Rosefinch Academy

ROSEFINCH ACADEMY PRIVACY POLICY

This Privacy Policy ("Policy") applies to courses.rosefinchacademy.com users or “Learner,” and Lee Hullender Rubin dba Rosefinch Academy ("Company") and governs data collection and usage. For the purposes of this Privacy Policy, unless otherwise noted, all references to the company include courses.rosefinchacademy.com. The company's website is an online professional continuing education site. By using the company website, the learner consents to the data practices described in this statement.

Collection of Personal Information

Learners enroll as a student or subscriber on the company’s site or related courses. As part of the enrolling process. The company may collect personally identifiable information, such as the learner’s:

    - First and last name 

    - Email address  

    - NCCAoM identification number

The company does not collect any personal information about learners unless voluntarily provided to the company. However, learners may be required to provide certain personal information to the company when learners elect to use certain products or services. These may include: (a) registering for an account; (b) entering a sweepstakes or contest sponsored by the company or one of its partners; (c) signing up for special offers from selected third parties; (d) sending the company an email message; (e) submitting your credit card or other payment information when ordering and purchasing products and services. To wit, the company will use your information for, but not limited to, communicating with you in relation to services and/or products you have requested from the company. The company also may gather additional personal or non-personal information in the future.

Use of your Personal Information 

The Company collects and uses your personal information in the following ways:  

    - to operate and deliver the services you have requested 

    - to provide you with information, products, or services that you request from us 

    - to provide you with notices about your account 

    - to carry out the Company's obligations and enforce the company’s rights arising from any contracts entered between you and us, including for billing and collection 

    - to notify you about changes to the company’s terms, policies, or any products or services the companyoffer or provide through it  

    - in any other way the companymay describe when you provide the information 

    - for any other purpose with your consent.  

The Company may also use your personally identifiable information to inform you of other products or services available from the Company and its affiliates.

Sharing Information with Third Parties

The Company does not sell, rent, or lease its customer lists to third parties.

The Company may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to the Company, and they are required to maintain the confidentiality of your information. 

The Company may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on the Company or the site; (b) protect and defend the rights or property of the Company; and/or (c) act under exigent circumstances to protect the personal safety of users of the Company, or the public.

Payments 

If you the learner makes a purchase on the company’s site, a third-party payment processor is used such as Stripe. Payments are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). The learner’s purchase transaction data is stored only as long as is necessary to complete the learner’s purchase transaction.

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.

PCI-DSS requirements help ensure the secure handling of credit card information by the company’s site and related courses and its service providers. Please keep in mind that if the learner directly discloses personally identifiable information or personally sensitive data through the company's public message boards, this information may be collected and used by others.

The company’s courses and site are hosted by Thinkific Labs Inc. (“Thinkific”). They provide the company with the online course creation platform that allow the company to sell product/services to learners.

Learner data is stored through Thinkific’s data storage, databases and the general Thinkific application. Thinkific stores learner data on a secure server behind a firewall.

For more insight, you may also want to read Thinkific’s Terms of Service here https://www.thinkific.com/resources/privacy-policy/ or Privacy Statement here https://www.thinkific.com/resources/terms-of-service/ .

Third Party Services

In general, the third-party providers used by the company will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to the company.

However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information the company is required to provide to them for learner purchase-related transactions.

For these providers, the company recommends that learners read their privacy policies so learners can understand the manner in which learner personal information will be handled by these providers.

Certain providers may be located in or have facilities that are located in a different jurisdiction than either the learner or the company. If learners elect to proceed with a transaction that involves the services of a third-party service provider, then the learners information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

As an example, if an learner is located in Canada and their transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

Once you leave the company’s course website or are redirected to a third-party website or application, the learner is no longer governed by this Privacy Policy or the website’s Terms of Service.

For more insight, you may also want to read Thinkific’s Terms of Service here https://www.thinkific.com/resources/privacy-policy/ or Privacy Statement here https://www.thinkific.com/resources/terms-of-service/ .

Links

When the learner clicks on links on the company’s course site, the link may direct the learner away from the company’s site. The company is not responsible for the privacy practices of other sites and encourages the learner to read their privacy statements.

Security

To protect your personal information, the company takes reasonable precautions and follows industry best practices to ensure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

If the learner provides the company with the learner’s credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with AES-256 encryption.  Although no method of transmission over the Internet or electronic storage is 100% secure, the company follows all PCI-DSS requirements and implements additional generally accepted industry standards.

