TELEHEALTH CENTER OF EXCELLENCE PRIVACY POLICY
Version 2.0 (Last Updated September 19, 2024)
Telehealth Center of Excellence LLC (“Telehealth COE,” “we,” “us”) collects, stores, and processes information from members, website visitors, and users (“you”) of our Services. Telehealth COE values your privacy and works hard to protect your information. This Privacy Policy (the “Policy”) describes the information we collect from you when you interact with our website, the websites of any of our affiliates (such as TMI Institute and ChangeMaker, the “Subsidiaries”), or attend one of our in-person or online events (collectively, the “Services”).
If you do not want us to collect or use your information according to our Policy, please do not use the Services.
Below, you will find our Policy separated into sections describing all aspects of our data collection practices. The sections are:
Our Privacy Policy is written to clearly explain and describe to you how we collect, use, share, and disclose the information collected by Telehealth COE through our Services. We have divided our Policy into two different sections: (1) this succinct summary section that provides a general overview of our privacy practices; and (2) a more comprehensive policy outlining the specifics of what information we collect, how and why we collect that information, and your rights regarding your data. In the bullet points below, you will find key areas of our Policy of which you should be aware. We encourage you to read the full policy before providing us with your information.
1. Consent to Data Collection
By using our Services, you consent to the collection of your personal information either by collecting the information directly from you or by our tracking technologies, like cookies. You also consent to Telehealth COE collecting and using your information as described in our Policy.
This website is not directed toward or intended for use by children or anyone under the age of eighteen (18). We do not knowingly collect information from anyone under the age of thirteen (13).
By accessing and using our Services, you accept all terms and conditions set out in this Policy. Before using our Services, you should read the Policy in its entirety and return to this page periodically to review any changes. We may update this policy from time to time and by continuing to use our Services after such updates you consent to those changes.
2. What Information We Collect
The Types of Data We Collect
Personal Data: “Personal Data” is data that someone could use to individually identify or contact you. This includes information like your name, email address, telephone number, or address. It can also include non-public information of yours that is either associated with or linked to any of the data mentioned above.
Sensitive Personal Information: “Sensitive Personal Information” is a personal subset of Personal Data that includes certain government identifiers (such as social security numbers), and account log-in, debit or credit card numbers in combination with any required access code/password, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, union membership, contents of mail or emails, text messages unless the business is the intended recipient of the communication and genetic data.
Telehealth COE may collect Sensitive Personal Information dependent upon your use of our services.
Anonymous Data: “Anonymous Data” is data that is neither associated with nor linked to your Personal Data. Anonymous Data on its own cannot identify you individually.
Account Information: When you sign up for an account, we collect certain information about you. This includes basic information such as your email address, name, phone number, and address. If you fill out any surveys through your account, we keep that information as well. We may also collect information about events you RSVP to and information about your interest in and use of various events, programs, services, and content you access through our Services.
Event Information: When you attend either in-person or virtual events through our Services we will document the event you attended, any surveys you filled out, or any purchases you make at the event. When you attend events, we may take an audio-visual recording of the presentation and share it through our digital channels. These recordings may include your name and likeness.
Social Media: You may be able to link some social media accounts to our Services. If you link such social media accounts, to enhance your experience, we may access surface level profile information from your account including your name, profile picture, contact list, username, pictures and videos, gender, birthday, location, people you follow and/or who follow you, and the posts you make or posts you “like.” By linking your account, you consent to Telehealth COE collecting any linked information in accordance with this Privacy Policy. If you do not wish to share certain information from another social media account, you should change your preferences on that account. Any information from another social media service is subject to the data protection practices of the social media network itself and is not controlled by Telehealth COE. As such, you should read through the privacy policy of any social media service you wish to link to before linking the account with our Services.
Device and Technical Information: When you access our Services through your computer or mobile device, we collect information on the device you are using, including : your browser type, your operating system, your IP address, your Internet service provider or mobile carrier, IDFA, MAC address, and unique device identifier. We also collect crash logs, reports on bugs, feedback on our services, support requests, and certain device usage information. You can deactivate cookies through your own browser settings. Each browser is unique, therefore look at your browser’s Help menu to learn the correct way to modify your cookies. As a reminder, some of our Services may not function properly if your cookies are disabled.
