Collection of Your Information
Using the RegEd Services
When you access any of the RegEd Services using the internet, the Services automatically collect Device Information and other information about how you and your device interact with the Services, including:
- Computer, device and connection information, such as IP address, browser type and version, operating system and other software installed on your device, mobile platform and unique device identifier and other technical identifiers, error reports and performance data; and/or
- Usage data, such as the features you used, the settings you selected, URL click stream data, including date and time stamp, and referring and exit pages, and pages you visited or searched for on the Service.
When you log into an Application, or you access a RegEd website either directly or through a link provided to you from another website, or register for a RegEd event (webinar, conference), depending upon the transaction in which you engage, you may be requested to provide us with your personal information, such as your name, social security number, CRD number, license number, mailing address, email address and, in some cases, your credit card information, employment information and other information about your background or history, or where applicable, your IP address). You may also send us your Personal Information in an email, by mail or facsimile transmission, or provide it during a telephone conversation. If you visit our offices, you may be required to register as a visitor and to provide your name, email address, phone number, company name and time and date of arrival.
Receipt of Personal Information from RegEd Clients
If you are employed by or associated with an organization that uses one or more of our Services (each, a “Client” and collectively, our “Clients”), our Clients may provide us with your Personal Information, or we may obtain and/or share your Personal Information from a regulator or other third party from which the Client has requested us to obtain your Personal Information. Such third parties may include social media networks, partners with which we offer co-branded services or whose services we resell, or parties with whom we engage in joint marketing activities.
Personal Information from Third Party Services
We also may collect data or information about you from the following:
- Our service providers that help us determine a location based on your IP address;
- Partners with which we engage for co-branded services, for whom we re-sell services, in joint marketing agreements or in event sponsorship and hosting;
- Social networks when you or your employer grants us permission to access your data on one or more networks; and/or
- Publicly-available sources and data suppliers from which we obtain data to process or supplement the information we hold.
When you visit our websites or use our Services, we or an authorized third party may place a cookie on your browser, which cookie collects information, including Personal Information, about your online activities over time and across different sites. Cookies allow us to track overall usage, determine your browsing preferences and improve and customize your browsing experience.
We also use web beacons on our websites and in email communications. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to one of our websites. Such technologies are used to operate and improve our websites and email communications.
Below are the different types of cookies that may be used in the Services. To the extent any Personal Information is collected through cookies, the RegEd Privacy Notice [insert URL] governs and compliments this Cookies Policy.
