ICHOM Education
Privacy Policy
Last Updated: [insert date]
This privacy policy (“Privacy Policy”) describes the types of personal information that Health Value Advisors, Inc. dba ICHOM Education (“ICHOM Education,” “we,” “our,” and/or “us”) collects, uses, and discloses from individuals (“you” or “your”) who use our website (including https://ichom-healthvalue.talentlms.com/plus/) and services that link to this Privacy Policy (our “Service”). As used in this Privacy Policy, “personal information” means any information relating to an identified or identifiable individual. By using our Service, you agree to the collection, use, disclosure, and procedures described in this Privacy Policy. Beyond the Privacy Policy, your use of our Service is also subject to our Terms of Service.
Personal Information We Collect
We may collect a variety of personal information from or about you or your devices from various sources, as described below. Where applicable, we indicate whether and why you must provide us with your personal information, as well as the consequences of failing to do so. If you do not provide your personal information when requested, you may not be able to use our Service if that personal information is necessary to provide you with our Service or if we are legally required to collect it.
A. Personal Information You Provide to Us
Registration and Account Information. When you sign up for an account and register for our Service, we ask you for your name, email, username, password, years of health care experience, country, time zone, job position/title, company name, and LinkedIn profile.
Health Care Transformation Community. We may host webinars, conferences, and other events as part of our Health Care Transformation Community. When you participate in any such webinar, conference, or other event, we may collect your [name, email, phone number, job position/title, and company name].
Communications. If you contact us directly, we may receive additional information about you, such as your name, email address, the contents of a message or attachments that you may send to us, and other information you choose to provide. [When we send you emails, we may use embedded pixels or other technologies to track information about your receipt and interaction with our emails, such as whether and when you open them, whether you access any links included in our emails, how long you read our emails, whether you forward our emails and to whom, your Location Information (described below), and your Device Information (described below), to learn how to deliver a better customer experience and improve our Service.]
Payment Information. If you make a payment on our Service, your payment-related information, such as credit card or other financial information, is collected by our third-party payment processor on our behalf.
B. Personal Information We Collect When You Use Our Service
Program Information. We may offer certain courses or programs as part of our Service (each such course or program, a “Program”). When you participate in a Program, we may receive your [name, email, assignments you submit, modules you’ve completed, content of communications during class discussions, photo, video, and audio from online classes, responses to quizzes and exams, your individual reflection, and other items submitted to satisfy certain Program requirements].
Location Information. When you use our Service, we may receive your location information (for example, your IP address may indicate your general geographic region).
Device Information. We receive information about the device and software you use to access our Service, including IP address, device type, device identifiers, web browser type and version, and operating system version.
Usage Information. We automatically receive information about your interactions with our Service, like the pages or other content you view, referrer information (the website you visited before coming to our Service), and the dates and times of your visits.
Information from Cookies and Similar Technologies. We and our third-party partners may collect information using cookies, which are small files of letters and numbers that we store on your browser or the hard drive of your computer. They contain information that is transferred to your computer’s hard drive. We and our third-party partners may also use pixel tags and web beacons on the Service. These are tiny graphic images placed on web pages or in our emails that allow us to determine whether you have performed a specific action. We use cookies, beacons, invisible tags, and similar technologies (collectively “Cookies”) to collect information about your browsing activities and to distinguish you from other users of the Service. This aids your experience when you use the Service and allows us to improve the functionality of the Service. Cookies can be used for performance management (i.e., collecting information on how the Service are being used for analytics purposes). They can also be used for functionality management, enabling us to make your visit more efficient by, for example, remembering language preferences, passwords, and log-in details. Below is an overview of the types of Cookies we and third parties may use to collect information.
Strictly Necessary Cookies. Some Cookies are strictly necessary to make the Service available to you. We cannot provide you with the Service without this type of Cookies. We use the following necessary Cookies:
Functional Cookies. Functional Cookies are used to recognize you when you return to the Service. This enables us to adapt our content for you and remember your preferences. For example, we use functional Cookies to remember your choice of language or region. We use the following functional Cookies:
Analytical and Performance Cookies. We also use Cookies for website analytics purposes to operate, maintain and improve the Service. We may use our own analytics Cookies or use third-party analytics providers. These providers may also collect information about your use of other websites, apps, and online resources. We use the following analytical or performance Cookies:
Advertisement Cookies. We also use Cookies for advertisement purposes to provide visitors with customized advertisements based on the pages you visited previously, and to analyze the effectiveness of the ad campaigns. We use the following advertisement cookies:
Please review your web browser’s “Help” file to learn how you may modify your cookie settings. Please note that if you delete or choose not to accept cookies from our Service, you may not be able to utilize the features of our Service to their fullest potential. You can find more information about your rights and choices, and how to block the use of certain Cookies in the section Your Rights and Choices below.
