Privacy Policy

1.Introduction and Scope

This Privacy Policy (this “Policy”) describes how [LEGAL ENTITY NAME], doing business as Jude Health Institute (“JHI,” “we,” “us,” or “our”), collects, uses, discloses, retains, and protects Personal Information in connection with the website at judehealthinstitute.com (the “Site”).

1. 1.1

   Scope. This Policy applies to Personal Information collected through the Site, including through the Inquiry Form, the Enrollment Application, the Call Booking, and Session Alerts, and to the communications we send or make in response.

2. 1.2

   Exclusions. This Policy does not govern (a) information about enrolled students, which is collected through enrollment documents and governed by the applicable enrollment agreement and [STUDENT RECORDS POLICY — owner to confirm whether one exists]; or (b) the practices of third-party websites linked from the Site (see Section 14).

3. 1.3

   Relationship to our Terms. This Policy is incorporated into our Terms and Conditions at our Terms. If they conflict on any matter concerning Personal Information, this Policy controls.

2.Who We Are

The business responsible for Personal Information collected through the Site (the “controller”) is [LEGAL ENTITY NAME], a [STATE OF ORGANIZATION] [ENTITY TYPE] doing business as Jude Health Institute, Suite 251, 6100 Lake Ellenor Drive, Orlando, Florida 32809; telephone (407) 606-7964; email info@judehealthinstitute.com. Privacy questions may also be directed to [PRIVACY CONTACT — responsible person or title, and a separate privacy email address if one is designated]. JHI is a healthcare training center. It does not provide medical care through the Site, and the Site is not designed to collect health information.

3.Definitions

1. 3.1

   “Personal Information” means information that identifies, relates to, or is reasonably capable of being associated with a particular individual, such as a name, email address, telephone number, or IP address. It does not include de-identified information.

2. 3.2

   “Inquiry Form” means the two-step course inquiry form on the Site, and “Session Alerts” means the “Next Session Alerts” email sign-up on the Site (sometimes described on the Site as our newsletter). “Call Booking” means the “Speak with a JHI advisor” window on the Site, through which you can book a free telephone call with an advisor. “Enrollment Application” means the five-step application form on the Site’s Apply page.

3. 3.3

   “Server Logs” means the access and error logs that the servers hosting the Site generate automatically.

4. 3.4

   “Sell” means to disclose Personal Information to a third party for money or other valuable consideration. “Share” means to disclose Personal Information to a third party for advertising targeted to an individual based on the individual’s activity across unrelated websites or services (cross-context behavioral advertising).

4.Information We Collect

We collect only the Personal Information described in this Section 4. Apart from Google Analytics and Cloudflare Turnstile, described in Section 4.2, we do not use cookies, web beacons, pixels, advertising tags, session recording, or any other technology that tracks your activity on the Site, and we use no technology that tracks you across other websites.

1. 4.1

   Information you provide.

   1. (a)

      Inquiry Form: your name, email address, and telephone number; the course you are interested in, your preferred schedule, and your preferred language; any message you write in the optional free-text field; and your confirmation, by checking a box, that “I agree to be contacted by Jude Health Institute about the course I have asked about.”

   2. (b)

      Call Booking: the day and time you choose for the call; your first and last name, telephone number, and email address; optionally, the course you are interested in and your preferred language for the call; and your confirmation, by checking a box, that “I agree to be called by Jude Health Institute at the time I choose, and to be emailed about this booking.”

   3. (c)

      Session Alerts: your email address and your confirmation, by checking a box, that you wish to receive emails about start dates and continuing education.

   4. (d)

      Direct communications: the information you choose to give us when you email, telephone, or write to us. [CALL RECORDING — owner to confirm that calls are not recorded or transcribed; if any are, say so here.]

   5. (e)

      Enrollment Application: your legal first and last name and any preferred name; your date of birth; your email address, mobile telephone number, home address, and preferred way of being contacted; the program you are applying for, when you would like to start, and your preferred schedule, language, and payment arrangement; your highest level of education completed, any current healthcare role, whether you hold a healthcare license or certification, your goals for the program, how you heard about JHI, and who referred you; the name, relationship, and telephone number of an emergency contact, which please give only with that person’s knowledge; your confirmations, by checking boxes, that the information is true and complete, that you must review and sign the enrollment agreement and student policies before enrollment is complete, and that JHI may contact you by phone or email about your application; if you choose, your agreement to receive admissions-related text messages; and your electronic signature (your typed full legal name) and the date.

   6. (f)

      Certificates: when JHI issues you a certificate, the details printed on it (your full name, the course, the completion date, any hours, any license number you give us for continuing education, and the name of the instructor), your email address if you ask us to send the certificate to you, and the date it was issued. The certificate number, your name, the course, the dates, the hours, any license number, and whether the certificate is valid are shown to anyone who enters the certificate number on the Site’s verification page or scans the QR code printed on the certificate, so that employers and others can confirm it is genuine.

