Privacy Policy

The updated CNEI Privacy Notice goes into effect on February 17, 2024

CNEI, LLC. (collectively “CNEI”, “us”, “we”, “our”) are committed to protecting your privacy while providing you with a positive experience on our website and in using our products and services.

This Privacy Notice (“Notice”) explains our privacy practices and provides information on how and why we collect, use, and share your personal information through our interaction with you in relation to our products and services, when you visit our websites, and associated sub-domains ("Website") when you use our desktop, mobile applications, our integrated business apps or our digital contract signing ("Apps," or “Products”) refers to our classes and educational products. (“Services”) refers to employee and student assistance activities such as Career Placement, Financial Aid, and Record Keeping. The Notice also describes choices that may be available to you regarding the use, access, deletion, and correction of your personal information.

Additional information on our personal information practices may be provided in supplemental terms and conditions, supplemental privacy statements, or notices provided prior to or at the time of data collection.

QUICK LINKS

SMS (Texting) Privacy Policy

We understand the importance of privacy, especially when it comes to communication via SMS (Texting). We are committed to safeguarding your SMS contact and content data. Therefore, we want to assure you that we do not sell or give out any SMS contact or content data to 3rd parties.

Collection and Use of SMS Data

When you communicate with us via SMS (Texting), we may collect certain information, such as your phone number and the content of your messages. This information is solely used to respond to your questions, provide customer support, communications regarding CNEI's programs, campus updates, or deliver requested services. We don't use this data for any other purpose without your written consent will not sell or share the SMS opt-ins with third parties.

Protection of SMS Data

We employ industry-standard security measures to protect your SMS data from unauthorized access, disclosure, alteration, or destruction. Our systems are designed to ensure the confidentiality and integrity of your SMS communications.

Disclosure of SMS Data

We do not disclose your SMS contact or content data to any third parties except in cases where such disclosure is required by law or necessary to protect our rights, property, or safety, or the rights, property, or safety of others.

Your Rights

You have the right to access, correct, or delete your SMS contact or content data that we hold, except where required by state or federal law. If you wish to exercise any of these rights or have any questions about our SMS privacy practices, please contact us at privacy@cnei.edu .

Changes to this SMS Privacy Policy

We reserve the right to update or modify this SMS Privacy Policy at any time. Any changes will be effective immediately upon posting the revised policy on our website. We encourage you to review this Privacy Policy periodically for any updates.

Contact Us

If you have any questions or concerns about our SMS privacy practices or this Privacy Policy, please contact us at privacy@cnei.edu .

HOW WE COLLECT YOUR PERSONAL INFORMATION

  • We collect your personal information when you actively provide it to us through your interactions with us.
  • We may automatically collect personal information from you as you use our Apps, Products and, visit our Website as a user or a participant, including recording communications, when enabled.
  • We may receive personal information about you from a business or commercial partner or another user of our Apps.
  • We may infer or derive personal information based on other information we collect, such as with conversational intelligence.

 

WHAT PERSONAL INFORMATION WE COLLECT

Personal Information you actively provide to us or we collect from third parties, business partners, other users, and service providers

Your Contact Information/Identifiers:

  • Name, username, email address, phone number, identity documents, IP address, and any other identifiers a user provides when accessing or using our website, Apps or Products.

Your payment information:

  • Billing name, address, and credit card or other payment information.

Other information:

  • Social media profiles, LinkedIn URLs and custom profiles.

Personal information we collect through your interactions with CNEI, our Website, Phone, Products and Apps as a user or a participant

Account information:

  • Account holders’ usernames and personal identifiable numbers, phone numbers, address, language preference..

Information about your use of non-CNEI Services through integrations with our Websites, Apps and Services or otherwise:

  • Social media account information

User content:

  • Files, any content of communication or other information you or another user or participant upload, provide, grant access to or otherwise implement.*Note that users and participants control the content that they provide, and it may include any category of personal information.

Service Usage Data:

  • Internet Protocol ("IP ") address, other device ID (“UDID”), device type, operating system type and version, client version, connection type and other related information.
  • User feedback ratings, internal feature usage analytics, usage logs, cookie identifiers.
  • Traffic data about the communications that take place through our platform (such as chat, video conferencing), intranet monitoring data.
  • Call Detail Records produced by a telephone call or other telecommunications transactions. The Call Detail Record contains various attributes of the call, such as time, duration, completion status, source number and destination number.
  • Chat Detail Records created online when communicating from the website.
  • Metadata such as session logs and join & leave time of participants.
  • Log data including IP address, Internet Service Provider ("ISP"), browser type, referring/exit pages, operating system, date/time stamp, and/or clickstream data.
  • Publicly available data from End User accounts.

