Bonding Health Privacy Policy

Personal Information We Collect From Others

Even if you aren’t a registered user of our Website, your information might still be collected. Some users may choose to share information about their contacts, including their name, email address, phone number, or other information. Users may also post or comment with personal information about other users.

What We Do with Your Personal Information

We may use your personal information for a variety of reasons. Depending on how you interact with our Platform, these include using personal information: 

• Delivering Our Platform to you and providing related customer support, communication, and security. 
• Policy Enforcement, including enforcing our terms of service, acceptable use policies, anti-spam policies, and similar policies. 
• Advertising & Marketing to send advertisements and marketing material via physical and electronic mail relating to product specials and other promotional events or offers, perform marketing research and data analytics, and perform similar activities.
• Contextual and Behavioral Targeting to provide contextual customization of ads shown as part of an interaction with our website or application, using tracking technologies like cookies and pixels.
• Counting Ad Impressions & Website Interactions to audit interactions with our websites, applications, or advertisements, count ad impressions to unique visitors, verify the position and quality of ad impressions, and perform similar activities.
• Customer Service to provide customer service, maintain and service products and accounts, provide training for quality assurance purposes, and perform similar activities.
• Fraud Prevention to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
• Processing Transactions to process or fulfill orders and transactions, verify customer information, process payments, confirm eligibility promotional benefits, and perform similar activities.
• Public Health and Safety to conduct screening or temperature checks for COVID-19 symptoms or similar screening activities related to public health and safety.
• Defending Against Claims & Litigation to defend against or respond to potential or actual claims and litigation.
• Determining Employment Eligibility to determine eligibility for employment, verify references and employment history, and conduct background checks.
• Claims & Benefits Administration to process claims, administer benefits, and conduct employee drug tests in accordance with applicable laws.

Our Legal Grounds for Processing Your Personal Information

When we process personal information about you to comply with legal requirements or to perform our obligations under a contract with you or with our customer through whom you use our offerings, failure to provide such information may prevent or delay our fulfillment of these obligations.

To the extent required by applicable law, we will collect your personal data with your consent, where required, and in accordance with our legitimate need to provide our Platform.

Under European data protection laws, Bonding Health is required to rely on one or more legal bases to collect, use, share, and otherwise process the information we have about you. We describe these legal bases and some accompanying examples in more detail below.

• Performing our Agreement. Bonding Health processes your information as is necessary to perform our contract(s) with you, including, without limitation, our Terms of Service and Payments Terms of Service, as applicable. For example:

• We use your information to create your account and set you up as a registered user on the Bonding Health Education Site.
• We transfer your information outside of the EU to the United States that you provide to our Website.

• Your Consent. Bonding Health processes certain information based on your consent, which you may revoke at any time. For example:

• We and our partners use cookies and similar technologies, as described in more detail in our Cookie Policy, based on your consent.
• Where you choose a method of verification to confirm your address, we do so in accordance with your consent.
• If you decide to use location services in the context of Bonding Health, we collect and process such location information based on your consent.
• We rely on your consent to tailor ads based on your activity and information on other websites and partner data, such as inferred interests.
• We will send you marketing communications where you have consented to receiving such communications in accordance with applicable law.

• Legal Obligation. Bonding Health may process your information to comply with a legal obligation, a court order, or to exercise and defend legal claims. For example:

• We may preserve and disclose your information if it is necessary to respond, based on applicable law, to a valid legal request (e.g., a subpoena, search warrant, court order, or other binding request from government or law enforcement).
• We may retain and process your information where it is necessary for compliance with applicable tax laws.

• Vital Interests. Bonding Health may process your information in certain circumstances when it is necessary to protect your vital interests, or those of others. For example:

• We may need to process your information in order to protect your life or safety or the lives or safety of others, or otherwise prevent physical injury or other harm to any person or the general public.
• We may preserve or share your information with law enforcement and related authorities where we have a good faith belief that it is required in the context of an imminent threat.
• We may share your personal data with disaster relief agencies, first responders and other individuals to facilitate disaster or emergency response efforts.