2. 4.2

   Information collected automatically.

   1. (a)

      Submission details. When you submit the Inquiry Form, the Enrollment Application, or a Call Booking, our server records the date and time, your IP address, your browser’s user-agent string (which describes your browser and operating system), and the web page from which you submitted the form (the “referring page”). When you sign up for Session Alerts, our server records the date and time, your IP address, and the referring page.

   2. (b)

      Anti-spam measures. Our forms use a hidden field that automated programs tend to complete, a minimum completion time, and a limit on submissions from a single IP address within a rolling one-hour period. To apply that limit, our server keeps a small file named with a keyed one-way hash of the submitting IP address, recording the times of recent submissions. These files are deleted automatically once they have not been used for 24 hours. Our forms also use Cloudflare Turnstile, a service of Cloudflare, Inc. that distinguishes people from automated programs, usually without asking you to do anything. Turnstile is loaded only when you begin to fill in a form. It runs checks in your browser and sends Cloudflare technical information such as your IP address and characteristics of your browser and device; when you submit the form, our server sends Cloudflare the resulting token and your IP address to confirm the result. We receive only a pass or fail result. Cloudflare’s handling of this information is described in its privacy policy at cloudflare.com/privacypolicy (opens in a new tab).

   3. (c)

      Server Logs. The servers that host the Site automatically log each request for a page or file, typically recording the IP address, date and time, the address requested, the server’s response, and the browser’s user-agent string. Error logs record technical problems, such as why a form submission was rejected or that an email notification failed to send. They do not record the contents of your submission.

   4. (d)

      Analytics. On the live Site we use Google Analytics 4, a web analytics service provided by Google LLC, to understand how visitors find and use the Site so that we can improve it. Google Analytics sets first-party cookies (named _ga and _ga_ followed by an identifier) and records the pages you view, how long you spend on them, the website that referred you, your device, browser and operating system, your approximate location (city or region, derived from your IP address, which Google Analytics 4 does not store), and actions such as selecting a telephone link or submitting a form. It does not record what you type into our forms. We have switched off Google signals and advertising personalization in our analytics tag, and we do not use analytics information for advertising. If your browser sends a Global Privacy Control or Do Not Track signal, the Site does not load Google Analytics at all. You can also block the cookies in your browser settings or install Google’s opt-out add-on at tools.google.com/dlpage/gaoptout (opens in a new tab). How Google uses information from sites that use its services is explained at policies.google.com/technologies/partner-sites (opens in a new tab).

3. 4.3

   Information from other sources. We do not buy Personal Information or receive it from data brokers, advertising networks, or analytics providers. If you post a public review of JHI on Google, we may reproduce a selection of reviews on the Site, showing the reviewer’s first name and surname initial, the star rating, and the review text or an excerpt of it. If you contact JHI through a social media page that JHI maintains, we receive the information that platform makes available to us.

4. 4.4

   Information we do not collect. The Site takes no payments and has no accounts or logins. We do not collect through the Site any payment card or bank details, usernames or passwords, Social Security numbers, driver’s license or other government identification numbers, or precise geolocation.

5. 4.5

   Please do not send sensitive information. Please do not include health or medical information, government identification numbers, financial account details, or similar sensitive information in the free-text message field. If you do, we will use it only to respond to you, and we may delete it.

6. 4.6

   Providing information is voluntary. Required fields must be completed for us to receive a submission. If you prefer not to use the forms, you may telephone us at (407) 606-7964.

5.How We Use Information

We use Personal Information only for the following purposes, and for purposes reasonably compatible with them. For each, we state in plain terms why the use is appropriate (the “basis”).

1. 5.1

   To respond to your inquiry, or to make the telephone call you booked, by email or telephone about the course you asked about, including its content, schedule, price, availability, and language assistance; and, for an Enrollment Application, to assess it, to confirm program requirements, tuition, payment arrangements, and start dates with you, to prepare your enrollment documents, and to contact your emergency contact in an emergency. Basis: your request and your consent to be contacted.

2. 5.2

   To send Session Alerts about start dates and continuing education, beginning with a welcome email when you sign up. Basis: your consent, which you may withdraw at any time (see Section 8). Session Alerts are sent from our own mailbox through our email provider; no third-party marketing platform is used.

3. 5.3

   To operate, secure, and improve the Site, including detecting and preventing spam, abuse, fraud, and security incidents, diagnosing technical problems, and understanding in aggregate which pages and courses visitors look at, using submission details, anti-spam information, Server Logs, and analytics information. Basis: our legitimate interest in a safe, working, useful website.

4. 5.4

   To keep records of the consents you give and of any request to stop communications, so that we can demonstrate what you agreed to and honor your choices. Basis: respecting your choices and meeting our legal obligations.

5. 5.5

   To comply with law, legal process, and lawful requests from public authorities; to enforce our Terms and Conditions; and to establish, exercise, or defend legal claims. Basis: legal obligation and our legitimate interest in protecting JHI and others.

