Privacy Policy

Sterling Credentials, LLC

Effective Date: June 1, 2021

Introduction

We know that trust is earned through safeguarding your data. That’s why everything at Sterling Credentials, LLC (“Sterling Credentials,” “we,” “us” and “our”) is done with an emphasis on security and privacy. At Sterling Credentials, we work diligently to achieve the maximum level of security with industry-leading security standards and best practices.

Sterling Credentials operates the website available at https://sterlingcredentials.com (the “Website“) and a web-enabled proprietary platform (“Platform“) which is accessible to subscribers through our Website. The Platform provides record-keeping, skill evaluation and communications tools for students, faculty, preceptors and other representatives and employees of educational organizations involved in the healthcare and medical education field.

 

This privacy policy (“Privacy Policy”) explains what personal information Sterling Credentials collects about you and why, what we do with that information, how we share it, and how we handle the content you place on the Platform. For the purposes of this Privacy Policy, “personal information” means any information related to an identifiable individual or that may be used to identify an individual. In addition, some of the information provided or data created through use of the Platform as a student may be considered “educational records” as defined by Family Educational Rights and Privacy Act (“FERPA”) and students may upload certain information that may be consider “protected health information” as defined by Health Insurance Portability & Accountability Act of 1996 (“HIPAA”).

 

Consent

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY

BY DOWNLOADING, ACCESSING, OR USING THE WEBSITE OR THE PLATFORM, AND/OR BY REGISTERING AN ACCOUNT WITH US OR PROVIDING INFORMATION TO US IN CONNECTION WITH THE WEBSITE OR THE PLATFORM, YOU ACCEPT THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY, AND YOU HEREBY CONSENT TO OUR COLLECTION, USE, AND SHARING OF YOUR INFORMATION AS SET FORTH IN THIS PRIVACY POLICY.

Your use of the Website and the Platform is also subject to our Terms of Service (“Terms“), which are available at https://www.sterlingcredentials.com/terms-of-service/ and are expressly incorporated into and made a part of this Privacy Policy by reference. Capitalized terms not defined in this Privacy Policy (if any) have the meanings set forth in the Terms.

 

Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on the Website prior to the change becoming effective. We encourage you to review this Privacy Policy each time you use our Website or Platform.

Our Relationship to Different Users

We collect information about those who use our Platform as students, preceptors and faculty on behalf of their educational organization. Such educational organizations use our Platform to, among other things, gather information necessary to satisfy their obligations relating to accreditation and readiness for state audit. To satisfy these obligations, educational organizations request and collect certain information about student users such as their name, telephone number, e-mail address, schedule tracking and feedback and evaluations from preceptors or faculty members. However, educational organizations may request and collect additional information from students which may include protected health information and educational records. We give educational organizations choices about what data they will collect. We offer multiple options that an educational organization can choose to determine what information is required from student, preceptor or faculty member. We let the educational organization make these choices.

Sterling Credentials is not responsible for and cannot control the types of information that such educational organizations request and collect from students. We collect such information on behalf of these educational organizations and their collection and use of such information is governed by their respective privacy policies and procedures. If you are a student then please contact the educational organization directly with any questions about how they collect or use information collected through our Platform. We may send any inquiries that we receive directly from you about our use of your information to the relevant educational organization.

What Information We Collect

You may provide or we may otherwise collect personal information by:

  • Students interacting with our Website or Platform. This will usually occur when you register for an account and use our services via the Platform. The type of personal information collected includes your first and last name, email address, graduation date, name of educational organization, IP address, location, birth date, username, password, recordings or transcripts of feedback, evaluations and other communications you receive through the Platform (i.e. through text messaging on the Platform) and any other information which you may choose to disclose when using our Website or the services on the Platform. Personal information may also be collected when you use the Platform to log information or activities or upload documents such as a CPR card, physical exam or immunization record. Some of the information provided or data created through your use of the Platform may be considered an “educational record” as defined by FERPA or “protected health information” as defined by HIPAA. You may also provide a cell phone number or other information, but this is not required.
  • Preceptors using our Website or Platform. This will usually occur when you register for an account and use the services on our Platform. The type of personal information collected during the registration process generally includes your first and last name, email address, phone number and the name and address of the educational organization, IP address, location, username, recordings or transcripts of feedback, evaluations and other communications which take place using the Platform (i.e. through text messaging on the Platform) and any other information which you may choose to disclose when using our Website or the services on the Platform.
  • Faculty and other representatives of educational organizations using our Website or Platform. If you are a faculty member or other representative of an educational organization you may need to provide us with personal information in order to register for an account and use the Platform. The type of information collected includes your first and last name, the name of the educational organization, business address, email address, phone number, username, password, recordings or transcripts of feedback, evaluations and other communications which take place using the Platform (i.e. through text messaging on the Platform) and any other information which you may choose to disclose when using our Website or the services on the Platform.
  • Financial Information. If you register for an account, you may need to provide your payment information, including name, credit or debit card number, card expiration date, CVV code and billing address. Your credit information is processed by a Payments Processor. We do not collect, store or maintain this information. The Payment Processor may retain this information in accordance with its own privacy policies and terms of use.
  • Corresponding with us by phone, e-mail or otherwise. We ask you to disclose only as much information as is necessary to provide you with our products or services or to submit your question/suggestion/comment in relation to our Website or Platform.
  • Filling in forms on our Website or Platform. In order to use the Platform as a student, preceptor or other representative of an educational organization you will be required to complete a registration form and profile. The type of information collected on the forms may include the personal information listed above.
  • Applying to work with us. If you apply for work with us through our Website you may need to provide personal information including the type of information you may provide in your CV, a cover letter, your name, address, e-mail address and phone number. CVs should include information relevant to your employment history and education (degrees obtained, places worked, positions held, relevant awards, and so forth). We ask that you do not disclose sensitive personal information (e.g. gender, height, weight, medical information, religion, philosophical or political beliefs, financial data) in your application.
  • Tracking data. Location, IP address, domain, browser, viewing data, type of device and other information may be collected as a part of our analysis of your use of our Website and Platform.
  • Supplying us with goods or services. Vendors and suppliers may provide us with information which may include a contact name, email address, business address and telephone number.

By using the Website or Platform, you consent to our collection of your information.

How We Use Your Information

We use the information we collect in the following ways:

  • To create and administer your account and to make the Website and Platform easier for you to use by not requiring you to enter your information more than once;
  • To provide access to and use of the Platform;
  • To provide the student, preceptor, faculty member and the educational organization with all information shared or exchanged through the Platform including evaluations, shift information, recordings or transcripts of conversations which take place using the Platform (i.e. through text messaging on the Platform) and other data;
  • To send you requested product or service information;
  • To respond to inquiries, client service requests or communicate with you;
  • To notify you of product upgrades, special offers, updated information, and new services via email, phone, chat or other means;
  • To send you marketing communications regarding our products and services;
  • To improve our Website, Platform, professional services or to enhance our marketing;
  • To consider you for employment, if you have provided information for such purpose; or
  • To comply with legal requirements and to prevent activities that may violate our policies.

By using the Website or Platform, you consent to our use of your information for these purposes.

How We Share Your Information

We may share your personal information with companies that provide services to help us with our business activities such as offering customer service, hosting our Website, providing IT services and payment processing. We will provide those companies with only the information they need to deliver the service and they are authorized to use your personal information only as necessary to provide these services to us.

In addition, we may disclose your personal information to third parties:

  • as required by law, such as to comply with a subpoena or similar legal process;
  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
  • if Sterling Credentials is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Website of any change in ownership and any choices you may have regarding your personal information with respect to the transaction;
  • including your student, preceptor, educational organization and faculty members, representatives or employees of the educational organization, as applicable, to be used for determining credentials, accreditation, readiness for state audit or other educational purposes; and
  • to any other third party with your prior consent to do so.

When a student requests that a preceptor provide an evaluation of their skills the student and the preceptor understand that all information recorded during a shift including recordings or transcripts of feedback, evaluations and other communications  which take place using the Platform (i.e. through text messaging on the Platform) is recorded and may be accessed by the student, the preceptor and the educational organization after the shift. You agree that we have permission to record and share such personal information as described herein. Although we advise educational organizations to maintain responsible practices when using student information, Sterling Credentials will not be liable or held responsible for any actions of those third parties with respect to their use of your information which will be subject to their internal privacy policies.

We will never transmit or sell your personal information to advertisers.

Access to and Retention of Your Information

We provide account settings and tools to access and control your personal information regardless of where you live. If you live in certain jurisdictions, you may also have legal rights with respect to your information.

You can access some of the information that we collect about you. If you are a registered user, you may access or modify your personal information at any time by signing into your account. You may access or modify your communications preferences by following the instructions included in any communications you receive. Administrative communications concerning the Platform are provided to all registered users and considered to be a part of the services.

