PRIVACY POLICY
Last
Updated: June 30, 2008
Success
Continuing Education (SCE).com, an Internet property of Success Continuing
Education (SCE) LLC (“Success Continuing Education (SCE),” “us” or
“we”), has created this privacy policy (the “Privacy Policy”) in order
to disclose our information gathering and dissemination practices. We
understand the importance that Internet users place on privacy and have designed
our website with this in mind. Success Continuing Education (SCE) is fully
committed to 100% permission-based marketing. You agree to this Privacy Policy,
in its entirety, when you: (1) access or use our website located at www.SuccessCE.com,
www.AffordableCE.com, www.FirstChoiceCE.com,
and www.ClienTellCE.com, (the
“Website”); (2) agree to receive e-mail from us; (3) obtain, or attempt to
obtain, a quote regarding the usage of Success
Continuing Education (SCE) materials; and/or (4) obtain, or attempt to obtain,
information and/or services from Success Continuing Education (SCE) at this
Website or at a website belonging to an affiliate of Success Continuing
Education (SCE) or (items (3) and (4) shall be referred to collectively as, the
“Service”).
1.
This Privacy Policy will address the following:
2.
What information this Website gathers/tracks about you.
3.
What this Website does with the information that it gathers/tracks.
4.
With whom this Website shares the information that it gathers/tracks.
5.
This Website's opt-out policy.
6.
This Website's policy on correcting and updating personally identifiable
information.
7.
This Website's policy on deactivating your name from our database.
SUCCESS
CONTINUING EDUCATION (SCE) IS NOT A COVERED ENTITY FOR PURPOSES OF THE HEALTH
INSURANCE PORTABILITY AND ACCOUNTABILITY ACT OF 1996 (“HIPAA”), NOR IS THE
INFORMATION PROVIDED BY YOU TO SUCCESS CONTINUING EDUCATION (SCE) CONSIDERED
PROTECTED HEALTH INFORMATION UNDER HIPAA. AS SUCH, THE ADDITIONAL PRIVACY
AND SECURITY PROTECTIONS AFFORDED TO CONSUMERS/PATIENTS UNDER HIPAA ARE NOT
CONTEMPLATED BY, NOR CONTAINED WITHIN, THIS PRIVACY POLICY.
For purposes of compliance with the Gramm-Leach-Bliley Act, 15 U.S.C. 6802 (the “GLB Act”), the California Financial Privacy Act (“CFPA”) and the Vermont Fair Credit Reporting Act, 8 V.S.A. 10202 (“VFCRA”), this Privacy Policy shall serve as both your initial customer relationship and annual "Privacy Notice" as defined under the GLB Act, CFPA and VFCRA, respectively. If you would like to opt-out from the disclosure of your personal information to any third-party for marketing purposes, please send an email to info@successce.com with subject "unsubscribe".
Information
Collected
Online
Registration/Application
We provide an online application and/or information request forms to process
your request for Service. Understand that the information that you submit is
voluntary, but required if you request Service, whether or not you enter into a
formal application with Success Continuing Education (SCE). The
information submitted in connection with your registration/application, the
information regarding your transactions with Success Continuing Education (SCE)
and any and all other information that Success Continuing Education (SCE)
collects, confirms or gathers in connection with your registration/application,
or otherwise, both online and offline, is referred to, collectively, herein as
"Personal Information." Upon registration, you may be required to
provide all or some of the following Personal Information: (1) name; (2) gender;
(3) e-mail address; (4) mailing address; (5) daytime telephone number, nighttime
telephone number and/or cellular telephone number; (6) birth date; (7)
information regarding your Broker/Dealer, General Agency, or other company
affiliations; (8) information regarding your license numbers; (9) Social
Security Number, or last four digits of your SS #; and (10) answers to various
eligibility questions, including providing credit card #’s and additional
information. We do not store nor retain credit card #’s. For purposes of
this Privacy Policy, items (7) through (10) in the preceding sentence shall be
referred to, collectively, as “Sensitive Information.”
Success
Continuing Education (SCE) reserves the right to transfer and/or sell aggregate
or group data about Success Continuing Education (SCE) users for lawful
purposes. Aggregate or group data is data that describes the demographics,
usage or other characteristics of Success Continuing Education (SCE) users as a
group without disclosing personally identifiable information. Subject to
applicable state and federal law, by submitting your Personal Information to,
and/or using, the Website, you agree to allow Success Continuing Education (SCE)
to transfer and/or sell such aggregate data to third-parties.
