The Institutes’/ RIG Privacy Policy

EFFECTIVE DATE: March 23rd, 2020

The Institutes, its subsidiaries, and its affiliated or controlled organizations (collectively, “The Institutes”) are committed to meeting the evolving professional development needs of the risk management and insurance community and to protecting the privacy of its members, customers, students and visitors to and users of their websites, apps and Services (as defined below). They prepare individuals to fulfill their professional and ethical responsibilities by offering customer-focused and innovative educational, research, networking, and career resource solutions.

This Privacy Policy describes the types  of information that The Institutes, collects from and about your when you (i) visit any of The Institutes websites (each a “Website”) or mobile applications (each an “App) where this policy (or a link to this policy) is posted; or (ii) use any of The Institutes other services including, without limitation, purchase an exam, webinar, or other educational materials, access The Institutes Community or otherwise interact with us or request services from us as described further in this Privacy Policy (collectively, the “Services”). This Privacy Policy also explains how The Institutes may use and disclose such information, as well as your ability to control certain uses of your personal information.  The purpose of this Privacy Policy is to notify you about our practices regarding the information we collect through the Website or App from which you are accessing this Privacy Policy and in connection with your use of the Services. The Institutes may share information we collect with our affiliate and subsidiary organizations. This Privacy Policy applies only to our Services, Websites and Apps.

By accessing this Website, App and/or our Services, you agree to the terms and conditions of this Privacy Policy. If you do not agree with the terms and conditions of this Privacy Policy, you are hereby instructed not to access or use information provided by the Website or App, to submit information to the Website or App, use our Services or to engage in any transactions through the Website or App.

INFORMATION COLLECTION

Information You Provide

We collect information from you when you choose to share it with us. This may include when you register to become a member, customer or student of The Institutes or otherwise use our Services, whether through a Website, App or over the phone. “Personal information” or “personal data” is any information that can be used to identify an individual, directly or indirectly, including, but not limited to:

• Personal identifiers, such as name, address(es), email address(es), fax number, telephone numbers, or mobile numbers
• Protected classification information, such as age, sex, gender, nationality, date of birth, or marital status
• Commercial information, such as credit or debit card number or other financial information
• Biometric information, such as facial recognition;
• Video images and audio of you and those that come within range of your cameras;
• Internet usage information, such as browsing time, cookie information, Internet
• Protocol (“IP”) address, or website history;
• Employer-related information, such as your title and the company’s name, address, and phone number;
• User account information, such as The Institutes account number;
• Geolocation of any computer, mobile device, or other electronic device used to access a Website or App;
• Information regarding the Services purchased;
• Information regarding your usage of, and performance of, our Services and Apps; and
• Charges you incur and other information relating to your transactions.

If you submit to us or to our service providers any personal information relating to other people in connection with the Services and Website, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

We will never solicit or require you to send us any special categories of personal data (including information related to racial or ethnic origin or religious or philosophical beliefs). We ask that you do not send or disclose any special categories of personal data to us on or through the Services or Websites or otherwise. Please note that if you do send or disclose such information, you do so voluntarily.

Notwithstanding the foregoing, on occasion The Institutes may collect personal information or demographic information through The Institutes’ Websites with the intent to afford more privacy for such information than is otherwise set forth in this Privacy Policy. In those relatively rare situations where The Institutes does so it will clearly disclose to you at the time it collects such information, what degree of privacy will be afforded to the personal information and demographic information collected at such time; and The Institutes will follow a process to assure that the specifically disclosed degree of privacy is in fact afforded to such information. For example, The Institutes may collect survey information through a survey where The Institutes’ use of any personal information from that survey is more limited than this Privacy Policy would otherwise allow; in such a case The Institutes’ will disclose the stricter privacy policy governing that survey information at the time such personal information is collected from the survey respondent.

Information Collected From Third Parties Or Other Sources

We may obtain personal or other information about you from third parties or other sources, and combine this information with the information we collect from and about you through the Websites, Apps and Services. Such information may include, but is not limited to:

• • Information, including geolocation information, collected through one of our mobile applications;
  • Information obtained through communications that you make through a third party;
  • Information obtained through transactions you complete with us, including charges you incur;
  • Information about your credit history or other publicly available information about you from consumer reporting agencies;
  • Through third parties, public databases, joint marketing partners, and social media:
    • We may receive your personal data from other sources, such as public databases, joint marketing partners, social media platforms, people with whom you are friends or otherwise connected on social media platforms, and other third parties. We may collect personal data from you offline, such as when you attend one of our programs, place an order over the phone, or contact Customer Success; and
  • Any other information obtained through companies that have business relationships with us, such as our licensees, subsidiaries, controlled or affiliated organizations, and business partners.

