The following statement discloses the consumer privacy policy of Commercial Institute as of January 1, 2003. As a convenience, we have organized our policy in an easy-to-follow question and answer format.


What is your policy in a nutshell?
What information do you collect and how? And why do you need it?
Do you ever disclose my email or information to outside parties?
How do you use my email?
Do I have a choice to "opt out" of email messages?
Can I ask you to delete all of my information?
How do you protect my information? Is it secure?
What about cookies?
Does your privacy policy ever change?
I've got questions or objections. Who will address my concerns?


Q: What is your policy in a nutshell?

A: We do not disclose your personal information to solicitors, and we do not use it without your prior knowledge and consent.

The only outside parties that would ever receive your personal information are: (1) State Real Estate Regulators, to authorize continuing education credit; (2) Payment Processors, to validate payment for a course by credit card; and (3) parties authorized by U.S. law or legal order to access your personal information.

If you enroll in a continuing education course, we do require that you receive certain administrative communications via email, like copies of invoices and forgotten password reminders. However, you can easily opt out of non-administrative emails, like notices of changes in state educational requirements.

Q: What information do you collect and how? And why do you need it?

A: We only collect information that is essential for our operations and your approval for continuing education credit from state real estate regulators. This information is as follows:

• Personal Enrollment Data, including information used by state real estate regulators to verify your identify, contact information, email, account password, etc. This information is collected when you complete our enrollment form. It is required to process your continuing education credit, login to your courses, and receive important communications.
  
• Order Data, including credit card validation data, courses ordered, promotional codes, etc. This information is collected when you complete our secure order form. Most of this information -- particularly credit card information -- is discarded immediately after your order has been approved by our payment processor, Innovative Merchant Solutions (Intuit); this information is never stored to our file or database systems. However, Innovative Merchant Solutions (Intuit), may maintain some record of your purchase on its secure servers for security and accounting purposes. A record of the courses you have ordered will be kept in our database and associated with your personal information; this is necessary to track your progress on incomplete courses, and to review your course and order history. Some state real estate regulators may also require us to archive your course and order history for some period of time after your receipt of continuing education credit.
  
• Technical Data, including information about your point of origin on the Internet (or so-called "IP" address), browser capabilities, pages viewed, etc. This information is collected automatically by our computer systems when you visit our web site. It helps us improve our system and monitor security issues. With the exception of your IP address, which is logged when you place an order on our site, technical information is not routinely associated with your personal data.

Q: Do you ever disclose my email or information to outside parties?

A: We do not allow any outside parties to see or use your information except: (1) State Real Estate Regulators, so they may authorize continuing education credit; (2) Our payment processor, Innovative Merchant Solutions (Intuit), so it may validate your credit card transaction; and (3) those parties authorized by U.S. law or legal order to access your information. State regulators and our payment processor do not currently require disclosure of your email so your email address is not currently disclosed to any party outside of Commercial Institute.

Q: How do you use my email?

A: We use your email to send two types of messages; administrative, and non-administrative messages.

Administrative messages are essential messages relating to specific courses you are taking, billing issues, correspondence with Commercial Institute staff, operational issues related to our web site, etc. You are required to receive these essential messages as a condition of taking our courses and engaging our services. Examples of these messages include copies of invoices/receipts, lost password reminders, warnings when incomplete courses are about to expire, responses to course evaluations and support inquiries, operational notices, etc.

Non-administrative messages are helpful, and often important, notices that are not required for a specific course or the operation of our school. Examples of non-administrative messages include notices of approaching credit deadlines, changes in state requirements, special discounts available to specific real estate companies and professional organizations, etc. You can always opt not to receive non-administrative messages.

Q: Do I have a choice to "opt out" of email messages?

A: You can always use your preferences to opt not to receive non-administrative, yet often important, messages, like approaching deadlines and changes in state requirements. However, we do require, as a condition of taking our courses and engaging our services, that you receive certain essential administrative messages by email. These messages include copies of invoices/receipts, lost password reminders, warnings when incomplete courses are about to expire, correspondence from Commercial Institute staff, etc.

Q: Can I ask you to delete all of my information?

A: If we are not required by state real estate regulators to archive certain information regarding previously completed courses, we will gladly remove all of your information from our computer databases. We will not "pass off" your information to other entities just before it is removed from our systems. Please contact us if you would like us to destroy your information. But be aware that if you destroy your information prior to completing a course or claiming credit all of your work will be lost.

Q: How do you protect my information? Is it secure?

A:We have taken technical and procedural steps to protect your personal information from unauthorized access, disclosure, misuse, and loss. For example, to avert certain security issues we simply do not store sensitive information, like credit card and banking information, and complete social security numbers. We also make sure that your financial transaction with our credit card payment processor is protected with 128-bit Secure Sockets Layer encryption. We avoid the publication of client lists and other information that might reveal your email address, phone number, or mailing address. We have made reasonable efforts to insure our servers and network infrastructure are protected from intruders; this includes application of current software updates, defensive network configurations, and other physical and logical security measures.

Q: What about cookies?

A: Commercial Institute uses temporary, session-only, cookies. These cookies are not stored on your computer hard drive and go away when you close your browser. Our cookies contain randomly generated codes that help our computers track your computer session as you move from one page to the next on our web site and in our courses. These randomly generated codes are not associated with any personal information. Please see our cookie information page for more information on how cookies work, how they are used, and how you can configure them.

Q: Does your privacy policy ever change?

A: We will attempt to keep changes to our policy to a minimum. But from time to time we may need to alter our policy to accommodate new consumer protection standards and guidelines, and to reflect changes in our business. These changes may be made without notice, so please check back periodically if you want to see our newest privacy policy.

Q: I've got questions or objections. Who will address my problems?

A: If you believe we are not conforming to our privacy policy or that our policy is somehow flawed (or even if you need clarification) please contact us immediately and our staff will gladly address your questions as soon as possible.