Privacy Policy

EHR GO Privacy Policy

 

Last updated: October 17, 2023

Privacy is important to everyone. At EHR GO, we care about your privacy as well and want you to feel comfortable and secure in your use of our websites (including all related EHR GO webpages, websites or other online services such as any mobile app we may offer, the “Sites”) and any dealings you have with us offline. The purpose of this Privacy Policy is to describe for you the types of information we collect from you and how we store and use that information. By viewing and using the Sites, you are, to the extent permitted by applicable law, accepting this Privacy Policy with respect to information collected by the Sites.

If you are under the age of 18, you have certain additional rights with respect to the removal of Content which you may provide to the Sites. These rights are set forth in Section 16 below.

 

Please Note: This Privacy Policy may be modified at any time so you should visit this page periodically to check for updates. The current version of this Privacy Policy can always be found under the Privacy Policy button on the Sites. You can tell if there have been changes to the Privacy Policy by checking the “Last Updated” date at the top of this page.

 

The key items the privacy policy addresses include:

  • Categories of Personal Information We Collect
  • Personal Information in Publicly Accessible Areas
  • How We Collect Personal Information Directly From You
  • How We Collect and Use Information About Your Use of the Sites
  • How We Collect and Use Personal Financial Information
  • How We Use Personal Information and Learner Records
  • When We Disclose Personal Information to Third Parties Who May Offer Products or Services that May be of Value to You.
  • When We Disclose Personal Information to Partners in Education
  • When We Disclose Personal Information to Employers or Sponsors
  • When We Disclose Personal Information to Contractors and Service Providers
  • When We Disclose Personal Information to Licensing, Certifying and Accrediting Organizations
  • Disclosures of Personal Information in Litigation, Investigations or Enforcement Actions or for Security Reasons
  • Disclosures in Conjunction with a Change in Control or Similar Event.
  • Your Access Rights
  • Children’s Privacy
  • Information Security and Storage
  • Rights to Opt Out of Online Communications
  • Additional State Disclosures
  1. Categories of Personal Information We Collect. Depending on the Sites you use and your interactions with us, we collect the following categories of Personal Information about you:
  • Identifiers, such as name, number of children in household, age of children, housing type, transportation, hobbies, and employment), contact details (e.g., phone number, email address, postal address);
  • Demographics, such as age, date of birth, gender, marital status, and primary language;
  • Education Information such as course assignment work, exams, academic records, confidential enrollment information, prior education, and learners’ personal, program-related communications with EHR GO;
  • Internet or other electronic network activity information, such as browser versions, internet domain, your computer’s operating system pages most visited, duration and time of visit, the links you followed to enter and leave our site, your IP address as well as standard fields from our web log reporting software;
  • Geolocation information;
  • Inferences, such as those reflecting your preferences, characteristics, abilities, or aptitudes;
  • Sensitive Personal Information, as defined under applicable local law, such as certain demographic information, including your ethnicity, account login credentials and passwords, social security number, financial account information, medical or health insurance information, and credit card or debit card information.

In addition, EHR GO generates, collects and stores, through its learning management systems, additional information and materials personal to or provided by learners enrolled in EHR GO programs, such as inferences drawn from any of the information identified above (collectively, “Learner Records”). Please note that EHR GO uses automatic logic to ensure that prospective learners meet any prerequisite enrollment requirements such as age and/or minimum educational attainment to make admissions decisions depending on the program that the prospective learner would like to enroll in.

Information from Third Parties: We may also collect Personal Information about you from third parties, as well as our affiliate sister companies1 to perform certain functions such as collections activities or to customize our marketing efforts.

The information we collect depends upon how you interact with us. Note that we may be required by law to collect certain information about you or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfillment of these obligations

  1. Personal Information in Publicly Accessible Areas. Some interactive portions of our Sites are open and visible to the larger public and/or people and entities engaged in providing or supporting EHR GO programs. If you include personally identifying information in materials you contribute to the Sites, via postings, chat rooms, or otherwise, that Personal Information will be available to members of the larger public. We therefore strongly encourage you not to include personally identifying information in your interactions in public forums made available through the Sites, such as in postings or in chat rooms, or in your Username.