We may also obtain information about you from other online sources, including when you connect with The Institutes through its official corporate pages on third party social networks (such as Facebook, LinkedIn, Instagram) or the “apps” on those pages. This information may include, but is not limited to, name, user name, demographic information, updated address or contact information, interests, and publicly-observed data, such as from social media and online activity. We may combine this information with the information we collect from and about you through the Services.

Information Automatically Collected

We may use cookies, web beacons, pixel tags, JavaScript, or other technologies to collect certain information about visitors to any of our Websites or Apps and interactions with our emails and online or mobile advertisements, and may use such information to allow The Institutes to keep track of analytics and certain statistical information that enables us to improve our Websites and Apps and provide you with more relevant content and advertising on our Websites, Apps, or other websites or mobile applications.

For example, we may automatically collect certain information from you, including but not limited to your browser type, device type, operating system, software version, IP address, geolocation, phone model, phone operating system, and the domain name from which you accessed the Services or the Website. We also may collect information about your use of a Website or App, including the date and time you visit the Website or App, the areas or pages of the Website or App that you visit, the amount of time you spend viewing or using the Website or App, the number of times you return to the Website or App, other click-stream or site usage data, emails that you open, forward or click-through to our Website or App, and other websites that you may visit.

We may also use third party cookies and other technologies to support our Services, provide services on our behalf, facilitate business transactions on our behalf, or provide relevant advertising to you. Some of these third parties may use technology such as cookies, web beacons, pixel tags, log files, or Flash cookies on our Websites or Apps, which may send some of the above-referenced information to those third parties.

Tracking Options and California Do Not Track Disclosures

Certain parts of our Websites and Apps require cookies. You are free to set your browser or operating system settings to limit certain tracking or to decline cookies, but by doing so you may not be able to use certain features on the applicable Website or App, or take full advantage of all of our offerings. Please refer to your Web browser’s or operating system’s website or “Help” section for more information on how to delete and/or disable your browser or operating system from receiving cookies or controlling your tracking preferences.

Our system may not respond to Do Not Track requests or headers from some or all browsers. To learn more about the use of cookies or other technologies to deliver more relevant advertising and to know your choices about not having this information used by certain service providers, please click here and here. On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising.

Certain parts of our Websites and/or Apps may also include advertisements from third parties. You can opt-out of being targeted by certain third-party ad-servers and The Institutes served ads online using the National Advertising Initiative’s opt-out tool, the About Ads opt-out tool, or on TRUSTe’s site.

This Privacy Policy does not cover the collection methods or use of the information collected by Third-Party Ad-Servers, and The Institutes is not responsible for cookies or other tracking technology in third-party ads. We encourage you to review the privacy policies or statements of these third-party advertising companies to learn more about their use of cookies and other technologies. If you would like more information about this practice and to know your choices about not having this information used by third-party advertisers, please visit http://www.networkadvertising.org and http://www.aboutads.info/choices/.

Combination of Information

We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Websites and Apps, as well as information collected from other online sources or from third party sources to help us tailor our communications to you and to improve our Services.

INFORMATION USE

How We May Use Personal Data

The Institutes may use the Information we collect from and about you for any of the following purposes:

• To validate, confirm, verify, and track your account, products or Services (including to process payment card transactions, or to contact you about your account, products or Services);
• To enhance your online experience, including as a way to recognize you and welcome you to a Website or App, make the account usage and purchasing process faster and smoother and provide you with customized Website or App content, targeted offers, and advertising on Websites, Apps (including geo-targeted advertising), or via email, telephone, text message, or by mail;
• To recognize your online activities over time and across different websites and devices;
• To contact you with information, newsletters, promotional materials and contests from The Institutes or on behalf of our business partners, sponsors, licensees, and affiliates;
• We may also share user information with our co-sponsors, affiliated organizations, subsidiaries, business partners and service providers to offer products or services which we believe may be valuable or useful to our visitors. They may use a pixel tag or other similar technology to collect anonymous information about your visits to the Websites, and they may use that information to target advertisements for our products and Services;
• To use your data in an aggregated non-specific format for analytical and demographic purposes;
• To review the usage and operations of our Websites or Apps, and improve our content, products, and services; and
• To protect the security or integrity of the Websites, Apps, and our business, such as by protecting against and preventing fraud, unauthorized transactions, claims and other liabilities, and managing risk exposure, including by identifying potential hackers and other unauthorized users.