IP
Addresses
We use your IP address to help diagnose problems with our server, and to
administer our Website. Your IP address is used to gather broad and specific
demographic information as well as for validation purposes.
Cookies
We use cookies to deliver content specific to your interests, to save your
password so that you do not have to re-enter it each time that you visit our
Website (if you choose), and for other purposes.
Web
Site Tracking Software
Web servers, or those of third-party vendors, are able to utilize certain
tracking software to capture your domain name address (the address of your
Internet Service Provider) for purposes of tracking Website statistics.
Note that we only collect information about you when you voluntarily provide
that information through an application or registration, by visiting the Website
request form, or some other Website activity that we may provide from time to
time. The capture of your domain name is a common practice among websites
for measuring the number of hits, pages visited, and length of user session. We
use this information to measure the effectiveness of the Website offerings in
order to service you better.
Sharing
of Information
In order for us to service your requests, process your applications and conduct
business from day-to-day, we must occasionally share your Personal Information
with other companies. These companies may include, but are not limited to,
state departments of Insurance, regulatory and designation granting authorities,
as well as affiliated Continuing Education providers. We reserve the right
to share this Personal Information in accordance with the terms of HIPAA, the
GLB Act, for California State residents only, the CFPA and, for Vermont State
residents only, the VFCRA. For purposes of compliance with the GLB Act,
CFPA and VFCRA, Success Continuing Education (SCE) will not share “non-public
personal information” with its affiliates or non-affiliates without providing
customers with an annual “Privacy Notice” explaining that Success Continuing
Education (SCE) will be sharing this non-public personal information with
affiliates or non-affiliates of Success Continuing Education (SCE) and, for
purposes of the GLB Act, providing customers with the opportunity to opt-out
from such disclosures. Notwithstanding the foregoing, the non-public
personal information of California State residents shall not be shared by
Success Continuing Education (SCE) with third-parties unless: (1) Success
Continuing Education (SCE) has obtained a fully executed consent acknowledgement
from the applicable California resident; or (2) the California resident already
has a relationship with a non-affiliated financial institution pursuant to, and
as defined under, the CFPA. To fully execute a CFPA consent
acknowledgement, please send an email to info@successce.com.
For purposes of compliance with the VFCRA, Success Continuing Education (SCE)
will not share “non-public personal financial information” (as defined in
the VFCRA) with third-parties without providing Vermont State residents with an
annual notice explaining that Success Continuing Education (SCE) will be sharing
this non-public personal information with non-affiliated third-parties.
Notwithstanding the foregoing, the non-public personal financial information of
Vermont State residents shall not be shared by Success Continuing Education (SCE)
with non-affiliated third-parties unless: (a) Success Continuing Education (SCE)
has obtained authorization from the applicable Vermont resident; provided,
however, that such authorization must be in written form, or where the
applicable Vermont resident agrees, electronic form; (b) the disclosure is made
to third-parties for the sole purpose of processing transactions or other
related processes on behalf of Success Continuing Education (SCE); and/or (c)
the disclosure is made to third-parties that market Success Continuing Education
(SCE)'s own products and services to its customers. To fully execute a
VFCRA authorization, please send an email to info@successce.com.
We
use the Personal Information that you supply to personalize your experience with
the Website, to evaluate whether you are qualified for the Service and for
verification purposes. The Personal Information that you submit to Success
Continuing Education (SCE) remains your property, but by submitting that
Personal Information to Success Continuing Education (SCE), you grant Success
Continuing Education (SCE) the right, subject to applicable state and federal
law, to use that Personal Information for marketing purposes. By agreeing
to this Privacy Policy, you authorize Success Continuing Education (SCE) to use
your Personal Information to obtain other information about you from
third-parties where such information was either not requested on the applicable
registration form, or where such registration form was incompletely or
improperly filled out. Such third-parties include, but are not limited to,
state departments of insurance (DOIS), regulatory and designation authorities,
FINRA, and other outside parties as permitted or required by applicable laws.
