Privacy Policy

Last updated: September 26. 2026

1. Scope of This Policy

This Privacy Policy explains how Sunrise International Education Inc., doing business as Reality Ready Training ("RRT," "360Works," "we," "us," or "our"), collects, uses, shares, and protects information in connection with the 360Works platform. The platform includes our marketing website (360works.org) and our course-builder, delivery, and administration application (app.360works.org), together with any related services we provide (collectively, the "Services").

360Works is a business-to-business platform. Our direct customers are universities, enterprises, associations, and other organizations ("Clients") that use 360Works to build and deliver training. The employees, students, or members of a Client who take that training are "Learners." This policy describes our practices toward Clients, Learners, and visitors to our website, and distinguishes between information we control directly and information we process on a Client's behalf.

This policy does not apply to third-party websites or services that may be linked from the Services.

2. Information We Collect

2.1 Information You Provide to Us

  • Contact and demo requests: name, email, company, phone number, and message content submitted through our contact form or when booking a call.

  • Account information: name, work email, organization, role, and login credentials when you or your organization create an account on app.360works.org. Passwords are stored in a secured, non-readable form.

  • Billing information: billing contact details and payment information. Payments are processed by our third-party payment processor, and we do not store full payment card numbers.

  • Communications: any information you send us by email, through support requests, or during a call.

2.2 Information Collected Automatically

  • Usage data: pages visited, features used, time spent, referring URLs, and general interaction patterns within the Services.

  • Device and log data: IP address, browser type, operating system, and device identifiers.

  • Cookies and similar technologies: as described in Section 6 (Cookies and Tracking).

3. Client Content and Learner Data

3.1 Client Content

Clients upload their own training materials to the Services, such as 360° video, standard video, images, 3D models, documents, and text. This content may depict real locations, facilities, equipment, or individuals. Clients are responsible for having the necessary rights and consents to upload and use this content, including consent from any identifiable individuals who appear in it.

3.2 Learner Data

As Learners use the Services, we process the following information on the Client's behalf:

  • Learner name and email address, as provided by the Client

  • Course progress and activity

  • Quiz and assessment results

  • Completion status

  • Where a course includes LiveOps remote-assistance sessions, session recordings, which may include audio and video

Where LiveOps sessions are recorded, the Client is responsible for providing any notice to, and obtaining any consent from, participants that applicable law requires.

3.3 Our Role

For Client content and Learner data, the Client is the data controller and 360Works acts as a data processor (or "service provider" under the California Consumer Privacy Act and similar U.S. state laws). We process this information only on the Client's instructions and as needed to provide the Services, and we do not use it for our own marketing purposes. Our handling of this information is also governed by our agreement with the Client.

Learners with questions about how their information is used should contact their organization directly. We will support the Client in responding to Learner requests where required.

4. How We Use Information

We use the information described above to:

  • Provide, operate, and maintain the Services, including course building, course delivery, and LiveOps sessions

  • Respond to inquiries, demo requests, and support questions

  • Process transactions and manage Client accounts

  • Generate the analytics and completion reporting Clients rely on, such as completion rates, assessment scores, and time-to-competency

  • Improve and develop the Services

  • Send administrative communications and, where you have opted in, marketing communications about 360Works

  • Detect, prevent, and address security incidents, fraud, or misuse

  • Comply with legal obligations

5. How We Share Information

We do not sell personal information. We share information only in the following circumstances:

  • With the relevant Client: a Learner's progress, assessment, and completion data is shared with the organization that assigned the training.

  • With systems a Client designates: where a Client connects 360Works to its own learning management system (LMS), learning record store (LRS), or similar system (for example, through SCORM or xAPI), we send Learner activity data to that system at the Client's direction.

  • Service providers: vendors who help us operate the Services, such as hosting, scheduling, form processing, analytics, customer support, and payment processing, who are bound by contractual confidentiality and data protection obligations.

  • Legal and safety reasons: where required by law, subpoena, or other legal process, or to protect the rights, property, or safety of RRT, our users, or others.

  • Business transfers: in connection with a merger, acquisition, financing, or sale of assets, subject to standard confidentiality protections.

  • With your consent: for any other purpose disclosed to you at the time we collect the information.

6. Cookies and Tracking

We and our service providers use cookies and similar technologies to operate the Services, remember preferences, and understand how visitors use our website. These may include analytics cookies, which help us understand site traffic, and functional cookies, which support features such as scheduling and forms. Some pages may also include embedded content from third parties, such as videos, which may set their own cookies under those providers' policies.

You can control cookies through your browser settings. Disabling certain cookies may affect how the Services function.

7. Third-Party Services

The Services use a limited number of third-party tools, each with its own privacy practices, including:

  • Calendly: scheduling demo calls

  • Wufoo: processing contact form submissions

We encourage you to review each provider's privacy policy for details on its data practices.

8. Data Security

We use administrative, technical, and physical safeguards designed to protect information against unauthorized access, alteration, disclosure, or destruction. These include encryption in transit, access controls, and role-based permissions within the platform. No method of transmission or storage is fully secure, and we cannot guarantee absolute security.

9. Data Retention

We retain personal information for as long as needed to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements. Learner and course data is generally retained for the duration of the Client's contract with us, plus a limited period afterward, unless the Client requests earlier deletion or a longer retention period is required by law. When information is no longer needed, we delete it or de-identify it.

10. Your Rights and Choices

Depending on where you live, you may have the right to access, correct, delete, or receive a copy of your personal information, and to object to or restrict certain processing. We may need to verify your identity before responding to a request, and we will not discriminate against you for exercising any of these rights.

  • Learners: please direct requests to your organization first, since it controls your data. We will assist your organization as needed.

  • Clients and website visitors: contact us using the details in Section 14.

  • Marketing emails: you can opt out at any time using the unsubscribe link in those emails.

11. Children's Privacy

The Services are intended for business use by adult professionals and, in educational settings, by university-level students. The Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has provided us with personal information, please contact us so we can address it.

12. International Users

We are based in the United States, and information we collect may be stored and processed in the United States or in other countries where our service providers operate. If you access the Services from outside the United States, your information may be transferred to, stored, and processed in a country whose data protection laws differ from those of your home country.

13. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will update the "Last updated" date at the top of this policy and, where appropriate, notify Clients directly. Your continued use of the Services after changes take effect means the updated policy applies.

14. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us:

Sunrise International Education Inc., d/b/a Reality Ready Training

259 Nassau St. #204, Princeton, NJ 08542-4609

Email: contact@360works.org

Preparing tomorrow's workforce, today.