Introduction: Who We Are and Why We Collect Your Information
What Information Does PrepMD RMS Collect?
Information You Provide to Us
We may collect and process Personal Information from and about you when you visit the Website, register for or subscribe to any Services, communicate with us, post information or content to message boards in the Services, and otherwise interact with the Website or Services. For example, when you create an account, we may collect your name, date of birth, contact information (including email address, work or home address, and phone number), payment information (including credit or debit card number, bank account information, or information regarding your loan(s), including the provider and amount), user name or e-mail address in combination with a password or security question, employer, job title and duties, educational background, education and career goals, picture or likeness, social media accounts, and the course you enroll in. Additionally, if you communicate with other users through the Services, we may collect the contents of those communications. You can choose not to provide us with certain information, although that may affect the functionality of the Website and Services.
Information Collected Automatically
When you use our Services, certain information is passively collected (that is, gathered without you actively providing the information) using various technologies and means, such as Internet Protocol (IP) addresses and cookies. These are described in more detail below:
- IP Addresses. The Services use IP addresses. An IP address is a number assigned to your device by your internet service provider to access the internet. In most consumer cases an IP address is dynamic (changing each time you connect to the internet), and not static (unique to a particular user’s device).
E-mail and Other Communications
We may communicate with you by email or other means. When we do this, in addition to the information contained in the email, we may collect a confirmation when you open email or click on links in the email. This confirmation helps us improve our service. If you do not want to receive email or other mail from us, please indicate your preference by visiting our email preference page. Please note that, if you do not want to receive legal notices from us, those legal notices will still govern your use of the websites, and you are responsible for reviewing such legal notices for changes.
Information Obtained from Third Parties
In some situations, you may use the Services as part of a contract PrepMD RMS has with your employer (each a “Customer Employer”) to provide the Services to its employees. When that occurs, we may receive the following Personal Information about users from the Customer Employer: name, contact information (including phone number, work address, and email address), job title and duties, and courses to enroll in. PrepMD RMS may purchase marketing and business development leads from direct marketing lead generation services. This information may include names, contact information, and professional background.
Special Categories of Personal Information and Sensitive Personal Information
Personal Information PrepMD RMS Has Collected in the Last 12 Months
What Does PrepMD RMS Do With Personal Information?
PrepMD RMS collects and uses Personal Information:
- To respond to inquiries and comments;
- To fulfill your requests concerning the Website and the Services;
- To provide you with information about products or services that we believe will interest you;
- To satisfy our contractual obligations with Customer Employers;
- To tailor content, recommendations, and advertisements we and third parties display to you on the Website, through the Services, and elsewhere online;
- To operate, maintain, develop, and grow PrepMD RMS;
- To operate, develop, maintain, and improve the Website and Services;
- To conduct market research;
- To analyze how visitors use the Website and Services;
- To investigate and resolve disputes and security issues;
- To comply with regulatory and legal obligations; and
- For any other lawful, legitimate business purpose.
PrepMD RMS may anonymize or aggregate Personal Information it collects. It may also use that information and other non-Personal Information it collects when you use or interact with the Website or Services to better understand our users and their behavior and to improve the user experience of the Website and Services.
We may also share certain Personal Information with third parties, including Customer Employers as applicable (as described in this Section and in Section V below).
Will PrepMD RMS Share Any of the Personal Information it Collects?
We share Personal Information with third parties as described below.
Agents and Service Providers
We employ other companies and people to perform tasks on our behalf and may need to share Personal Information with them to provide products and services to you. Unless we tell you differently, our agents and service providers do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
If you have received access to the Website and/or Services pursuant to a contractual relationship we have with your employer, we may share Personal Information with your employer to fulfill our contractual obligations and continue to provide access to you.
We may choose to buy or sell assets. In these types of transactions, Personal Information is typically one of the business assets that is transferred. Also, if we (or all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred or acquired.
Protection of PrepMD RMS and Others
With Your Consent
Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.
Personal Information PrepMD RMS Has Sold in the Last 12 Months:
PrepMD RMS does not sell Personal Information, however, we share Personal Information with Customer Employers as part of the Services provided to those clients, as described in Section V.G below, which may qualify as a sale of Personal Information under applicable Privacy Laws, including the CCPA and CPRA.
Personal Information PrepMD RMS Has Disclosed to or Shared with Third Parties in the Last 12 Months
PrepMD RMS has disclosed the following categories of Personal Information to Customer Employer clients in the 12 months immediately preceding the Effective Date: names; contact information; employers; job titles and duties; pictures; likenesses; social media accounts; courses enrolled in; and test answers and scores. PrepMD RMS relies on third party vendors to support the Services, including, but not limited to, cloud hosting platforms for all data storage. As a result, all Personal Information collected and described in Section III.G has been disclosed to third party vendors in the 12 months immediately preceding the Effective Date.