Strictly Necessary Cookies. These cookies enable you to navigate the Sites and to use their services and features. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as logging in or filling in forms. Without these cookies, Services you have asked for, like providing you with an online exam, cannot be provided. You can set your browser to block or alert you about these cookies, but some parts of the site will not work. These cookies do not store any personally identifiable information.
|Cookie Name||Description of Purpose||Expiration||1st / 3rdParty|
|JSESSIONID…||Trax Application session identifier||Session||1st Party|
|…masterSessionId||Trax Session identifier||Session||1st Party|
|…loginRepId||Trax Session identifier||Session||1st Party|
|Tracks authentication token for CODE
|cklDNAME||Xchange persistent cookie: stores User ID if user chooses to save||Persistent||1st Party|
|Xchange session cookie for Classic ASP||Session||1st Party|
|ASPSESSIONIDQCAQRTSQ||Xchange session cookie for 3.5/MVC application
|BIGipServerxchange||Xchange F5 Session Tracking||Session||3rd Party|
|exchangecookie||Xchange classic ASP session cookie||Session||1st Party|
|CE (KLZIBVIMLKMNKVKBVKXKJKDGKLKHYIBIIKTXGNKLXAIQIQUZDKPKCKAWIEKLKDHBIAYKLKXIDYIBKHKHKBKMKDKLLKNJ)||Xchange CE session cookie||Session||1st Party|
|ekit (KLZIBVIMLKMNKVKBVKXKJKDGKLKHYIBIIKTXGVKRKAXRKCUZDKPKCKAWIEKLKDHBIAYKLKXIDYIBKHKHKBKMKDKLLKNJ)||Xchange ekit session cookie||Session||1st Party|
|SECURITIES (IMLKMNKVKBVKXKJKDGKLKHYIBIIKTXHNKLYICVKYKAXRKPZXNKCUZDKPKCKAWIEKLKDHBIAYKLKXIDYIBKHKHKBKMKDKLLKNJKLZIBV)||Xchange profile session cookie||Session||1st Party|
|update (ZIBVIMLKMNKVKBVKXKJKDGKLKHYIBIIKTXHVKWZGF0ZVKWIQUZDKPKCKAWIEKLKDHBIAYKLKXIDYIBKHKHKBKMKDKLLKNJKL)||Xchange Update area session cookie||Session||1st Party|
|ff (KLZIBVIMLKMNKVKBVKXKJKDGKLKHYIBIIKTXGZKMXAIQIQUZDKPKCKAWIEKLKDHBIAYKLKXIDYIBKHKHKBKMKDKLLKNJ)||Xchange FF area session cookie||Session||1st Party|
|break (IBVIMLKMNKVKBVKXKJKDGKLKHYIBIIKTXGJKYZWFKRXAIQIQUZDKPKCKAWIEKLKDHBIAYKLKXIDYIBKHKHKBKMKDKLLKNJKLZ)||Xchange break area session cookie||Session||1st Party|
|sri2 (KLZIBVIMLKMNKVKBVKXKJKDGKLKHYIBIIKTXHNKYKATJKCUZDKPKCKAWIEKLKDHBIAYKLKXIDYIBKHKHKBKMKDKLLKNJ)||Xchange SRI2 area session cookie||Session||1st Party|
|pinit & XDB(BVIMLKMNKVKBVKXKJKDGKLKHYIBIIKTXHBKPKBKMKL0XAIQIQUZDKPKCKAWIEKLKDHBIAYKLKXIDYIBKHKHKBKMKDKLLKNJKLZI)||Xchange PINIT & XDB area session cookie||Session||1st Party|
|OT (KLZIBVIMLKMNKVKBVKXKJKDGKLKHYIBIIKTXGII0XAIQIQUZDKPKCKAWIEKLKDHBIAYKLKXIDYIBKHKHKBKMKDKLLKNJ)||Xchange OT area v||Session||1st Party|
|PDB (LZIBVIMLKMNKVKBVKXKJKDGKLKHYIBIIKTXHBIMYKLKWIQUZDKPKCKAWIEKLKDHBIAYKLKXIDYIBKHKHKBKMKDKLLKNJK)||Xchange PDB area session cookie||Session||1st Party|
|Email maintenance (KJKDGKLKHYIBIIKTXGVKTYWKLKSKDGVIDKDGIAKHKAWIE0ZWIEKHKBKMNKLXAIQIQUZDKPKCKAWIEKLKDHBIAYKLKXIDYIBKHKHKBKMKDKLLKNJKLZIBVIMLKMNKVKBVKX)||Xchange Email Maintenance area session cookie||Session||1st Party|
|Forms repository (BVKXKJKDGKLKHYIBIIKTXGZKVKCKMIAKZKCKMVKWKBICNKPKDGIIKYKEVKWIQUZDKPKCKAWIEKLKDHBIAYKLKXIDYIBKHKHKBKMKDKLLKNJKLZIBVIMLKMNKVK)||Xchange forms repository area session cookie||Session||1st Party|
|XDB (LZIBVIMLKMNKVKBVKXKJKDGKLKHYIBIIKTXHKHIMYKLKWIQUZDKPKCKAWIEKLKDHBIAYKLKXIDYIBKHKHKBKMKDKLLKNJK)||Xchange XDB area session cookie||Session||1st Party|
|EXT_CtisAuthToken||Xchange CTIACOMNew area session authentication token||Session||1st Party|
|PHPSESSI||Arkovi PHP Session Cookie||Session||1st Party|
Performance Cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Services. They help us to know which pages are popular and see how visitors move around our websites. If you do not allow these cookies, we will be less able to optimize the Services’ performance. All information these cookies collect is aggregated and anonymous.
|Cookie Name||Description of Purpose||Expiration||1st / 3rd Party|
|Google Universal Analytics
Microsoft Application Insights
|These cookies are set by Google Universal Analytics. They are used to calculate visitor, session and campaign data for the RegEd websites’ analytics reports.
