This Privacy Policy is designed to help you understand how National Health and Safety Association, LLC and its related organizations and affiliates (“NHSA”, “we”, “us” or “our”), collects, uses and shares personal information collected through the Interactive CPR Trainer (the “Tool”). We value your privacy, and we will not share your personal information with third parties except as described in this Policy without your consent.  

 

BY USING THIS TOOL, YOU AGREE TO BE BOUND BY THIS POLICY. IF YOU DO NOT AGREE WITH ANY OF THE TERMS OF THE POLICY, PLEASE DO NOT USE THIS TOOL OR PROVIDE US WITH YOUR INFORMATION.

 

What this Policy Covers

This Policy applies to our collection, use and sharing of your personal information when you register for or otherwise use our Tool.  This Policy does not apply to any other information or websites not owned or operated by us or information collected by us by other means, including through our general website (https://www.cpr.io/), which is subject to separate terms posted on the website. 

 

Personal Information We Collect

This section of our Policy describes the categories of personal information we collect about you and the different ways in which we collect your personal information.

Information You Give Us.  Personal information you may provide through the Tool or otherwise communicate to us includes:

• Contact information. We collect information about you when you provide contact information to us through the Tool, including as a result of creating an account. This information may include your first and last name, email address, mailing address, phone number.
• Recordings. The Tool will record your face and body images and movements.
• Correspondence. We may collect personal information you provide when you request information or otherwise correspond with us.
• Other information. We may collect other information from you that is not specifically listed here. We may use such information in accordance with this Policy.

Information We Get From Others.  We may obtain additional information about you from third party sources, such as service providers, vendors, and the organization that made the Tool available to you, which may include your contact information, registration information, or cookie information. 

Information Automatically Collected.  Our servers and third party service providers may automatically record cookie information in connection with your use of the Tool, which includes information such as your Internet Protocol (IP) address, device and browser type, operating system, DNS, the pages or features of the Tool that you browsed and the time spent on those pages or features, the frequency with which you use the Tool, the links that you click on or use, and other statistics.  We collect this information in server logs and by using cookies and similar tracking technologies. See our Cookie Policy, below, for more information.

Statistical Analyses. We use tools like Google Analytics to help us gather statistical information about the visitors to our Tool and how they use the Tool on an anonymous, aggregate basis. We may use this information to gain a better understanding of the users of our Tool, to improve our Tool, and to improve our services. However, we will not associate this data with your personally identifiable data unless required to do so to cooperate with law enforcement activity or other governmental requests or to comply with law.  This information is collected via cookies and other identifiers that we and third parties place on our site.  See our Cookie Policy, below, for more information. 

 

How We Use Your Personal Information

This section of our Policy describes the different purposes for which we may use the personal information we collect about you.  

To Provide our Services and Communicate With You. We use your contact information and other personal information to provide you with our services and respond to your requests, questions, comments, and feedback.

To Improve our Tool.  We use your cookie information and recordings to provide, maintain and improve the Tool; personalize your experience with the Tool; and perform analytics and database management services. 

To Send You Marketing Communications. We may use your contact information to send you newsletters, promotions or other marketing communications, but you may opt out of receiving them as described in the Your Choices section below.

To Create and Maintain Your Account. In order to utilize the Tool, you must create an account using certain personal information, including your name and email address. 

For Compliance, Fraud Prevention and Safety.  We may use some or all of your personal information as we believe appropriate to: (a) investigate or prevent violation of the law or your agreements with us; (b) protect our, your or others’ rights, privacy, safety or property (including by prosecuting and defending legal claims); (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; (d) comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; and (e) where permitted by law in connection with a legal investigation. For example, we may share information with law enforcement to reduce the risk of fraud or if someone uses or attempts to use our site for illegal reasons.

With Your Consent.  In some cases we may ask for your consent to collect, use or share your personal information.

 

How We Share your Personal Information

This section of our Policy describes the categories of personal information we share with third parties and the types of third parties with whom we share that information.    

We do not sell your personal information; however we may share your personal information with third parties for a number of reasons.  For example, we may use third parties to help us design and operate the Tool, provide services to support the Tool, and help us analyze our data.  Unless otherwise indicated at the time we collect your information, if we allow third parties to access the personal information we collect, we will have contractual provisions or other appropriate protections in place to ensure such access is for limited purposes and in compliance with this Policy. Specifically, we share your personal information with the following categories of third parties:

With Your Organization.  If you are participating in the Tool at the direction of your organization, we will share your personal information with your organization.  This information will include your contact information and recordings of your session.

