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Introduction (effective December 20, 2019)
Our principle guidelines are simple. We will be clear about the data we collect and why. We do not and will not sell your data to third parties. The prime purpose of collecting your data is to assist you in using our video role play solution. Whether you are practicing a scenario, coaching or mentoring a student, or collaborating with your team, our aim is to make practice fun and as beneficial as possible.
We will update this Policy when necessary to reflect legal changes, customer feedback, and changes in our Services. When we post changes to this Policy, we will revise the “effective” date at the top of the Policy and may describe the changes in a change history. If there are material changes to the Policy or in how Rebellion will use your personal information, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this Policy to learn how Rebellion is protecting your information.
IMPORTANT INFORMATION (EU AND CALIFORNIA USERS)
Who We Are
For the purpose of the GDPR, and depending on the specific Personal Information of interest, the data controller of your specific Personal Information of interest is either the subscriber company of the Rehearsal instance in which your data is entered and stored, or Rehearsal, a division of Rebellion Training, Inc. of 5475 Reno Corporate Dr #500, Reno, NV 89511. You may contact our data protection officer at email@example.com.
Sale of Personal Data
You may opt out of all sales of your Personal Information. We never exchange Personal Information for money or any other consideration (e.g., trade it for free services). However, the CCPA’s definition of “sale” is very broad, and may include situations where, for example, browsing data is sent to referral advertisers. We, along with millions of other sites, use these services. While we limit the information sent to what is needed to properly record the referral, the fact that you clicked on the link and visited Rehearsal may be added to your profile by the ad publisher. This is all done with cookies, the use of which can be controlled as described below in the “How to control cookie settings” section.
The Types of Personal Information We Collect
Information you provide to us
We collect information you voluntarily provide to us, such as your name and email address; for instance, when you want to update your profile or when you contact our Customer Care department for assistance.
Information we collect automatically
We automatically collect information about you, such as data about your use of Our services. We may, for example, collect information about the type of device you use to access our websites, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the webpages you view on our websites, and whether and how you interact with content available on our websites.
Information obtained from other sources
We may receive information about you from other sources, including third parties, such as Rebellion partners and partners with whom we offer co-branded services or engage in joint marketing activities. We may also receive information about you from Rebellion partner websites, for instance, when you interact with us on those sites. We protect data obtained from third parties according to the practices described in this Policy and we also apply any additional restrictions imposed by the source of data.
Information of children
Rebellion does not target and is not intended to attract children under sixteen. Although visitors of all ages may navigate through our websites or use our app, we do not knowingly collect or request personal information from those under the age of sixteen without parental consent. If, following a notification by a parent or guardian or discovery by other means, a child under sixteen has improperly accessed or used our Services by using false information, we will delete the child’s personal information from our records.
Customer Interactions with Rebellion
To make the information in this Policy easy to understand, we have highlighted different occasions when Rebellion could potentially collect personal information from customers. The customer interactions with Rebellion are broken down into the following segments:
Learning about Rebellion
As you gather more information about Rebellion, you may virtually or physically visit or interact with a site that we own or operate. Examples include browsing our website, calling our in-house sales representatives, or attending Rebellion-sponsored events. To learn more about Rebellion Services, you may voluntarily provide personal information, such as your name and email address during these interactions. We may also collect information about you online when you visit our websites.
We collect: name, email address, phone number, company, and IP address.
Why: We use this information to share news about events, and Services offered by Rebellion. Additionally, the IP address helps us to understand geographic information about our websites’ visitors better so that we can improve our websites for everyone. It is our legitimate interest to process your personal data for these purposes.
Updating your profile
When you update your profile, we allow you to enter or modify certain information. You may voluntarily provide personal information such as your first name, last name, and email.
We collect: first name, last name, email address, sales territory, image, and preferred language.
