Privacy & Cookie Policy

Last Updated: December 27, 2023

This Privacy Policy describes the privacy practices of TrueLearn, LLC (“TrueLearn,” “we,” “us,” or “our”) in relation to personal information we collect about you when you use our websites and related services located at truelearn.com, truelearn.net, picmonic.com, apexanesthesia.com and any other website that we own or control and that link to this Privacy Policy, and related technologies, which may include mobile applications (collectively, the “Service” or “Services”). 

The Service is designed to provide curricular support, test preparation, continuing education and related services.

This Privacy Policy does not apply to our handling of personal information that we process on behalf of our customers as a service provider or processor. Our processing of that information is governed by our agreement with our customers.

Personal Information We Collect

Information you provide to us may include:

• Contact details, such as your first and last name, email and mailing addresses, phone number, and professional title.
• Account information, such as the username and password you use to access our Service.
• Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
• Payment information needed to complete your transactions with us, including name, payment card information, and billing information. This information is processed by our payment service providers which may handle your payment information in accordance with its own respective privacy policies. We do not have access to your full payment card information. 
• Usage information, such as information about how you use the Services and interact with us, including information associated with any content you upload to the Services or otherwise submit to us, and information you provide when you use any interactive features of the Services.  
• Image and likeness. Periodically we may host live and in-person sessions (the “Live Program”). We may videotape the Live Program for future viewing purposes and that such video might include your picture or image if you attend the Live Program. Please refer to our Terms of Use  for details on the media release that you grant to your picture, image and likeness.
• Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with them.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from third parties.

• Social Media Services. We may maintain pages on social media platforms, such as Twitter, LinkedIn, Facebook, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy. 
• Information We Get From Others. We may obtain your personal information from other third parties, such as publicly available sources and data providers.
• Schools. We may receive certain information including your name and email address from the school in which you are enrolled.

Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our website and the Services (in your capacity as our customer’s authorized user), our communications and other online services, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state, or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the website, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

We collect this information using cookies and other similar technologies. For more information, please visit our Cookie Policy.

How We Use Personal Information

We use your personal information for the following purposes:

To operate our Services. We use your personal information to operate, maintain, and provide our Services. We do so to perform our contract with you.

To communicate with you. We use personal information when it is in our legitimate business interests to respond to your requests, questions and feedback, provide customer support and communicate with you about our Services, including by sending you announcements, updates, security alerts, and support and administrative messages.

To improve, monitor, personalize and protect our Services. We use personal information where it is in our legitimate business interests to improve and keep our Services safe for our users, which includes:

• Understanding your needs and interests and personalizing your experience with the Services and our communications.
• Troubleshooting, testing and research and to keep the Services secure.
• Investigating and protecting against fraudulent, harmful, unauthorized or illegal activity.

Research and development. We may use personal information for our legitimate interests to carry out research and development, including to analyze and improve the Services and our business. As part of these activities, we may create aggregated, de-identified or other anonymized data from personal information we collect. We may use this anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services, and promote our business.

Marketing and advertising. We, our service providers, and our third-party advertising partners may collect and use personal information for the following marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications as permitted by law, including by email and text message. You may opt out of our marketing communications as described in the “Privacy Rights and Choices” section below. 
• Interest-based advertising. We engage advertising partners, including third party advertising companies and social media companies, to display ads around the web. These companies may use cookies and similar technologies to collect information (including the automatically-collected data described above) about your interactions over time across our Services, our communications, and other online services, and use that information to serve online ads that they think will interest you. For more information, or to understand your choices, please visit our Cookie Policy.

Except where consent is required, we undertake such marketing and advertising on the basis of our legitimate business interests. Where we seek your consent, you may withdraw your consent at any time.

Compliance and protection. We may use personal information where it is in our legitimate business interest to comply with legal obligations, and to defend TrueLearn against legal claims or disputes, including to:

• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
• Protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims).
• Audit our internal processes for compliance with legal and contractual requirements and internal policies.
• Enforce our Terms of Use.
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

How We Disclose Personal Information

We may disclose your personal information as follows:

• Affiliates.  We may disclose the categories of personal information described above to our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
• Service providers.  We may disclose the categories of personal information described above to companies and individuals that provide services on our behalf or help us operate our Services or our business (such as banking partners, hosting, information technology, customer support, email delivery, and website analytics services).
• With Your Institution: If your institution mandates the use of our Service, we may disclose to your institution all of your personal performance data and information, including but not limited to your test scores, frequency of use of our services, and other data regarding you. Where required by applicable law or by our contract with your institution, we will obtain your prior consent before disclosing this information to your institution. 
• Professional advisors. We may disclose the categories of personal information described above to professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
• Authorities and others.  We may disclose your personal information to law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above. The type of personal information we may disclose to such parties depends on the nature of the request or the applicable compliance requirement. 
• Business transferees.  We may disclose the categories of personal information described above to acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in TrueLearn (including, in connection with a bankruptcy or similar proceedings).
• Third Party Business Partners:  We may disclose your contact information to business partners or other entities with whom we deliver co-branded services, provide content to or participate with in events, seminars and conferences.  You may receive e-mails from our third-party business partners informing you of available services and products from the third-party business partner that are related to the Services. If you wish to opt-out of having your personal information shared with these third-party business partners, please Contact Us. Where required under applicable law, we will ask your prior permission to disclose your personal information to our partners. 

International Data Transfers

TrueLearn is based in and processes personal information in the United States. We may also transfer personal information to our affiliates and service providers in the United States and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.

When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for personal information and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision/regulation for transfers outside of the European Economic Area and United Kingdom, or on contractual protections for the transfer of personal information. For more information about how we transfer personal information internationally, please contact us as set out in the “Contact Us” section below.