 

  1. How We Collect Personal Information Directly From You. We collect Personal Information that you voluntarily provide to us. For example, when you register as a User on the Sites in order to participate in the Sites activities, we ask you for Personal Information such as your name, email address, and telephone number. We may also collect this information if you contact us requesting information, participate in or provide feedback on the Sites or Site activities, or forward information from the Sites to internet addresses outside of the Sites. In addition, if you are a learner, we collect and store your Learner Records consistent with our business practices, certifying and licensing institutions, and applicable United States and state laws and regulations.

 

  1. How We Collect and Use Information About Your Use of the Sites. We and our third party business partners use common tracking tools such as cookies, clear GIFs (also referred to as web beacons or pixel tags), device identifiers or IP addresses to collect information about your use of the Sites. These tools, described in more detail below, are associated with standard internet protocols and are commonly implemented on web sites. The information collected through these tools is primarily used for aggregate, statistical reporting and stored in log files. Log files are simply transaction records that web servers maintain and record information, such as: service provider IP addresses, browser versions, referring websites, search terms used, average number of pages requested, average duration of visit, and/or total visitor traffic.
  • Cookies are small files web sites place on your hard drive that allow sites to identify you. For example, if you allow a site to remember your login name or password, the site places a cookie on your computer. Cookies cannot read any other information on your hard drive. If you do not wish to receive cookies or want to be notified of when they are placed, your browser may permit you to do so.
  • GIFs can tell us whether you have visited a Web page or received or opened a message we send to you.
  • An IP address is a number that’s automatically assigned to your computer by your Internet service provider whenever you’re on the Internet. In addition to logging your IP Address, our server may also record the referring page that linked you to us (e.g., another web site or a search engine); the pages you visit and how long you stay on the Sites; and other Web usage activity and data. In some cases, your IP address stays the same from browser session to browser session; but if you use a consumer internet access provider, your IP address probably varies from session to session.

The information we collect about your use of the Sites may be used to measure the Sites’ traffic, help us to evaluate and improve the Sites, provide data points for marketing and business analysis, and better serve our Users. It is in our legitimate interests to evaluate and improve the Sites so that we may better serve our Users. Our third party business partners, such as analytics and advertising partners, may also use these technologies to collect information about your online activities over time and across different services.

 

  1. How We Collect and Use Information from Other Sources. We may also collect Personal Information about you from other sources, such as third parties and our corporate affiliates, to perform certain functions such as collections activities or to customize our marketing efforts.

 

We may use third parties to show you EHR GO ads when you visit different sites on the internet. These third parties use cookies to collect information and show ads based on your prior visits to the EHR GO website. You can opt out of the use of cookies by these third parties by visiting the Network Advertising Initiative opt-out page or the Digital Advertising Alliance opt-out page. You can opt out of the use of cookies generally by having your browser disable cookies or warn you before accepting a cookie. However, opting out of these third parties’ use of cookies or the use of cookies generally may impact your user experience. For more information on cookies, including how you can delete or reject cookies, please refer to your web browser help file.

  1. How We Collect and Use Personal Financial Information. We collect Personal Financial Information you provide only when you are applying for or enrolling in a EHR GO academic program, purchasing products or services from EHR GO, or involved in other financial transactions with EHR GO, and we use this information only in connection with your application, enrollment, purchases and other financial transactions. We collect this information so we can comply with our contractual obligations to you or interact with you in furtherance of initiating a contractual arrangement (e.g., if you are applying to enroll) and so that we can comply with our legal obligations. Personal Financial Information is retained by EHR GO as required by law and its internal business practices. If you are not currently enrolled in a EHR GO program and have no outstanding, pending, or contractual financial obligation to EHR GO, you may ask that we delete your financial information and we will do so subject to legal, regulatory, and licensing obligations.
  2. How We Use Personal Information and Learner Records. We use your Personal Information for our business purposes in multiple ways:
  • Deliver products and perform services you purchase. This is so we can comply with our contractual obligations to you or engage in pre-contractual measures (e.g., if you apply to enroll in one of our programs).
  • Respond to your requests for information. It is in our legitimate interests to respond to your requests for information.
  • Contact you regarding products and services in which we believe you may be interested. It is in our legitimate interest to provide relevant and interesting advertising messages. Where necessary, we will obtain your consent before sending such marketing messages.
  • Notify you about community events and activities. It is in our legitimate interests to notify you about events and activities that may be of interest to you.
  • Ask you questions about your interests and your experience on the Sites. It is in our legitimate interests to learn more about your experience with the Sites.
  • To perform proactive outreach to encourage and engage you in your studies
  • To offer savings opportunities and/or promotional items only available to EHR GO learners