What Is PrepMD RMS’ Legal Basis for Collecting and Using Personal Information?
Director of Global Marketing and Admissions
50 Braintree Hill Park Suite 102
Braintree, MA 02184
How Long Does PrepMD RMS Retain Personal Information?
Except upon the request of an individual, as explained in Section VIII below, and except as the law permits and requires, PrepMD RMS will determine the retention period for Personal Information based on the following criteria:
- The nature of our relationship with the relevant individual and the Customer Employer, if applicable;
- The existence of other ongoing or expected projects with the relevant Customer Employer;
- The nature of the Personal Information in question; and
- Our business needs.
What Are Users’ Rights to Control Their Personal Information?
To the extent required by the Privacy Laws, except where permitted or required by law (including, but not limited to, compliance with a legal obligation, to further a public interest, and establishing and/or exercising a legal claim or defense), you have the following rights regarding the collection and use of your Personal Information.
Requests to PrepMD RMS
You may request the following from PrepMD RMS with respect to your Personal Information:
- Correction, updating, deletion, or restriction of collection and processing of your Personal Information;
- The categories of your Personal Information that PrepMD RMS collects or processes;
- The categories of sources from which PrepMD RMS collects or processes your Personal Information;
- The expected period for which PrepMD RMS will store your Personal Information, or if not possible, the criteria used to determine that period;
- The business or commercial purpose(s) that PrepMD RMS collects and disclosing your Personal Information;
- A description of how PrepMD RMS has used or is using your Personal Information;
- A copy of your Personal Information, including the specific pieces of Personal Information, in a format that is easily understandable to the average consumer, and to the extent technically feasible, in a structured, commonly used, machine-readable format, which also may be transmitted to another entity at your request without hindrance;
- Categories of third parties with whom PrepMD RMS shares your Personal Information, and list of third parties with whom PrepMD RMS has shared your Personal Information;
- Categories of your Personal Information that we have shared with third parties, including Customer Employers, and the categories of third parties to which we have shared each particular category of Personal Information;
- Your specific Personal Information PrepMD RMS has collected, used, or disclosed.
If you request that your Personal Information be erased or deleted or that PrepMD RMS otherwise restrict its collection and processing of Personal Information, PrepMD RMS may terminate or limit your access to the website and service. If PrepMD RMS has not collected or processed your Personal Information, or has not shared your Personal Information with another party, PrepMD RMS will inform you of that in response to any of the above requests. Some information may remain in PrepMD RMS’ backup media after erasure or deletion for a period of time. When you request that PrepMD RMS update information, PrepMD RMS may retain a copy of the unrevised information in PrepMD RMS’ records. PrepMD RMS also may use any anonymized aggregated statistical data derived from or incorporating Personal Information after it is updated, erased, or deleted, but not in a manner that would identify you.
We will confirm receipt of all such requests, provide information about how PrepMD RMS will process the request, and substantively respond to all such requests consistent with the Privacy Laws. There may be a delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized third party.
Our verification process varies based on the source and nature of the request, but may include: comparing data in the request against Personal Information we retain; contacting you using other contact information; requesting further information, although we will avoid doing so to the extent possible; and the consideration of certain factors, including the type, sensitivity, and value of your Personal Information, the risk of harm to you posed by an unauthorized request, the likelihood that fraudulent or malicious actors would seek your Personal Information, the manner in which we interact with you, the available technology, and whether the information you have provided to verify your identity is sufficiently robust to protect against fraudulent requests. To the extent permitted by the Privacy Laws, PrepMD RMS retains the right to deny any request if we cannot verify that it originated from you.
PrepMD RMS retains records of all of the above requests and our responses as required by the Privacy Laws.
When you update information, we may maintain a copy of the unrevised information in our records. Please note that some information may remain in our private records after your deletion of such information from your account.
PrepMD RMS may use any anonymized aggregated statistical data derived from or incorporating Personal Information after it is updated, erased, or deleted, but not in a manner that would identify you.
Making Foregoing Requests
The foregoing requests may be made by (1) email: RMS@prepmd.com, (2) phone: (888) 633-7737, or (3) mail: Director of Global Marketing, PrepMD Professionals LLC, 50 Braintree Hill Park Suite 102, Braintree, MA 02184.
You may authorize an agent to take any of the acts permitted in this Section VIII on your behalf. To do so, you must provide written and signed authority to the agent, and written and signed notice to PrepMD RMS that PrepMD RMS may act on such requests by that agent.