Geolocation information:

  • Information about where you are located when using the website via IP.

Recordings:

  • A user hosting a phone or video conferencing meeting may choose to record the session, and if so, the host is responsible for obtaining any required consent from you. CNEI helps hosts obtain consent from other users by providing visual and audio cues to alert users of a recording.
  • As with all user content, recordings may contain personal data and may be stored with CNEI at the request of the meeting host. A meeting host on or off property may choose to store a recording of a meeting on the host’s local storage device, not with CNEI. When a host chooses to do that, CNEI does not have any control over the recording. Transcripts, which may also contain personal data, are treated the same way as recordings.

SMS messages:

  • Content of blocked SMS messages that violate our spam rules.

Inferred or derived data:

  • Inferred or derived data may include a summary of information included in recorded content processed by conversational intelligence. Users and participants control the content they provide.

Your communications with us:

  • Surveys, calls (including recordings), emails, chat sessions and messages, etc.

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for the following purposes: Communicate with you; Verify your identity to prevent fraud in compliance with applicable law; Create your account; Provide you with CNEI Services including our Learning Management and Customers Relationship Management, or support logging platforms, respond to your requests for support; Develop and improve the CNEI Service and our customer relationship; Market and advertise our products; Perform surveys; Provide internal training and ensure quality assurance; Improve and optimize your interactions with our teams; Connect you to and optimize your experience using our Website, Apps, Products and Services; Conduct fraud and threat analysis and, detect and prevent spam or unlawful or abusive activity or other violations of our Acceptable Use Policy (“AUP”); Monitor performance of our and networks; Conduct analytics to improve CNEI’s Website, App and Product performance; Personalize your experience with our Websites, Apps ,Products and Services; Comply with applicable law including those regulating call detail records.

We may use artificial intelligence, machine learning, or other similar technology to provide, maintain, support, and improve our Products and Services.

Limited Use for APIs

CNEI’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. For further information about the types of Cookies we use, the functions they perform, and how you can control Cookies, please see our Cookie Notice.

HOW, WHY, AND WHAT PERSONAL INFORMATION WE SHARE WITH THIRD PARTIES

We may share and disclose your personal information (as identified in the section What Personal Information We Collect solely for legitimate business or legal purposes as described in this Notice and in accordance with applicable law, with the following third parties:

      • CNEI, the Department of Education, Bureau for Private Postsecondary Education or any other required Federal or State agencies.
      • Contractors, vendors or agents who operate on our behalf to:
        • Operate, deliver, improve and customize our Websites, Apps, Services and Products;
        • Provide support and technical services;
        • Send marketing and other operational communications related to our Websites, Apps, Products, and Services;
        • Enforce our acceptable use policy;
        • Conduct analytics in order to improve your experience using CNEI Websites, Apps Products and Services;
        • Provide offers and advertisements to customers based on their interests and interactions with us.
      • Any third parties as part of, or in connection with, an actual or prospective corporate business transaction, such as a sale, merger, acquisition, joint venture, financing, corporate change, reorganization or insolvency, bankruptcy or receivership;
      • Law enforcement agencies, regulatory or governmental bodies, or other third parties in order to respond to legal process, comply with any legal obligation; protect or defend our rights, interests or property or that of third parties; or prevent or investigate wrongdoing in connection with the Website, Apps or our Services; and/or
      • Other third parties with your consent. We do not sell or offer your Personal Information to other companies for the purpose of selling their products.

HOW WE RESPECT YOUR PRIVACY RIGHTS

We provide you with the opportunity to access, review, modify, and delete your personal information that we process.

Requests from End Users regarding personal information we process on behalf of our Customers as a Data Processor

In general, when processing the content of communications such as voicemails, faxes, Chat sessions, SMS, phone recordings etc. in connection with our Products or Services, we do so on behalf of our Regulating Agencies such as the Department of Education, State of California BPPE, and in accordance with their instructions as a data processor. This means that if you believe CNEI may have collected or stored personal information about you on behalf of one of our Regulating Agencies as a data processor or if you wish to access, review, modify or delete any content of your communications, under applicable law or otherwise, you should direct your request to that Agency.

