Information we collect
SOFR collects personal data about you when you enter your user account information and participate in course content, including in user posting areas (such as bulletin boards, discussion forums and surveys). We also automatically collect information about how you use the SOFR Academy site, such as what you have bookmarked, searched for and viewed. Further, we collect information about your academic performance and behavior related to test and poll taking, like progress, score, time spent, and your answers to these tests and polls. The information automatically collected will be associated with any other personal data you have provided.
Use of information
SOFR uses your personal data to enable you to access courses and SOFR Academy content. SOFR also uses your personal data to evaluate and improve our services, distribute newsletters and alerts to you, analyze SOFR Academy performance and functioning, compare the use of SOFR Academy content among different audiences. We also use your personal data to identify other courses, services or offerings provided by us that may be of interest to you.
SOFR and its service providers may use first and third party Cookies and Other Tracking Technologies, including web beacons, to manage our Sites and our services and collect analytics about how you use them. SOFR and its service providers may collect information about whether you open or click any links in the knowledge, research or event communications that we send to you.
SOFR Academy does not collect personal data about your online activities over time and across third party websites or online services. Accordingly, we do not alter our data collection and use practices in response to “do not track” signals transmitted from web browsers.
Sharing information with your Sponsoring Organization
From time to time we may provide your Sponsoring Organization with user progress and proficiency data with respect to particular SOFR Academy courses or courses, some of which may constitute your personal data (collectively, “Participation Data”). SOFR Academy shall not be responsible or liable for the use of such information by your Sponsoring Organization, and such use shall be subject to your Sponsoring Organization’s policies (including privacy policies) applicable to you.
The legal basis by which we process your personal data
Our processing of your personal data for the purposes mentioned above is based
- on our legitimate interests in promoting and protecting SOFR Academy, building and maintaining relationships, and providing our services, for example where we analyze usage data to see how the SOFR Academy is functioning;
- on your consent, for example if you register for our newsletters or alerts;
- to comply with the law, when certain information is necessary to satisfy our legal or regulatory obligations.
Data recipients and international data transfers
SOFR shall not intentionally disclose or transfer (and shall take reasonable steps to prevent the unauthorized or accidental disclosure of) your personal data to third parties without your consent unless otherwise permitted by law, whether for such third parties’ own marketing purposes or otherwise, except as follows
In addition, we may disclose information about you:
- If we are required to do so by law or legal process;
- To law enforcement authorities or other government officials;
- When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
- If disclosure is necessary to protect the vital interests of a person;
- To enforce our Terms;
- To protect our property, services and legal rights;
- To prevent fraud against SOFR Academy, our subsidiaries and affiliates and business partners;
- To support auditing, compliance, and corporate governance functions; or
- To comply with any and all applicable laws.
In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.
You should be aware that whenever you publicly disclose information, even to a limited group of recipients (for example, other users who are enrolled in the same SOFR Academy course as you), that information could be collected and used by others. SOFR is not responsible for any action or policies of any third parties, including other SOFR Academy users, who collect information that users disclose to such third parties.
Third-party websites and platforms
SOFR Academy has implemented generally accepted standards of technology and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorized SOFR Academy personnel and third party service providers are provided access to personal data, and these personnel and service providers are required to treat this information as confidential. Despite these precautions, SOFR Academy, however, cannot guarantee that unauthorized persons will not obtain access to your personal data.
Data retention policy
Where granted by local law, you may have the right to request access to the personal data that we have hold about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may also have the right to request a copy of the personal data that we hold about you and to have any inaccuracies in that data corrected.
If you would like to make a request to access, review, or correct the personal data we have collected about you, or to discuss how we process your personal data, please contact our support team.
To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring you to provide or confirm your identity, including your User Account Information, before granting access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Different laws or circumstances may prevent us from providing access to your personal data or otherwise fully complying with your request depending upon the circumstances and the request; such as for example, where producing your information may reveal the identity of someone. We may, including where required by applicable law or contract, notify your Sponsoring Organization of your request and coordinate with your Sponsoring Organization in responding to your request. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or deny your requests where they may be manifestly unfounded, and/or excessive, or otherwise objectionable or unwarranted under applicable law.
Where the processing of your personal data is based on consent (for example if we send you newsletters), you may withdraw your consent at any time, by contacting our support team.
In addition, and where granted by local law, you have the legal right to lodge a complaint with a competent data protection authority.
Your California privacy rights
Pursuant to California Civil Code Section 1798.83(c)(2), SOFR Academy does not share your personal data with third parties for those third parties’ direct marketing use.
Contact our privacy department
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