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Privacy Policy – Evidence in Motion, LLC

Last Modified: May 26, 2020

INTRODUCTION

Evidence In Motion, LLC is an affiliate of, and subsidiary of, Confluent Health LLC (collectively, “EIM” or “we” or “us”). EIM provides educational programs relating to health care such as educational courses for specialty certifications, post-professional programs, and continuing education and manages hybrid academic programs (collectively, the “Programs”) for our University Partners (“UP”).

Because EIM values your privacy, we have created this Privacy Policy to explain how we collect information from and about you when you use our website and services (including the websites and applications associated with academic programs we manage for colleges and universities) and their features and services, whether appearing on a website, a mobile application, or any other device or technology (“EIM Technology”) and how we may disclose and use that information.

This Privacy Policy applies to EIM’s collection and use of personally identifiable information, which is information that can be used to identify or contact a specific person, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline as well as information which may be on your resume and results of courses in which you participate (collectively, “Personal Information”), as well as our practices for handling non-personally identifiable information, such as user preferences and services usage information.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to take any of our courses or use our services or our website. By accessing or using EIM Technology or our website, you agree to this privacy policy. This policy may change from time to time. Your continued use of our website or our services or taking any of our courses after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. If you do not agree with the terms of this Privacy Policy, please leave this site immediately and do not use or access EIM Technology.

COLLECTION OF INFORMATION

We collect information to provide services to all of our users and to improve our services. We limit the collection of information to only that which is necessary to carry out our legal or business obligations. We store the information we collect with unique identifiers tied to the browser, application, or device you’re using.

We may collect the following information from and about you:

  • First Name and Last Name
  • Email Address
  • Phone Number
  • Address
  • Program of Interest
  • Level of Education Attained
  • Whether or not you’ve taken an Admissions Exam
  • Years of work experience
  • Results of courses taken or Programs in which you have participated
  • Information from Social Media and Other Sites

As you may access our website with more than one device, we can track data from all devices that you use and aggregate it in your profile and elsewhere in our system.

You may have the option to access EIM Technology through a social network site (e.g., Facebook) or another third-party site (collectively, an “SNS”). If you access EIM Technology in this way, we may collect information about you from that service or site, which may include the username associated with the SNS, your name, profile picture or its URL, your user ID number (linked to publicly available information), the login email address provided to the SNS, your physical location and that of your access device, gender, birthday or friends lists, your likes, preferences, searches, comments and posts, where and when you stream or upload a video or other content to a third-party service such as Facebook or YouTube, and any other information or content of yours collected by that service or site. All information from and about you that is collected from an SNS or third-party site in this manner may be used and disclosed by EIM in accordance with this Privacy Policy. When you access our website through an SNS, such as Facebook, you allow us to access and import certain information from your profile for that SNS which may affect the privacy settings you establish on the SNS. You can find out more about the settings on the SNS. By entering our website through an SNS, you are authorizing us to collect, store, and use any information that the SNS provides to us through the SNS interface with our website. You agree to this when you “accept” or “allow” (or similar term) one of our applications on the SNS.

We may receive and store the information you provide, including your mobile telephone number, when you opt in to have SNS notifications or text messages sent directly to your mobile phone. If available, these messages notify you of events or other matters. You can adjust the types of notifications you receive and when you receive them by editing your SNS notification settings. If we use these and you no longer wish to receive SNS notifications or text messages from us, please contact us or click on the “opt out” link contained in a message received by you.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of our website, or transmitted to other users of our website or third parties, including teachers (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of our website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Application Data
Should you start an application for a Program, the application information may be collected by EIM or the UP. If collected directly by a UP, then the UP’s Privacy Policy applies to the collection of application data. The UP will share some or all of the application data with EIM; any data shared with EIM will be subject to our Privacy Policy and signing up for the course gives your permission to share such data with EIM. If the application information is collected by EIM, then we will share the application data with the UP and signing up for the course gives your permission to share such data with the UP.

Activity Information
When you access and interact with EIM Technology, we may collect certain information about those visits, such as your searches and preferences as well as technical information about your computer and its operating system, your internet browser, your internet protocol address, your navigation path (including your navigation on EIM Technology and the domain names of the sites from and to which you link), and other information about your software and hardware. If you access EIM Technology from a mobile or other device, we may collect certain information including the unique device identifier assigned to that device, geolocation data, your wireless service provider, operating system, browser type, and other transactional information for that device.

