This Business Privacy Statement was updated on January 21, 2021.
In the course of providing RTDC for Business services and related services to its corporate, non-profit organization and governmental customers (“Customers”), Ricasi Consultancy Limited will receive and have access to personal data of individual users to whom customers grant access (“Users”). For the purposes of this privacy statement, Customers are data controllers and Ricasi Consultancy Limited is a data processor. Ricasi Consultancy Limited’s processing of User data and the security measures implemented to protect such data are detailed in and governed by a written agreement between Ricasi Consultancy Limited and each of its Customers.
As a data processor, Ricasi Consultancy Limited will access, store and use the personal data of individual Users solely for the purpose of providing the RTDC for Business services to its Customers and will process the data as instructed by its Customers.
As data controllers, Customers decide which of their employees or other authorized personnel are given access to the RTDC for Business services. They do this by designating one or more RTDC for Business account administrators or group administrators (“Administrator”) who have the ability to customize the Customer account, manage individual User accounts, access the RTDC for Business Insights tool and related reporting features, access the RTDC for Business Administrator tools, and, when instructed by the Customer, populate the Customer account with Customer-provided courses. Customers are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, relating to the collection of personal information relating to individual Users selected by Customers for accessing the RTDC for Business services. Ricasi Consultancy Limited has no direct relationship with individual Users, who should contact Customers (their employer) for assistance with any requests or questions relating to the processing of their personal information.
For avoidance of doubt, this Privacy Statement does not apply to:
- any processing of data for the purpose of marketing the RTDC for Business service to enterprise and corporate prospects;
In the event where Ricasi Consultancy Limited makes any material changes to the manner in which it processes User data to provide its services to Customers, it will notify Customers.
Business Privacy Statement
- Information about Users collected and stored by Ricasi Consultancy Limited
- Purpose of User Data Processing
- Cookies and other Tracking Technologies
- Sharing User Information with Sub-Processors
1. Information about Users collected and stored by Ricasi Consultancy Limited
- When a User is given access to the RTDC for Business services by the Administrator, a User may set up an individual User account and Ricasi Consultancy Limited will collect information provided by the User or the Administrator. The Customer can customize the type of data requested to create an account, which may include the following:
- first name, last name, and email address required
- photo, areas of interest, job skills, goals, and role (optionally provided by User or Customer)
- other personal data, as allowed by the Customer
A unique identifying number is assigned by Ricasi Consultancy Limited upon the creation of a User account.
- Individual User account information may be set to private or public, as selected by Users. If set to public, the information is searchable via search engines and viewable by anyone, including by other Users and the Customer.
- Administrators may assign a User to a group membership
- Customers may select to integrate with RTDC for Business a Single Sign On (SSO) identity provider to enable Users to log in to RTDC for Business User accounts without the need to disclose passwords to Ricasi Consultancy Limited. In such case Users may log in by providing their individual SSO credentials to the SSO identity provider, which will authenticate them and allow or deny access to the Customer account. In such case, SSO identity providers share with Ricasi Consultancy Limited a unique cookie ID and authentication “token” information to recognize the User as an authorized user of Customer.
- At the option of the Customer, the RTDC for Business service may enable Administrators and Users to interact with others, including with instructors, teaching assistants, facilitators, other students, other event attendees, and the Customer, by posting reviews on a course or event, sending messages to or chatting with others, posting questions or answers, or posting other content. Such public or shared content is stored by Ricasi Consultancy Limited and may be publicly available or viewable by others, including Administrators, Users, facilitators, or instructors and teaching assistants, depending on where such content is posted.
- Ricasi Consultancy Limited stores information relating to the activities of Users as they use and interact with the RTDC for Business services, such as courses enrolled in and viewed (and information relating to these courses); interactions with facilitators, instructors, teaching assistants, Administrators, and other Users; and progress within a course; as well as answers, essays, and other items submitted by Users to satisfy the course requirements and event attendance. This information is linked to a User’s unique account ID and is shared with Customers via the Customer Account reporting tools or upon request of the Customer.
