under California Civil Code sections 1798.83 – 1798.84, California residents who have an established business relationship with Rustici Software are entitled to ask us for a notice describing what categories of personal customer information we share with third parties for those third parties’ direct marketing purposes and to opt-out of sharing your personal information with third parties for direct marketing purposes.  That notice will identify the categories of information shared and will include a list of the third parties with which it was shared, along with their names and addresses. If you choose to opt-out or would like a copy of this notice, please submit a written request to the following address: Rustici Software LLC, California Resident Privacy Request, c/o Rustici Privacy Department 210 Gothic Court Suite 200, Franklin, TN 37067. Please allow 30 business days for a response.

EU Privacy Shield

Rustici Software has implemented Amazon Web Services’ data processing addendum. On March 6, 2015, the AWS data processing addendum, including the Model Clauses, was approved by the group of EU data protection authorities known as the Article 29 Working Party. This approval means that any AWS customer who requires the Model Clauses can now rely on the AWS data processing addendum as providing sufficient contractual commitments to enable international data flows in accordance with the Directive. For more detail on the approval from the Article 29 Working Party, please visit the Luxembourg Data Protection Authority webpage here: http://www.cnpd.public.lu/en/actualites/international/2015/03/AWS/index.html All SCORM Cloud data is processed in Amazon Web Services us-east-1 region. All Managed Content Controller and Managed SCORM Engine data is processed at Amazon Web Services in a region of the customer’s choosing. Customers may choose to have their Managed environment situated in European datacenters. Rustici Software is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. Rustici Software complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Rustici Software has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/ In compliance with the EU-US Privacy Shield Principles, Rustici Software commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Rustici Software at privacyshield@scorm.com Rustici Software has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus.  If you do not receive a timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. Rustici Software complies with the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. Rustici Software has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement . If there is any conflict between the policies in this privacy policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern. To learn more about the US-Swiss Safe Harbor and to view our certification page, please visit http://www.export.gov/safeharbor/ In compliance with the US- Swiss Safe Harbor Principles, Rustici Software commits to resolve complaints about your privacy and our collection or use of your personal information. Swiss citizens with inquiries or complaints regarding this privacy policy should first contact Rustici Software at privacyshield@scorm.com Rustici Software has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/us/safeharborcomplaints for more information and to file a complaint.

Questions

If you have questions to report regarding this privacy policy or about the security practices of Rustici Software, please contact us by email us here or by mail at: 210 Gothic Court Suite 200 Franklin, TN 37067