• Customer Success.
  • To process your membership with The Institutes; complete, fulfill, and communicate with you regarding your request to participate in a program; provide you with study materials; and provide you with related customer service. Our server may store this information so that registering for future seminars will be quicker and easier.
  • To process your payments and orders, deliver your order reports to you, communicate with you regarding your membership or login, and provide you with related customer service.
  • To respond to your inquiries and fulfill your requests, such as to send you study materials, newsletters, brochures, catalogs, and emails.
  • To diagnose problems.
  • To facilitate social sharing functionality.
  • To allow you to send messages to a friend through the Services or Websites. By using this functionality, you are telling us that you are entitled to use and provide us with your friend’s name and email address.
• Marketing.
  • To send you messages about The Institutes’ newsletters, offers, promotional announcements, and consumer surveys. Occasionally, we may send you special offers and promotional information via email or postal mail using the shipping address provided.
  • To send you marketing communications that we believe may interest you.
  • To personalize your experience of the Services and Websites by presenting products and offers tailored to you.
• Analytics.
  • Aggregated and nonaggregated data analysis to detect, monitor, and prevent fraud or to perform processing or data auditing.
  • Aggregated and nonaggregated data analysis to enhance services.
  • Aggregated analytics for developing new products; enhancing, improving, or modifying our Services or Websites; identifying usage trends; determining the effectiveness of our promotional campaigns; and operating and expanding our business activities.
  • Data analysis using geo-fencing, cookies, web beacons, and similar technologies  to keep track of what users view, how long they spend on different pages, and how they arrived on a particular page (for example, through a search query, link from another property, or bookmark).
• Legal Obligations.
  • To send administrative information to you—for example, information regarding your membership status; the Services and Websites; and any changes to our terms, conditions, or policies.
  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal processes; (c) to respond to requests from public and governmental authorities, including public and governmental authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety, or property and/or that of you or others; and (g) to allow us to pursue available remedies or limit the damages we may sustain.
  • Otherwise to comply with all applicable law.
• Business Needs.
  • Payment processing, contract management, website administration, web-forum administration.
• Forums and Communities.
  • The information we collect in connection with our online forums and communities is used to provide an interactive experience. We use this information to facilitate participation in these online forums and communities and, from time to time, to offer you products, programs, or services. If you choose to submit content (for instance, through discussion or comments in the community pages, online forums, or communities), we may publish your name, screen name, and other information you have provided to us. You hereby consent to this publication and use.
• Other. As otherwise described to you at the point of data collection

Additionally, if you use any of the Websites or Apps to connect with third party services you authorize us to use information from and about you, on your behalf, to interact with these third-party services based on your requests.

How Your Personal Data May Be Disclosed or Shared

Your personal data may be disclosed or shared with:

