The Center for Affiliated Learning ( The CAL ) Privacy Policy

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1 The Center for Affiliated Learning ( The CAL ) Privacy Policy Welcome to the Center for Affiliated Learning ( The CAL ) an education and training platform owned and operated by Affiliates Risk Management Services, Inc., a New York not-for-profit corporation ( ARMS or we ). This Privacy Policy applies to you if you are a user of The CAL. Users of The CAL are referred to in this policy as you or user. This Privacy Policy applies regardless of whether you are using a computer, a mobile device or other device to access or use The CAL. We urge you to read this Privacy Policy carefully. Personal Information Defined. This Privacy Policy explains how The CAL may collect, use, and disclose Personal Information and other information we obtain through your access and use of The CAL, and from communications between you and The CAL. The CAL considers Personal Information to include information that, alone or when in combination with other information, may be used to readily identify or contact you, such as your name, username, address, address, phone number, organization name, and job title. In addition, in connection with processing your Continuing Medical Education ( CME ) or Continuing Education ( CE ) activity request and/or certificates, we will ask for your medical degree. This will also be considered Personal Information. The CAL does not consider Personal Information to include information that has been anonymized in a way that prevents a third party from easily identifying a specific individual. Use and Acceptance. By using The CAL, you agree to this Privacy Policy. In addition, by using The CAL s engagement technology to communicate with or engage with The CAL, you agree to this Privacy Policy. If you do not accept this Privacy Policy, you must not use The CAL, and you must not otherwise use The CAL s engagement technology to communicate with or engage with The CAL. What information do we collect from The CAL users and how do we collect such information? Personal Information. When you use or access The CAL, you may be required to submit Personal Information. Registration. When you register for The CAL, we ask you to provide certain Personal Information. We keep this information in a contact database for future reference, as needed. CME/CE Certificates. If you request a CME and/or CE certificate in connection with the successful completion of a course on The CAL, The CAL or a third party providing services to The CAL will grade your post-test and issue a certificate of completion documenting your participation in the CME/CE activity. In connection with the issuance of the CME/CE certificate, The CAL may be required to contact you for any additional information necessary to provider documentation of a completed CME/CE activity, such as completion of the evaluation questionnaire. In addition, The CAL may send you information about other CME/CE activities offered by The CAL, respond to formal request for CME/CE activity participation reports from your employer, and otherwise use the information as provided in these Privacy Policies. Communication Products. If you engage in a communication with The CAL Help Desk using The CAL s chat, , voice or other communication products or services, or if you engage in a pre- or postinteraction survey ( Survey ), you may voluntarily provide, or otherwise be asked to provide, Personal

2 Information, such as your name, organization name, job title, contact information and other information to facilitate service. The CAL may maintain transcripts of chats, s and other written communications that are conducted between you and The CAL (collectively, Transcripts ). The CAL also maintains copies of Surveys. The CAL may, in accordance with applicable law (including laws related to notice and/or consent), record and maintain recordings of voice communications ( Recordings ). By providing Personal Information and other information via The CAL s products or services, you consent to The CAL collecting and processing such information for the purposes outlined in this Privacy Policy. Requests for Information, News and other Content. You may sign up to receive information, news and other content related to new and existing CAL products and services, The CAL events and other information related to The CAL that may be of interest to you. You will be asked to provide Personal Information, such as contact details and other information, relevant to delivering such news and information. We maintain all such information in a contact database for future reference, as needed. Participation in one or more Communities offered by The CAL. You may participate in one or more communities offered by The CAL. You may be asked to provide Personal Information, such as contact details, and other information prior to becoming a member of any such community. We maintain all such information in a contact database for future reference, as needed. In the event that you participate in any message board or blog on The CAL, please see the terms below under the heading The CAL Community, Message Boards, Blogs. If you need technical support related to our services or your access or use of The CAL, we may request that you complete a form or send an or other written communication for the purposes of defining and clarifying your technical support request. When submitting a technical support request, you are asked to provide Personal Information, including an address and a description of the issue. We maintain copies of all technical support requests and other information submitted with or related to such requests. Promotions. From time to time, we may offer promotions to The CAL users. If we do, and if you wish to participate, you may be required to provide Personal Information, such as contact information and other information. We maintain such information in a contact database for future reference, as needed. Recruitment and Job Applications. Personal Information such as that contained on a resume or curriculum vitae may be submitted to The CAL or ARMSConnect.org, ARMS s extranet site, in connection with a job offered by ARMS. Any information supplied by or on behalf of an applicant may be maintained by The CAL as well as third parties performing recruitment and/or other employmentrelated services. Please note that The CAL may have additional privacy terms that apply to job applicants. Such terms will be made available when an applicant applies for a job or, if applicable, when an applicant otherwise accesses his or her job account. Non-Personal Information. We also collect non-personal Information about you. Non-Personal Information means information that we cannot use to identify or contact you. Browser Information and Usage Information. We log web browser information (e.g., Internet Protocol addresses and browser types) and other usage information from The CAL and otherwise via The CAL s engagement technology. Such information may include page view tallies, time spent on each page, geographic location information, organization name, page browsing information and operating system information. If you are using a mobile or other device to visit The CAL or otherwise communicate or engage with The CAL via The CAL s engagement technology, we may collect hardware information