These cookies are set by Microsoft Application Insights. They are used to calculate visitor, session and campaign data for the RegEd websites’ analytics reports and for performance analytic support
|<1 hour – 2 years
Functional Cookies. These cookies enable the Services to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies some services may not function properly. These cookies do not directly store personal information, but are based on uniquely identifying your browser and internet device.
Pardot. Pardot tracks visitor activities on our website and landing pages by setting cookies on their browsers. Cookies are set to remember preferences (like form field values) when a visitor returns to our site. Pardot sets first-party cookies for tracking purposes, and sets third-party cookies for redundancy. Pardot cookies don’t store personally identifying information, only a unique identifier. Pardot sets a few kinds of cookies:
|Cookie Name||Description of Purpose|
|pi_opt_in||If Tracking Opt-in preferences is enabled, the pi_opt_in cookie is set with a true or false value when the visitor opts in or out of tracking. If a visitor opts in, the value is set to true, and the visitor is cookied and tracked. If the visitor opts out or ignores the opt-in banner, the opt-in cookie value is set to false. The visitor cookie is disabled, and the visitor is not tracked.|
|visitor_id||The visitor cookie includes a unique visitor ID and the unique identifier for your account. For example, the cookie name visitor_id12345 stores the visitor ID 1010101010. The account identifier, 12345, makes sure that the visitor is tracked on the correct Pardot account. The visitor value is the visitor_id in your Pardot account. This cookie is set for visitors by the Pardot tracking code.|
|visitor_id-hash||The visitor hash cookie contains the account ID and stores a unique hash. For example, the cookie name visitor_id12345-hash stores the hash “855c3697d9979e78ac404c4ba2c66533”, and the account ID is 12345. This cookie is a security measure to make sure that a malicious user can’t fake a visitor from Pardot and access corresponding prospect information.|
||This LPV cookie is set to keep Pardot from tracking multiple page views on a single asset over a 30-minute session. For example, if a visitor reloads a landing page several times over a 30-minute period, this cookie keeps each reload from being tracked as a page view.|
|pardot||A session cookie named pardot is set in your browser while you’re logged in to Pardot as a user or when a visitor accesses a form, landing page, or page with Pardot tracking code. The cookie denotes an active session and isn’t used for tracking.|
How do we use and/or share your Personal Information with third parties?
Your Personal Information may be used and shared in the following ways:
- For the specific purpose for which your Personal Information is provided to us by you or by our Clients, such as
- to provide you with information or notifications related to our Services or events,
- to submit forms about you to insurance carriers to enable you to do business for them,
- to obtain background investigation results for purposes of obtaining licensing or appointments for you,
- to enable you to use services provided by our partners or third parties with whom our applications exchange information on your behalf, or
- to obtain information from or make certifications or other filings on your behalf with state insurance regulatory agencies or their designees, the National Insurance Producer Registry Gateway, FINRA, and similar entities (collectively, “Regulators”). In addition, we provide your Personal Information to Regulators as necessary to test or monitor our transactions with them.
- Your Personal Information may also be accessed by any person or company authorized by any of the foregoing entities to access your Personal Information.
- If you are employed by or associated with one or more of our Clients, if you have attended a continuing education course provided by one of our Clients, or you have completed an online course offered by one of our Clients, or you have redeemed a coupon or voucher you have received from one of our Clients, to allow such Client(s) to view and administer your Personal Information, the status of its requests of us or the status or your use of our Services. Your Personal Information may also be accessed by any person or company authorized by such Client(s) to access your Personal Information.
- To provide you with information via email, mail or telephone regarding your transactions with us, your usage of our Applications, Products and Services or transactions with the third parties noted above on your behalf, or to contact you with information that may be of use or interest to you.
- To provide or enhance our Services or to develop new ones. We may also use unaffiliated companies to perform services on our behalf, such as printing and shipping, managed hosting services, email services, software testing and development, processing services, customer relationship management services and other services to facilitate our business and the provision of Services to you. These other companies may be supplied with or have access to your Personal Information solely for the purpose of providing these services to us or on our behalf, and directly or indirectly, to you.
