Privacy Policy

Infocus Continuing Education LLC, a Virginia limited liability company (“Infocus CE,” “we,” “us,” or “our”), operates the website and learning management system through which continuing education courses and services offered by Affirm Mental Health LLC (“Affirm”) are made available (collectively, the “Services”).

Infocus CE respects your privacy and is committed to protecting your personal information. This Privacy Policy explains the types of information we collect when you access or use the Services, how we use and disclose that information, and the choices available to you.

Affirm is the continuing education provider and provides the educational content and applicable continuing education approvals associated with courses offered through the Services. Certain learner information may be shared with Affirm as necessary to provide continuing education services, document course participation and completion, issue certificates, maintain required records, and satisfy applicable accreditation, licensing, regulatory, and other continuing education requirements.

By accessing or using the Services, you acknowledge the practices described in this Privacy Policy.

1. Information We Collect

We may collect personal information that you provide directly to us when you create an account, purchase a course or continuing education package, participate in a course, contact us, or otherwise use the Services.

Depending upon how you use the Services, this information may include:

• Name;
• Email address;
• Mailing address;
• Telephone number;
• Profession or professional designation;
• State of licensure or practice;
• License-related information that you choose or are required to provide;
• Account and login information;
• Course selections and enrollments;
• Course participation, progress and completion information;
• Quiz, examination or assessment results;
• Continuing education credits earned;
• Certificates of completion;
• Transaction and purchase information;
• Communications with customer support; and
• Other information you voluntarily provide through the Services.

We may also automatically collect certain technical and usage information when you access the Services, such as your Internet Protocol (IP) address, browser type, device type, operating system, pages visited, dates and times of access, referring pages, and information about how you interact with the Services.

2. Payment Information

Infocus CE processes purchases made through the Services. Payments are processed using Stripe, a third-party payment processor.

When you make a purchase, payment information such as your credit or debit card information is submitted to and processed by Stripe. Infocus CE does not store your complete payment-card number or card security code.

We may receive and maintain limited information relating to your payment and transaction, such as your name, billing information, transaction amount, payment status, date of purchase, and a transaction or payment identifier.

Stripe's collection and use of payment information is governed by its own privacy policies and terms.

3. How We Collect Information

We may collect information:

• Directly from you when you provide it to us;
• Through your use of the website and learning management system;
• Automatically through cookies and similar technologies;
• From Stripe and other service providers involved in providing the Services; and
• From Affirm when necessary to administer continuing education courses and services.

We may combine information obtained through these different sources when reasonably necessary to operate and improve the Services.

4. How We Use Your Information

We may use the information we collect to:

• Create, maintain and secure your account;
• Process course and continuing education package purchases;
• Enroll you in courses;
• Provide access to course materials;
• Track course participation and progress;
• Administer quizzes, examinations and other course requirements;
• Verify course completion;
• Calculate and document continuing education credits;
• Issue and maintain certificates of completion;
• Maintain continuing education records;
• Provide customer and technical support;
• Respond to your questions and requests;
• Communicate with you regarding your account, purchases, courses or certificates;
• Send information about courses, continuing education programs and related services, subject to applicable law and your communication preferences;
• Personalize and improve the Services;
• Analyze use and performance of the website and LMS;
• Detect and prevent fraud, misuse and security incidents;
• Maintain the security and integrity of the Services;
• Comply with accreditation, continuing education, licensing, regulatory, tax, accounting and legal requirements;
• Enforce our agreements and policies; and
• Carry out other purposes disclosed to you at the time information is collected or with your consent.

5. Information Shared With Affirm

Because courses offered through the Services are provided by Affirm, Infocus CE may provide Affirm with information reasonably necessary to administer and document continuing education activities.

This information may include your name, contact information, profession, state, license-related information where applicable, course enrollment, participation, completion information, assessment results, continuing education credits, and certificate information.

Affirm may use this information to provide educational services, maintain continuing education records, verify participation and completion, support continuing education documentation, respond to learner inquiries, and satisfy applicable accreditation, licensing, regulatory and continuing education requirements.

Infocus CE and Affirm will use personal information only for legitimate business, educational, administrative, regulatory and legal purposes consistent with their respective roles in providing the Services.

6. Information Shared With Service Providers and Other Parties

We may disclose personal information to third parties that provide services necessary to operate our business and the Services, including:

• Payment processors, including Stripe;
• Learning management system and technology providers;
• Website hosting and cloud-service providers;
• Email and communications providers;
• Analytics providers;
• Customer support providers;
• Security and fraud-prevention providers; and
• Professional advisers and other vendors supporting our operations.