Financial Information: When you purchase a membership or a product through our Services, we save your purchase for internal audit purposes or send you additional content and product offerings, and we collect your credit card information to complete your transaction. However, we do not retain the card information. That information is provided directly by you to our financial service provider, whose use of your personal information is governed by their Privacy Policy, for the sole purpose of completing the transaction. The financial service provider adheres to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information. The financial service provider we work with is Quick Books Payments.
Location Information: We may collect precise or approximate location information, such as country or address, when you provide it to us directly, through device information, or other means. For instance, if you access our Services through your computer or mobile device, we may collect your precise device location through your IP address for security, regulation, and performance considerations. You can restrict what location information you provide to Telehealth COE through your device settings. When you attend an in-person event, we will have a record of your location while on the premises. You may set your web browser software to reject tracking technologies. Please note that the opt-out is cookie-based and will only affect the specific computer and browser on which the opt-out is applied.
Applicant Data: When you apply for a position with Telehealth COE or our Subsidiaries, we collect some of your personal information. This information includes your name, address, social security number, birthday, and educational background.
Information From Other Sources: We may collect information from other sources such as sponsors for events to give you access to promotions or specific event information, or we may collect information from your school or employer if they register you for a course.
3. How We Collect Your Information
Information Collected Directly From You
We collect information directly from you when you fill out any registration forms through our Services, fill in account information, and when you access our Services through any of your devices. We collect device information using cookies, web beacons, pixels, and other similar technologies either used by us or used by other entities on behalf of Telehealth COE.
Categories of Personal Information Collected From Third Parties.
We may collect information from third parties such as social media websites you link to, event co-sponsors, and credit card processing companies.
4. How We Use Your Information
Communications With Users: We may contact you by email or physical mail to inform you about events you have signed up for or orders you have made.
Marketing and Promotions: We use your contact information, including your email address and physical address, from time to time to send you marketing and promotional materials regarding our Services or other offerings. These materials include sponsored content or information on upcoming events or opportunities. You may opt-out of or change your preferences for marketing communications at any time by either clicking the “Unsubscribe” button within the communications or by emailing your request to privacy@coecompliance.com.
Technical Improvements: We use technical and usage information to improve our Services and make your experience with our Services more enjoyable, improve the accuracy of information, reduce waiting times, improve product offerings, and perform analytics on our Services.
Compliance: To ensure that our Services comply with legal obligations and our own Terms of Use, we collect information to detect, investigate, and prevent activities that may violate the Telehealth COE Terms of Use, infringe on the copyright of another, be fraudulent or otherwise illegal, or to ensure the safety of other users.
5. Why We Collect and Use Your Information
We collect your information under the lawful basis of legitimate interest, consent, and contract. To provide you with the best experience on our Services, our legitimate interest is to collect your information to direct you to relevant seminars and trainings based on your previous courses or material related to your institution. We also collect what you allow us to collect, what you voluntarily provide, and what is necessary to fulfill our contracts with you. You may withdraw consent at any time by emailing privacy@coecompliance.com. When you or your representative organization signs up for a membership (i.e. you are a teacher and your school registers you with our Services) with Telehealth COE or our affiliates, we collect and keep information on the basis of contract and will keep and use your information in order to execute our membership agreements or purchases with you.
6. Data Transfers
We may transfer your data outside of the country in which it was collected. We may need to do this to fulfill orders or complete transactions with you. Other countries may not have the same rules, regulations, or protections as your country or the country in which your data was collected. When transferring data across borders, we ensure that any entity with which we share that information will protect your data according to our Privacy Policy through contractual clauses or through Binding Corporate Rules.
7. Sharing Your Information
We may share and disclose certain information in the following ways or for another purpose disclosed at the time of collection:
8. Your GDPR Rights Regarding Your Information
Under the General Data Protection Regulation (GDPR) you may have the following rights regarding your Personal Data:
To exercise any of the above rights, please email our Data Protection Officer at privacy@coecompliance.com with your request in the subject line.