For Accreditation, Quality Control, and Auditing Purposes. We may share your personal information with third party auditors and accreditation agencies for compliance and quality control purposes to ensure both you and our Tool are performing as indicated.  This information may include your contact information and recordings of your session.

Related and Affiliated Organizations.  We may share all of the personal information we collect about you with our affiliates and related organizations for use consistent with this Policy.

Service Providers. We may share your personal information with third party companies and individuals as needed for them to provide us with services that help us with our business activities and to promote our services to you. This information may include your contact information, account information, recordings, and cookie information. 

Compliance, Fraud Prevention and Safety. We may disclose some or all of the personal information we have collected about you as we believe appropriate to government or law enforcement officials or private parties for the purposes described above under the section “For Compliance, Fraud Prevention and Safety.”

Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, including all of the personal information we have collected about you, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy.

 

Your Choices

This section of our Policy describes your choices with respect to the personal information you provide and the marketing communications you may receive.  In addition, some states may grant you additional rights as further described in the “Location-Specific Disclosures” section, below.

Opt Out of Marketing Communications. You may opt out of marketing-related emails by changing the communication preferences in your account settings or by following the opt-out prompt in the email.  To opt out of other forms of marketing communications, please contact us using the contact information provided at the end of this Policy.

Consequences of Not Providing Personal Information. You are not required to provide all personal information identified in this Policy to use our Tool, but certain functionality will not be available if you do not provide personal information. For example, if you do not provide personal information, we may not be able to respond to your request or provide you with marketing that we believe you would find valuable.

 

Cookie Policy

This section of our Policy describes how we and our business partners may collect and store information about you and your use of the Tool through cookies and other tracking technologies.  

What are Cookies?  Cookies are small data files that are placed on your computer or mobile device when you visit a website or application.   Cookies set by the site owner are called “first party cookies”. Cookies set by parties other than the owner are called “third party cookies”.  Third party cookies enable third party features or functionality, such as advertising or analytics, to be provided on or through the site. The parties that set these third party cookies can recognize your computer or device both when it visits the website in question and also when it visits certain other websites and/or mobile apps.

What Cookies and Other Tracking Technologies do We Use?  We use several different kinds of cookies, including strictly necessary cookies, which are cookies that are necessary for the Tool to function and cannot be switched off in our systems; performance cookies, which allow us to count visits and traffic sources so we can measure and improve the performance of our Tool; and functional cookies, which enable the Tool to provide enhanced functionality and personalization.  In addition to our own cookies, we collaborate with various third-party service providers who also use cookies to help us optimize the Tool and understand more about Tool users.  

Cookies are not the only way to track users. We may use similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has used our Tool.  These technologies often depend on cookies to function properly, and so disabling cookies may impair their functioning.  When your browser downloads any graphic content in the e-mail, we will also place a cookie on your computer that will tell us if you come to our website at a later date.

Google Services.  We use Google Analytics to help us gather statistical information about the users of the Tool. This information is collected via cookies and other identifiers that we and third parties place on the Tool. We and our third party partners may use this information to gain a better understanding of the users of our Tool and to improve our services.  To understand how Google collects and processes data, including through the use of cookies and other technologies, please visit please visit https://policies.google.com/technologies/partner-sites. To opt out of the Google Analytics, we encourage you to check out Google Analytics' currently available opt-outs for the web.

How Can You Disable Cookies and Other Tracking Technology?  Depending on the type of browser and device that you use, you may have the ability to control the type of information that these tools use. 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 computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com. Some Internet browsers also may 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.

 

Other Important Privacy Information

Security.  The security of your personal information is important to us.  We take a number of organizational, technical and physical measures that are designed to protect the personal information we collect.  However, security risk is inherent in all internet and information technologies and we cannot guarantee the absolute security of your personal information.

International Data Use and Cross-Border Transfers.  We are located in the United States and have affiliates and service providers in other countries, and your personal information may be collected, used and stored in the United States or other locations outside of your home country.  Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. However, we will handle your personal information in accordance with this Policy regardless of where your personal information is kept.  Regarding transfers from the European Economic Area, Switzerland or United Kingdom to the United States, we rely on the derogations for transfers which are necessary to perform the transaction with you. Where required by law, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below. If you reside in other non-US jurisdictions, your use of the Tool or provision of any personal information constitutes your consent for the transfer of such data to the United States for the purposes identified in this Policy.  If you have questions about cross-border transfers, please contact us as detailed at the end of this Policy.