Data Retention

Where required under applicable laws, we retain personal information only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations.

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 personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

Privacy Rights and Choices

Opt-out of marketing communications. You may opt out of marketing-related emails, text-messages and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us or you may Contact Us. You may continue to receive Services-related and other non-marketing emails.

Online tracking opt-out. You can opt out of third-party cookies as described in our Cookie Policy.

Account deactivation and deletion. You may deactivate your account and request that we delete your personal information by contacting us as set out in the “Contact Us” section below. . Note that deactivating your account may not cause us to fully delete all of your personal information. For example, we may need to retain certain personal information that is already integrated into our system to maintain the integrity of our platform, as well as for legitimate business purposes, including for preparing for and participating in audits and for security purposes.

Personal information requests. We also offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to personal information: 

• Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
• Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
• Correction of personal information that is inaccurate or out of date.
• Deletion of personal information that we no longer need to provide the Services or for other lawful purposes.
• Withdrawal of consent, where we have collected and processed your personal information with your consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• Opt-out of the sharing of your personal information or use of your information for targeted advertising purposes. To exercise this right, you can click the “Privacy Choices” link on the footer of our website.
• Additional rights, such as to object to and request that we restrict our use of personal information.

To make a request, please email us or write to us as provided in the “Contact Us” section below. We may ask for specific information from you to help us confirm your identity. Depending on where you reside, you may be entitled to empower an authorized agent to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination. Where provided under applicable law, you can appeal a decision with regard to your privacy requests by contacting us as set out in the “Contact Us” section below.

Limits on your privacy rights and choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “Contact Us” section below. 

Right to complain. Depending on where you reside, such as if you reside in the European Economic Area or United Kingdom, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred. Click here to find your local supervisory authority.

Comments or Discussion Forums

If you use a forum or comment section on the Service, you should be aware that any personal information that you submit, including your name and email address, can be read, collected, or used by other users of the Service, and could be used to send you unsolicited messages. We are not responsible for the privacy or security of the personal information you choose to share on forums on this Service.

Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Data Security

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe, and we cannot guarantee the security of your personal information.

Children

Our Services are not intended for use by children under 13 years of age. If we learn that we have collected personal information through the services from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service.

Contact Us

Responsible entity: TrueLearn is the entity responsible for the processing of personal information under this Privacy Policy (as a controller or business, where provided under applicable law).

How to contact us: You can reach us by email at support@truelearn.com or at the following mailing address:

3540 Toringdon Way

Suite 200 #1178, Charlotte

NC 28277-4650

United States

EEA and UK Representative Contact Information: For individuals in the EEA and the UK, we have appointed:

EEA:

Osano International Compliance Services Limited

ATTN: GEML

3 Dublin Landings

North Wall Quay

Dublin 1

D01C4E0

UK:

Osano UK Compliance LTD

ATTN: GEML

42-46 Fountain Street

Belfast

Antrim

BT1 – 5EF

Cookie Policy

This Cookie Policy explains how TrueLearn, LLC (“TrueLearn”) (collectively, the “TrueLearn,” “we,” “us,” or “our”) uses cookies and similar technologies in connection with our Services. This Cookie Policy should be read in conjunction with our Privacy Policy.[GP9] 

If you have any questions or concerns about the Cookie Policy, please contact us by email at support@truelearn.com or as otherwise described in our Privacy Policy.

What are cookies and similar technologies?

• Cookies are text files that websites store and access on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser to allow us to distinguish you from other users of our Services for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand activity and patterns, and facilitating online advertising.
• Local storage technologies, like HTML5, provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

This Cookie Policy refers to all these technologies, and other types of tracking technologies used through our Services, collectively as “cookies.”

How do we use cookies and other similar technologies?

We use both persistent cookies and session cookies. Persistent cookies stay on your device for a set period of time or until you delete them, while session cookies are deleted once you close your web browser. We use persistent cookies, for example, to record your choice of language and country location. The cookies placed through your use of our website are either set by us (first-party cookies) or by a third party at our request (third-party cookies).

We also allow our advertising partners to collect this information through our website.

What types of cookies and similar technologies do we use?

We use the following categories of cookies:

Essential Cookies: These cookies are necessary for the Services to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Services may not work. 

Analytics Cookies. These cookies allow us to count visits and traffic sources and to better understand our users’ needs and optimize our Services and user experience. They help us to know which pages are the most and least popular and see how visitors move around the Services (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.). All information these cookies collect is aggregated. If you do not allow these cookies we will not know when you have visited our Service and will not be able to monitor its performance.

Personalization Cookies. These cookies enable the Services to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Targeting Cookies. These cookies may be set through our Services by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. If you do not allow these cookies, you will experience less targeted advertising.

How can you control the use of cookies?

Depending on where you access the Services from, you may be presented with a cookie banner or other tool to provide permissions prior to non-Essential cookies being set. In this case, we only set these non-Essential cookies with your consent.

You can also limit online tracking by:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. 
  • Use the following links to learn more about how to control cookies and online tracking through your browser: Firefox; Chrome; Microsoft Edge; Safari (Mac); Safari (Mobile/iOS)

• Blocking advertising ID use in your mobile settings. Your mobile device settings can provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

• Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also install a browser add-on to opt out of Google Analytics.

• Advertising industry opt out tools. You can also use these opt out options to limit use of your information for interest-based advertising by participating companies:
  • Digital Advertising Alliance for Websites: outout.aboutads.info  
  • Network Advertising Initiative: optout.networkadvertising.org  

• Platform opt-outs. Some of our advertising partners offer opt-out features that let you opt out of use of your information for interest-based advertising, including:
  • Google 
  • Facebook 
  • LinkedIn

Note that because these opt out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track. Some Internet browsers can be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.