Your Additional Privacy Rights as a Resident of Certain U.S. states

The rights described in this section apply only if you are a resident of a state within the United States that has an applicable and effective privacy law providing for the below rights.

Data portability: You can ask for a downloadable copy of your personal information in a machine-readable format. You can also request that we transmit the data to someone else where it’s technically possible.

Knowledge and access: You may have the right to know more about personal information that we have collected and disclosed in the preceding 12 months. You may be able to access, receive details on collection, the purpose of processing, and any sharing that may have occurred.

Deletion: You have the right to request CNEI to delete the personal information we have collected about you under certain circumstances.

Non-discrimination for the exercise of your privacy rights: You have the right to not receive discriminatory treatment by CNEI for the exercise of your privacy rights.

Rectification: If you believe that any personal information we are holding about you is incorrect or incomplete, you can request that we change, correct, or supplement the data. You can also correct some of this information directly by logging into your account, if you are a customer. Please contact us as soon as possible if you notice any inaccuracy or incompleteness.

Opt-out of selling or sharing your personal information: You have the right to request CNEI to stop sharing your personal information for the purposes of cross-context behavioral advertising or targeted advertising. You may opt out of having your cookie identifiers used for this type of sharing by turning on the Global Privacy Control at the browser level. CNEI does not sell your personal information as may be commonly understood. However, you may opt out of having your personal information shared with certain vendors that we use for providing insights about user interactions with our website and for delivering ads to you.

Federal Agencies: after agreeing to CNEI sharing your information with Federal agencies such as The Department of Education, FASA, State of California BPPE, other credential agencies and other agencies associated with your application for the purposes of your continuation of your enrollment at CNEI, this information cannot be withdrawn, deleted or expunged. The information may be updated if inaccurate with proof of inaccuracies. To remove this information please contact the appropriate agency directly.

No Automated Decision Making: We do not undertake any decision making about you based solely on automated processing, including profiling; however, certain features of our Services could be used by our staff for decision-making purposes.

We will not share your personal information with third parties for the third parties’ direct marketing purposes unless you have agreed to such disclosure.

We will verify your request using your name and email. Depending on the nature of your request, we may need additional information to verify your identity. You may not authorize an agent other than legal representation to make a request on your behalf to exercise your privacy rights under applicable California privacy laws. California laws prevails in regards to representation issues that may arise in regards to our Privacy Policy.

We are a California corporation and the use of our website, products, and services apps, you agree to be subject to California laws. You further agree that California laws supersedes all other state laws. If you do not agree, do not use our website, products, services, or apps.

To exercise your rights or to allow your authorized agent to exercise your rights, please submit, or have your authorized agent submit, a ticket through our Data subject access request portal, or contact our Privacy Team at privacy@cnei.edu.

Unsubscribe from our mailing list

You can manage your communication preferences through the following methods:

Following the instructions included in each promotional email from us to unsubscribe from that particular mailing

Sending us an email at unsubscribe@cnei.edu

Visiting the CNEI Subscription Center

These choices do not apply to service notifications or other required communications that are considered part of certain Apps and Services, which you may receive periodically unless you stop using or cancel the App or Service in accordance with its terms and conditions.

HOW WE KEEP YOUR PERSONAL INFORMATION SECURED

Keeping your information secure is important to us. We have taken appropriate steps designed to reduce the risk that your personal information may be subject to loss, misuse, unauthorized access, disclosure, alteration or destruction.

For more information on CNEI security measures, please visit the Security Trust Center.

HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

We will retain your personal information for no longer than is necessary to fulfill the purposes for which the information was originally collected unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other legitimate and lawful business purposes.

Where we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it.

INTERNATIONAL DATA TRANSFERS

We operate and may process information in multiple jurisdictions, both in and outside the United States, such that some Education Partners and Service Providers may be located or process information outside of the jurisdiction in which you reside. In such cases, your Personal Information may be collected, used, disclosed, stored, and processed in these other jurisdictions for the purposes described in this policy. The data protection and other laws of the United States and other countries might differ from your jurisdiction. In addition, your Personal Information may be subject to the laws of those other jurisdictions, including lawful requirements to disclose Personal Information to government authorities.