Verifying, Changing, and Deleting Your Information. You can contact us as detailed below and ask us to change, update or fix your information in certain cases, particularly if it is inaccurate. You can also request that we erase or delete all or some of your personal information or otherwise object to, limit, or restrict the use of such information (if we have no legal right or legitimate business interest in retaining such information).   

Children. 

The Tool is not intended for use by anyone under the age of 18, nor do we knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, you should not attempt to use the Tool or send any information about yourself to us.

 

Changes to this Policy 

We reserve the right to modify this Policy at any time. If we make changes to this Policy, we will post them on the Tool and indicate the effective date of the change.  If we make material changes to this Policy we will notify you by email or through the Tool.

 

Location-Specific Disclosures

The law requires that we provide additional disclosures to residents of certain countries, regions and states. Please see below for disclosures that may be applicable to you.  

 

Notice to California Residents 

If you are a California resident, this section applies to you in addition to the rest of this Policy. 

 

Personal Information We Collect. We collect your personal information when you interact with our Tool or otherwise communicate with us. In the past 12 months, we have collected the following categories of personal information from consumers and have used that information for the following purposes:

 

Category of personal information collected	Business purpose of collection	Source(s) of information
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	To provide you with our Tool and for marketing purposes	Directly from you when you provide it, passively when you use the Tool, and from third parties (e.g. your employer)
Your physical characteristics, biometric information, and other Audio, electronic, visual, thermal, olfactory, or similar information.	To aid in the development of our Tool and for accreditation and auditing purposes	Directly from you via session recording.
Geolocation data.	To assist in identifying Tool usage	Passively when you use our Tool
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.	To provide you more relevant content, track Tool usage, and optimize your experience as well as to ensure our systems are properly functioning	Passively when you use our Tool
Professional or employment-related information.	To provide you with our Tool	Directly from you when you provide it and from third parties (e.g. your employer)

We will not collect additional categories of personal information or use or retain the personal information we collected for materially different, unrelated, or incompatible business purposes without providing you notice. 

Retaining Your Information.  We will only keep your personal information in an accessible form which can identify you for as long as we need to for the purposes for which it was collected.  Because retention periods vary depending on the purpose for collection, we use certain categories and criteria to determine how long we keep personal information, as further described below. Where your personal information is used for more than one purpose, we will retain your Information for the longer of those periods. 

 

Type of Personal Information	Retention Period
Personal information processed in connection with customer matters	Up to 7 years after the date of completion of our program, unless:  (a) otherwise required by applicable law;  (b) required for regulatory, compliance or insurance purposes;  (c) there is a dispute that requires it to be kept for longer; or (d) there is another legitimate reason which requires it to be kept for longer.
Personal information processed in connection with session recordings	Up to 7 years after the date of collection.
Personal information processed for marketing purposes	For as long as you have not opted out of our marketing. If you ask us to no longer use your personal information for marketing purposes, we will need to retain certain of your details in our database to ensure that we do not accidentally send you marketing material.
Personal information held in our electronic backups	Our electronic backups are retained for six months

 

When we no longer require your personal information, we will take steps to delete or de-identify it. If the information cannot be permanently deleted or de-identified (for example when it is stored in our electronic backups), we will take appropriate steps to ensure that it is: (a) not used in connection with any decision involving you; (b) not shared with anyone except when we are legally required to do so; (c) kept secure; and (d) permanently deleted once possible.

Sharing Your Information. We do not share your personal information with third parties for cross-context behavioral advertising purposes or otherwise sell your personal information, but we may disclose your personal information to third parties for a business purpose. In the past 12 months, we have disclosed the following categories of personal information to certain third party subcontractors and service providers for a business purpose:

 

Category of personal information Disclosed	Category of third parties to whom information is disclosed	Business or commercial purpose for disclosure
The following identifiers: real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, and email address	Third parties who make the Tool available to you (e.g. your employer), credentialing providers, internet service providers, and marketing intelligence service providers	To provide our Tool and to operate and improve our Tool
Geolocation data.	Marketing intelligence service providers	To operate and improve our Tool
The following internet or other electronic network activity information:  browsing history, search history, and information regarding a consumer’s interaction with an internet website application	Marketing intelligence service providers and internet service providers	To operate and improve our Tool

 

Sensitive Personal Information.  We do not use or disclose sensitive personal information except as necessary to provide you with our products and services, prevent fraud, or other permissible uses under applicable law. 

Personal Information of Children. We have no actual knowledge that we sell or share personal information of consumers under 16 years of age.   