Cookies and California Do Not Track Disclosures
Cookies are small bits of data that a site or its service provider transfers to your computer through your browser that enables the site or service provider to recognize your browser and remember certain information about you. We may use cookies and other tracking technologies (such as pixel tags, ad tags, and web beacons) to collect information to help us understand your interactions with EIM Technology, such as pages you have visited, content you have viewed, search queries you have run, and advertisements you have seen. Third parties that support EIM Technology by serving advertisements or providing services, such as allowing you to share content or tracking aggregate usage statistics, (e.g., Google Analytics tracking and Google AdWords) may also use these technologies to collect similar information. EIM does not control these third-party technologies and their use is governed by the privacy policies of the third parties using such technologies. Your browser may permit you to disable these technologies.

If you would like to delete cookies or instruct your web browser to disable tracking please visit the help pages on your web browser. However, doing so may prevent you from using certain parts of EIM Technology. Please note that EIM does not respond to “Do Not Track” settings configured in your web browser.

Information from Other Sources
We may supplement the information we collect through EIM Technology and aggregate it with information from other sources, such as information that you submit to EIM directly by email, telephone, at trade shows, or other means (e.g., information you provide to EIM’s customer service team) and publicly available information from social media services, commercially available sources, and information from our affiliates or business partners.

USE AND DISCLOSURE
When information collected from or about you does not identify you as a specific person, EIM may use that information for any purpose or share it with third parties who may use it for any purpose. When information collected from or about you is personally identifiable, your Personal Information, EIM and our service providers may use and disclose that information in the following ways:

To provide and personalize the EIM Services
We use your Personal Information to provide our service and their features to you, including: to improve those services and their features; to personalize and to improve your experience with EIM Technology by delivering content you will find relevant and interesting, to provide you with customer support, and to respond to inquiries.

To provide you with customer support
EIM may share your Personal Information with the UP, who may contact you to provide you with more information about the Program, assist you with the application process, or answer your questions.

To share with the UP
EIM will share your Personal Information with the UP, who may use it:

To allow service providers to assist us in providing and managing our services
EIM may make your Personal Information available to certain third party service providers solely for the purpose of helping us with our business operations, such as data processing, website maintenance, and marketing and technology service providers.

To allow social sharing functionality
By logging in with or connecting your EIM Technology account with SNS or third-party site, you are authorizing us to share your Personal Information with the SNS or third-party site provider and other users and your friends on that service or site and you understand that use of such shared information by the SNS or third-party site provider will be governed by its privacy policy. If you do not want your Personal Information shared in this way, please do not connect your SNS or other third-party account with your EIM Technology account and do not participate in social sharing on the EIM Technology.

To deliver relevant information and advertisements
EIM and our service providers may use your Personal Information to deliver relevant information to you when you use EIM Technology or another service. As noted above, third-party networks may use cookies and similar technologies to collect and track information such as demographic information, inferred interests, aggregated information, and activity, including but not limited to information about your visits to websites to display advertisements more tailored to your interests and to provide you the most relevant advertising. If you wish to know more about this practice or would like to know more about your options, you can visit the Network Advertising Initiative (“NAI”) web-site. The NAI is a cooperative of online advertising companies who are committed to responsible practices and consumer protection.

To contact you
EIM may periodically send you promotional materials or notifications related to the Program or services. These emails are meant to be useful to you while helping us improve our user experience. However, if you want to stop receiving promotional materials, you can follow the unsubscribe instructions at the bottom of each email. If you want updates but prefer to keep your email inbox uncluttered, you should check out our Twitter feed and Facebook page. There are certain service notification emails that you may not opt-out of, such as notifications of changes to EIM Technology or policies.

To share with our EIM Affiliates
EIM may share your Personal Information with our affiliates for the purposes described in this Privacy Policy.

To protect the rights of EIM and others
There may be instances when EIM may disclose your information, including situations where EIM has a good faith belief that such disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of EIM; (ii) protect the safety, privacy, and security of users of EIM Technology or members of the public; (iii) in connection with a dispute or enforce EIM’s terms relating to our website or the Program; (iv) protect against fraud or for risk management purposes; (v) comply with the law or legal process; or (vi) respond to requests from public and government authorities.

To complete a merger or sale of assets
If EIM intends to sell all or part of its business or make a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, EIM may show your Personal Information to a potential buyer in connection with the buyer’s review of assets and, if completed, transfer your Personal Information to the party or parties involved in the transaction as part of that transaction.

