Privacy Policy
Last Updated August 13, 2024
Please see our Privacy Snapshot for a high-level overview of our privacy practices.
Cell-Ed, Inc. (“Cell-Ed,” “we,” “us,” or “our”) provides a technology and services platform to enable organizations to deliver and track digital learning across various devices (the “Service”). We have prepared this Privacy Policy to explain (1) what personal information we collect, (2) how we use and share that information, and (3) your choices concerning our privacy and information practices.
1. APPLICABILITY OF THIS PRIVACY POLICY
Scope of this Privacy Policy: This Privacy Policy addresses the personal information we collect about the following categories of individuals:
Business Contacts: Individuals who are employees, contractors or representatives of the businesses that we do business with, including but not limited to our customers and prospective customers (“Customers”); and
Website Visitors: Individuals who visit our websites (the “Websites”).
Information from Learners: In the course of providing the Service to Customers, we may collect information about individuals who download and are provided access from our Customers to use our digital application and related technology (“Learners”). This information may include:
Account Information: We collect your name, phone number, e-mail and similar personal information when you create an account to use the Service.
Survey Information: We collect certain information that you voluntarily provide to us in connection with surveys and questionnaires that we send to you on behalf of our Customers regarding your use of the Service, including but not limited to, age information, demographic information, learning progress, physical activity levels, etc.
If you are a Learner, this Privacy Policy does not apply to our processing of your personal information. In that case, the corresponding Customer will be responsible – i.e. the controller – for any personal information that we have about you and we will process your personal information in accordance with the contract we have in place with such Customer. Please contact the relevant Customer if you have any questions about the processing of your personal information and any rights you may have.
Customers are independent third parties that maintain their own business practices and policies outside of their relationship with Cell-Ed and their use of the Service. We are not responsible for the privacy policies or data practices of our Customers, who may maintain separate policies and practices.
2. PERSONAL INFORMATION COLLECTION
Business Contact Information. Cell-Ed may collect, generate and/or receive the following information from Business Contacts:
Business Contact Information: If you are a representative of one of our actual or prospective customers, suppliers or business partners, we may collect personal information about you (such as your name, contact details and role) when entering into an agreement with your company and during the course of our relationship with your company.
Marketing Information: If you have expressed an interest in our products and services, we may collect your personal information (such as your name, contact details and role) for marketing purposes.
Communication Information: We collect personal information when you contact us or otherwise interact with us, including via phone, email, post or social media. This information may include your name, contact details and details of your interaction with us.
Feedback Information: We collect personal information about you when you voluntarily respond to our questionnaires, surveys or requests for market research seeking your opinion and feedback, such as your name, contact details, job role and details of feedback you have provided.
Additional Information We Collect Automatically: If you are a Learner, Business Contact or Website Visitor, we may automatically log the following Additional Information:
Device Information: The manufacturer and model, operating system, browser type, IP address, and unique identifiers of the device you use to access the Service or Websites. The information we collect may vary based on your device type and settings.
Usage Information: Information about how you use our Service or Websites, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities. For example, we use Google Analytics, a web analytics service provided by Google LLC (“Google”) to help collect and analyze Usage Information. For more information on how Google uses this information, click here.
Location Information: We may derive a rough estimate of your location from your IP address when you visit our website or use the Service or Websites.
Email Open/Click Information: We may collect information about the date and time you open or click links in emails we send.
We use the following technologies to collect the following Additional Information by automated means:
Cookies, which are text files stored on your device to uniquely identify your browser or to store information or settings in the browser to help you navigate between pages efficiently, remember your preferences, enable functionality, help us understand user activity and patterns, and facilitate online advertising.
Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
3. PERSONAL INFORMATION USE
We use your personal information for the following purposes:
Service Delivery, including to provide, operate, maintain, and secure the Service;
Communicating with You, including to:
Send you updates about administrative matters such as changes to our terms or policies; and
Provide customer support, and respond to your requests, questions and feedback.
Service Improvement, including to:
Improve the Service and create new features;
Personalize your experience; and
Create and derive de-identified or aggregated statistics and insights.
Marketing and Advertising, including:
To send you marketing communications, including notifying you of special promotions, offers and events via email and other means.
Compliance and Protection, including to:
Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
Audit our compliance with legal and contractual requirements and internal policies; and
Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
4. PERSONAL INFORMATION SHARING
Our Sharing: We do not sell personal information. We may share personal information with:
Service Providers, including hosting services, email services, advertising and marketing services, payment processors, customer support services, and analytics services.
Professional Advisors, such as lawyers and accountants, where doing so is necessary to facilitate the services they render to us.
Business Transaction Recipients, such as counterparties and others assisting with a merger, acquisition, financing, reorganization, bankruptcy, receivership, dissolution, asset sale, or similar transaction, and with successors or affiliates as part of or following that transaction.
Government Authorities, where required to do so for the Compliance and Protection purposes described above.
Affiliates: We may share personal information with our current and future affiliates, meaning an entity that controls, is controlled by, or is under common control with Cell-Ed. Our affiliates may use the personal information we share in a manner consistent with this Privacy Policy.
5. RETENTION OF PERSONAL INFORMATION
We generally retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy. This will generally be for the duration of time you interact with us, however, there may be situations where we retain your personal information for a longer or shorter period.
6. COLLECTION AND USE OF SENSITIVE AND HEALTH-RELATED DATA
We are committed to protecting the privacy and security of our users. We collect sensitive and health-related data to enhance our services, specifically for program tracking, activity tracking, and coaching purposes. This data may include:
Sensitive Information: Data related to your interactions with our programs, progress, and feedback.