Security of your Personal Information
RegEd employs a variety of security technologies, policies and procedures that are reasonably designed to protect your Personal Information from unauthorized access, use or disclosure. RegEd has implemented commercially reasonable security technologies on the network, server, and application level. RegEd utilizes secure (“SSL”) connections and commercially reasonable encryption policies designed to protect against the loss, misuse and alteration of your Personal Information during transmission. We cannot, however, control the manner in which your Personal Information is transmitted to us, either by you, a third party acting on your behalf or by one of our Clients, or the manner in which a Regulator may require disclosure of your Personal Information to them.
We retain your personal information for as long as necessary to provide the Service and fulfill the transactions you have requested, and for other essential purposes such as complying with our legal or regulatory obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements.
We do not knowingly collect information from children under the age of 13 or target any of our Services to children under 13.
Locations of Processing
Your personal information will be stored and processed in the United States.
Grounds for Processing
When we collect directly from you any Personal Information that is subject to the European data protection laws, we do so (a) with your consent; (b) where necessary to provide the Service, fulfill a transaction or otherwise perform a contract with you or at your request prior to entering into a contract; (c) where necessary for our compliance with a legal obligation; (d) where necessary for the performance of a task carried out in the public interest; and/or (e) as necessary to fulfill our legitimate interests as described below, except where our interests are overridden by your privacy rights. Where we rely on your consent to process personal information, you have the right to withdraw your consent at any time, and where we rely on legitimate interests, you have the right to object.
Our legitimate interests are: to deliver our Applications and Services to our Clients and their end users; to detect or prevent fraud; to protect the security of our systems, and the data of our Clients and end users; to further develop our Applications and Services; to conduct marketing; to operate our business (by processing payments/invoices, perform sales activities and vendor management, manage our Clients’ and their end users’ accounts); to enable our Clients to comply with their legal obligations; or fulfil our other legitimate interests as described above.
Your Rights Regarding Your Personal Information
You have certain rights relating to your Personal Information, subject to local data protection laws. Depending on the applicable laws and, in particular, if you are located in the EEA, these rights may include:
- To access your Personal Information that we hold;
- To rectify inaccurate Personal Information and, taking into account the purpose of processing the Personal Data, ensure it is complete;
- To erase/delete your Personal Information, to the extent permitted by applicable law;
- To restrict our processing of your Personal Data, to the extent permitted by applicable law;
- To transfer your Personal Data to another controller, to the extent possible;
- To object to any processing of your Personal Data carried out on the basis of our legitimate interests;
- Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects. Automated Decision-Making currently does not occur in our Services; and
- To the extent we base the collection, processing and sharing of your Personal Infomration on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.
If you are a resident of California, under the age of 18 and have registered for an account with us, you may ask us to remove content or information that you have posted to our websites. Please note that your request does not ensure complete or comprehensive removal of the content or information, because, for example, some of your content may have been reposted by another visitor to our websites.
Please contact us at the address set forth below if you wish to exercise any of the foregoing rights. We will respond to your request consistent with applicable law, and may require verification of your identity to protect your privacy and the security of your data. However, we primarily process Personal Information in the role of a processor. If your data has been submitted to us by a Client and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable Client directly. Because we may only modify a Client’s data upon instruction from that Client, if you wish to make your request directly to us, please provide to us the name of the Client who submitted your data to us. We will refer your request to that Client, and will support them as needed in responding to your request within a reasonable timeframe.
Reviewing and Updating Your Personal Information
If you are an end user (e.g., employee, administrator, registered representative associated with or an independent agent) of one of our Clients, please contact the applicable Client’s compliance, licensing or registration department for the purpose of accessing and correcting data about you. If you have used our Applications by logging in directly, you may access and correct your data by logging into the Application and following directions for updating and/or correcting your information or by contacting us via email at info@RegEd.com, or as set forth below. Any revisions you provide to your Personal Information will be applied in our own records but may not be updated in the records of the third parties to which we have provided your data at your request, and, if you are and end user that is employed by, associated with or an independent contractor of one of our Clients, may be overwritten by data that is provided by such Client to us. If you would like to review and correct the Personal Information that has been provided to these other entities, you will need to contact them directly.
2100 Gateway Centre Blvd., Suite 200
Morrisville, NC 27560
We hope that we can resolve any query or concern you raise about our use of your information, and you may also raise any complaint with the applicable data protection regulator.
Revised: March 29, 2019