• Affiliates and Partners. With our subsidiaries, affiliates, or business units, select licensees and business partners that we believe may have offers of interest to you, including for their own marketing purposes.
• Third Party Service Providers and Vendors. With our third-party service providers that provide services such as data analysis, payment processing, order fulfillment, experience personalization, business, professional or technical support, information technology and related infrastructure provision, customer service, email delivery, credit card processing, auditing, and similar services.
• Social Networks. By you on message boards, chats, profile pages and blogs, and other services to which you are able to post information and materials (including, without limitation, The Institutes Community pages and our social media pages). Any information you post or disclose through these services will become public information and may be available to users of the Services or Websites and to the general public. We urge you to be very careful when deciding to disclose your personal data, or any other information, on the Services or Websites. We share your personal information with various social media and networking platforms and websites (such as Facebook, Google and LinkedIn) and other providers for use in connection with retargeting platforms and services (such as Facebook’s Custom Audience tool, Google AdWords and others) that deliver advertisements to our users, customers, students, and test-takers (collectively, “customers”). Specifically, The Institutes may share personal information it collects with from its customers (such as email addresses and phone numbers) with Facebook and others to make its advertisements and offerings more responsive to its customers interests and to those of other similar or like-minded individuals. The Institutes may share your email address and phone number with Facebook (or other providers) for the purpose of creating “Custom Audiences” (where targeted interest-based ads are displayed to people using Facebook who are customers of The Institutes), and “Lookalike Audiences” (where targeted ads are sent to people on Facebook who have similar characteristics to people on The Institutes Custom Audience list). This tool (and others like it) allow The Institutes to personalize its ads based on your interactions with The Institutes. Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from The Institutes website and elsewhere on the internet and use that information to provide The Institutes measurement services and target ads.
• Interest-Based Advertising. With companies with which we may partner whose products or services we believe will interest our users. Either we or our partners occasionally send promotional announcements to particular customers. The Institutes may use a vendor to carry out our mailings. We do not automatically include our users in any particular marketing promotion; instead, we use a variety of factors, including user activity at the Website or a customer’s attainment of a certain certification or designation, to determine the appropriate audience (for example, the personal data of top scorers may be shared with other organizations). We may share your personal data (name, email, etc.) with other organizations, including other nonprofit organizations, whose products or services we believe will interest our users, and they may reach out to you regarding their services, products, or initiatives.
• Mailing Providers. If you correspond with us via email, the postal service, or another form of communication, we may retain such correspondence and the information contained therein and use such to respond to your inquiry and/or notify you of our conferences, news, or related opportunities. Importantly, email and postal address information is never sold, given, or otherwise shared or disclosed to third parties except as set forth herein. If you do not wish to receive such notifications, you may express your preference to not be so contacted by sending a letter or by calling or emailing The Institutes at the contact information below, informing us of your preference.
• Contemplated or Actual Sale. With a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). The Institutes may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information provided through the Services in a manner that is consistent with this Privacy Policy.
• Legal Compliance. As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal processes; (c) to respond to requests from public and governmental authorities, including public and governmental authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety, or property and/or that of you or others; (g) to provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; and (h) to allow us to pursue available remedies or limit the damages we may sustain.
• Membership Directory. The Institutes makes member information available through The Institutes’ Member Directory using this Website. In addition, The Institutes may incorporate information members provide into hard copies of a membership directory that may be provided to members. You may opt out of having your information included in this directory. Please refer to “How You Can Access and Manage Your Personal Data”.
• Designation/Certificate/Course/Conferences/Exam Information.
  • Unless you have taken affirmative action to set your account information as “Confidential”*, The Institutes will confirm whether a customer/student/examinee holds an Institutes designation or certificate, or is a member of the Society of Chartered Property and Casualty Underwriters (CPCU Society), upon the request of a third party because, among other reasons:
    • It is in the public’s interest to know whether someone holds a credential or designation.
    • It assists in enforcing the CPCU Code of Professional Conduct.
    • Lists of designation program completers and CPCU designees who participate in the Continuing Education for CPCUs program are a matter of public record.
      • The public may determine that someone holds an Institutes designation or certificate by using the search program on our Website.
      • CPCU Society members may log on to the CPCU Society website and perform a membership search.
      • The public may find designees who are participants in the Continuing Education for CPCUs program by searching the CE for CPCU Active Participants List on our Website.
  • The Institutes may provide their affiliated organizations and subsidiaries with their customers’ personal data for the purpose of making customers aware of certain educational opportunities, news, activities, additional courses and programs, services, and membership benefits available to them.
  • The Institutes may release personal data to their instructors so that instructors can monitor examination pass ratios and recognize educational achievement and for related reasons.
  • In connection with conferences they host, The Institutes may provide an attendee list (the same list provided to attendees at the event) to the sponsors, co-sponsors, and exhibitors.
  • The Institutes may also make available (through a third-party mailing service) addresses for use by sponsors, co-sponsors, and exhibitors in one pre- and one post-conference mailing. If you do not wish to receive the information from such sponsors, co-sponsors, and exhibitors, you may express your preference to not be so contacted by either checking the appropriate box on the registration form at the time of registration or by sending a letter, calling, or emailing The Institutes at the contact information below, informing us of your preference. By accessing this Website/Services/program, you are aware of and approve of The Institutes’ acquiring licensing information from national and state associations and organizations for the sole purpose of CE compliance. Acquired data will not be sold or provided to any third party.
• Other. As otherwise described to you at the point of collection.

Except as set forth herein, at no time when disclosing your information will we sell, rent, or disclose your personal data to third parties without notifying you of our intent to share the information and giving you an opportunity to prevent your information from being shared. (Please refer to the “How You Can Manage Your Personal Data” section.)

The Institutes may also share aggregate or anonymous non-personal information with third parties for their marketing or analytics uses.

How You Can Access and Manage Your Personal Information

The Institutes provides its members, students and customers the opportunity to opt-out of having their information used for purposes not directly related to purchase, processing, registration or ongoing Services. To “opt out” of receiving future e-mail marketing messages from The Institutes, you can click on the “unsubscribe” link at the bottom of an e-mail marketing message or by following the instructions below. You can always access, review, change, and update your various profile, password, membership and other associated information by:

• Going to the My Account dashboard and making the appropriate changes. You must be signed in to access My Account.
• Going to the appropriate account profile page on the applicable Website or App.
• At any time, you may call The Institutes at (800) 644-2101 to update your information and opt into or out of any Service or marketing contact (including emails, postal mail or other announcements). We also provide opt-in and opt-out opportunities as applicable to the service or product being offered through hyperlinks provided in the email.
• You may also send an email to [email protected] with your request.

