DEMENTIA REALITY PRIVACY POLICY

January 10, 2024:

Dementia Reality, LLC (“Dementia Reality”, “us,” “we” or “our”) has created this Privacy Policy (this “Policy”) in compliance with applicable laws and in order to demonstrate our firm commitment to privacy. This Policy describes how we collect, use, disclose, transfer, store, retain, or otherwise process your information when you (whether in your individual or business capacity) access or use, in any manner, any of our content, products, services, or related activities (collectively “Services”), including through the Internet domain dementiareality.org and all sub-domains (the “Website” or “Site”).

Dementia Reality is a not-for-profit, tax exempt 501(c)(3) entity. We are operated through a partnership between CJE SeniorLife (“CJE”) and Elderwerks Educational Services (“Elderwerks”). 

When we refer to “we,” “us,” or “our,” we mean Dementia Reality. When we refer to “you” or “your,” we mean the person accessing the Website or engaging our Services. If the person interacting with Dementia Reality does so on behalf of, or for the purposes of, another person, including a business or other organization, “you” or “your” also means that other person, including a business organization.

Please read this Policy carefully. By continuing to interact with our Services and our Website, you are consenting to the practices described in this Policy.

Our Policy includes:

 

  1. General Disclosures
  2. What Information We Collect And For What Purposes
  3. To Whom Do We Disclose Your Information?
  4. How Long We Retain Your Information
  5. Personal Information Relating To Children
  6. Linking Sites
  7. Security
  8. Changes To This Privacy Policy
  9. Cookie Policy

 

GENERAL DISCLOSURES

This Policy only discloses our privacy practices. It does not apply to the practices of other entities or organizations and you should always review the privacy practices of every entity with whom you provide your information. For example, you may engage with our Services through virtual reality headsets provided by companies such as Meta. Meta may collect your information through the use of their products and services, which will be subject to Meta’s privacy practices. Dementia Reality has no control over Meta’s privacy practices and this Policy does not describe Meta’s privacy practices. Similarly, if our products and Services are provided to you through a licensed third-party, such as a master trainer or your employer, your information will be subject to the privacy practices of that third-party, and not Dementia Reality.

We take your privacy and the protection of your personal information seriously. We will only store, process and disclose your personal information in accordance with applicable law.

WHAT INFORMATION WE COLLECT AND FOR WHAT PURPOSES

What information we collect and the purposes for which it is collected will depend on the context of how you interact with us. Therefore, just because this Policy lists a particular data collection practice does not mean that we have necessarily collected that data from you. Instead, please review the applicable disclosures below to learn about how we may have collected personal information from you depending on how you have interacted with us. We generally use your information for the proper and lawful administration and operation of our organization, including to provide our products, Services and Website, to perform analytics, market our Services, and to communicate with you or our customers.

When you Visit Our Website

When you visit our Website, we will collect cookie, electronic and device information from you in order to administer and operate the Website. This will include your IP address, information about the device that you are using and cookie information. More information about cookies can be found in our Cookie Policy. We use this information to analyze how individuals interact with our Website, including examining what content or links individuals engage with. We also use this information to improve our Website, inform us about the types of individuals who visit our Website and in the development of new products and services.

If you elect to make any accessibility adjustments through our web accessibility plug-in, your adjustments will be tracked in the form of cookies stored on your device so that the Website can remember your adjustments the next time you visit the Website. We will only use this information for this purpose. More information about cookies can be found in our Cookie Policy.

You also have the option to provide your identity, contact and professional information to us in order to receive more information about our Services through our Website. We will use this information to contact you and provide you with additional information about our Services, which could include marketing-related communications.  

You also have the option to provide your log-in and password credentials to access an account that you maintain with us. We will use this information to contact you and maintain your or your employer’s account and business relationship with us.  

When You Participate or Engage With Our Services

Dementia Reality may collect different information from or about you depending on the manner in which you engage with our Services. For example, if you engage with our Services as:

  • A caregiver or provider receiving training through our products and Services.  We will collect and process your identity, contact and professional information as well as records of how you have engaged with our Services and our related products. This may be information in your professional or personal capacity, depending on how your engage with us. If you engage our Service in a personal capacity, we may collect related payment and account information from you. We will use this information to provide our Services to you or your employer and to administer and operate our organization, including in the improvement of our Services and the development of new products and services.
  • A representative of an entity licensing our products and Services.  We will collect and process your professional or business identification and contact information. We will use this information to facilitate our relationship with your employer or related entity and to administer and operate our organization.
  • A individual receiving training to provide related services to others.  We will collect and process your identity, contact and professional information as well as records of how you have engaged with our Services. We will use this information to provide our Services to you and to administer our certification program. We will also use this information to administer and operate our organization, including in the improvement of our Services and the development of new products and services.