- The RTDC for Business service enables Users to contact the Ricasi Consultancy Limited Support Team for assistance or to report a problem, concern, potential abuse or other issues regarding the RTDC for Business services or other users. Ricasi Consultancy Limited may collect and store the User’s name, email address, location, operating system, IP address as well as the User’s activity on the RTDC platform and communications with the Ricasi Consultancy Limited help desk team. Ricasi Consultancy Limited may request additional information from Users in order to resolve any issue reported by a User or by another user.
- When a User uses the RTDC for Business services, Ricasi Consultancy Limited collects and stores certain information by automated means: (a) technical information about the User’s computer or wireless device, such as IP address, operating system type and version, unique device ID, browser, browser language, domain, and other operating systems or platform information. This information is collected through the use of server log files and tracking technologies, such as: (i) cookies, which are small files that websites send to a computer or wireless device to uniquely identify a browser or mobile device or to store information in a browser setting; and (ii) other tracking technologies.
- IP addresses received from browsers or devices of Users may be used to determine the approximate location of Users.
- If a Customer makes purchases via credit card, Ricasi Consultancy Limited collects certain data about the purchase (such as name and zip code) as necessary to process the order. Customers must provide certain payment and billing data directly to Ricasi Consultancy Limited’s payment processing partners, including name, credit card information, billing address, and zip code. For security, Ricasi Consultancy Limited does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.
2. Purpose of User Data Processing and Retention Period
Ricasi Consultancy Limited processes the information collected about Users and Administrators for the purpose of providing the RTDC for Business services to its Customers, specifically:
- Providing, administering, and facilitating access to the RTDC for Business services, for Customers and Users, and managing Customer or User account preferences
- Fulfilling Customer’s instructions with respect to personal data of Users
- Displaying and sending via email notifications to Users for:
- Responding to User questions or concerns
- Making notifications to Users at the request of the Customer
- Sending Users administrative messages and information, including confirmation of account creation, course enrollment, course progress and notifications of responses from instructions to User questions; and events registered for and attended
- Providing information to Users about courses and events available to Users, available and new RTDC for Business service features; personalized course recommendations, which Users can opt out of at any time
- Sending push notifications to User wireless devices to provide updates and other relevant messages, which can be managed from the “options” or “settings” page for the mobile application.
- Enabling communications among Users and facilitators, instructors or teaching assistants
- Soliciting feedback to improve RTDC for Business User experience
- Resolving User support requests or claims
Users can individually opt out of receiving non-transactional emails by: (i) following the unsubscribe instructions provided in the email communication; or (ii) managing User account email preferences. A Customer can also instruct Ricasi Consultancy Limited to configure email preference settings for all Users of a Customer.
Retention of Personal Data
Ricasi Consultancy Limited will retain the data of Users for as long as instructed by the Customer. Ricasi Consultancy Limited will delete certain or all personal data relating to Users upon request of the Customer. Ricasi Consultancy Limited may retain aggregated or anonymized data as set forth below.
Use of aggregated data
In addition, User data is aggregated with other RTDC marketplace user data to enable Ricasi Consultancy Limited to improve its products and services and develop new products and services, including:
- Reviewing and analyzing User browser and wireless device technical information
- Reviewing user activity across RTDC for Business and the RTDC marketplace (for example, Ricasi Consultancy Limited analyzes trends and User traffic and and usage information to identify which courses are most popular)
- Facilitating the technical functioning of the RTDC for Business services and RTDC marketplace, including to troubleshoot and resolve issues, secure the RTDC for Business services, and prevent fraud and abuse
- Developing a personalized course content recommendation engine
When User data is used for the above purposes, it is aggregated and/or anonymized so that no personal data of Users is processed.
3. Cookies and other Tracking Technologies
Like many online platforms, Ricasi Consultancy Limited and its analytics vendors use server log files and automated data collection tools, such as browser cookies, pixel tags, scripts and web beacons. These tools are used for analytics purposes to enable Ricasi Consultancy Limited to understand how Users interact with the RTDC for Business services. Ricasi Consultancy Limited and its analytics vendors may tie the information gathered by these means to the unique account ID of Users.
