Privacy Policy 

 

You agree to allow the use of personal information as stated below:

PROMPT Institute respects your concerns about privacy and has instituted the following privacy policy.  

This Privacy Policy describes the types of personal information our systems partners obtain, how our systems partners may use that personal information, with whom our systems partners may share it and how you may exercise your rights regarding our processing of that information. The Privacy Policy also describes the measures our systems partners take to safeguard the personal information our systems partners obtain and how you can contact us about our privacy practices.

This Privacy Policy applies to the personal information our systems partners obtain through our systems partnerships with Google, Eurekos, and Stripe (hereafter referred to as Systems Partners). Please note the Institute stores no personal data. All personal data is collected and maintained by the three providers listed above and is subject to the privacy policies or notices of these providers. Please refer to the privacy policies of the above providers for additional privacy policy information. To the extent permitted by applicable law, the PROMPT Institute is not responsible for these providers’ information practices.

Our systems partners privacy policies are listed below:

  Google Privacy Policy

  Eurekos Privacy Policy

  Stripe Privacy Policy

Personal Information Our Systems Partners Obtain

The data our systems partners obtain varies based on website sections you use. Our systems partners obtain personal information through your interaction with the Offerings, such as when you:

• Create an account on the Eurekos platform;
• Sign up for a PROMPT course, online course, practicum/certification project or register for a PROMPT course wait list
• Request products, services or information;
• Correspond with us or request information from us.

The types of personal information obtained by our systems partners include:

• Contact information (such as name email address, telephone number, postal or other physical address) for you or for others (e.g., principals in your business or billing contacts);
• Information used to create your online account (such as username and password);
• Biographical and demographic information (such as gender, job title/position and occupation);
• Business profile and practices information used to evaluate you as a partner;
• Photographs;
• Billing and financial information (such as name, billing address, payment card details and bank account information and purchase history);
• Location data (such as data derived from your IP address, country and zip code); 
• The precise geolocation of your mobile device; Clickstream data and other information about your online activities (such as information about your devices, browsing actions and usage patterns)
• Personal information contained in forums, blogs, and testimonials you provide or that our systems partners obtain from publicly available sources (such as social media channels);
• Personal information contained in content you submit to us (such as through our “Contact” feature or other in-product or in-service messaging); and
• Other personal information our systems partners obtain through our Offerings.

Please note that providing personal information to us is voluntary on your part. If you choose not to provide us certain information, our systems partners may not be able to offer you certain products and services, and you may not be able to access certain features of the PROMPT Institute.

How Our Systems Partners Use Personal Information

Our systems partners use the information our systems partners obtain to:

• Provide and administer our products and;
• Process and fulfill orders in connection with our products and services and keep you informed about the status of your order;
• Help you complete a transaction or order and provide customer support;
• Bill you for products and services you purchased;
• Provide training and support services;
• Create and manage your account with PROMPT Institute;
• Operate, evaluate and improve our services;
• Perform data analytics (such as research, trend analysis, financial analysis and customer segmentation);
• Communicate with you about your account and orders (including sending emails relating to your registration, account status, order confirmations, renewal or expiration notices and other important information);
• Conduct marketing and sales activities (including sending you promotional materials, generating leads, pursuing marketing prospects, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns and managing our brand);
• Communicate with you about, and administer your participation in, events, programs, promotions and surveys;
• Verify your identity and protect your account against unauthorized use or abuse of our services;
• Protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
• Comply with and enforce relevant industry standards, contractual obligations and our policies;
• Maintain and enhance the security of our products, services, and employees; and
• Respond to your inquiries.

Depending on the purposes for which personal information is used, and the context in which the data is obtained, our systems partners may rely on one or more of the following legal bases:

• Performance of a contract with you or a relevant party;
• Our legitimate business interests;
• Compliance with a legal obligation, a court order, or to exercise or defend legal claims; or
• Your consent to the processing, which you can revoke at any time.

Our systems partners may combine data collected from you with other sources to help us improve the accuracy of our marketing and communications as well as to help expand or tailor our interactions with you. This includes combining personal information our systems partners obtain through our website as well as other information (such as referral programs), for the purposes described above. Our systems partners may anonymize or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. Our systems partners also may use personal information for additional purposes that our systems partners specify at the time of collection. Our systems partners will obtain your consent for these additional uses to the extent required by applicable law.

Where required by applicable law, our systems partners will obtain your consent for the processing of your personal information for direct marketing purposes.

Cookies and Other Technologies

A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser.