3 related to the device used by you. The CAL may review and run reports related to the browsing and online behavior and activities of users to The CAL. The CAL maintains records of such usage and reports. Cookies. The CAL s services use cookies and other technologies such as pixel tags to collect and store information that is generated automatically as you use the services, including your preferences and anonymous usage statistics. Browsers are usually set to accept cookies. However, if you prefer not to receive cookies, you typically have the option of setting your browser to refuse cookies. If your browser is set to refuse cookies, it is possible that some of the functionality offered by The CAL will not be available or will not work as effectively for you. By providing Personal Information and other information via The CAL s engagement technology and otherwise via The CAL, you consent to The CAL collecting and processing such information for the purposes outlined in this Privacy Policy. How does The CAL use and disclose information it collects from The CAL users? General. Information collected by The CAL is used to administer your account, provide you with access to certain tools and services, and to the extent requested, prepare and deliver a certificate of CME/CE credit or participation, and provide reports and other information to certain parties regarding your participation in The CAL Transcripts, Surveys and Recordings. The CAL may use Transcripts, Surveys and Recordings for purposes of performing or delivering a service to you, providing maintenance or support services to you, for training and quality assurance purposes, for purposes of improving our services and for other lawful purposes. Third party service providers retained by The CAL to perform agent or operator services or other services on behalf of The CAL may also have access to Transcripts, Surveys and Recordings for purposes of performing or delivering a service to you, providing maintenance or support services to you, and/or for training and quality assurance purposes. Browser Information and Cookies. We use browser information, cookies and pixel tags to determine whether a chat, voice or button or other communication service should be deployed on your browser (in order to allow The CAL to offer assistance or offers to you or otherwise engage with you). We may also use browser information, cookies and pixel tags to help us adjust and improve our product and service offerings, to allow The CAL to recognize whether you are a return user, for quality assurance and training purposes, to gather broad demographic information, to administer and optimize our services, to deliver marketing or other materials to you and for other lawful purposes. Aggregate Information. We may aggregate information so that it is not Personal Information and we may use such aggregated information, and share such aggregated information with our customers and third party service providers, for training and quality assurance purposes, for purposes of delivering services to you and our other customers, for purposes of improving our services and for other lawful purposes. Third Parties. Certain third parties may provide services that connect to or leverage The CAL s services. For example, The CAL may use third party data facilities, web and data analytics providers, CME sponsors, and other third party service providers (including platform hosting) to perform services related to The CAL and services that are routinely handled by such providers. Such providers may store and, if applicable, process Personal Information and other information in keeping with the services that they provide. The CAL does not divulge the content of your usage on The CAL or any Transcripts, Surveys