Cookies are small text files placed onto a computer or device while browsing the Internet. Cookies are used to collect, store and share bits of information about User activities. Ricasi Consultancy Limited uses both session cookies and persistent cookies.
- A session cookie is used to identify a particular visit to the RTDC for Business services and collect information about interaction with the RTDC for Business service. These cookies expire after a short time, or when the User closes their web browser after using the RTDC for Business service. Ricasi Consultancy Limited uses these cookies to identify a User during a single browsing session, such as when you log into the RTDC for Business services. This helps Ricasi Consultancy Limited improve the RTDC for Business service as well as improve the Users’ browsing experience.
- A persistent cookie will remain on a User’s device for a set period of time specified in the cookie. Ricasi Consultancy Limited uses these cookies to identify and recognize a specific User over a longer period of time. They allow Ricasi Consultancy Limited to:
- analyze the usage of the RTDC for Business services (e.g. what links Users click on) in order to improve our RTDC for Business offering
- test different versions of the RTDC for Business services to see which particular features or content Users prefer to optimize the RTDC for Business services
- provide a more personalized experience to Users with more relevant content and course recommendations and
- allow Users to more easily log in to use the RTDC for Business services. Persistent cookies include:
- preferences cookies to remember information about a User’s browser and settings preferences, such as preferred language. Preference cookies make User experience more functional and customized
- authentication and security cookies to enable a User to log in or stay logged in and access the RTDC for Business service, to protect User accounts against fraudulent log-ins by others, and help detect, fight, and protect against abuse or unauthorised usage of User accounts.
- functional cookies to make the experience of using the RTDC for Business service better, like remembering the sound volume level selected by the User.
Ricasi Consultancy Limited uses tracking technology to: (i) determine if a certain page was visited (e.g. the landing page of an advertisement for RTDC for Business services that is displayed on third party sites) or whether an email sent by Ricasi Consultancy Limited was opened or clicked on by a User; and (ii) to customize the learning experience of individual Users by recommending specific courses, events and other content.
User Preferences with respect to cookies and other tracking technologies
A User can set his or her web browser to notify about the placement of new cookies, limit the type of cookies or reject cookies altogether; if enabled, a User may not be able to use some or all of the features of the RTDC for Business services (for example, may not be able to log in). General information about cookies and how to disable them can be found at www.allaboutcookies.org.
Various browsers may offer their own management tools for removing HTML5 LSOs. Users can manage Flash LSOs here. To manage flash cookies, visit the Adobe website and make changes at the Global Privacy Settings Panel.
Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a website should respond to this signal, and we do not take any action in response to this signal. Instead, in addition to publicly available third-party tools, we offer you the choices described in this policy to manage the collection and use of information about you.
4. Sharing User Information with Sub-Processors
In order to provide the RTDC for Business services to its Customers, Ricasi Consultancy Limited shares data regarding Users with a number of third party service providers. These companies are contractually required to use User data solely as directed by Ricasi Consultancy Limited for the purpose of providing services to Ricasi Consultancy Limited.
- Instructors who upload courses on the RTDC platform and made available through the RTDC for Business services as well as their teaching assistants, who may receive names and account profile information of Users, to enable them to respond to user questions and feedback.
- Facilitators who list and conduct virtual events on the RTDC platform and made available through the RTDC for Business services.
- Other service providers of Customer, as instructed by Customer.
- To perform its services, Ricasi Consultancy Limited leases servers from data centers located in France.
- Ricasi Consultancy Limited shares User information with third party companies that perform email services to enable Ricasi Consultancy Limited to send email communications to Users and to manage email preference settings of Users.
- Ricasi Consultancy Limited shares User information with third party company, Google Analytics, that perform data analysis services to enable Ricasi Consultancy Limited to better understand how Users use the RTDC for Business service. To prevent Google Analytics from collecting information for analytics, a User may install the Google Analytics Opt-Out Browser by clicking here.
Any other sharing of User data is subject to the consent and instructions of Customer.