Why: We use this information to notify you of activities and events within Our Services depending on your notification preferences, identify your associated assets, such as practice videos, identify you to other authorized collaborators in Our system, properly display content in Our Services, and authenticate access to content based on associated roles and privileges. Processing your personal data for these purposes is necessary for the performance of the agreement we have with you.
Submitting a video
The Rebellion Service is a video role-play solution, and the submission of videos by trainers, mentors, and students is the core function of the technology. We use the videos to facilitate training by example, by practice, by evaluation, and by screen capture.
We collect: Video data, audio data, screen-capture data.
Why: We use this information to to facilitate practice, training, and collaboration between coaches, mentors, and students. Processing your personal data for these purposes is necessary for the performance of the agreement we have with you.
Getting Help from Rebellion
From time to time, you may decide to contact our Customer Care department for assistance with the Rebellion Services, such as if you are having issues with the operation of your camera or your microphone. To be able to offer you the best service possible, we may collect certain data from you.
We collect: This may include contact information, such as your name, email address, phone number, and the content of your chats and other communications with Rebellion Customer Care.
Why: We collect this information to give you the best and most efficient customer support possible. For instance, for Customer inquiries and technical questions, we use contact information to respond to the Customer in their preferred channel (e.g., phone or email). Processing your personal data for this purpose is necessary for the performance of the agreement we have with you.
How We Use Personal Information
Rebellion uses the data we collect to provide you with the Services we offer, which includes using data to improve your experiences. We also use the data to communicate with you, for example, informing you about, new Services available, security, and other types of updates.
Rebellion uses the data for the following purposes:
Providing our Product Experience
We use data to provide, operate, support and improve the Services we offer to ensure our customers can practice, coach, and collaborate as efficiently as possible. This processing is necessary for the performance of our agreement we have with you.
We use data to respond to customer inquiries, diagnose problems using the Services, address technical issues, and provide other Customer Care and support services. This processing is necessary for the performance of our agreement we have with you, as well as to serve our legitimate interest.
We continually use data for research purposes and to develop and improve Our Services, including maintaining and improving the performance of Our Services, developing and adding new features or capabilities, such as using verification to improve security, and using usage data to determine what new features to prioritize. This processing is necessary to serve our legitimate interest.
Security, Safety and Dispute Resolution
We use data to protect the security and safety of Our Services and our customers, to detect and prevent fraud, to resolve disputes and enforce our agreements. This processing is necessary to serve our legitimate interest.
We use data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business. This processing is necessary to serve our legitimate interest.
Communication, Marketing, and Advertising
How We May Share Personal Information
Rebellion does not and will not sell personal information about our customers. We only disclose your data as described in this Policy. We may share information with the following types of third parties.
Entity or Company provisioning your account
All accounts in the Rebellion platform are provisioned by a Rebellion customer. Rebellion does not control the creation or deletion of these accounts, and the creators of these accounts may have access to some or all of your personal information based upon agreements you may have executed. Sharing information with our Rebellion customer companies for this purpose is necessary for the performance of our agreement we have with you and with the associated customer company.
When legally required, strictly necessary for the performance of the services or to protect our rights, or the rights of our affiliates or users, we disclose your personal information to law enforcement authorities, investigative organizations, our affiliates or in legal proceedings.
Sale or Merger
We may share your personal information in the event of a merger, acquisition, or sale of all or a portion of our assets. Of course, we shall notify you via email and/or a prominent notice on our website and inform you of your rights.
The Legal Bases for Using Personal Information
There are different legal bases that we rely on to use your personal information, namely:
Performance of a contract
The use of your personal information may be necessary to perform the agreement you have with us. For example, to process your submission of a video response, to search for assignments, to post to the leaderboard, to help with technical issues, and to respond to your requests.
We may use your personal information for our legitimate interests. For example, we rely on our legitimate interest to analyze and improve Rebellion Services, to send you notifications about Rebellion Services, or to use your personal information for administrative, fraud detection or legal purposes.