By supplying your contact information when requesting information or signing up in one of our courses, you authorize EHR GO and its agents (outsource calls centers and academic partners) to contact you (using the information you provide to us) about EHR GO or its agents’ products and services, including product releases and updates, seminars, events, surveys, trainings, and special offers. You can opt out of future communications from EHR GO by sending an email to [email protected] or calling 1-800-246-7837.

Additionally, if you are a EHR GO learner, we may also use your Personal Information including Learners Records to:

  • Support and monitor your progress through the program in which you are enrolled. We do this so we can comply with our contractual obligations to you.
  • Offer you various learner support services. It is in our legitimate interests to offer support to our learners.
  • Ask you questions regarding your satisfaction with the program. It is in our legitimate interests to learn more about your experience with the program.
  • Maintain your academic records. We do this so we can comply with our contractual obligations to you.
  • Complying with our obligations. We process your Personal Information to, for example, carry out fraud prevention checks or comply with other legal, accreditation or regulatory requirements, where required by law or where in our legitimate interests to do so.
  • Maintain close communications with you in order to provide you with a rich, fulfilling and personalized academic experience. It is in our legitimate interests to communicate with our learners and provide a personalized learning experience.

We do not use or disclose sensitive Personal Information for purposes other than permitted under applicable local law.

 

We may aggregate and/or deidentify your Personal Information and use it for any purpose, including product and service development and improvement activities. To the extent we deidentify any data originally based on Personal Information, we will maintain and use such data only in deidentified form and will not attempt to reidentify the data.

 

  1. When We Disclose Personal Information to Third Parties Who May Offer Products or Services that May be of Value to You. We may provide your Personal Information (exclusive of Learner Records) to third parties, including our affiliates, who offer products or services we believe may be of value to you. Within the preceding 12 months, this may include identifiers, such as your email address. Such third parties are only allowed to use your Personal Information to contact you regarding those products or services and you are able to “opt out” from receiving such contacts at any time through the “opt out” procedures of those third parties. (See also Section 21 (“Rights to Opt Out of Online Communications”) below).
  2. When We Disclose Personal Information to Partners in Education. EHR GO often collaborates with school districts, individual schools, colleges and universities, vocational schools, organizations like the Job Corps, and other private educational or education-related programs (each an “Educational Partner”) to provide a broad range of educational programs responsive to different types of learners’ requirements. We may disclose Personal Information, including Personally Identifying Information, Learner Records and Personal Financial Information of learners enrolled in these collaborative or partnership education programs to the associated Educational Partner. Within the preceding 12 months, this may include identifiers, educational records, and certain financial information.
  3. When We Disclose Personal Information to Employers or Sponsors. We may share program progress, completion status and scores with employers or potential employers with whom a learner has applied or expressed interest; sponsor paying all or part of the learner fees; third party resolution agencies; third-party organizations through whom a learner has signed up with EHR GO. We may share financial status (fee balance) with a sponsor who is paying all or part of learner fees.
  4. When We Disclose Personal Information to Contractors and Service Providers. We may use third parties (including contractors, business partners, investors and their representatives, and service providers) to help us with certain aspects of our operations and this may require disclosure of your Personal Information to them. Within the preceding 12 months, this may include identifiers, demographics, education information, internet activity, geolocation information, inferences, and sensitive Personal Information as that term is defined under applicable law. For example, we use third party financial institutions to help us process payments and we may use third party agencies to help us with debt collection. We may also use third parties to help us to operate the Sites, deliver products and provide learner services. We expect these third parties to use your Personal Information only as necessary to perform the services they are asked to perform.