  • Deidentified and Aggregated Information

We may process your personal information into aggregated, anonymized or de-identified form for any purpose. Aggregated, anonymized or de-identified information is information that can no longer reasonably identify a specific individual and is no longer “personal information.” 

TO WHOM DO WE DISCLOSE YOUR INFORMATION?

Generally, we disclose your information to other entities as is necessary for the proper administration and operation of our organization, Services and Website. We may disclose your personal information:

    • To our organizational service providers.  We may utilize a variety of service providers and vendors to facilitate our performance of the Services, such as our external communication vendors, website and software developers or our marketing vendors. With regards to the Website, Google Analytics receives information relating to your device and how you interact with our Website so that we can analyze how individuals interact with our Website.
  • To our database hosting vendors.  Like many organizations, we utilize cloud databases to host our data, including your personal information, so that we can effectively and safely operate the Website and perform our Services.
  • To our auditors.  We may be subject to audits from a number of entities as well as due to our own internal auditing policies. In order to accomplish an effective audit, we must provide information, which may include your personal information, to external auditors. We always ensure that your information is safely disclosed and stored and that auditors can only use your information for the purposes of completing an audit.
  • To individuals or entities you authorize.  We may disclose your personal information to individuals or entities at your direction.
  • Our affiliates.  We may share your personal information with our affiliates, such as CJE and Elderwerks.
  • To entities who operate links or plug-ins on our Website.  If you click a link or plug-in on our Website (like the Meta Facebook plugin), you may be re-directed to that third-party website. That third-party website may receive your online identifier and device information along with that referral. We are not responsible for the privacy practices of these third-parties (see the section titled Linking Sites for more information about links to third-party websites). We also utilize accessibility plug-ins from our Website accessibility providers.
  • In corporate transactions.  We may share all or part of your personal information with other entities in connection with the sale, assignment, merger or other transfer of all or a portion of our organization or assets to such entities (including due to a sale in connection with a bankruptcy). We will require any such purchaser, assignee or other successor organization to honor the terms of this Policy.
  • For legal purposes.  We may disclose all or part of your personal information to courts, litigants, regulators, arbitrators, administrative bodies or law enforcement when we have reason to believe that disclosing this information is necessary to resolve actual or suspected claims. We may also disclose your personal information in order to identify, contact or bring legal action against someone who may be violating any agreement with us, or may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of the Website, or anyone else that could be harmed by such activities. We may disclose information in response to a subpoena, search warrant, in connection with judicial proceedings, or pursuant to court orders, legal process or other law enforcement measures. 

 

HOW LONG WE RETAIN YOUR INFORMATION

We generally retain your information as long as reasonably necessary to provide you the Services or to comply with applicable law and in accordance with our data retention practices. We may retain copies of information about you and any transactions or Services you have used for a period of time that is consistent with applicable law, applicable statutes of limitations, or as we believe is reasonably necessary to comply with applicable law, regulation, legal process or governmental request, to detect or prevent fraud, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce other applicable agreements, or policies or to take any other actions consistent with applicable law. Cookies are stored on your own device. You can find out more information about the retention of cookies in our Cookie Policy.

PERSONAL INFORMATION RELATING TO CHILDREN

The Children’s Online Privacy and Protection Act (COPPA) regulates online collection of information from persons under the age of 13. It is our policy to refrain from knowingly collecting or maintaining personal information relating to any person under the age of 16. If you are under the age of 16, please do not supply any personal information through the Website. If you are under the age of 16 and have already provided personal information through the Website, please have your parent or guardian contact us immediately using the information provided under Contact Us so that we can remove such information from our files. Please delete all Dementia Reality related cookies and restrict further collection of cookies using the methods outlined in the section How to Restrict Cookies in our Cookie Policy.

LINKING SITES

This Policy applies only to our Website, and not to other companies’ or organizations’ websites to which we link from our Website. Dementia Reality is not responsible for the privacy practices or the content of such websites or organizations, including any websites that may indicate a special relationship or partnership with us (such as co-branded pages or “powered by” or “in cooperation with” relationships). Other linked websites may collect personal information from you that is not subject to our control. To ensure protection of your privacy, always review the privacy policy of the websites you may visit by linking from our Website.  

