​

OUR ROLE IN PROCESSING PERSONAL INFORMATION

Empathetics determines the purposes for which it processes personal information collected directly through its public websites, marketing communications, direct customer relationships, and ordinary business operations.

When a customer organization provides learner or participant information to Empathetics, or makes the Services available to its employees, learners, or other authorized participants, that customer organization determines the purposes for which that information is collected and used. Empathetics processes that information on the customer organization’s behalf to provision accounts, administer access, deliver learning offerings, maintain enrollment, progress, and completion records, provide agreed reporting, and support the Services.

If you are a learner or participant whose access is provided by a customer organization, direct your privacy requests concerning your customer-provided learning information first to that organization. Empathetics will work with the customer organization as appropriate to address requests under the applicable agreement and law.

This Privacy Notice for Empathetics, Inc. ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit any of our websites that link to this Privacy Notice.

• Visit, interact with, or use an account at our public website, Leadership Development Profile, mobile application, hosted learning and eLearning services, instructor-led offerings, direct purchases, marketing communications, and support activities. 

• Use Empathetics Training products and/or services. 

• Engage with us in other related ways, including any marketing or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@empathetics.com.

 

1. WHAT INFORMATION DO WE COLLECT?

 

Personal information disclosed to us by you, or by your employer or affiliated organization

 

We collect personal information directly provided to us by your employer or affiliated organization or that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information We Collect. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names

• email addresses

• job titles

• contact or authentication data

• passwords

• usernames

• phone numbers

• organization

• ​

Sensitive Information. Empathetics does not require individuals to provide sensitive personal information through its public website or ordinary support channels. If a visitor, customer organization, or participant provides information that is considered sensitive under applicable law, Empathetics will process it only as necessary to respond to the submission, provide the relevant Services, meet contractual or legal requirements, or protect the security and integrity of the Services. Where information is provided by or on behalf of a customer organization, Empathetics processes that information to provide contracted services and as directed by that organization. Please do not submit sensitive personal information through a public contact form unless Empathetics specifically requests it.

Payment Data. If you make a purchase through our services, payment information is processed by our third-party payment processors, such as Stripe and Authorize.net. Empathetics does not collect or store your payment-card number, expiration date, or card security code. We may receive limited transaction information, such as payment status, transaction identifiers, or billing-related information, as needed to administer the purchase. You may find their privacy notice link(s) here:

https://support.authorize.net/knowledgebase/Knowledgearticle/?code=000002490 

https://stripe.com/privacy 

 

Application Data. If you use our application(s), we also may collect the following information and/or send you certain communications if you choose to provide us with access or permission:

• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

• ​

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

 

Information automatically collected

 

Depending on the service, we may collect technical and usage information needed to operate, secure, analyze, and improve the service, which may include IP addresses, browser or device information, access times, pages or features used, and diagnostic or performance information. The technologies used differ by service and are described below.

Like many businesses, we also collect information through cookies and similar technologies (see Section 5 below).

The information we collect includes:

​

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we may record, possibly in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings, and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports, sometimes called "crash dumps", and hardware settings).

• Learning and assessment information. Depending on the service, we process information such as enrollment, progress, completion, assessment-related information, evaluation responses, and assessment responses and resulting profile information.

 

2. HOW DO WE PROCESS YOUR INFORMATION?

 

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

​

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

• To fulfill and manage your orders. We may process your information to process payments for LDP and other services and administer related transactions.

• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.

• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

• Course Accreditation. For data associated with courses accredited by the Massachusetts Medical Society or other similar organizations on the LMS, Empathetics may provide participant identity and learning records needed for accreditation administration and reporting, including enrollment, completion, and evaluation information.

• Service providers. Personally identifiable information may be shared with service providers and contractors that host, operate, support, or develop the services; with customer organizations for learner administration, progress, completion, or reporting; and with payment processors for payment processing. Empathetics does not sell personal information.