 

  1. When We Disclose Personal Information to Licensing, Certifying and Accrediting Organizations. From time to time EHR GO will seek additional certifications, accreditations and similar confirmations of quality and eligibility from third party institutions. EHR GO may disclose Personal Information to each of these accrediting, certifying and licensing bodies as reasonably required to maintain, renew or establish EHR GO’s accreditation, licenses, certifications and other institutional qualifications. Within the preceding 12 months, this may include identifiers, demographics, and education information. All such bodies are committed to maintaining the confidentiality of learner Personal Information.

 

  1. Disclosures of Personal Information in Litigation, Investigations or Enforcement Actions or for Security Reasons. We may disclose your Personal Information when compelled or requested to do so by government or law enforcement authorities or when otherwise required or permitted by law, such as to respond to court orders and subpoenas or regulatory agency requests. We also may disclose Personal Information when we have reason to believe that someone is causing or threatening to cause injury to, or interfering or threatening to interfere with, the rights or property interests of EHR GO or its affiliates (or their respective employees, agents, consultants, contractors or representatives), EHR GO learners or alumni, other Site Users, EHR GO business partners (including Education Partners and service providers), accrediting/licensing/certifying bodies, or other persons or entities that could be harmed by such activities.

 

  1. Disclosures in Conjunction with a Change in Control or Similar Event. If EHR GO undergoes or contemplates undergoing a business transition, such as a merger or acquisition by another company, or a sale of all or a substantial portion of its assets, your Personal Information may be among the assets transferred or subject to new ownership. Changes in the terms governing the collection, storage or use of any third party successor in interest or transferee of your Personal Information will be communicated to you by EHR GO or such third party via email, the applicable website, or a comparable means notification.

 

  1. Your Access Rights. You may review and correct the Personally Identifying Information that is retained by EHR GO in your account after you login. You may review and correct the Personal Financial Information that is retained by EHR GO in your account by contacting EHR GO at [email protected]. If you are a learner, you may also review your Learner Records through your Learner Portal account or by contacting EHR GO at [email protected]. For information relating to rights you may have under applicable state law, see the Additional State Disclosures Section below.
  2. Children’s Privacy. The Sites do not knowingly collect information from (a) children under the age of 13 and does not offer products, services or activities targeted at children under the age of 13, or (b) individuals older than 13 but under the age of legal majority in their state of residence whose registration or participation on the Sites has not been authorized by their parent or legal guardian. If you have reason to believe that a child has provided personal information to us, please contact us and we will attempt to remove that information from our databases.

 

  1. Special Rule for Site Users under 18. If you are under the age of 18, you may at any time request EHR GO to remove from the Sites any Content (as defined in the Site Terms of Use) you provide to or post on the Sites by sending your request to [email protected]. However, please understand that EHR GO’s removal of such Content may not be complete or comprehensive. Removal of Content may be limited to making Content no longer visible to the public or other Site Users. In addition, EHR GO reserves the right not to remove Content you have provided if EHR GO is required to maintain the Content pursuant to federal or state legal requirements, if the Content has been independently provided to the Site by a third party, if the Content is anonymized, or if you have been compensated for providing the Content to the Sites. Any Personal Information and Learner Records retained by EHR GO will continue to be governed by the terms of this Privacy Policy.