Withdrawal of Consent
You may withdraw your consent for PrepMD RMS to collect or process your Personal Information in any of the following manners: (1) contact us at firstname.lastname@example.org; contact us at (888) 633-7737; or (3) contact us at Director of Global Marketing, PrepMD Professionals LLC, 50 Braintree Hill Park Suite 102, Braintree, MA 02184. Please be aware that such withdrawal does not affect the lawfulness of PrepMD RMS’ collection or processing of your Personal Information before such withdrawal. We reserve the right to terminate or limit your access to the Website and Services in the event that you withdraw your consent.
“Do Not Sell My Personal Information” and Opting Out of Sharing Personal Information
Other than providing Personal Information to Customer Employers as described in Section V.B above, PrepMD RMS does not “sell” Personal Information, as that term is defined by the CCPA and CPRA. You may opt out of PrepMD RMS’ disclosure of your Personal Information in any of the following manners: (1) contact us at email@example.com; contact us at (888) 633-7737; (3) contact us at Director of Global Marketing, PrepMD Professionals LLC, 50 Braintree Hill Park Suite 102, Braintree, MA 02184; or (4) completing the contact us form.
We will act upon any request to opt out of all disclosure and sharing of your Personal Information, including notifying all third parties to whom we have disclosed or shared your Personal Information and ceasing to disclose or share your Personal Information, consistent with the requirements of the Privacy Laws.
If you exercise your right to opt out of the disclosure of your Personal Information to third parties, PrepMD RMS will cease disclosing your Personal Information as of the date we receive notice in a manner provided above. PrepMD RMS will not contact you about opting in to disclosing your Personal Information for at least 12 months following the date that it receives your notice.
Object or Challenge
You may object to, or otherwise challenge, PrepMD RMS’ collection and processing of your Personal Information in any of the following manners: (1) contact us at firstname.lastname@example.org; contact us at (888) 633-7737; or (3) contact us at Director of Global Marketing, PrepMD Professionals LLC, 50 Braintree Hill Park Suite 102, Braintree, MA 02184. PrepMD RMS will respond consistent with the requirements of the Privacy Laws.
Filing a Complaint
Regulatory authorities that oversee the Privacy Laws typically advise individuals to file an objection or challenge with the company before lodging a formal complaint with a regulatory authority. If an individual is dissatisfied with PrepMD RMS’ response to an objection or challenge filed under Section VIII.F, or wishes to file a complaint with a regulatory authority first, the individual may do so, including as follows:
PIPEDA: Office of the Privacy Commissioner of Canada
GDPR: Supervisory authority in the relevant European Union member state
CCPA and CPRA: California Attorney General
PII Laws: Relevant state Attorney General
Prohibit Automated Processing
PrepMD RMS does not use any automated decision making or profiling at this time. If and to the extent we do so in the future, at your request, PrepMD RMS will terminate any automated decision making, including profiling, that is the sole source of decisions that produce a legal effect concerning or similarly significantly affecting you.
Accessibility for Users with Disabilities
PrepMD RMS will not discriminate against you because you have exercised any of the rights above or any other rights you retain pursuant to Privacy Laws, including, but not limited to by:
- Not denying goods or services to you;
- Not charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Not providing a different level or quality of goods or services to you; and
- Not suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Consistent with Privacy Laws, PrepMD RMS: (a) retains the right to charge you a different price or rate, or provide a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to PrepMD RMS by your Personal Information; (b) may offer financial incentives, including payments to you as compensation, for the collection, disclosure, or deletion of your Personal Information; (c) may enter you into a financial incentive program only if PrepMD RMS clearly describes the material terms of the financial incentive program, so long as you give PrepMD RMS prior opt-in consent, which you may revoke at any time; and (d) shall not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.
What Are PrepMD RMS Service Differences?
PrepMD RMS does not offer any financial incentives for providing your Personal Information.
Is Personal Information About Me Secure?
We employ appropriate administrative, organizational, technical, and physical measures designed to protect the confidentiality, integrity, and availability of your Personal Information, which we regularly review and update as necessary.
We do not knowingly collect or solicit, and expressly instruct you not to provide, any Personal Information from anyone under the age of 18. If and to the extent we learn that we have collected Personal Information from a child under age 18 without verified parental consent, we will delete that information, except as provided below. If you believe that we might have any information from or about a child under age 18 without verified parental consent, please contact us immediately us at email@example.com, (888) 633-7737, or Director of Global Marketing, PrepMD Professionals LLC, 50 Braintree Hill Park Suite 102, Braintree, MA 02184.
Contractual or Statutory Requirement
Failure to Provide Personal Information
You can always opt not to disclose information to us. Please keep in mind, some information may be needed to register with us or to take advantage of some or most of our features.
Automated Decision Making
Questions or Concerns; Contact Information
If you have any questions or concerns regarding our privacy policies, please contact us at firstname.lastname@example.org, (888) 633-7737, or Director of Global Marketing, PrepMD Professionals LLC, 50 Braintree Hill Park Suite 102, Braintree, MA 02184.
Effective Date: November 1, 2021