Where we process your personal information based on our legitimate interest and no opt-out mechanism is available to you on our website, you may exercise your right to object by sending an email to firstname.lastname@example.org.
Security, Storage and Retention of Personal Information We Collect
Rebellion is committed to protecting the security of your personal information. However, while we take reasonable precautions to guard the personal information we collect, no security system is impenetrable.
We use a variety of appropriate technical and organizational measures and industry standards to protect your personal information and help prevent information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. We ensure that our data center has adequate security measures. Additionally, your data is protected with encryption, such as Transport Layer Security (TLS), during transmission over the Internet. You can only access your information and our service through the use of an individual user login and password. To protect the confidentiality of your personal information, you must keep your password confidential and not disclose it to any other person. Please alert us immediately if you believe your password has been misused. Additionally, always log out and close your browser when you finish using the Services. Please note, we will never ask you to disclose your password.
If you have any questions about the security of your personal information, you can contact us at email@example.com.
Personal data collected by Rebellion may be stored and processed in your region, in the United States (for instance in our data centers), or in any other country where Rebellion is located or maintains facilities. Rebellion has put in place adequate mechanisms to protect personal information when it is transferred internationally, for example by using the Standard Contractual Clauses as approved by the European Commission.
Rebellion will retain your personal information for as long as we deem it necessary to enable you to use the website and Rebellion Services, to provide services to you, to comply with applicable laws (including those regarding document retention), and resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. All personal information we retain will be subject to this Policy and our internal retention guidelines. If you have a question about a specific retention period for certain types of personal information we process about you, please send an email to firstname.lastname@example.org.
Your Rights and Choices
We want you to be in control of how your personal information is used by us. Subject to local law, you can do this in the following ways:
Where we are using your personal information on the basis of your consent, you are entitled to withdraw that consent at any time. Moreover, where we process your personal information based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal information.
We rely on you to ensure that your personal information is complete, accurate and current. Please inform us promptly of any changes to, or inaccuracies of, your personal information by contacting email@example.com.
We will respond to your request as soon as possible but certainly within 30 days.
We are committed to working with you to obtain a fair resolution of any complaint or concern you may have about our use of your personal information. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to lodge a complaint with the data protection authority in your country (if one exists in your country) or supervisory authority.
Rights for EU and California Users Only
The GDPR and CCPA grant EU and California residents certain rights regarding their Personal Information, including the right to access and modify Personal Information held by providers (like us), and to have providers “forget” Personal Information that is no longer relevant. You may always contact us for assistance in exercising these rights. Please include information about which rights you are seeking to exercise if you contact us. We may need to verify your identity before fulfilling your request. It should not need to be said, but we will never provide worse services to, or in any way punish anyone who chooses to exercise these rights.
You have the following rights with respect to your Personal Information that we process. Except where indicated, these rights apply equally to EU and California users:
If you wish to exercise any of these rights, please contact us at firstname.lastname@example.org, or write us at the address below. In your request, please make clear: (i) what Personal Information is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only fulfil requests with respect to the Personal Information associated with the email address you send your request from, and we will need to verify your identity before doing so (which is typically done by having you make the request from within the Services). We will comply with your request promptly, but in any event within thirty (30) days of your request (forty-five (45) days for requests under the CCPA). We may need to retain certain information for recordkeeping purposes or to complete transactions that you began prior to requesting such change or deletion.
Service data submissions
If you wish to access, edit or remove video or content, change your password, or request deletion of your personal data, you can do it by sending an email to email@example.com. We will respond to any request to access or delete your personal data as soon as possible but certainly within 30 days. Note that some data requests will require authorization from the customer company that provisioned your account, as it is typically the case they have an ownership interest in the data.
Your Communication, Marketing and Advertising Preferences
You can opt out of receiving direct marketing communications from Rebellion by following the instructions included in every email sent to you via the “Unsubscribe” link. We respect your choice, and we will stop sending you promotional emails once you unsubscribe.