 

  1. Third Party “Linked-To” Web Sites. The Sites may contain links to third party web sites which are neither operated nor controlled by EHR GO. This Privacy Policy does not address the information practices of those third-party web sites, and we encourage you to read the legal notices posted on such websites, including their Terms of Use and Privacy Policies. To be clear, EHR GO has no responsibility or liability for your experience with, and the data collection and use practices of, such third-party websites. All inquiries concerning the terms and policies of third-party websites should be addressed to the third party hosting the respective website.
  2. Information Security and Storage. The protection of your Personal Information is very important to us. To that end, we take reasonable steps to protect the Personal Information you share with us from unauthorized access or disclosure. However, you should know that no security measures are impenetrable and no company, including EHR GO, can fully eliminate security risks to its telecommunications and computer systems. In addition, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet, will not be destroyed, hacked, hijacked, misdirected, stolen, modified or otherwise interfered with or misused. Accordingly, your transmission of information to or through the Sites is at your own risk.
  3. Retention Period. We retain your Personally Identifying Information, Personal Financial Information, and Learner Records for as long as we have a relationship with you. When deciding how long to keep this information after our relationship with you has ended, we take into account our legal obligations. We also retain records to investigate or defend against potential legal claims. If there is any information that we are unable to delete entirely from our systems for technical reasons, we will put in place appropriate measures to prevent any further processing or use of the data.
  4. Rights to “Opt Out” of Online Communications. If you are receiving emails, texts or similar online communications from EHR GO, it is because you consented or we understood from your participation on our Sites that you were interested in receiving ongoing information from us. If at any point you no longer wish to receive such communications, you may at any time “unsubscribe” from these communications by following the ‘opt out’ directions to be found at or near the end of the communication. Learners can also “opt out” from certain communications on the Learner Portal by editing their personal account preferences. If you have any questions about the opt-out process, you can contact us at [email protected]. Please note that if we have already shared your personal contact information with one of our business partners, unsubscribing from our communications list will not prevent these third parties from continuing to email or text you. You will have to send an opt-out request to those third parties directly. Opportunities to “opt out” from receiving emails and texts are usually found on these companies’ websites or at the end of their emails or texts.
  5. Additional State Disclosures. This section provides information required under various state privacy laws about how we handle certain personal information we have collected, used, and disclosed.

 

Collect. As we describe in more detail in the section above titled Categories of Personal Information We Collect, we collect personal information online and offline directly from consumers, automatically when consumers use the EHR GO website or contact EHR GO by phone, and from third parties (such as from our sister companies) and have collected the following categories of personal information in the past 12 months:

 

  • Identifiers, such as your name, email address, or IP address.
  • Information that identifies, relates to, describes, or is capable of being associated with you, including your address or phone number (and other data elements listed at Cal. Civ. Code 1798.80(e))
  • Commercial information (e.g., records of products or services purchased, obtained, or considered).
  • Protected classification characteristics under California or federal law, such as age.
  • Internet or other similar network activity, such as information on your use of the EHR GO website.
  • Geolocation data.
  • Audio, electronic, visual, thermal, olfactory, or similar information.
  • Professional or employment-related information.
  • Sensitive information, as defined under applicable law, such as your Social
  • Social security number, demographic information, account login credential and passwords, and credit card or debit card information.

 

Use. The section above entitled Use of Information discloses how the categories of personal information we collect are used.

 

Disclose. As we describe in more detail in the above Disclosure sections, we may disclose the following categories of your personal information for business purposes with funding services, payment processing services, background check services, placement/externship services, and employment/hiring partners, advertisers and affiliate sister companies, or other business partners: (1) identifiers, (2) information that identifies, relates to, describes, or is capable of being associated with you, including your address or phone number (and other data elements listed at Cal. Civ. Code 1798.80(e)), and (3) professional and employment-related information. We may also disclose the following categories of personal information for business purposes with advertisers: (1) identifiers and (2) Internet or other similar network activity. We do not use or disclose sensitive Personal Information for purposes other than permitted under applicable local law.