Any and all Sensitive Information that we collect as part of your Service
application, and from third-parties, will be used to determine your eligibility
for the Service only and will not be shared with third-parties other than who
are involved in the processing of certificates, posting CE hours, courses, and
credits earned, broker/dealers, general agencies and product distribution
companies, as applicable, for purposes of evaluating your qualifications.
If you choose to provide information such as your Social Security Number, or
authorize us to obtain your Social Security Number on your behalf, we may use
that information for any other lawful purposes. If you do not provide such
information, we may also use other information that you provided for the purpose
of verifying your eligibility for continuing education credits or for any other
programs, offers or services applied for by and through the Website.
Subject
to restrictions contained in applicable state and federal law, we may sell
Personal Information (other than: (i) Sensitive Information; (ii) where you have
opted-out from the use of such information; (iii) where we have not received
your authorization or met the requirements of an exception under the VFCRA, if
you are a Vermont State resident; and (iv) where we have not received your
acknowledgement and consent or met the requirements of an exception under the
CFPA, if you are a California State resident;) and/or join together with other
businesses to bring selected opportunities to our customers. Success
Continuing Education (SCE) is able to offer its Service to you, in part, based
on your willingness to be reached by our third-party advertisers. This
information may also be shared with advertisers on an aggregate basis. We
also use contact information from your registration data to send you information
about Success Continuing Education (SCE) and to keep you informed of our other
products and services that may be of interest to you. Please keep in mind,
though, that Success Continuing Education (SCE) does not control, and is not
responsible for, the practices of our third-party advertisers. Your
contact information is also used to reach you, when necessary, regarding issues
concerning your use of the Website. If you wish to stop receiving future
communications from us and/or third-party advertisers, or if you wish to prevent
the transfer and/or sale of your Personal Information to third-parties (subject
to restrictions contained in applicable state and federal law), please see the
Opt-Out/Unsubscribe section below.
By
submitting your e-mail address at the Website and/or submitting an application
for the Service, you agree to receive information from Success Continuing
Education (SCE) and/or its corporate affiliates. You also agree that by
submitting your e-mail address at the Website, you may receive e-mail marketing
from Success Continuing Education (SCE) (including other Success Continuing
Education (SCE) properties) and our third-party advertisers.
In
addition, you agree that such act constitutes a purchase, an inquiry and/or an
application for purposes of the Amended Telemarketing Sales Rule, 16 CFR §310
et seq. (the “ATSR”). With respect to the ATSR, and notwithstanding
that your telephone number may be listed on the Federal Trade Commission's
Do-Not-Call List, Success Continuing Education (SCE), affiliated companies, and
third party organizations, retain the right to contact you via telemarketing in
accordance with the terms of the ATSR. Moreover, by registering with, or
requesting information from, a third-party advertiser at or through the Website,
such action shall constitute a purchase, an inquiry and/or an application with
the respective third-party advertiser for purposes of their compliance with the
ATSR and you may be contacted via e-mail, direct mail and/or telemarketing by
such third-party advertiser in accordance with the terms of the ATSR.
Success
Continuing Education (SCE) reserves the right to release current or past user
information and Personal Information: (A) in the event that we believe that the
Website and/or the Service is being or has been used in violation of the Website
Terms and Conditions or to commit unlawful acts; (B) if the information is
subpoenaed; or (C) if Success Continuing Education (SCE) is sold or acquired.
Moreover, you hereby consent to disclosure of any record or communication to any
third-party when Success Continuing Education (SCE), in its sole discretion,
determines the disclosure to be appropriate including, without limitation,
sharing your e-mail address with other third-parties for suppression purposes in
compliance with the CAN-SPAM Act of 2003, as amended from time to time.
Other
Websites
This Website may contain links to other third-party owned and/or operated
websites. In some cases, you may be able to make a purchase through one of
their third-party websites. In these instances, you may be required to
provide certain information, such as a credit card number, to register or
complete a transaction at such website. These third-party websites have
separate privacy and data collection practices and Success Continuing Education
(SCE) has no responsibility or liability relating to them. Additionally, some
third party departments of insurance, regulatory and designation authorities and
others that are involved in the processing, funding and reporting of your CE
information, as well as broker/dealers, general agencies, professional
organizations, and marketing partners may require the transfer of some or all of
the Personal Information that you supplied to Success Continuing Education (SCE).