Data Privacy Frameworks (EU-U.S. DPF, UK Extension, Swiss-U.S. DPF)

CNEI, LLC. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Data processed and purposes of data processing

Please see the relevant sections of this Notice, sections WHAT PERSONAL INFORMATION WE COLLECT and HOW WE USE YOUR PERSONAL INFORMATION, for information regarding the data categories processed by CNEI as a controller on our own behalf and the purposes.

CNEI processes personal data that customers choose to submit to the services as customer-generated content, call detail records, and account information. The purposes for such processing is the provision, maintenance, support, and improvement of the services.

Type of third parties to which CNEI discloses personal data and purposes

Please see the relevant section of this Notice: HOW, WHY, AND WHAT PERSONAL INFORMATION WE SHARE WITH THIRD PARTIES for more information regarding the type of third parties to which CNEI discloses personal data and for what purposes.

Independent Recourse Mechanism

If you have any questions, comments or concerns about this Notice, you may contact us at privacy@cnei.edu. In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, CNEI commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF. Under certain conditions, individuals may invoke binding arbitration through the Data Privacy Framework Panel. For more information, please see Annex I of the EU-U.S. Data Privacy Framework Principles.

Enforcement Authority

The Federal Trade Commission has jurisdiction over CNEI’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

Lawful Requests for Personal Information

Please see https://www.CNEI.edu/legal/policies/data-request-guidelines.html for information regarding how CNEI responds to lawful requests by public authorities for CNEI to disclose personal information.

Individual rights to access and to limit use and disclosure

Please see the relevant section in this Notice HOW WE RESPECT YOUR PRIVACY RIGHTS for information regarding how individuals can exercise their rights to access their personal data and to limit the use and disclosure of their personal data.

Liability for Onward Transfers

In the context of an onward transfer, CNEI has responsibility for the processing of personal information it receives under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on its behalf. CNEI shall remain liable under the EU-U.S. DPF Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless CNEI proves that it is not responsible for the event giving rise to the damage.

CHILDREN'S PRIVACY

CNEI does not knowingly provide products or services directly to children under the age of 16, or knowingly collect or solicit personal information from or about children under the age of 16 outside of the school offering, which is subject to the Children’s COPPA notice. If you believe that a child under the age of 16 has disclosed personal information to CNEI outside of the school offering, please contact privacy@cnei.edu

If you have received a meeting invitation for your child from a teacher or school, or for information regarding how CNEI handles personal data as part of the school offering, please visit: www.cnei.edu/legal/childrens-privacy-notice-school-parental-notification.

California State-Related

The California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (“CCPA”) requires us to make additional disclosures. If you are a California resident, please read this section for additional disclosures and information on rights you may have under California law. In the event of a conflict between this California Addendum and the remainder of this Privacy Policy, this section shall take precedence for California residents. Terms used in this section and not defined have the meaning given in the CCPA.

Categories of Personal Information Collected. In the prior 12 months, we may have collected the types of Personal Information described in the “Categories of Personal Information Collected” section above. The Personal Information in this section falls into the following categories of Personal Information:

Name, contact information, and other identifiers

Customer records as described in California Civil Code 1798.80(e)

Protected classifications

Commercial information

Biometric information

Internet or other electronic network activity information

Geolocation data

Audio, video, and other electronic data

Employment history

Education information

Inferences drawn from any of above

Sensitive Personal Information

Categories of Third Parties to Whom Personal Information is Disclosed. In the last 12 months, the above categories of Personal Information may have been disclosed to the categories of third parties set forth in the “Disclosure of Personal Information” section above.

Sale or Sharing of Personal Information. While we do not disclose Personal Information to third parties in exchange for monetary compensation, we do disclose or make available Personal Information to Service Providers in order to receive certain services or benefits from them, such as when we allow third-party tags to collect information such as your browsing history when using our Services, in order to improve and measure our ad campaigns. California law may consider these activities to be the “sale” or “sharing” of Personal Information for cross-contextual behavioral advertising. The categories of Personal Information that we may “sell” or “share” as defined under California law include:

Name, contact information, and other identifiers

Customer records

Protected classifications

Internet or other electronic network activity information

Geolocation data

Education information

Inferences drawn from any of above

We do not have any actual knowledge that we have sold or shared Personal Information of any consumer under the age of 16.

Sensitive Personal Information. We do not use Sensitive Personal Information for any purpose other than that reasonably anticipated to accomplish the purpose for which it is collected.