Telehealth COE has the right to refuse to honor your request to delete any of your Personal Data if it is necessary to (1) exercise the right of freedom of expression and information; (2) to comply with any legal obligation that may require processing of your Personal Data; (3) for reasons of public interest in the area of public health; (4) for archiving purposes in the public interest; (5) scientific or historical research purposes or statistical purposes; (6) or for the establishment, exercise or defense of legal claims. Telehealth COE may also refuse to delete or delay deleting information if it is necessary to carry out a contract we have with you.
Telehealth COE does not use your Personal Data to make any automated decisions about you.
9. Confidentiality and Security
Telehealth COE takes your privacy concerns very seriously and protects your information with appropriate technology, policies, and procedures to prevent unauthorized use, access, disclosure, modification, copying, or destruction, and to maintain integrity. We protect your information both online and offline. We only process your Personal Data fairly and lawfully after receiving your consent and we do not use your Personal Data in any manner inconsistent or incompatible with the purposes for which Telehealth COE collects the information. Telehealth COE may retain your personally identifiable information if there is a business requirement, or if otherwise required under applicable laws.
To prevent unauthorized access, maintain data accuracy, and ensure appropriate use of information, Telehealth COE has put in place appropriate physical, electronic, and managerial procedures, including encryption and tokenization, to protect your Personal Data. However, Telehealth COE cannot guarantee its absolute security, as no method of transmission over the Internet, or method of electronic storage, is entirely secure.
10. Third-Party Services
Categories of Third-Parties With Whom We May Share Your Information.
Third parties, with whom we may occasionally share your information include financial service companies, business partners, co-sponsors, event hosts, analytics services, email service providers, event management software, point of sale management software, customer relationship management software, technical support, marketing platforms, and cloud service providers.
11. Your California Rights
As a California resident, you have additional rights given to you by the California Consumer Protection Act (CCPA). The CCPA applies to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California consumer or household (“California Information”). Your general rights regarding California Information include:
The Selling of Your Personal Data
Telehealth COE does not sell your Personal Data at this time, but you can email us at privacy@coecompliancel.com to request that your information not be sold in the future should our practices regarding selling data ever change.
Requesting Disclosure: If you are a California resident, you have the right to request that Telehealth COE provide information to you about our practices related to disclosure of your Personal Data to particular third parties for their direct marketing purposes. You can send requests for such disclosure to privacy@coecompliance.com (with the subject line of “Your California Privacy Rights”). We do not currently sell your information for direct marketing purposes.
As a California resident, you may also request more specific information like:
No Discrimination: Telehealth COE is committed to honoring your California rights. As such, you will never be denied or charged different prices or rates for either goods or services or provided with differing levels of quality of goods or services, should you choose to enforce your California rights.
If you have any questions regarding this Privacy Policy, please contact our Data Protection Officer either by email at privacy@coecompliance.com or by mail.
Telehealth COE, LLC
c/o Besnoy Law P.C.
11 Broadway, Suite 615
New York, New York 10004
COOKIE POLICY
When you visit our website or use our app, we will request to store a small text file on your computer, called a cookie. Cookies allow us to remember certain information about you so that we may recognize you when you return to our website. It remembers information like language preferences or log-in information. The cookies we set on your device are first-party cookies, whereas third-party cookies are cookies that we may store on your computer that originate from a domain other than ours. We may use third-party cookies for advertising or marketing purposes. Below, you can read about all the specific cookies we use, the purposes for the cookies, and information on how to manage your cookie preferences.
Types of Cookies
Strictly Necessary Cookies
Some cookies we use are essential for our website to function. These cookies cannot be deactivated.
These cookies include PHPSESSID session cookies that assign you a user id during your session. This cookie is deleted at the end of the session when all browser windows are closed.
Performance Cookies
We use certain cookies to improve the performance of our Services. We measure site traffic and count visits through performance cookies, allowing us to learn how users navigate our site and what pages may need some changes.
Functionality Cookies
We use some cookies to make features on our site function. For example, we use Twitter cookies to allow you to see embedded tweets on our website.
Targeting and Advertising Cookies
We use certain cookies to recognize you as a user and your preferences so that we may occasionally advertise to you on other platforms.
Managing Cookies
You can control cookies both through our own cookie consent mechanism and through your browser settings. Your browser may have settings that allow you to disable cookies. You can also delete cookies that were previously placed on your device through your browser.