You may modify or delete your information or content, subject to limitations, through your account. Preceptors, faculty members and other representatives of educational organizations can also permanently delete their account by contacting us. If you are a student you can deactivate your account by contacting us, however, the educational organization associated with your account will continue to have access to and the right to use your personal information only to the extent required to satisfy their obligations such as accreditation, readiness for state audit and other regulatory requirements. We take reasonable steps to remove personal information and other information associated with your account promptly after you delete your account.

Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, and/or where we otherwise reasonably believe that we have a legitimate reason to do so. Preceptors, faculty members and other representatives of education organizations are solely responsible for retrieving, exporting and otherwise securing any information or content needed for accreditation or other purposes prior to deleting or requesting we permanently delete your account.

Data Retention

Typically, we retain your personal information for the period necessary to provide you with access to the Platform and to otherwise fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law or regulation. In addition, we may keep your personal information as needed to comply with our legal obligations, resolve disputes, and/or enforce our agreements. The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it.

Cookies and Other Tracking Technologies

A cookie is placed on your machine (if you accept cookies) or is read if you have visited our Website or Platform previously. All of this is done in accordance with applicable laws. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like  Google Chrome, Firefox, Safari, etc.) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.

Web beacons, also known as clear gif technology, or action tags, assist in delivering the cookie. This technology tells us how many visitors clicked on key elements (such as links or graphics) while using the Website or Platform, remembers users’ settings (e.g. language preference) and is used for authentication. We do not use this technology to access your personal information on the Website or Platform; it is a tool we use to compile aggregated statistics about Website or Platform usage. We may share aggregated statistics with our business partners, but do not allow other companies to place clear gifs on the Website or Platform.

To ensure we are creating and publishing relevant content, we may use information collected from cookies and other mechanisms. We may use this information in aggregated form and use site-visitation statistics to better understand the experience of our users and improve our Website. If you choose to not have your browser accept cookies from our Website or Platform, you will be able to view the text on the screens, however, you will not experience a personalized visit and your ability to use some features or areas of our Website or Platform may be limited.

As is true of most websites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We do not link this automatically collected data to other information we collect about you.

This Website uses the Google AdWords remarketing service to advertise on third-party websites (including Google) to previous visitors on our Website. It could mean that we advertise to previous visitors who haven’t completed a task on our Website – for example, completing a registration form. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to our Website. Of course, any data collected will be used in accordance with our own Privacy Policy and Google’s Privacy Notice.

Security of Your Information

We are committed to protecting the security of your personal information and we honor your choices for its intended use. We have implemented the appropriate safeguards to protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction both during transmission and once we receive it. For example, your personal information is stored in password-controlled servers with limited access. We make good faith efforts to provide the security measures necessary to keep the integrity and confidentiality of your information safe. However, no system can be completely secure and we do not guarantee that our security measures are impenetrable or that unauthorized access, hacking, data loss, or other breaches will not occur.

You also have a significant role in protecting your information. As an example, you should not share your password with anyone. If you believe that your password has been compromised, you should immediately change your password or contact us immediately at [email protected].

If you have any questions about security on our Website or Platform, please contact us [email protected].

Treatment of Protected Health Information and Educational Records

Our Platform is utilized by users to track skills and shifts, evaluate competency, maintain records and provide communications which may include educational records protected by FERPA and/or to upload certain documents which may contain protected health information governed by HIPAA. The educational organization is the sole decision-maker regarding what personal information, protected health information or educational records are provided and how such information is used, maintained and otherwise processed in connection with your use of our Platform. The use, processing and maintenance of any personal information a student shares with a preceptor or educational organization will be governed by the privacy policies of the educational organization. Sterling Credentials provides a technology platform to users. Any personal information (including any educational record or protected health information) transmitted through our Platform is maintained on behalf of, and at the direction of, the user and we do not use such information for other purposes except as permitted by applicable law, including FERPA and HIPAA, and in accordance with our Privacy Policy.

Children Under the Age of 13

Our Website and Platform are not directed to individuals under 13. If you are under the age of 13, you may not use the Platform or provide any personal information to us. Sterling Credentials does not knowingly collect personal information from individuals under the age of 13. We reserve the right to immediately delete the information of any individual, to the extent permitted by law, who we believe is under the age of 13.