Your Rights. California residents have certain rights regarding their personal information:

• Right to Know. You may request no more than twice in a 12-month period that we provide you with copies of specific personal information we have collected, sold, or disclosed about you. However, under California law, we cannot provide you with certain sensitive information, despite your request (for example, we will not send you copies of your social security number even if it is something we collected).
• Right to Delete. You may request that we delete certain personal information we have collected about you, with certain exceptions.
• Right to Correct. You may request that we correct inaccurate personal information that we maintain about you.
• Shine the Light. Under California’s “Shine the Light” law, you have the right to ask us once a year if we have shared your personal information with third parties for direct marketing purposes.

Exercising Your Rights. To exercise your rights above, please submit a request to us by clicking here or contact us by phone at (310) 340-0081, by email at [email protected] or by mail at National Health and Safety Association, LLC, P.O. Box 126, Allendale, MI 49401 USA.  Please describe your request with sufficient detail so we can properly respond to your request. As part of your request, please specify which right you are exercising and be prepared to provide your name, email, and phone number. We may ask for additional information to verify your identity. The information you provide in your request and any follow up information we ask for from you will be used solely to verify your request. After receiving your request, we may need to contact you for further information and will notify you if your request has been granted or declined, or if an exception applies to your request. Only you or an individual designated as your authorized agent to act on your behalf may make a request related to your personal information. We will not discriminate against you if you choose to exercise your rights. 

Responding to Your Rights Request. We will try to respond to your request within 45 days. If we need more time, we will contact you with the reason we need more time and the extension period. We will deliver our written response using the method you used to contact us (e.g. email). In response to your request to know, we will only disclose the information we have collected in the 12 months prior to our receipt of your request. Our response will also explain the reasons we cannot comply with any request, if applicable. We do not charge a fee to process or respond to your request unless your request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate prior to completing your request.

If you have any questions or concerns about our privacy practices or information practices, please contact us as detailed at the end of this Policy.

 

Notice to Colorado, Connecticut, Utah, and Virginia Residents 

We do not collect sensitive data or make sensitive data inferences about you under the law of your state. We will only retain your information as long as it is reasonably necessary for the purposes for which it was processed. We do not sell your personal information to third parties, process your personal information for targeting advertising, or process your personal information for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers. 

The law of your state gives you certain rights regarding your personal information:

• Right to Correct. You may request that we correct inaccurate personal information we maintain about you.
• Right to Delete. You may request that we delete certain personal information we have collected about you, with certain exceptions.
• Right of Access. You have the right to confirm whether we are processing your personal information and to access such personal information, and, under certain circumstances, to receive a copy of such personal information.

 

Only you or an individual designated as your authorized agent to act on your behalf may make a request related to your personal information. To exercise your rights above, please contact us as described at the end of this Policy. As part of your request, please specify which right you are exercising and be prepared to provide your name and contact information.  After receiving your request, we will use the information you provided to authenticate your identity or your authority as an authorized agent.  However, we may ask you to provide additional information if we cannot authenticate your identity or authority based on the information you have provided and the information in our records. We will not discriminate against you if you choose to exercise your rights.

We will try to respond to your request within 45 days and notify you if your request has been granted or declined, or if an exception applies to your request. If we need additional time, we will contact you with the reason and the extension period. We will deliver our written response by mail or electronically, at your option. Our response will also explain the reasons we cannot comply with any request, if applicable. We do not charge a fee to process or respond to your request unless your request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate prior to completing your request. 

If you are a resident of Colorado, Connecticut, or Virginia, you have the right to appeal our refusal to take action on a rights request within 30 days after receiving our decision by contacting us as detailed at the end of this Policy. We will try to inform you of our decision in writing within 45 days after receipt of your appeal, with a written explanation of our decision. If we need more time, we will contact you with the reason and the extension period. If your appeal is denied or if you have concerns about the results of an appeal, you may contact your state’s attorney general by clicking the appropriate link below.

• Colorado Attorney General
• Connecticut's Office of the Attorney General
• Attorney General of Virginia

 

Notice to Nevada Residents

Nevada law gives Nevada consumers the right to request that a company not sell their personal information for monetary consideration to certain other parties. We do not sell your personal information for monetary consideration; however, this right still applies. If you are a Nevada consumer and wish to exercise this right, please submit your request by contacting us as detailed at the end of this Policy.

 

How to Contact Us

If you have any questions or complaints about this Privacy Policy, please click here, email us at [email protected] or write to us at National Health and Safety Association, LLC, P.O. Box 126, Allendale, MI 49401 USA.

 

This Policy was last modified September 21, 2023