THIRD PARTY WEBSITES

This website contains a link to a third-party website (the payment service) and may contain others. These linked websites are not under our control, and we are not responsible for the privacy practices or the contents of any such linked website or any link contained in any linked website. We provide such links only as a convenience, and the inclusion of a link on the website does not imply endorsement of the linked website by EIM. If you provide any personal data through any such third-party website, your transaction will occur on the third party’s website (not this website) and the personal data you provide will be collected by and controlled by the privacy policy of that third party. We recommend that you familiarize yourself with the privacy policies and practices of any third parties. PLEASE NOTE THAT THIS PRIVACY POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES.

YOUR RIGHTS AND HOW YOU CAN ACCESS, CHANGE OR DELETE, OR MANAGE THE PROCESSING OF, YOUR PERSONAL INFORMATION

Please do not submit to us or post on EIM Technology any personally identifiable information that you do not want us to collect. In particular, we ask that you do not send us, and you do not share any sensitive information, such as social security numbers, on or through EIM Technology. Please keep in mind that, although you are not required to provide any personally identifiable information that we request, in many cases, if you do not provide us with the requested information, we may not be able to provide you with certain services or respond to any questions you may have.

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Withdrawing Your Consent. Where consent is the basis of processing your information, you may at any time withdraw the consent you provide for the processing by contacting us at or EIM, Inc., 860 Broadway, 6th Floor, New York, NY 10003, provided that we are not required by applicable law or professional standards to retain such information. If you want to stop receiving future newsletters, informational material or marketing messages and materials, you can do so by clicking the “unsubscribe” link included in our email marketing messages or by contacting us at or EIM, Inc., 860 Broadway, 6th Floor, New York, NY 10003.

Receiving Electronic Communications from Us. If you no longer want to receive emails from us on a going-forward basis, you may opt-out of receiving these emails by following the unsubscribe instructions in the email. We will process your request within a reasonable time after receipt. However, we are not responsible for removing your personally identifiable information from the lists of any third party who has previously been provided your information in accordance with this Privacy Policy or your consent.

Canceling Your Account. While your account is active, we retain your Personal Information. If you cancel your account by following the instructions set forth in the Terms of Use or if we terminate your account for any other reason, we may continue to retain your Personal Information for reasons including, but not limited to, complying with our legal obligations or our internal security policies, meeting regulatory requirements, for fraud detection, improving our site and services, or enforcing this Privacy Policy. Remember that even after your account is cancelled, copies of some information from your account may remain viewable in some circumstances, for example, where you have shared information with a third-party application or web site or where you have posted your Personal Information publicly on the EIM Technology. In addition, because of the nature of caching technology, your account may not be instantly inaccessible to others, and there may be a delay in the removal of the content from elsewhere on the Internet and from search engines.

Data Subject Rights. You have the right in certain circumstances to request confirmation from us as to whether or not we are processing your Personal Information. Where we are processing your Personal Information, you also have the right to request access to, modification of, or deletion of such Personal Information. You also have the right in certain circumstances to receive the Personal Information concerning you that you provided to us, to restrict processing of your Personal Information, or to transmit such data to another controller. To exercise your rights with respect to your Personal Information, please contact us at [email protected] or EIM, Inc., 860 Broadway, 6th Floor, New York, NY 10003. As permitted by law, certain data elements may not be subject to access, modification, portability, restriction, and/or deletion. Furthermore, where permissible, we may charge for this service if we choose and notify you in advance that there will be a charge. We will respond to reasonable requests as soon as practicable and as required by law.

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of our Websites may then be inaccessible or not function properly.

Promotional Offers from the Company. If you do not wish to have your email address/contact information used by EIM to promote our own or third party products or services, you can opt out by so indicating in your registration/preferences file or by notifying us at or EIM, Inc., 860 Broadway, 6th Floor, New York, NY 10003. This opt out does not apply to information provided to EIM as a result of a contest, promotion, purchase of services or products, or other transactions.

Third Party Collaboration. We do not control third party collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative on its website.

ACCESSING AND CORRECTING YOUR INFORMATION

You may send us an email at to request access to, correct or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from our website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other website users. Proper access and use of information provided on our website, including User Contributions, is governed by our terms of use: www.evidenceinmotion.com/privacypolicy

LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

We collect and process information about you only where we have a legal basis for doing so under applicable law. The following are the legal bases for collecting and processing your Personal Information:

  • When you give us your consent to do so, this includes:
    • Where consent is required by law, and where we ask for your consent to process your Personal Information for a stated purpose.
    • Where we rely on your consent to process your Personal Information, you may withdraw your consent at any time. You will not suffer any detriment for withdrawing your consent; however, we may be required to retain the information for legal purposes and may affect the ability to provide information to any UP. If you withdraw your consent, this will not make the processing which we undertook before you withdrew your consent unlawful.
  • To meet contractual obligations or obligations related to a contract, this includes:
    • Providing our services and their features to you.
    • Providing you with customer support.
    • Responding to your communications and requests.
    • Communicating with you.
    • Creating an account and profile for you.
  • For EIM’s legitimate interests, this includes:
    • Developing and operating our business.
    • Maintaining and improving our products and services.
    • Operating our website and providing our services.
    • Conducting market research, audits, and other business operations.
  • For purposes which are required by law, this includes:
    • Complying with any regulations, procedures, and laws which apply to us.
    • Investigating misuse of your account.

GDPR PRINCIPLES

EIM complies with the principles of the GDPR and adheres to that Personal Information shall be:

  • Processed lawfully, fairly, and in a transparent manner in relation to the person.
  • Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
  • Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
  • Accurate and, where necessary, kept up to date.
  • Kept in a form which permits identification of persons for no longer than is necessary for

    the purposes for which the Personal Information is processed.

  • Processed in a manner that ensures appropriate security of the Personal Information.

SECURITY

The security of your information is very important to us. EIM implements a variety of security measures to maintain the safety of your Personal Information. However, due to the inherent open nature of the Internet, no data transmission over the Internet or any wireless network can be guaranteed to be secure. As a result, while we take measures to protect your Personal Information, we cannot ensure or guarantee the security of any information you send to us or that we store on our servers. Your use of EIM Technology demonstrates your assumption of this risk.

The safety and security of your information also depends on you. If we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our website.

WE TAKE SECURITY PRECAUTIONS IN AN EFFORT TO PROTECT YOUR INFORMATION AGAINST SECURITY BREACHES. HOWEVER, THIS IS NOT A GUARANTEE THAT SUCH INFORMATION MAY NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY A BREACH OF SECURITY MEASURES RELATING TO OUR WEBSITE OR FACILITIES. YOU ACKNOWLEDGE THAT YOU UNDERSTAND AND AGREE TO ASSUME THESE RISKS.

DATA RETENTION

We back up all information on our system, including your personal information onto servers via secured networks that are collected periodically, currently nightly. Quarterly backups are archived for two years and then destroyed. We will retain your information on the current system for as long as we believe your account may be active or as otherwise necessary to provide you services. We also will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

DATA TRANSFERS

Your information will be processed by us primarily in the United States and, if you live outside the United States, your information will be transferred there. Some of our data process providers may maintain servers around the world, and your information transferred to servers located in other countries. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in our Privacy Policy.

LINKED SERVICES

EIM Technology may contain links to third-party services and sites. EIM is not responsible for the privacy practices or content of such third-party services and sites and unaffiliated companies. Once you leave our EIM Technology websites and apps or click a link to a third- party website or app, you will be bound by, and should review, the applicable privacy policy of the other site or service.

SOCIAL MEDIA

EIM Technology may contain links to our presence on various social media platforms. We do not operate or control these platforms. You should be aware that personally identifiable information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others. We are unable to control these uses of your personally identifiable information, and by using such services you assume the risk that the personally identifiable information provided by you may be viewed and used by third parties.

RESIDENTS OF THE EEA

If you reside or are located in the European Economic Area (“EEA”) you have the right, under certain circumstances, to request that we:

  • Erase your Personal Information without undue delay.
  • Provide you with your personal information in a structured, commonly used and machine-readable format.
  • Rectify any inaccurate Personal Information concerning you.
  • Restrict the way we process your Personal Information.
  • Inform you about what Personal Information we collect about you.
  • Don’t subject you to a decision based solely on automated processing.
  • Do not process your Personal Information and that we do not provide your Personal Information to third parties.

EIM, LLC may be the data processor, which means that we are responsible for responding to your requests in relation to how your Personal Information is used. If you have any privacy concerns or if you would like to exercise any of your statutory rights described above please let us know by contacting us at this email address; you may use this same email address to contact EIM’s VP of Technology. We will address your request or inquiry without undue delay.

CALIFORNIA RESIDENTS CONSUMER PRIVACY ACT DISCLOSURES

Under the California Consumer Privacy Act (CCPA), California consumers are entitled to disclosures regarding the collection and use of their Personal Information. This section describes your CCPA rights and how to exercise those rights.