These providers may access personal information only as reasonably necessary to perform services on our behalf, subject to applicable contractual and legal requirements.

We may also disclose information:

• When required by law, regulation, subpoena, court order or governmental request;
• When reasonably necessary to protect the rights, property, security or safety of Infocus CE, Affirm, our users or others;
• To investigate or prevent fraud, misuse or unlawful activity;
• To enforce our agreements and policies;
• In connection with a merger, acquisition, financing, reorganization, sale of assets or similar business transaction; or
• With your consent or at your direction.

We may use and disclose information that has been aggregated or de-identified so that it cannot reasonably identify you.

7. Cookies and Analytics

The Services may use cookies and similar technologies to operate the website and LMS, remember user preferences, maintain sessions, understand how the Services are used, improve performance and security, and analyze website traffic.

We may use third-party analytics or technology providers for these purposes.

Most web browsers allow you to control or disable cookies through browser settings. Disabling certain cookies may affect the functionality or availability of portions of the Services.

Additional information regarding cookies may be provided through a cookie notice or cookie preferences tool where applicable.

8. Email and Marketing Communications

We may send you transactional or administrative communications relating to your account, purchases, courses, continuing education requirements, certificates, customer service requests or changes to the Services.

We may also send promotional communications regarding continuing education courses, packages, programs or related services where permitted by law.

You may opt out of promotional emails by using the unsubscribe link included in those communications. Opting out of promotional communications will not prevent us from sending necessary transactional or administrative communications relating to your account or use of the Services.

9. Data Security

We use reasonable administrative, technical and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration and disclosure.

You are responsible for maintaining the confidentiality of your account credentials and password and should not share them with others.

No method of transmitting information over the Internet or storing information electronically can be guaranteed to be completely secure. Accordingly, while we take reasonable measures to protect personal information, we cannot guarantee absolute security.

10. Data Retention

We retain personal information for as long as reasonably necessary to provide the Services and fulfill the purposes described in this Privacy Policy.

Certain information may be retained for longer periods when necessary to comply with legal, tax, accounting, accreditation, continuing education, licensing, regulatory or recordkeeping requirements.

In particular, records concerning course enrollment, participation, completion, continuing education credits, assessments and certificates may need to be retained even after an account is closed or a user requests deletion of other personal information.

11. Accessing, Correcting or Deleting Your Information

You may be able to review or update certain personal information through your LMS account.

You may also contact us to request access to, correction of, or deletion of personal information we maintain about you.

We will consider and respond to such requests in accordance with applicable law. We may be unable to delete certain information when retention is reasonably necessary or required for continuing education, accreditation, licensing, regulatory, legal, security, fraud-prevention, tax, accounting or other legitimate recordkeeping purposes.

We may take reasonable steps to verify your identity before processing a privacy request.

12. State Privacy Rights

Depending on where you reside, applicable state privacy laws may provide additional rights concerning your personal information.

These rights may include, where applicable, the right to request access to personal information, correction of inaccurate personal information, deletion of certain personal information, or information concerning how personal information is collected, used or disclosed.

We will process applicable privacy requests in accordance with the laws that apply to us and to your request.

13. Third-Party Websites and Services

The Services may contain links to websites, applications or services operated by third parties.

Infocus CE and Affirm are not responsible for the privacy practices of third-party websites or services. We encourage you to review the privacy policies of third parties before providing personal information to them.

14. Children's Privacy

The Services are intended for adults seeking professional continuing education and are not directed to children under the age of 18.

We do not knowingly collect personal information from individuals under 18 through the Services. If we learn that we have collected personal information from an individual under 18 without appropriate authorization, we will take reasonable steps to delete the information.

15. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, Services, legal requirements or other circumstances.

When we update this Privacy Policy, we will post the revised version and update the “Last Updated” date at the top of this page. Your continued use of the Services following the effective date of an updated Privacy Policy will be subject to the updated Policy.

16. Contact Us

If you have questions about this Privacy Policy, our privacy practices, or would like to submit a privacy-related request, please contact:

Infocus Continuing Education LLC
Email: support@infocusce.com

For questions concerning continuing education records, course content, provider approvals, CE eligibility, accreditation, or regulatory requirements:

Affirm Mental Health LLC
support@affirmmentalhealth.com