When necessary, Success Continuing Education (SCE) provides this information to
those third parties that are involved and our marketing partners (subject to
restrictions contained in applicable state and federal law). Success
Continuing Education (SCE) is not responsible for the privacy practices of these
third party underwriters and lenders.
Third-Party
Offers
Success Continuing Education (SCE) provides you with the opportunity to receive
special offers, products and/or services from other third-party companies.
To receive such offers, products and/or services, certain of your Personal
Information (other than the Sensitive Information) will be shared with such
third-party companies (subject to restrictions contained in applicable state and
federal law), so that they may provide their offer, product or service to you
without requiring that you first complete another registration form.
Security
All collected information is stored in a technically and physically secure
environment. When our registration/application process asks users to enter
Sensitive Information (such as license numbers, Social Security Number, etc),
and when we store and transmit such sensitive information, that information is
encrypted and is protected with SSL encryption software. While we use SSL
encryption to protect Sensitive Information online, we also do everything in our
power to protect user Personal Information (including Sensitive Information)
off-line. Unfortunately, no data transmission over the Internet can be
guaranteed to be 100% secure. As a result, while we strive to protect your
Personal Information (including Sensitive Information), we cannot ensure or
warrant the security of any information that you transmit to us, and you do so
at your own risk. Once we receive your transmission, we make reasonable
efforts to ensure its security on our systems. Access to this information
is strictly limited, and not accessible to the public. All of our users’
Personal Information, not just the Sensitive Information, is restricted in our
offices. Only employees who need the information to perform a specific job
(for example a customer service representative) are granted access to Personal
Information. Our employees are dedicated to ensuring the security and
privacy of all Success Continuing Education (SCE) user information.
Employees not adhering to our firm policies are subject to disciplinary action.
In compliance with applicable federal and state law, we shall notify you
and any applicable regulatory agencies in the event that we learn of an
information security breach with respect to your Personal Information. You
will be notified via e-mail in the event of such a breach. Please be
advised that notice may be delayed in order to address the needs of law
enforcement, determine the scope of network damage, and to engage in remedial
measures.
Minors
Visitors under eighteen (18) years of age are not permitted to use and/or submit
their personal information at our Website. Success Continuing Education (SCE)
does not knowingly solicit or collect information from visitors under eighteen
(18) years of age. Success Continuing Education (SCE) encourages parents
and guardians to spend time online with their children and to participate and
monitor the interactive activities of their children.
Opt-Out/Unsubscribe
To stop receiving future communications from Success Continuing Education (SCE),
please send an email to info@successce.com
with the subject "unsubscribe". Success Continuing
Education (SCE) uses Personal Information to provide promotional offers by
e-mail to individuals. Success Continuing Education (SCE) may maintain
separate e-mail lists for different purposes. If e-mail recipients wish to
end their e-mail subscription to a particular list, they need to follow the
instructions at the end of each e-mail message to unsubscribe from the
particular list. To unsubscribe from all Success Continuing Education (SCE)
e-mail lists, please send an email to
info@successce.com with the subject
"unsubscribe".
Changes
in Privacy Policy
Success Continuing Education (SCE) reserves the right to change or update this
Privacy Policy at any time by posting a notice at the Website explaining that we
are changing our Privacy Policy. If the manner in which we use Personal
Information changes, Success Continuing Education (SCE) will notify its users by
posting the changes on the Website, sending out an e-mail notification to its
customers notifying them of the changes and providing them with the opportunity
to opt-out of the provisions relating to the transfer of their Personal
Information. Other than where the user opts-out, and other than where
affirmative consent is required for California residents and Vermont residents,
the user's continued use of the Service and/or continued receipt of Success
Continuing Education (SCE) e-mails constitutes an affirmative acknowledgement
and acceptance by the user of the modified Privacy Policy.
Correct/Update
Personal Information supplied to Success Continuing Education (SCE) during
registration can be modified by: (1) logging in to your Success Continuing
Education (SCE) account; (2) clicking on edit; or (3) modifying any of the
desired fields.
Contacting
the Website
Our "About Us" page contains information that allows you to contact us
directly with any questions or comments that you may have. We listen to or
read, as applicable, every message that we receive and endeavor to reply
promptly to each one. This information is used to respond directly to your
questions or comments. If you have any questions about this Privacy Policy
or the practices of Success Continuing Education (SCE), please feel free to
contact us at 1-949-706-9453 or info@SuccessCE.com.