 

Certain laws also require us to provide you with information about certain disclosures of personal information to third parties, where the disclosure involves monetary or other consideration. Some laws treat these disclosures as “sales” of information, even if no money changes hands. Some of the disclosures we have made in the last 12 months may constitute “sales” or “sharing” for cross-contextual behavioral advertising under local law and involve the disclosure of the following types of personal information to partners, advertisers, and our affiliate sister companies: (1) identifiers; (2) information that identifies, relates to, describes, or is capable of being associated with you, including your address or phone number (and other data elements listed at Cal. Civ. Code 1798.80(e)), (3) professional and employment-related information; and (4) Internet or other similar network activity. We disclose this information to contact you regarding products and services in which we believe you may be interested, including through personalized marketing and advertising.

 

Under applicable local law,

you may have certain additional rights regarding the Personal Information we hold about you. Depending on where you live, and subject to certain exceptions, you may have the right to make the following requests, at no charge:

 

 

  • Copy: You may request, up to twice every 12 months, a copy of the specific pieces of Personal Information that we have collected, used or disclosed about you in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows you to transmit this information to another entity without hindrance.
  • Correct: You may request the correction of your Personal Information that we have collected about you if it is inaccurate or incomplete.
  • Deletion: You may request the deletion of your Personal Information that we have collected about you.
  • Know: You may request that we provide certain information about how we have handled your Personal Information, including the categories and sources of Personal Information we collect, the purposes for which we collect and disclose that information, and the categories of third parties to whom we disclose that information for a business purpose as well as the associated categories of disclosed Personal Information.

 

To exercise any of these rights, please submit your request by either calling 1-800-246-7837 or emailing EHR GO at [email protected]. We may need to verify your identity before completing your rights request by, for example, requesting additional information from you. You may designate an agent to make a request on your behalf. That agent must have access to your account in order for us to verify the request. The agent must also provide proof that you gave the agent signed permission to submit the request on your behalf.

 

You may also have a right to appeal a decision we make relating to requests to exercise your rights under applicable local law. To appeal a decision, please contact us by emailing [email protected].

 

You may also have the right to opt out of the use of your Personal Information for targeted advertising, as that term is defined under applicable law. ou may exercise your right to opt out of the use of your personal information by clicking here and following the instructions.

 

Where applicable, you may exercise your right to opt out of “sales” by clicking this Do Not Sell or Share My Personal Information link and following the instructions. We do not knowingly “sell” or “share” personal information from consumers under 16 years old.

 

Non-Discrimination. We will not discriminate against you, including by denying or providing a different level or quality of goods or services should you choose to exercise your options under applicable state law.

 

Please contact us at the contact information below, if you have any questions regarding this Section.

  1. Construction of Privacy Policy. This Privacy Policy supersedes any other representations, agreements, statements or understandings with respect to the terms pursuant to which EHR GO collects, stores and uses information relating to you which is collected by the Sites. This Privacy Policy may not be modified, extended, limited, waived or terminated except with the written consent of EHR GO. If any portion of this Privacy Policy is deemed void or unenforceable, then that provision shall be deemed severable from the Privacy Policy and the remaining terms shall remain in full force and effect. The word “including” shall be construed to mean “including but not limited to.”
  2. Modification to Privacy Policy. As noted above, EHR GO reserves the right to modify this Privacy Policy at any time and will notify Users by posting the modified version of its Privacy Policy on this webpage. Under certain circumstances, we may also elect to notify registered Users of changes or updates to this Privacy Policy by additional means, such as posting a notice on the front page of the Sites or by sending you an e-mail but you should not rely on receiving such additional notice.

 

SECURITY

 

EHR GO website(s) have security measures in place to protect against the loss, misuse, and alteration of the information under our control. We utilize industry standard SSL encryption when accepting your credit card information during the online sign-up process.

QUESTIONS or CONCERNS? EHR GO is the controller responsible for the Personal Information it processes about you. If you have any questions or concerns about this Privacy Policy or its application, or for general questions about the Sites, please contact EHR GO at [email protected].

 

The EHR GO sister companies include Penn Foster High School, Penn Foster Career School, Penn Foster College, ICS Canada, the New York Institute of Art and Design, the New York Institute of Photography, Ashworth College, James Madison High School, PCDI Canada, ACLS, CareerStep, and Sokanu.

FAQs

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