For more information about the Children’s Online Privacy Protection Act, please visit the Federal Trade Commission’s website.

California Residents

This section supplements our Privacy Policy with respect to the California Consumer Privacy Act (“CCPA”) and certain other California laws and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). Any terms defined in the CCPA have the same meaning when used in this section.

  1. Information We Collect. We collect certain information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (for the purposes of this section only, “personal information”). Personal information does not include publicly available information, such as deidentified or aggregate consumer information, or information excluded from the CCPA’s scope.

The following are all of the categories of personal information which we collect, or reasonably believe have been collected, through the Website and Platform from California Residents, in the twelve (12) months prior to the effective date of this policy (each, a “Category”): (i) identifiers; (ii) personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)); (iii) commercial information; and (iv) internet or similar network activity.

We obtain each Category directly from you or by way of collection through the Platform, service providers and/or payment processors. We share each Category for a business purpose with service providers, payment processors, and other third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

  1. Uses of Personal Information. We may use or disclose the personal information we collect for one or more of the following purposes: (i) providing services through the Platform (including without limitation maintaining your account, processing and fulfilling orders); (ii) providing customer support; (iii) operating the Website and the Platform (including without limitation managing third party relationships and enabling usage of our service providers); (iv) communicating with you; (v) customizing the Website and the Platform; (vi) securing and protecting the Website and the Platform (including without limitation auditing, bug and fraud detection, debugging and repair of errors and the detection, protection and prosecution of security incidents or illegal activity); (vii) enforcing our terms and policies; (viii) complying with law; (ix) verifying your identity; and (x) other business purposes about which we may notify you from time to time.
  2. Sale. In the preceding twelve (12) months, we have not sold personal information as that term is defined based on our understanding of the CCPA and its implementing regulations.
  3. Requests. Subject to certain exceptions and restrictions, the CCPA provides California consumers the right to submit requests to a business which has collected their personal information (each, a “California Request”).
  • You have the right to request to know (i) the specific pieces and categories of personal information we have about you, (ii) the categories of personal information we have collected about you in the last twelve (12) months, (iii) the categories of sources from which that personal information was collected, the business or commercial purposes for collecting such information, (iv) the categories of your personal information that we sold or disclosed in the last twelve (12) months, (v) the categories of third parties to whom your personal information was sold or disclosed in the last twelve (12) months, and (vi) the purpose for collecting and selling your personal information.
  • You have the right to request that we delete the personal information that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your personal information was collected such as the satisfaction of obligations by educational organizations including accreditation, readiness for state audit or other regulatory requirements. If we deny your request for deletion, we will let you know the reason why.
  • If you choose to exercise any of these rights, we will not discriminate against you in anyway. If you exercise certain rights, understand that you may be unable to use or access certain features of our services or the Platform.

You may exercise your right to know and your right to deletion twice a year free of charge. To exercise your right to know or your right to deletion, please contact us at [email protected].

We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to verify you are the individual about whom we collected personal information. If you have an account with us, we will use our existing account authentication practices to verify your identity. If you do not have an account with us, we may request additional information about you to verify your identity. We will only use the personal information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose.

You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your personal information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

  1. California Do Not Track Disclosure. We do not track our customers over time and across third party websites to provide targeted advertising and therefore do not respond to Do Not Track (DNT) signals. Third parties that have content embedded on our Website such as a social feature may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited our Website from a certain IP address.

Transfer of Your Information Across Borders and Your Rights Under GDPR

Our company is located in the United States. Your information may be transferred to, stored and processed in the United States or any other country in which Sterling Credentials or its vendors maintain facilities. By using our Website or Platform, you consent to any transfer, storage, or processing of information outside of your country. Several countries, including those in the European Economic Area (“EEA”) and Switzerland, have established data protection laws and regulations that place restrictions on the transfer of personal information across country borders. We are committed to complying with all of those laws and regulations; however, when you use our Website or Platform and provide such personal information, you should do so in compliance with the applicable data protection laws and regulations in your country.

Links to Third Party Websites

Our Website and Platform may include links to third party websites whose privacy practices may differ from those of Sterling Credentials. We are not responsible for and do not control the privacy practices of any third party. If you submit personal information to another user or to any of those websites, your information will be governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

How to Contact Us

If you have any questions or comments on our Privacy Policy, please contact us at:

Sterling Credentials, LLC

701 N Hwy 281

Suite E #105

Marble Falls, Tx 78654

888-846-5431

[email protected]