How We Use the Personal Information We Collect
We use the personal information we collect:
[To provide, maintain, improve, and enhance our Service;
To personalize your experience on our Service, such as by providing tailored content and recommendations;
To understand and analyze how you use our Service and develop new products, services, features, and functionality;
To issue certifications;
To connect you with other members of our Health Care Transformation Community;
To communicate with you, provide you with updates and other information relating to our Service, provide information that you request, respond to comments and questions, and otherwise provide customer support;
To generate anonymized or aggregate data containing only de-identified, non-personal information that we may use for any lawful purposes;
For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;
To send you text messages;
To facilitate transactions and payments;
To find and prevent fraud and abuse, and respond to trust and safety issues that may arise;
For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
For other purposes for which we provide specific notice at the time the information is collected.]
Legal Bases for Processing European Personal Information
If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), we only process your personal information when we have a valid “legal basis,” including as set forth below.
Consent. We may process your personal information where you have consented to certain processing of your personal information. For example, we may process your personal information to send you marketing communications or to use Cookies where you have consented to such use.
Contractual Necessity. We may process your personal information where required to provide you with the Service. For example, we may need to process your personal information to respond to your inquiries or requests.
Compliance with a Legal Obligation. We may process your personal information where we have a legal obligation to do so. For example, we may process your personal information to comply with tax, labor and accounting obligations.
Legitimate Interests. We may process your personal information where we or a third party have a legitimate interest in processing your personal information. Specifically, we have a legitimate interest in using your personal information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of the Service. We only rely on our or a third party’s legitimate interests to process your personal information when these interests are not overridden by your rights and interests.
How We Disclose the Personal Information We Collect
Partners and Affiliates. We may disclose any information we receive to our current or future partners and affiliates for any of the purposes described in this Privacy Policy.
Vendors and Service Providers. We may disclose any information we receive to vendors and service providers retained in connection with the operation of our Service.
ICHOM. Our Programs are offered in partnership with the International Consortium for Health Outcomes Management (“ICHOM”). When you complete a Program, we will disclose your name, Program completion status, and certification to ICHOM. You understand and agree that the collection, use, and disclosure of your information by ICHOM will be governed by ICHOM’s privacy policy (available at https://www.ichom.org/privacy-policy). We encourage you to review ICHOM’s privacy policy.
Health Care Transformation Community. If you participate in our Health Care Transformation Community, may disclose your name and contact information to other members of our Health Care Transformation Community.
Analytics Partners. We use analytics services to collect and process certain analytics data.
As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to comply with law enforcement requests and legal process, such as a court order or subpoena, respond to your requests, or protect your, our, or others’ rights, property, or safety.
Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.
Consent. We may also disclose your information with your permission.
Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional email messages from us, you will continue to receive administrative messages from us. You can opt out from our promotional SMS text messages by replying “STOP” to our message.
Your European Privacy Rights. If you are located in the EEA or the UK, you have additional rights described below.
You may request access to the personal information we maintain about you, update, and correct inaccuracies in your personal information, restrict or object to the processing of your personal information, have your personal information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your personal information to another company. In addition, you have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
You may withdraw any consent you previously provided to us regarding the processing of your personal information at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.
You may exercise these rights by contacting us using the contact details at the end of this Privacy Policy. Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain personal information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
How to Block Cookies. You can block Cookies by setting your internet browser to block some or all Cookies. However, if you use your browser settings to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Service. You can change your browser settings to block or notify you when you receive a Cookie, delete Cookies or browse the Service using your browser’s anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of Cookies or similar technologies which store information on your device, you should change your browser settings accordingly. Where required by applicable law, you will be asked to consent to certain Cookies and similar technologies before we use or install them on your computer or other device.
If you choose not to provide us with personal information we collect, some features of the Service may not work as intended.
Our Service may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.
Retention
When you request that we do so, we take measures to delete your personal information or keep it in a form that does not permit identifying you when this personal information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this personal information for a longer period. When we process personal information for our own purposes, we determine the retention period taking into account various criteria, such as the type of services provided to you, the nature and length of our relationship with you, possible re-enrollment with the Service, the impact on the Service we provide to you if we delete some personal information from or about you, and mandatory retention periods provided by law and the statute of limitations.
Security
We make reasonable efforts to protect your information by using security measures designed to safeguard the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.
Children’s Privacy
International Visitors
Our Service is hosted in the United States (“U.S.”). If you choose to use our Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the U.S. for storage and processing. We may transfer personal information from the EEA or the UK to the U.S. and other third countries based on European Commission-approved or UK Government-approved Standard Contractual Clauses, or otherwise in accordance with applicable data protection laws. We may also transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our Service. By providing any information, including personal information, on or through our Service, you consent to such transfer, storage, and processing. For more information about the tools that we use to transfer personal information, or to obtain a copy of the contractual safeguards we use for such transfers (if applicable), you can contact us as described below.
Changes to this Privacy Policy
We will post any updates to this Privacy Policy on this page, and the revised version will be effective when it is posted. If we make a material update, we may notify you of such update by through our Service, by email, or other means.
Contact Information
ICHOM Education is responsible and the data controller for processing your personal information. If you have any questions, comments, or concerns about our processing activities, please email us at [insert email address] or write to us at:
ICHOM Education
[insert address]