• Legitimate Interests. We may process your information where it is necessary for the purposes of Bonding Health’ or a third party’s legitimate interests, such as those of Creators. We process your information in furtherance of the following legitimate interests:

• Providing, improving, and developing our Website. We use your information to provide our Website, including any personalized services, and to understand and improve our business and our user relationships.
• Sending marketing communications. We rely on our legitimate interests in marketing and promoting our Services to use your contact information and send you marketing communications in accordance with applicable law, except where applicable law requires that we rely on your consent to send such communications.
• Sharing information for legal and safety reasons. Where required for legal and safety reasons, we may disclose information to law enforcement and related agencies and authorities in furtherance of the legitimate interests described further below.
• As detailed in this Privacy Policy, where we process your information based on legitimate interests, you have the right to object to such processing. Where you exercise your right to object, we will cease processing your information for that specific purpose, unless there are compelling legitimate grounds overriding your objection or where your information is processed for legal reasons.

Our Sharing of Your Personal Information

We may share your personal information with the following:

Business Services Providers. These are those persons or entities with whom we have a relationship to provide business operations services and support to Bonding Health. These providers may include the following:

• IT Operations Providers. These include cloud computing service providers, internet service providers, data backup and security providers, functionality and infrastructure providers, and similar service providers. 
• Operations Providers. These include service providers with whom we partner to provide day-to-day business operations, including payment processors, security vendors, business software service providers, hospitality service providers, banks, and facilities management providers. 
• Professional Advisors. These include lawyers, accountants, consultants, security professionals, and other similar parties when disclosure is reasonably necessary to comply with our legal and contractual obligations, prevent or respond to fraud or abuse, defend ourselves against attacks, or protect the rights, property, and safety of us, our customers, and the public.

Marketing and Advertising Providers. These include advertising, direct marketing, and lead generation providers, affiliate marketing program providers, retargeting platforms, data brokers, ad networks, marketing consultants, and similar service providers. 

Legally Required Parties/Governmental Entities. Persons to whom we are required by law to provide information, such as pursuant to a subpoena or a court order.

Reorganization. Persons involved in the consideration, negotiation, and completion of a business transaction, including the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration.

Authorized Disclosures: To any party when authorized by the individual to whom it pertains to share it. 

Publicly Posted Content

Bonding Health users may have the ability to post content to one or more Bonding Health forums, such as chat rooms and bulletin boards. You should be aware that when you voluntarily disclose personal information in any forum, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances. Please take care when using these features. You may request and obtain the removal of such posted content by contacting us at [email protected] and specifically identifying the content to be removed.  Please be advised that any such removal does not ensure the complete or comprehensive removal of all traces of the content posted on the Bonding Health forums.

Data Retention

We will retain your personal information only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; and the applicable legal requirements. In some circumstances, you may ask us to delete your information. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

Data Security

We have implemented and maintain reasonable security procedures and practices, appropriate to the nature of the information, to protect your personal information from unauthorized access, destruction, use, modification, or disclosure. However, no security measure is perfect, so we cannot guarantee the security of your personal information. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply common protections described in this policy. These protections align with well-known standards such as ISO 27001:2017 and others.

International Data Transfers

We are located and operate in the United States. By submitting personal information to us, you understand that we may transfer your personal information to a country foreign to you, including the United States, for processing. The laws that apply to the use and protection of personal information in the United States, or other countries or jurisdictions in which we transfer or process personal information, may be different from the laws and protections in your country. These transfers may include transfers to our service providers located in foreign jurisdictions. Whenever we engage a service provider, we require that its privacy and security standards adhere to our requirements and applicable privacy laws.

Your Privacy Preferences

You can control the collection and use of personal information for some of our processing activities. This includes: 

• Adjusting Communication Preferences

Emails From Bonding Health. During the registration for the Bonding Health Education Site, you were presented with an opt-in to receive email communications. If you wish to no longer receive email communications, you can click on the “unsubscribe” link located at the bottom of the email, email Bonding Health at [email protected] to let us know, and we will remove you as soon as possible. Opting out of marketing or newsletter emails will not opt you out of all emails—we may need to send you transactional or similar emails related to your Bonding Health account, purchases, legal or contractual updates, or similar topics. You are not able to opt out of these emails. 