4 or Recordings to third parties other than to your organization and service providers performing services on behalf of The CAL, others as provided in this Privacy Policy or with your permission. The CAL does not sell, trade or rent Personal Information for direct marketing or any other purpose, except as provided in this Privacy Policy or with your permission. The CAL is not responsible for the privacy practices of any third party. Reports. From time to time, your organization or the third party who has granted you the right to register with and access The CAL, may request a report from The CAL regarding your participation and use of The CAL. This report may disclose your Personal Information you provided at registration (name, organization, and the like), your use of The CAL, the courses that you have registered for, accessed and/or completed and the results of the test you take at the end of the course, if applicable. Technical Support Requests. If you submit a technical support request via or our Live Chat function, we may use and maintain such request or Live Chat Transcript in order to respond to the questions posed, improve our product and service offerings, for training and quality assurance purposes, for record keeping purposes and for other lawful purposes. Offers. We may use Personal Information provided by you and other information in order to keep you posted on product and service offerings, important announcements, and updates to product offerings and events. We may also use such information for purposes of improving our product and service offerings, for training and quality assurance purposes, for record keeping purposes and for other lawful purposes. Promotions. From time to time, we may offer promotions on The CAL. If we do, and if you wish to participate, you may be required to provide Personal Information, such as contact information and other information. We will use and maintain such information for purposes of delivering the promotion and for purposes of improving our product and service offerings, for record keeping purposes, for data analysis purposes and for other lawful purposes. Legal Requirement to Disclose/Discretion to Disclose. The CAL may disclose your information including Personal Information if The CAL reasonably believes that disclosure: (i) is necessary in order to comply with a legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirement of any governmental authority, (ii) would potentially mitigate our liability in an actual or potential lawsuit, (iii) is necessary to enforce this Privacy Policy or our User Agreement or any other agreement in place between you and ARMS, (iv) is intended to investigate and prevent unauthorized transactions or other illegal activities, or (v) is otherwise necessary or appropriate to protect our rights or property (including our rights related to payment for services), or the rights or property of any person or entity. Special Notice to The CAL Users located in countries other than the United States. Because The CAL operates globally, we may transfer Personal Information about you within our global operations to fulfill The CAL s obligations to you, but always subject to the requirements of applicable data protection laws and this Privacy Policy. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, including those whose privacy laws may be more restrictive than U.S. law, please note that you are transferring your personal data to the United States to The CAL. By providing your personal data you consent to that transfer.

5 The CAL Community, Message Boards, Blogs. If you use any communities, groups or spaces on The CAL, you should be aware that any information you submit there may be read, collected, copied and used by other users, and could be used to send you unsolicited messages. The CAL is not responsible for the information that you choose to submit or post on any of these areas of The CAL s Website or on third party websites and The CAL is not responsible for how any such information may be used by others or responded to by others. You should think carefully before posting any Personal Information in any public forum. The CAL s privacy obligations set forth in this Privacy Policy are not applicable to your use of any community, message board or blog on The CAL or any third party website. Additional terms made available via any such community, message board and/or blog may apply to your use of any of the foregoing. How does The CAL secure and protect your information? Data transmissions over the Internet cannot be guaranteed to be fully and absolutely secure. The CAL and our services have security measures in place designed to protect against the loss, misuse and alteration of the information under our control. Our security measures include the following: Encryption and Firewalls. Chat transcripts are encrypted during transmission. Transcripts are maintained and archived on secure servers. Access to such data is protected by multi-layered security controls including firewalls, role-based access controls and passwords. Data is backed up daily and archives are stored off-site in a secure location. Third-Party Websites. The CAL is not responsible for and does not control the privacy practices of any websites owned by third parties to which The CAL may link. We encourage you to review the privacy practices to any such third party websites. New Uses of Information. From time to time, The CAL may use information for new, unanticipated uses not previously disclosed in our Privacy Policy. If our information practices change regarding information previously collected, The CAL will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law. Contacting The CAL. The CAL welcomes your feedback on our Privacy Policy. Please send your comments to calhelp@arms.org or to: ARMS, Inc., 215 Lexington Avenue, 12th Floor, New York, NY Changes to this Privacy Policy. We recommend that you review this policy periodically, as we may update it from time to time. To the extent any updates are material, we will notify you. Your use of The CAL, any service offered on The CAL or any of The CAL s engagement technology to communicate with The CAL (whether on The CAL or on a third party website) following a change to this Privacy Policy represents your consent to the new Privacy Policy to the fullest extent permitted by law. Definitions. Cookies are pieces of information that some websites transfer to a user s web browser accessing the website and are used for record-keeping purposes by many websites. Use of cookies makes web-surfing easier by performing certain functions such as saving passwords, lists of potential purchases and personal preferences regarding the use of the particular website, and ensuring that the user does not see the same ad repeatedly. Data masking is the process of obscuring (masking) specific data elements within a communication or storage device. Once data is masked the masking cannot be reversed. Encryption is the process of transforming information into unreadable text so that it is only

6 legible to those possessing an encryption key. The process of making encrypted information readable again is referred to as decryption. Pixel tags are small graphic images that are embedded in a web page or for purposes of tracking activity on web pages or whether a user has opened or accessed an . A pixel tag may be set to identify on what browser and computer it was viewed, whether that browser has cookies received from a server associated with the pixel tag, and whether the web page or with the pixel tag was forwarded or copied. Web browser is a software program that allows a user to access, retrieve and view information on the World Wide Web. Examples of browsers include Internet Explorer, FireFox, Google Chrome and Safari.