Please note we will continue to communicate with you regarding changes to terms and conditions, policy updates, Rebellion Service updates, routine customer service messages such as information about service interruptions, data breaches, or other significant information about your use of the Services.
A ‘cookie’ is a small data file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. The length of time a cookie will stay on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Rebellion uses both types of cookies. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted. We use the following types of cookies on our website.
How to control cookie settings
Advertising and Modern Marketing Tools
To help more people achieve increased expertise on the Rebellion platform, we use several modern marketing tools in support of our advertising efforts.
If you have opted out of receiving communications from us, we will not use your email for interest-based advertising.
How to Contact Us
In many cases, the Rebellion customer provisioning your account may be a data controller subjecting you to different privacy policies. You can contact the provisioning Rebellion customer or Rebellion directly for more information.
Our address is 5475 Reno Corporate Drive #500, Reno, Nevada 89511, USA.
Privacy Shield Statement
EU-U.S. and Swiss–U.S. Privacy Shield
Rebellion Training participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Rebellion Training is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov
Rebellion Training is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Rebellion Training complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Rebellion Training is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Rebellion Training may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
“Personal Data” means information that (1)is transferred from the EU/EEA or Switzerland to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.
“Sensitive Personal Information” means Personal Data that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.
Rebellion Training may receive Personal Data from itself as well as from its affiliates, customers, prospective customers and business partners and other parties located in the EU/EEA. Such information may contain names, addresses, email addresses, title, department, location, training materials, training performance data, and includes information recorded on various media as well as electronic data.
Rebellion Training complies with the Principles with respect to processing Personal Data:
Rebellion Training generally does not receive personal data directly from individuals. In the event that Rebellion Training does receive Personal Data directly from individuals, Rebellion Training shall inform an individual of the purpose for which Rebellion Training collects and uses their Personal Data and the types of third parties to which v discloses or may disclose that Personal Data. Rebellion Training shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Data. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Data to Rebellion Training or as soon as practicable thereafter, and in any event before Rebellion Training uses or discloses the Personal Data for a purpose other than for which it was originally collected. Rebellion Training may be required to disclose Personal Data in response to lawful request by public authorities, including to meet national security or law enforcement requirements.
Rebellion Training generally does not receive Personal Data directly from individuals. In the event that Rebellion Training does receive Personal Data directly from individuals, Rebellion Training will offer individuals the opportunity to choose (opt out) whether their Personal Data is (1) to be disclosed to a non-Agent third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, Rebellion Training will give individuals the opportunity to affirmatively or explicitly (opt in) consent to the disclosure of the information to a non-Agent third party or for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Rebellion Training shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information. Agents, technology vendors and/or contractors of Rebellion Training may have access to an individual’s Personal Data on a need to know basis for the purpose of performing services on behalf of Rebellion Training or providing or enabling elements of the services. All such agents, technology vendors and contractors who have access to such information are contractually required to keep the information confidential and not use it for any other purpose than to carry out the services they are performing for Rebellion Training or as otherwise required by law.
Accountability for Onward Transfer. Rebellion Training shall ensure that any third party to which Personal Data may be disclosed subscribes to the Principles or is subject to laws providing the same level of privacy protection as is required by the Principles and agrees in writing to provide an adequate level of privacy protection.
Data Security. Rebellion Training shall take reasonable steps to protect the Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction. Rebellion Training has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Personal Data from loss, misuse, unauthorized access or disclosure, alteration or destruction. However, Rebellion Training cannot guarantee the security of Personal Data on or transmitted via the Internet.
Data Integrity and Purpose Limitation. Rebellion Training shall only process Personal Data in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, Rebellion Training shall take reasonable steps to ensure that Personal Data is accurate, complete, current and reliable for its intended use.