Emails from Third Parties. During registration for a Bonding Health virtual event or webinar, you may be asked to opt-in to receive emails from third parties. If you choose to opt-in to receive email communication from a third party, you can opt out or unsubscribe at any time by clicking on the “unsubscribe” or similar opt-out link in the third party’s’ email communication. Opting out of marketing or similar communications from third parties may not prevent all emails from third parties.  Third parties have their own privacy policies regarding the personal information they collect and process about you. We urge you to review their privacy policies regarding their processing of your personal information. 

Most web browsers automatically accept cookies by default, but you can alter how your browser responds to cookies by adjusting the settings. Information about managing cookies for popular web browsers can be found in the links below:

• Safari (Desktop) and Safari Mobile (iOS)
• Firefox
• Chrome
• Microsoft Edge
• Brave

Many websites, including ours, employ Google Analytics. To opt out of Google Analytics data collection, follow these instructions from Google.

Your Privacy Rights

Some jurisdictions provide covered individuals with specific privacy rights which can be exercised against covered entities. Depending on the jurisdiction, these rights may include the following: 

• Access and Portability. The right to know (or confirm) what personal information a business has collected about you, and to receive a copy of it. 
• Deletion/Restriction. The right to request that a business delete personal information it has collected from you or restrict how it is used, subject to certain exceptions.
• Correction/Rectification. The right to request correction of inaccurate personal information maintained by the business. 
• Opt-Out of the Sale/Sharing of Your Personal Information. The right to opt out of the sale of your personal information to third parties. The term “sale” varies by jurisdiction, but sometimes includes the right to opt out of the use of personal information for targeted advertising purposes.
• Revoke Consent. Where consent is required for processing under applicable law, you may withdraw your consent to the processing of your information at any time.
• Object to Processing. Object, on grounds relating to your situation, to our processing of personal data concerning you which is (i) necessary for the performance of a task carried out in the public interest, (ii) carried out in the exercise of official authority vested in us, or (iii) processed by us on the basis of our legitimate interest. In this case, where applicable, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
• Limitation/Restriction. The right to limit or restrict a business’s use or disclosure of certain personal information.
• Opt-out of Profiling/Automated Decision-Making: The right to opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. 
• Non-Discrimination. The right not to be discriminated against for exercising any of the rights conferred at law.
• Complaints. The right to lodge a complaint with the appropriate governmental authority. 

Bonding Health will honor the privacy rights afforded to individuals in accordance with applicable law and will not discriminate against individuals for exercising their privacy choices under the law.

Exercising Your Privacy Rights

You may make a request at any time to exercise your access, deletion, correction, and restriction rights listed above emailing us at [email protected].  We will respond to your request within a reasonable period (if properly submitted) and in accordance with applicable law. If we need more time to process and respond to your request, we will notify you of that fact along with the reason for the delay. If we decline to act regarding your request, we will inform you of our decision and the reason for it, and, if applicable, with instructions on how you may appeal our decision. 

Children’s Privacy

Our Website is not intended for persons under 16 years of age. We do not knowingly collect or process the personal information of individuals under the age of 16. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us their Personal Information, please contact us at [email protected]. 

Jurisdiction-Specific Privacy Disclosures

1. Canada

If you are a Canadian resident, this section applies in addition to all other applicable rights and information contained in the Privacy Policy. 

We are committed to openness and accountability with respect to how we handle your personal information pursuant to Canadian federal and provincial privacy laws (“Canadian Privacy Law”), including: 

• The Personal Information Protection and Electronic Documents Act (PIPEDA)
• Alberta’s Personal Information Protection Act (Alberta PIPA)
• British Columbia’s Personal Information Protection Act (BC PIPA)
• Québec's Act respecting the protection of personal information in the private sector (Québec Act).

Consent. Where you have provided your consent to the collection, use, and transfer of your personal information (whether orally, in writing, or electronically), you may have the legal right to withdraw your consent under certain circumstances. In addition to the methods described above with respect to your privacy choices, you may withdraw your consent by contacting us at [email protected]. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

Use of Your Personal Information. We will not collect, use, or disclose personal information except for the identified purposes identified above (See What We Do with Your Personal Information), unless we have received additional consent or the processing is authorized without consent. Where we engage service providers who utilize the personal information we provide to them, we ensure that an agreement is place the ensure compliance with applicable Canadian Privacy Law.  