• To fulfill contracts. Participant identity and roster data are used to create/provision accounts, administer access, deliver learning content, track enrollment/progress/completion, support customer reporting, and provide support and service operations. Empathetics also handles limited business-contact and employee information for ordinary business operations. Additionally, data collected through the webform is used to provide customer service and respond to inquiry. Empathetics handles some data on behalf of customer organizations, including participant/learner roster and learning-administration data used to provide the contracted services and reporting. It handles its own business-contact, employee, and operational information for its own internal purposes.

 

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

 

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We may disclose personal information to service providers and contractors that host, operate, support, secure, analyze, develop, or maintain our services; to payment processors for direct purchases; to customer organizations for participant administration and reporting; and to accreditation organizations where needed for accredited offerings

​

The categories of third parties we may share personal information with are as follows:

• Cloud Computing Services

• Data Analytics Services

• Data Storage Service Providers

• Sales & Marketing Tools

• User Account Registration & Authentication Services

• Website Hosting Service Providers

• Payment Processors

• Performance Monitoring Tools

• Communication & Collaboration Tools

​

We also may need to share your personal information in the following situations:

​

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

• Other Users. When you share personal information or otherwise interact with the Services, such personal information may be viewed by all users. Similarly, other users will be able to view your progress on the Leaderboard feature of the mobile application and send pre-set recognition badges through the “Connect” feature of the mobile application. 

 

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

 

We may use cookies and similar tracking technologies to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

​

Different Empathetics services use different technologies. The public website uses cookies and Google Analytics to support website operation and understand website usage. The Leadership Development Profile uses session technologies necessary for authentication, limited browser storage for application functionality, and Vercel Web Analytics. The native mobile application uses device-local storage rather than browser cookies and uses third-party services for analytics and push notifications. The hosted LMS uses cookies necessary for authentication and normal platform functionality.

 

Google Analytics

 

We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page: https://policies.google.com

 

5. HOW LONG DO WE KEEP YOUR INFORMATION?

 

We retain personal information for as long as reasonably necessary for the purposes for which it is processed, including providing services, maintaining appropriate business records, meeting contractual or accreditation requirements, protecting our services, and complying with applicable legal obligations. Retention may vary depending on the type of information and the context in which it was collected. 

 

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

 

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information. No method of electronic transmission or storage can be guaranteed to be completely secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

 

7. DO WE COLLECT INFORMATION FROM MINORS?

 

Empathetics’ Services are designed for adult professional and workplace-learning audiences and are not directed to children under 13. Empathetics does not knowingly collect personal information from children under 13 through its public website or Services. If Empathetics learns that it has collected personal information from a child under 13, it will take reasonable steps to delete that information. If you believe that a child under 13 has provided personal information to Empathetics, contact privacy@empathetics.com.

 

8. WHAT ARE YOUR PRIVACY RIGHTS?

 

Depending on applicable law and the circumstances in which we process your information, you may have rights regarding your personal information. You may contact us at privacy@empathetics.com with a privacy question or request. We may need to verify your identity before acting on a request. If your information was provided to us by a customer organization in connection with services provided through that organization, we may coordinate the request with that organization where appropriate.

 

How to contact us:

Email: privacy@empathetics.com

 

What happens after you complain

• We will acknowledge your complaint within 30 days of receiving it.

• We will investigate without unjustifiable or excessive delay.

• We will keep you informed of progress and explain the outcome.

 

Withdrawing your consent: If we are relying on your consent or that of your employer or affiliated organization to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent or request to be excluded at any time. To do so, simply contact us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below or, in some cases, by updating your preferences.

 

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

 

Account Information

 

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Contact us using the contact information provided.

​

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. If your account information was provided to us by your employer or affiliated organization, we will notify them of your request for account removal. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

​

If you have questions or comments about your privacy rights, you may email us at privacy@empathetics.com.

 

9. CONTROLS FOR DO-NOT-TRACK FEATURES

 

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

​

10. DO WE MAKE UPDATES TO THIS NOTICE?

 

We may update this Privacy Policy from time to time. When we do, we will post the updated version and update the effective date. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

 

If you have questions or comments about this notice, you may email us at privacy@empathetics.com or contact us by post at:

​

Empathetics, Inc.

867 Boylston St. 5th Floor

Boston, MA 02116

United States