Our systems partners use these automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information our systems partners obtain in this manner includes IP address and other identifiers associated with your devices, types of devices connected to our Offerings, device characteristics (such as operating system), language preferences, referring/exit pages, navigation paths, access times, browser preferences and characteristics, installed plugins, local time zones, local storage preferences, clickstream data and other information about your online activities. Some of these cookies are session cookies (which are automatically deleted when you close your browser) and others are persistent cookies (which remain on your computer or other Internet-connected device for a period of time after you end your browsing session, unless you delete them).

The cookies our systems partners use on our website include (1) essential and functional cookies; (2) analytics cookies, and (3) targeting and advertising cookies, as described below.

Essential and Functional Cookies
Our systems partners use cookies on our website that are necessary for us to provide you with our products and services. This includes essential cookies (such as those used to authenticate you to our systems and identify you after you have logged in), functional cookies (such as those that remember what you added to your shopping cart or the language preference you selected), and user-centric security cookies used to increase the security of the products and services our systems partners provide to you (such as to detect authentication abuses). Given the necessary functionality of these cookies, they typically may not be disabled.

Analytics Cookies
Our systems partners use analytics cookies to collect information on how users navigate and use our website, such as how the users traverse our website, the pages they view, how long they stay on a page and whether the page is displayed correctly or whether errors occur. Such cookies help us to improve the performance of our Website and make the Website more user-friendly. These cookies are provided by third-party analytics providers, including Google Analytics. To learn more about Google Analytics and how to opt out, please visit Google Analytics.

Advertising Cookies
Advertising cookies are used to control and manage advertisements. These Cookies may collect information on whether a user has reacted to an advertisement and visited another website. Such cookies help us to offer you content and provide targeted information that is more relevant to your interests. They also help us to measure the effectiveness of our advertisements and communications. In the EU, our systems partners deploy analytics and advertising cookies on websites only when users have opted-in as required by applicable law.

Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Website. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.

The providers of third-party apps, tools, widgets and plug-ins on our Website (such as Twitter, LinkedIn and Facebook) also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. To the extent permitted by applicable law, PROMPT Institute is not responsible for these providers’ information practices.

Interest-Based Advertising

When you use our Website, both our systems partners and certain third parties (such as our advertising networks, digital advertising partners and social media platforms) collect information about your online activities, over time and across third-party websites. Our systems partners may use such information to provide you with advertising about products and services tailored to your individual interests. Our systems partners also may obtain information for this purpose from third-party websites on which our ads are served.

How Our Systems Partners Share Your Personal Information

Our systems partners do not sell or otherwise disclose personal information about you except as described here or at the time of collection. PROMPT Institute may share personal data in the following ways:

• If sharing your data is necessary to provide a product, service or information you have requested;
• Within the PROMPT Institute (including among affiliates and subsidiaries) for the purposes described in this Privacy Policy;
• For the purposes of validating employment, training completed or product certifications achieved;
• With our customers to report and help manage issues requiring support;
• With our customers and partners to inform them about their users’ use of our services (such as when a user has obtained credentials or completed a course);
• With service providers our systems partners have engaged to perform services on our behalf (such as payment processing, order fulfillment, customer support, customer relations management and data analytics). These service providers are contractually required to safeguard the information provided to them and are restricted from using or disclosing such information except as necessary to perform services on our behalf or to comply with legal requirements;
• With our joint marketing and sales partners and other business partners who help us with our business operations or other aspects of our business and for the purposes described in this Privacy Policy.

Our systems partners also may disclose personal information about you (1) if our systems partners are required or permitted to do so by applicable law, regulation or legal process (such as a court order or subpoena), (2) to law enforcement authorities or other government officials to comply with a legitimate legal request, (3) when our systems partners believe disclosure is necessary to prevent physical harm or financial loss to the PROMPT Institute, its users or the public as required or permitted by law, (4) to establish, exercise or defend our legal rights, and (5) in connection with an investigation of suspected or actual fraud, illegal activity, security or technical issues.

In addition, our systems partners reserve the right to transfer to relevant third parties information our systems partners have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) or other business transaction.

Our systems partners also may share the information in other ways for which our systems partners provide specific notice at the time of collection and obtain your consent to the extent required by applicable law.

International Data Transfers

Our systems partners transfer the personal information our systems partners collect through the website to, and store such data in, other countries in which the PROMPT Institute and its service providers operate, including the U.S., which may have different data protection laws than the country in which the information was provided. If our systems partners do so, our systems partners will transfer the personal information only for the purposes described in this Privacy Policy. To the extent required by applicable law, when our systems partners transfer your personal information to recipients in other countries, our systems partners will take measures to protect that information including, as appropriate, by executing data transfer agreements based on the European Commission’s Standard Contractual Clauses pursuant to article 46 of the General Data Protection Regulation (GDPR), or by selecting data recipients that are certified to the EU-U.S. and Swiss-U.S. Privacy Shield frameworks described below.