Cookies

The company collects cookies or similar tracking technologies. This means information that the website’s server transfers to the learner’s computer. This information can be used to track your session on the company’s website. Cookies may also be used to customize the company’s website content for learners as an individual. If a learner is using one of the common Internet web browsers, the learner can set up their browser to either let them know when they receive a cookie or to deny cookie access to their computer.

• The company uses cookies to recognize your device and provide learners with a personalized experience.
• The company also uses cookies to attribute visits to its websites to third-party sources and to serve targeted ads from Google, Facebook, Instagram, and other third-party vendors.
• The company’s third-party advertisers use cookies to track learner’s prior visits to the websites and elsewhere on the Internet in order to serve learner’s targeted ads. For more information about targeted or behavioral advertising, please visit https://www.networkadvertising.org/understanding-online-advertising.
• Opting out: Learners can opt out of targeted ads served via specific third-party vendors by visiting the Digital Advertising Alliance’s Opt-Out page.
• The company may also use automated tracking methods on its websites, in communications with learners, and in its products and services, to measure performance and engagement.
• Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, the company does not alter the company’s data collection and usage practices when the company detects such a signal from the learner’s browser. 

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, the company will:

    - Delete your personal information from the company’s records; and 

    - Direct any service providers to delete your personal information from their records. 

Please note that the company may not be able to comply with requests to delete your personal information if it is necessary to:

    - Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, and provide a good or service requested by you, or reasonably anticipated within the context of the company’s ongoing business relationship with you, or otherwise perform a contract between the learner and the company; 

    - Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;  

    - Debug to identify and repair errors that impair existing intended functionality; 

    - Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; 

    - Comply with the California Electronic Communications Privacy Act; 

    - Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the company’s deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided the companyhave obtained your informed consent;  

    - Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; 

    - Comply with an existing legal obligation; or 

    - Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which the learner provided the information. 

Children Under Thirteen

The Company does not knowingly collect personally identifiable information from children under the age of 13. If you are under the age of 13, you must ask your parent or guardian for permission to use this website.

Disconnecting your Company's Account from Third Party Websites

You will be able to connect your Company's account to third-party accounts. BY CONNECTING YOUR COMPANY'S ACCOUNT TO YOUR THIRD-PARTY ACCOUNT, YOU ACKNOWLEDGE AND AGREE THAT YOU ARE CONSENTING TO THE CONTINUOUS RELEASE OF INFORMATION ABOUT YOU TO OTHERS (IN ACCORDANCE WITH YOUR PRIVACY SETTINGS ON THOSE THIRD-PARTY SITES). IF YOU DO NOT WANT INFORMATION ABOUT YOU, INCLUDING PERSONALLY IDENTIFYING INFORMATION, TO BE SHARED IN THIS MANNER, DO NOT USE THIS FEATURE. You may disconnect your account from a third-party account at any time. Lee Hullender Rubin dba Rosefinch Academy

Opt Out and Unsubscribe from Third-Party Communications

The company respects your privacy and gives you an opportunity to opt out of receiving announcements of certain information. Users may opt out of receiving any or all communications from third-party partners of the Company by contacting us here: 

    - Email: [email protected] 

    - Phone: (503) 807-0158 

Email Communications

From time to time, the Company may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. In order to improve the company’s services, the company may receive a notification when you open an email from the Company or click on a link therein.

If you would like to stop receiving marketing or promotional communications via email from the Company, you may opt out of such communications by clicking the unsubscribe button..

Changes to This Statement

The Company reserves the right to change this Policy from time to time. For example, when there are changes in the company’s services, changes in the company’s data protection practices, or changes in the law. When changes to this Policy are significant, the company will inform you. You may receive a notice by sending an email to the primary email address specified in your account, by placing a prominent notice on the company’s Lee Hullender Rubin dba Rosefinch Academy, and/or by updating any privacy information. Your continued use of the website and/or services available after such modifications will constitute your: (a) acknowledgment of the modified Policy; and (b) agreement to abide and be bound by that Policy.

Contact Information

The Company welcomes your questions or comments regarding this Policy. If you believe that the Company has not adhered to this Policy, please contact the Company at:

Lee Hullender Rubin dba Rosefinch Academy

Email Address:  [email protected]

Phone Number: +1 (503) 807-0158

Effective as of February 02, 2024