HOW YOU CAN OPT OUT OF ONLINE BEHAVIORAL ADVERTISING

We may also use third-party advertising companies, such as Google, to serve ads on our behalf. These companies may employ cookies or pixel tags (also known as web beacons and clear GIFs) to collect non-personal data about the actions you take on our Services, App and Website. This information may be used to display online behavioral advertisements, including retargeted ads, on other sites and to measure the success of our marketing campaigns. Any information that these third parties collect is not linked to any personal information we collect. You can opt out of third-party vendors’ use of cookies or pixel tags by either visiting www.networkadvertising.org/choices/ or the Digital Advertising Alliance’s (DAA’s) www.AboutAds.info. You can opt out of Google’s ads by visiting Google’s Ads Preference Manager. We also support the DAA’s Self-Regulatory Program for Online Behavioral Advertising.

CHILDREN’S PRIVACY

The Institutes do not direct its Websites or Apps to, nor does it knowingly collect any personal information from visitors under the age of thirteen. In the event that we learn that we have collected personal information from a child under age thirteen without verification of parental consent, we will use reasonable efforts to remove such information from the files of such Website or App.

THE INSTITUTES COMMUNITY AND OTHER PUBLIC FORUMS

Any information you may disclose on our Websites or Apps, in blogs, on The Institutes Community, on message boards, in chat rooms, creating Community profiles or on other public areas on a Website, App, or other third-party website that the Website or App may link to, becomes public information. When you use these features, you should be aware that any information you submit, including your name, location, and email address, may be publicly available to others. Please exercise caution when disclosing personal information in these public areas. We reserve the right to remove any posting or content in a posting at our sole discretion. We are not responsible for any information you choose to submit through these interactive features, and we strongly discourage you from disclosing any sensitive personal data (such as health or credit card information) through these features. If you use these features, your personal data may remain on the Website even after you cease use of the Website. You further agree to abide by the terms provided in The Institutes’ Guidelines.

Third-Party Content, Links to other websites and Plug-ins

The Services and Websites contain links to other websites not owned by The Institutes or their subsidiaries and affiliates. This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or service to which the Services or Websites link. The inclusion of a link on the Services or Websites does not imply our endorsement of the linked site or service. We are not responsible for the privacy practices of those or any other sites. If you have questions about how those websites collect and use data, you should carefully read those sites’ privacy policies.

This site may also offer you the ability to interact with social plug-ins from social media sites, such as Facebook (Facebook.com), LinkedIn (LinkedIn.com), and Twitter (Twitter.com). The social media sites may receive data when you visit a website—such as www.Insurance-Research.org—that has plug-ins. In some cases, The Institutes may know that you clicked on a social plug-in, such as a Facebook Like button, or received other information from the social media sites. Similarly, if you have previously provided personal data to a third party operating a plug-in on this website, then this third party may recognize you on this website. Your use of social network plug-ins is subject to each social media site’s privacy policy, which may be different from ours, so please read these policies carefully to understand them and your options. As with linked sites, The Institutes have no control over the information that is collected, stored, or used by social network plug-ins.

DATA SECURITY

We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about our members, students, members, customers and Website and App visitors. While we make every reasonable effort to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures. When you enter sensitive information (such as credit card information) on our forms, we encrypt the transmission of that information using secure socket layer technology (SSL). If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section below.

DATA STORAGE

Your personal information may be stored on servers in the United States and is subject to the laws of the United States, where the data protection and other laws may differ from those of other countries. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the countries in which we operate.

Updates to This Privacy Policy

Because of the changing nature of privacy laws, user needs, and our business, The Institutes reserves the right, at its sole discretion, to change, modify, add, remove, or otherwise revises portions of this Privacy Policy at any time. If changes are made, we will put a notice on the Website or App, and if it is a material change, we will notify you directly (for example, via email). You can determine when this Privacy Policy was last revised by referring to the date on which it took effect, as indicated above. Your continued use of our Services, the Website or App following the posting of changes to these terms means you accept these changes.

Contact Us

If you have questions concerning this Privacy Policy, please email us at [email protected] or call us at (800) 644-2101 (U.S. and Canada) or (800) 644-2100 (outside the U.S. and Canada). Because email communications are not always secure, please do not include credit card information or sensitive information in your emails to us