Activity Tracking Information: Usage patterns, engagement with our application, and participation in activities within the program.
Health-Related Information: Health-related data you provide or that is collected through your interactions with our services, including wellness metrics.
How We Use This Data
We use the collected data solely for improving our services and providing tailored coaching and support. This includes tracking user progress, personalizing experiences, and incorporating health-related insights.
Protection of Data
We employ industry-standard security measures to protect your data against unauthorized access, disclosure, alteration, or destruction. All sensitive and health-related data is encrypted and securely stored.
No Sharing with Third Parties
We do not share your sensitive or health-related information with any third parties. Your data is used exclusively within Cell-Ed and is not sold or traded.
7. CHILDREN
Our Service is not directed to children who are under the age of 15. Cell-Ed does not knowingly collect personal information from children under the age of 15. If we learn that we have collected personal information from a child under the age of 15 without the consent of the child’s parent or guardian as required by law, we will delete that information.
8. LINKS TO OTHER WEBSITES
The Service may contain links to other websites not operated or controlled by Cell-Ed, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.
9. SECURITY
Keeping your data secure is important. Cell-Ed follows current industry standards to protect your personal information. We take reasonable steps to protect the personal information provided to the Service from loss, misuse, unauthorized access, disclosure, alteration, or destruction. No network or email transmission is fully secure or guaranteed to be error free. We cannot guarantee the security of your personal information and you use the Service at your own risk. In particular, email sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing personal information to Cell-Ed.
10. HIPAA COMPLIANCE
Cell-Ed, along with its employees and contractors, is committed to complying with the Health Insurance Portability and Accountability Act (HIPAA) by safeguarding the security, confidentiality, integrity, availability, and privacy of Protected Health Information (PHI). Access to HIPAA and PHI data is restricted to a strict need-to-know basis. This data must be kept confidential and protected from unauthorized access, modification, and disclosure.
In the course of providing our products and services (the “Business Associate Activities”), Cell-Ed may receive, store, process, transmit, create, or access PHI, triggering HIPAA compliance requirements. To ensure compliance, Cell-Ed will:
Establish HIPAA Policies: Implement policies that outline the necessary technical, physical, and administrative safeguards to maintain the security and privacy of electronic PHI.
Define Roles and Responsibilities: Assign roles and responsibilities to ensure Cell-Ed meets its obligations concerning business associate activities and PHI.
The Cell-Ed Security, Privacy, and Trust Team, in consultation with relevant stakeholders, oversees the HIPAA Compliance Program, ensuring PHI protection at all levels:
Storage and Transmission: All HIPAA and PHI data must be encrypted with strong cryptography whenever stored on or transmitted by Cell-Ed systems.
Disposal: Paper records containing PHI must be securely shredded before disposal. Electronic media must be securely wiped, sanitized, or physically destroyed before disposal or reuse.
Awareness Training: Relevant personnel will receive training on information security and data privacy responsibilities related to HIPAA and PHI handling.
If you have any questions about our HIPAA Policy or compliance practices, please contact us at security@cell-ed.com. In the event of any unauthorized use or disclosure of HIPAA-protected information, affected parties will be notified in accordance with the HIPAA Breach Notification Rule, 45 CFR 164.400-414.
11. YOUR CHOICES
Update or Correct Personal Information: You can contact us and request any updates or corrections needed to keep your personal information accurate, current, and complete.
Opt Out of Marketing Communications: You may opt out of marketing communications by following the unsubscribe instructions in any marketing email we send you. Please note, however, that you may continue to receive communications, including updates about administrative matters such as changes to our terms or policies; to provide customer support, and respond to your requests, questions, and feedback after opting out of marketing communications.
Personal information requests. Depending on your location and the nature of your interactions with us, you may request the following in relation to your personal information:
Information about how we have collected and used your personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily-usable format.
Correction of personal information that is inaccurate or out of date.
Deletion of personal information that we no longer need for lawful purposes.
To exercise the above rights, please contact us as provided in the “Contact Us” section below. We will not discriminate against you for exercising any of these rights. Prior to responding to your requests, we may verify your identity by matching any requested identifying information you provide against the information we have about you. If you are in California, you may designate an authorized agent to make a request on your behalf. We will require the authorized agent to have a written authorization confirming that authority.
In some instances, these rights may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights.
Limit online tracking: Here are some of the ways you can limit online tracking:
Block cookies. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Use the following links to learn more about how to control cookies and online tracking through your browser:
Limit the use of advertising ID. You may be able to limit use of your mobile device’s advertising ID for interest-based advertising purposes through your device’s settings.
Use privacy plug-ins or browsers. You can block cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers. You can also install a browser add-on to opt out of Google Analytics.
Advertising industry opt-outs. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
Platform opt-outs. The following advertising platforms offer opt-out features that let you opt out of use of your information for interest-based advertising:
Note that the above opt-out mechanisms are specific to the device or browser on which they are exercised. You will need to opt-out on every browser and device that you use.
Do Not Track. We currently do not respond to “Do Not Track” or similar signals. Learn more about “Do Not Track” here.
12. CHANGES TO THE PRIVACY POLICY
The Service and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by applicable law. By continuing to use our Service or providing us with personal information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and the practices described in it.
13. CONTACT US
If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address: security@cell-ed.com.
Privacy Snapshot
Here is a high-level snapshot of our privacy practices, but you need to read the entire Privacy Policy for complete information.