SECURITY

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. We hold information about you at our own premises and with the assistance of service providers. Further public disclosure here of our security measures could aid those who might attempt to circumvent those security measures. If you have additional questions regarding security, please contact us directly using the information provided under Contact Us.

CHANGES TO THIS PRIVACY POLICY

We may amend this Policy at any time by posting revisions on our Website. If we make any material changes in the way we collect or process your personal information, we will notify you by prominently posting notice of the changes on our Website.

CONTACT US

Please contact Dementia Reality with any questions or concerns regarding this Privacy Policy:

If you have any questions or concerns regarding our Policy, or if you believe our Policy or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with Dementia Reality using the contact information listed above, and we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We may keep records of your request and any resolution.

COOKIE POLICY

Like many website operators, Dementia Reality and its analytics vendors use server logs and automated data collection tools, such as browser cookies, pixel tags, scripts and web beacons. These tools are used for analytics purposes to enable us to understand how users interact with our Website. Dementia Reality and our analytics vendors may tie the information gathered by these means to the identity of users.

What is a Cookie?

A cookie is a small text file that is placed on your hard drive by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you.  There are several types of cookies:

  • Session cookies provide information about how a website is used during a single browser session while a user is visiting a website. Session cookies usually expire after the browser is closed.
  • Persistent cookies remain on your device between different browser sessions for a set amount of time in order to enable the website to remember user preferences, settings, or actions across other sites. A persistent cookie will remain on a user’s device for a set period of time specified in the cookie.
  • First-party cookies are cookies set by the operator of the website you are visiting.
  • Third-party cookies are cookies set by third parties that are different from the operator website you are visiting. 
  • Web beacons, tags and scripts may be used in the Website or in our emails to help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. More information about each cookie can be found by viewing our current cookie table below, which is updated periodically.

 

Our Collection of Cookies

We and our analytics service providers use cookies and other similar technologies. We group the cookies that we collect into the following categories based upon their function (note that all types of cookies, as described above, will be found in each category):

Category Description
Essential Cookies Essential cookies are sometimes called “strictly necessary” as without them we cannot operate and administer the Website. For example, essential cookies help remember your preferences as you move around the Website.
Analytics Cookies These cookies track information about visits to the Website so that we can make improvements and report our performance. For example: analyze visitor and user behavior so as to provide more relevant content or suggest certain activities. They collect information about how visitors use the Website, which site the user came from, the number of each user’s visits and how long a user stays on the Website. We might also use analytics cookies to test features to see how users react to them.
Functionality or Preference Cookies During your visit to the Website, cookies are used to remember information you have entered or choices you make (such as your accessibility preferences) on the Website. They also store your preferences when personalizing the Website to optimize your use of the Website, for example, your preferred language. These preferences are remembered, through the use of the persistent cookies, and the next time you visit the Website you will not have to set them again.

Third-party cookies

The Website allows third-parties to place cookies on your Internet-connected device in order to provide interoperability and plug-ins from various social media websites (like YouTube and Meta). 

Do Not Track

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking across websites. Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a website should respond to this signal, so we do not take any action in response to this signal. Dementia Reality does not have a mechanism in place to respond to DNT signals. Instead, in addition to publicly available external tools, we offer you the choices described in this Cookie Policy to manage the collection and use of information about you.

How to Restrict Cookies

You can adjust the settings in your browser in order to restrict or block cookies that are set by the Website (or any other website on the Internet). Your browser may include information on how to adjust your settings. Alternatively, you may visit the U.S. Federal Trade Commission’s website www.consumer.ftc.gov to obtain comprehensive general information about cookies and how to adjust the cookie settings on various browsers. 

You can control and delete these cookies through your browser settings through the following:

Or you can also use the following cookie management and disposal tool from Google Analytics by downloading and installing the browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout.

Please be aware that restricting cookies may impact the functionality of the Website. For example, refusing cookies will not allow Dementia Reality to remember your accessibility adjustments. Additional general information about cookies, including how to be notified about the placement of new cookies and how to disable cookies, can be found at www.allaboutcookies.org.

Changes to this policy

If there are any material changes to this Policy, you will be notified by the posting of a prominent notice on our Website. We encourage you to periodically review this page for the latest information on the Policy. Your continued use of the Websites constitutes your agreement to be bound by such changes to this Policy. The content of this Policy is for your general information and use only. These cookies are subject to change without notice.