Retention. For each category of Personal Information collected, we only retain such Personal Information for as long as necessary to fulfill the purposes outlined in this Privacy Policy and as otherwise needed to address tax, corporate, compliance, litigation, and other legal rights and obligations.

Opt-Out Preferences. For information on whether and how we process opt-out signals, see the “Do-Not-Track” section above.

Individual Rights Under California Law

California law grants California consumers certain rights and imposes restrictions on businesses as set forth below. If you are a resident of California, you have the following rights:

Do Not Sell or Share. The right to opt out of the “sale” or “sharing” of your Personal Information (as those terms are defined in the CCPA).

Verifiable Requests to Delete, Requests to Know, and Requests for Correction. Subject to certain exceptions, California residents have the right to make the following requests at no charge:

Request to Delete: The right to request deletion of their Personal Information we have collected and to have such Personal Information deleted, except where an exemption applies.

Request to Know: The right to request and, subject to certain exemptions, receive a copy of the specific pieces of Personal Information that we have collected about them and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their Personal Information, including the:

Categories of Personal Information collected;

Categories of sources of Personal Information;

Business and/or commercial purposes for collecting, selling, or sharing their Personal Information;

Categories of third parties with whom we have disclosed or shared their Personal Information;

Categories of Personal Information that we have disclosed or shared with a third party for a business purpose;

Categories of third parties to whom their Personal Information has been sold and the specific categories of Personal Information sold to each category of third party.

Request to Correct. The right to request that we correct inaccurate Personal Information.

Right to No Discrimination. You also have the right to not receive discriminatory treatment if you elect to exercise the above rights.

How to Exercise Your California Consumer Rights.

Do Not Sell or Share My Personal Information Requests. To exercise your right to opt-out of the sale or sharing of your Personal Information for cross-contextual behavioral advertising, you may submit your request here.

Note: We will also treat Global Privacy Control browser signals as opt-out of sale/sharing requests in accordance with the do-not-track section above.

Submitting a Verifiable Request. You may submit your verifiable request here. Alternatively, you may call 866-809-3444 (US Toll Free).

Who May Exercise Your Rights. You may make a request to exercise the above rights on behalf of yourself or on behalf of a minor if you are the parent or legal guardian of the minor. In addition, you may authorize an agent to exercise your rights on your behalf, if you provide the agent with written signed permission.

Verification of Your Request. Once we receive your request, we will contact you to confirm receipt of your request, unless your request is a “Do Not Sell or Share My Personal Information” request submitted through our automated processes. We will require sufficient information from you in order to verify your identity and the authenticity of your request. If you do not provide us with sufficient information, we may request additional information to verify your identity, the identity of the data subject of the request, and the authenticity of the request. Certain types of requests may require additional verification, as we are subject to higher standards of authentication for such requests. We will only use Personal Information we collect during the verification process for the purpose of verifying your identity.

If an authorized agent contacts us to exercise the above rights, we will need to verify their identity as well as your identity. We will also require proof of your written authorization to the agent to act on your behalf, unless the agent holds a lawful Power of Attorney under applicable laws, in which case we will require evidence of such Power of Attorney.

We may deny your request as permitted or as required by law.

We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.

THIRD-PARTY SITES

This Notice does not apply to, nor are we responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Website or Apps link including but not limited to social media sites. The inclusion of a link on the Website or Apps does not imply our endorsement of the linked site or service. You should check the privacy notices of those sites before providing your personal information to them.

BLOGS AND FORUMS

Our Website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas is public and may be read, collected, and used by others who access them and may remain on the public forum indefinitely. To request removal of your personal information from our blog or community forum, you can submit a request through our online portal. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. We encourage all users to exercise caution when providing personal information in blogs and community forums.

UPDATES TO THIS NOTICE

We may update this Notice from time to time in response to changing legal, technical, or business developments. If we make changes to our Notice, we will post those changes on this page in addition to updating the "Last Updated" or effective date at the top of this webpage. If we make material changes, we will notify you either by emailing you or by posting a notice of such changes prominently on this page prior to such material changes taking effect.

CONTACT US

If you have any questions, comments or concerns about this Notice, please e-mail our data protection officer at privacy@cnei.edu. Or, you can write to us at:

CNEI, LLC.
Attn: CNEI Chief Privacy Officer
California Nurses Educational Institute
72769 Dinah Shore Dr
Rancho Mirage, CA 92270 USA