Collection and Disclosure of Personal Information
In the past 12 months, we have collected, and may have disclosed to third parties for our business purposes, the following categories of Personal Information relating to California residents:

  • First Name and Last Name
  • Email Address
  • Phone Number
  • Zip Code
  • Program of Interest
  • Level of Education Attained
  • Whether or not you’ve taken an Admissions Exam
  • Years of work experience
  • Information from social media and other sites
  • Application Data
  • Usage Data
  • Other Personal Information described in the section above titled “Collection of Information” may have been collected.

The categories of sources from whom we collected this Personal Information are:
Categories of sources from whom we collect Personal Information are described above under the section titled “Collection of Information.”

Purposes of collecting Personal Information:
We collect the Personal Information described above to provide services to all of our users, to improve our services, and for our business purposes. We limit the collection of information to only that which is absolutely necessary to carry out our legal or business obligations, and for the purposes described under the section titled “Use and Disclosure.”

The categories of third parties to whom we disclose Personal Information for our business purposes are:

  • Affiliates of EIM for the purposes described in this policy.
  • To our UP in connection with managing a Program.
  • Third party service providers solely to assist us in providing and managing our services, such as data processing, marketing, and technology.
  • To third parties to protect the rights of EIM and others.

Rights of California Consumers under the CCPA
If you are a California resident you have a right to request that we provide you with the following information from 12 months prior to your request:

  • The categories of personal information that we have collected about you.
  • The categories of sources from which the personal information was collected.
  • The business or commercial purpose for collecting personal information about you.
  • The categories of third parties with whom we shared your personal information.
  • The specific pieces of personal information we have collected about you and may have

    shared.

  • You have the right to request that we delete any Personal Information we may have collected about you, unless the CCPA recognizes an exception.

The CCPA prohibits discrimination against any consumer for exercising any of the rights described above. You have the right for us to disclose and deliver the requested information to you free of charge within 45 days of us receiving a verifiable consumer request.

Sale of Personal Information
Under the CCPA a consumer shall have the right, at any time, to direct a business that sells personal information about the consumer to third parties not to sell the consumer’s Personal Information.

Except for providing services in connection with a UP for which it receives compensation, EIM does not sell and has not sold any Personal Information we collect about you. EIM does provide Personal Information it collects to its affiliates.

How to exercise your rights

If you have any privacy concerns or if you would like to exercise any of your rights under the CCPA please let us know by contacting us at this email address. Please provide your full name, contact information, and a detailed description of your request.

You may use the email above to contact EIM’s Data Protection Officer. We will address your request or inquiry without undue delay.

California Civil Code Section § 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to or write us at: EIM, Inc., 860 Broadway, 6th Floor, New York, NY 10003.

OTHER IMPORTANT INFORMATION

Protection for Children
EIM Technology is not targeted to children, and we do not knowingly collect personally identifiable information from anyone younger than 18 years of age. If we become aware that personally identifiable information from anyone younger than 18 years of age has been collected without the consent of such child’s parent or guardian, we will delete such information from our database without requesting permission to do so.

Education Records
The Family Educational Rights and Privacy Act of 1974 (“FERPA”) governs the privacy of students with respect to their education records, defined as any record directly related to a student and maintained by an educational institution or a party acting for the institution. EIM’s policy is to comply with FERPA, which applies to all educational institutions that receive funds under any program administered by the Secretary of Education. You may have various rights that arise under FERPA. FERPA grants students the following rights:

  • The right to control the disclosure of their education records.
  • The right to inspect and review their education records within 45 days of making a

    request.

  • The right to request an amendment of inaccurate or misleading portions of their education records.
  • The right to file a complaint with the U.S. Department of Education regarding non-compliance with FERPA.

When partnering with a UP, education records received by EIM either from a student or another party are the property of the UP. EIM cannot release any education records to students or third parties and students must go through the UP’s procedures. Please contact the UP to exercise any of the rights described above. With respect to records relating to Programs which are not affiliated with a UP, a student should contact EIM to exercise any of the rights described above.

If you would like more information about EIM Partner’s FERPA policy please contact us at this email address.

QUESTIONS, CONCERNS, AND COMPLAINTS
CONTACT INFORMATION

If you have any privacy related questions or concerns please contact us at [email protected]. You may also write to us to EIM, Inc. 860 Broadway, 6th Floor, New York, NY 10003.

If you reside or are located in the EEA and you have any complaints as to how we handle your Personal Information, please contact us at the email above.

You also have a right to lodge a complaint with a supervisory authority in the European Union member state that you reside in.

Updates to Privacy Policy

We may modify this Privacy Policy. Please look at the date below to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the EIM Technology. Policy changes will apply only to information collected on and after the date of the change.