Access and Recourse. Rebellion Training acknowledges the individual’s right to access their Personal Data. However, Rebellion Training generally does not receive Personal Data directly from individuals but indirectly, via its customers. In the event that Rebellion Training does receive Personal Data directly from individuals or that a Rebellion Training customer cannot access the individual’s Personal Data, Rebellion Training shall allow an individual access to their Personal Data and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.
Rebellion Training, LLC
Head of Global Product Operations
5475 Reno Corporate Dr., Suite #500
Reno, NV 89511
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim.
Please note that if your complaint is not resolved through any of the above channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
The following are basic questions you may have about our Policy. We encourage you to read the detailed statement above for additional details.
What is the GDPR?
The GDPR is a regulation intended to strengthen and unify data protection for everyone within the European Union (EU). And because we believe that all our customers can benefit from its mandates, we’re implementing it globally. The GDPR requires greater openness and transparency from companies on how they collect, store and use personal data, while also imposing tighter limits on the use of personal data. You can learn more here.
What is the CCPA?
The CCPA was created to protect the privacy and data of consumers. The CCPA initiative states that the act is intended to “give Californians the ‘who, what, where, and when’ of how businesses handle consumers’ personal information.” The act requires businesses tell consumers what data its collecting and gives consumers the right to say no to the sale of their personal information.
We will update our Policy as necessary to ensure that our policies are in line with international regulations, our product and business practices.
What information does Rebellion collect about me?
Rebellion collects your first name, last name, street address, city, state, postal code, country, phone number, email address, territory, image, video content, audio content, and the content of your chats and other communications with Rebellion Customer Care.
Why does Rebellion need my information?
Rebellion uses the data we collect to provide you the best experience within the Services we offer, which includes using data to improve your experiences. We also use the data to communicate with you, for example, informing you about your assignments and assignment deadlines, new services available, security, and other types of updates.
How is my information used?
Rebellion uses the data we collect for the following purposes:
How does collecting my information help Rebellion improve its Services?
We use the information to make sure that we are efficiently and accurately capturing your video submissions, displaying submitted videos, and facilitating coaching and collaboration interactions. We also collect service error information, so we can make improvements to eliminate potential bugs and problems. And finally, understanding how and when our customers collectively use our service helps us design new ways to improve the video role play practice process.
Does Rebellion sell information to third parties?
No. We never have.
Can I opt out of sharing my information to Rebellion?
Yes, you can opt out of submitting certain types of personal information to Rebellion, but because Rebellion collects mostly data related to practice, coaching, and collaboration, the decision not to submit some information may impact Rebellion’s ability to provide efficient and effective services.
How do I delete my personal data from Rebellion and what are the consequences?
You can always send us an email to firstname.lastname@example.org or contact our Customer Care team and request that your data be deleted. Please note, however, that by deleting your personal data, submitted content may no longer be available, and we will be unable to provide further practice or historical training records.
How long does Rebellion keep my information?
Rebellion retains personal data for as long as necessary to provide the Services, and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes and enforcing our agreements. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly.
How is information stored and secured on Rebellion’s servers?
Rebellion is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. Any data we transmit over the internet is protected using encryption.
Is Rebellion using cookies to gather information?
Does Rebellion use interest-based advertising?
Yes. We work with third-party advertisers that utilize cookies and similar technologies to provide more relevant advertising about Rebellion on our website and across the internet. To provide interest-based advertising, the advertisers combine non-personal data learned about your online activities over time to customize the advertising delivered to you. We do not share your personal information to do this.
What safeguards are in place for children who have access to Rebellion services?
Rebellion does not target and is not intended to attract children. Rebellion does not knowingly solicit personal information from children or send them requests for personal information. Although visitors of all ages may navigate through our website, we do not intentionally collect personal information from persons under the age of sixteen. If following a notification by a parent or guardian, or discovery by other means, that a child under sixteen has improperly accessed or used the site or Services, we will delete the child’s personal information from our records.
If you have any questions about the use of your personal information, please send us an email to email@example.com.