EU-U.S. and Swiss-U.S. Privacy Shield
With respect to transfers of personal information from the EU and Switzerland to the U.S., our systems partners are certified under the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce and the European Commission regarding the transfer of personal information from the EU to the U.S., pursuant to article 45 of the GDPR (each a “Privacy Shield Framework” and collectively the “Privacy Shield Principles”). If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Our systems partners are responsible for the processing of personal information it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Our system partners comply with the Privacy Shield Principles for all onward transfers of personal information from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal information received or transferred pursuant to a Privacy Shield Framework, our systems partners are subject to the regulatory enforcement of the U.S. Federal Trade Commission. In certain situations, our systems partners may be required to disclose personal information in response to lawful requests by public authorities, including to satisfy national security or law enforcement requirements.

Under certain conditions, more fully described on the website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

In compliance with the Privacy Shield Principles, Citrix commits to resolve complaints about our collection or use of your personal information. If you have questions or complaints regarding our Privacy Policy or practices, please contact us here.

EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact the PROMPT Institute here.

Submitting Practicum and Certification Projects via Google Drive

Please refer to the Google Drive Privacy Policy when considering project submissions. Please note it is the clinician's responsibility to ensure compliance with all local regulations when submitting projects. 

Your Rights and Choices

Our systems partners offer you certain choices in connection with the personal information our systems partners obtain about you, such as how our systems partners use the information and how our systems partners communicate with you. To update your preferences, limit the communications you receive from us or submit a request, please contact us as specified in the How to Contact Us section of this Privacy Policy. You can also unsubscribe from our mailing lists by following the “Unsubscribe” link in our emails.

To the extent provided by the law of your jurisdiction, you may request access to the personal information our systems partners maintain about you or request that our systems partners correct, update, amend or delete your information, or that our systems partners restrict the processing of such information by contacting us as indicated below or by accessing your PROMPT Profile. To help protect your privacy and maintain security, our systems partners may take steps to verify your identity before granting you access to the information. To the extent permitted by applicable law, a charge may apply before our systems partners provide you with a copy of any of your personal information that our systems partners maintain. Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response.

Opting out of interest-based advertising does not mean you will no longer see advertisements from us or on the Website; rather, opting out means that the online ads that you do see will not be based on your interests. When you opt-out of receiving interest-based advertisements through the links above, cookies and other technologies on the Website may still collect information about your use of the Website, including for analytics, fraud prevention and any other purpose permitted under the Self- Regulatory Principles.

When you use our Website, both our systems partners and certain third parties may collect personal information about your online activities, over time and across third-party websites. Certain web browsers allow you to instruct your browser to send Do Not Track (“DNT”) signals to websites you visit, informing those sites that you do not want your online activities to be tracked.

Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and our systems partners will apply your preferences going forward. This will not affect the lawfulness of our use of your information based on your consent before its withdrawal.

How Our Systems Partners Protect Personal Information

Our systems partners maintain administrative, technical and physical safeguards, consistent with legal requirements where the personal information was obtained, designed to protect against unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the personal information provided to us through the website.

Retention of Personal Information

To the extent permitted by applicable law, our systems partners typically retain personal information our systems partners obtain about you for as long as it is needed (1) for the purposes for which our systems partners obtained it, in accordance with the terms of this Privacy Policy, which generally means that our systems partners will keep your personal information for the duration of our relationship or as long as you keep your account open with us; or (2) to take into account applicable statute of limitation periods and comply with applicable laws, resolve disputes and enforce our agreements. As described in the “Your Rights and Choices” section above, to the extent provided by the law of your jurisdiction, you may request that our systems partners delete your information or restrict the processing of such information by contacting us as indicated below.

Notice to California Residents

Subject to certain limits under California law, California residents may ask us to provide them with (1) a list of certain categories of personal information our systems partners have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties. To obtain this information, please send an email to admin@prompt.org with "California Shine the Light Privacy Request" in the subject line and in the body of your message.

Children’s Personal Information

The Website are designed for a general audience and are not directed to children under the age of 13. Our systems partners do not knowingly collect or solicit personal information from children under the age of 13 through the Website. If our systems partners become aware that our systems partners have collected personal information from a child under the age of 13, our systems partners will promptly delete the information from our records. If you believe that a child under the age of 13 may have provided us with personal information, please contact us admin@prompt.org.

Changes to Our Privacy Policy

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information practices. Our systems partners will indicate at the top of this Privacy Policy when it was most recently updated. Our systems partners encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.

How to Contact Us

If you have any questions or comments about this Privacy Policy or if you would like us to update information our systems partners have about you or your preferences, please contact us at admin@prompt.org or by mail at:

PROMPT Institute

PO Box 4249

Santa Fe, NM 87505

United States