Exercising Your Canadian Privacy Rights. If you have an account with us, you may view and update your account information (as noted above) directly by logging into your account. To submit a request for access to information not contained within your account, or to challenge the accuracy or completeness of your personal information, you may submit a request by emailing us at [email protected]. When submitting a request, we may require that you take additional steps to validate your identity or legal authority. We will begin processing your request once you have completed the verification process. 

We have put procedures in place to receive and respond to inquiries about our policies and practices relating to the handling of personal information. We will provide a response to any personal information request within the timeframe required by law. If we cannot substantively respond to your request in a timely manner, we will notify you and state the reason for the delay. Under certain circumstances, we may not be able to fulfill your request, such as when doing so would interfere with our regulatory or legal obligations, where we cannot verify your identity, or if your request involves disproportionate cost or effort. However, we will respond to your request within a reasonable time, as required by law, and provide an explanation. 

Additional information about how to exercise your rights under Canadian Privacy Law can be found here: 

‍

Office of the Privacy Commissioner of Canada

Website

Toll-free: 1-800-282-1376

‍

Office of the Information and Privacy Commissioner of Alberta

Website

Toll-Free: 1-888-878-4044

Edmonton office: (780) 422-6860

Calgary office: (403) 297-2728

‍

Office of the Information and Privacy Commissioner of British Columbia

Website

Vancouver: (604) 660-2421

Elsewhere in BC: (800) 663-7867

Commission d’accès à l’information du Québec

Website

Toll-free: 1-888-528-7741 

2. Members of the European Economic Area and the United Kingdom

You may lodge a complaint with a supervisory authority at any time if you are of the opinion that the processing of personal data relating to you violates applicable law. If the complaint relates to provisions of the EU and UK GDPR, you can lodge such complaint with a supervisory authority in the Member State of your place of residence, your place of work or the place of the alleged infringement. You may identify the applicable supervisory authority based on your location on the European Data Protection Board website. If the complaint relates to provisions of the UK GDPR, you can lodge such complaint with the Information Commissioner’s Office. For contact details of your local Data Protection Authority, please see:  https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

EU Representative

European Data Protection Office (EDPO)

Avenue Huart Hamoir 71, 1030 Brussels, Belgium

Email: [email protected]

Online request form: https://www.edpo.brussels/contact 

UK Representative

EDPO UK 

8 Northumberland Avenue, London WC2N 5BY, United Kingdom

Online Request Form: https://edpo.com/uk-gdpr-data-request/ 

3. Australia

We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles. You consent to us processing your personal information in accordance with this Privacy Policy.  You may access or request correction of the personal information that we maintain about you by using our Privacy Portal. There are some circumstances in which we are not required to give you access to your personal information. There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material). We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date and complete. 

If you have complaints about our privacy practices, please contact us using the contact methods provided. We will evaluate any complaints and determine if further action is necessary and keep you informed of our investigation and decisions.  If you remain dissatisfied with our handling of a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (OAIC) (www.oaic.gov.au) for guidance on alternative courses of action which may be available.

4. U.S. State-Specific Privacy Rights

Residents of certain U.S. States have the rights indicated below as of the date in which the applicable laws granting such rights are effective, which are as follows:

California: January 1, 2023

Virginia: January 1, 2023

Colorado: July 1, 2023

Connecticut: July 1, 2023

Utah: December 31, 2023

Bonding Health does not engage in automated decision making/profiling so no action is required to exercise this right under state law. 

If you would like to opt-out of the sale or sharing of your personal information for cross-contextual behavioral or targeted advertising, please send an email to [email protected] with the subject line "do not share".

We will respond to your request within 45 days of receipt (if properly submitted). If we need more time to process and respond to your request, we will notify you of that fact along with the reason for the delay. In all cases we will complete your request within 90 days from the date of our receipt of your properly submitted request. If we decline to act regarding your request, we will inform you of our decision and the reason for it, along with instructions on how you may appeal our decision. 

5. Nevada

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

Changes to this Notice

We may update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access our Platform or otherwise interact with us to stay informed about our information practices and the choices available to you.

If you have questions or comments about this Privacy Policy or complaints and our privacy practices, please contact us at:

• By email: [email protected]
• By postal service: Bonding Health, 1508 Bay Road,   Apt 504,  Miami Beach, FL,  33139,  Attn: Pen King
• By visiting this page on our website: www.courses.bondinghealth.com/contact