6. 5.6

   If we wish to use Personal Information for a materially different purpose, we will update this Policy first and, where the law requires, obtain your consent.

6.How We Disclose Information

We do not Sell or Share Personal Information, and we do not disclose it to third parties for their own marketing. We disclose it only as follows.

1. 6.1

   Service Providers, which receive or store Personal Information only as needed to provide their services to us:

   1. (a)

      our hosting provider, Hostinger [HOSTING CONTRACTING ENTITY — owner to confirm], on whose servers the Site, form submission records, and Server Logs are stored;

   2. (b)

      our email provider, Hostinger, which hosts the info@judehealthinstitute.com mailbox and sends our emails. Each inquiry, Enrollment Application, or Call Booking generates a notification email containing the details you entered, but not your IP address or user-agent string, which is sent to that mailbox and to the mailbox of our website administrator (a Gmail address hosted by Google); a confirmation email, which for a Call Booking includes a calendar file and for an Enrollment Application leaves out your date of birth, address, and emergency contact, is also sent to the address you gave us;

   3. (c)

      Cloudflare, Inc., which provides the Turnstile anti-spam check described in Section 4.2(b);

   4. (d)

      Google LLC, which provides the Google Analytics service described in Section 4.2(d);

   5. (e)

      any email marketing platform we may use for Session Alerts in future; we will update this Policy to identify it before any subscriber information is transferred to it; and

   6. (f)

      our lawyers, accountants, and insurers, where reasonably necessary, under duties of confidentiality.

2. 6.2

   Legal requirements. We may disclose Personal Information if we believe in good faith that law, legal process, or a governmental authority with power to compel it requires disclosure, or that disclosure is reasonably necessary to protect the rights, property, or safety of JHI, our students, or others.

3. 6.3

   Business transfers. If JHI is involved in a merger, acquisition, financing, reorganization, sale of assets, or bankruptcy, Personal Information may be transferred as part of the transaction. We will take reasonable steps to require the recipient to honor this Policy for information collected under it.

4. 6.4

   At your direction. We may disclose Personal Information to a third party when you ask us to or otherwise consent.

5. 6.5

   Nothing submitted through the Site is reported to CE Broker, the Florida Board of Nursing, Prometric, or any certifying body. Continuing education completions of enrolled participants are reported, where applicable, under the relevant course and enrollment documents.

7.Cookies, Tracking, and Similar Technologies

1. 7.1

   Cookies. The only cookies set through the Site are the Google Analytics cookies described in Section 4.2(d), which help us count visits and understand how the Site is used. They are not used for advertising, and they are not set if your browser sends a Global Privacy Control or Do Not Track signal. Apart from those cookies, the Site keeps only one thing in your browser: a note, for the current browsing session, of whether you have opened, closed, or used the advisor call window, so that it stays as you left it from page to page. That note contains no Personal Information, is never sent to us, and is deleted when you close your browser. Separately, the certificate administration page, which only JHI staff use, sets one strictly necessary cookie when a member of staff signs in, to keep them signed in; it is never set for other visitors.

2. 7.2

   Third-party services. The Site loads two third-party services: Google Tag Manager, which loads Google Analytics (Section 4.2(d)), and, when you begin to fill in a form, Cloudflare Turnstile (Section 4.2(b)). Google Tag Manager does not itself collect information about you beyond what any web request carries, and it loads only the analytics described in this Policy. It uses no advertising or retargeting tags or social media pixels, and embeds no maps, videos, or social media feeds. Its fonts, images, and other scripts are served from our own hosting.

3. 7.3

   Do Not Track and Global Privacy Control. If your browser sends a Global Privacy Control or Do Not Track signal, the Site does not load Google Analytics, so no analytics cookies are set and no analytics information about your visit is collected. We do not Sell or Share Personal Information, whether or not your browser sends either signal. We will update this Policy before changing these practices.

4. 7.4

   When you follow a link from the Site to another website, such as Google (for reviews or map directions), a social media platform, CE Broker, or a government website, that website may set its own cookies and collect information under its own policies.

8.Communications and Marketing

1. 8.1

   Replies to inquiries. If you submit the Inquiry Form, we send one automatic email confirming what you sent us, and we will then contact you by email or telephone about the course you asked about. Submitting the Inquiry Form does not add you to Session Alerts.

2. 8.2

   Session Alerts. We send Session Alerts only to people who ask for them, starting with a welcome email when you sign up. Each will identify JHI as the sender, carry a subject line that reflects its content, include our postal address, and include a working way to unsubscribe, consistent with the federal CAN-SPAM Act. You may unsubscribe at any time, free of charge, by replying to any Session Alert, by using the unsubscribe link in any Session Alert (which also works as a one-click unsubscribe in email apps that support it), by emailing info@judehealthinstitute.com, or by telephoning (407) 606-7964. We will act on your request promptly and in any event within ten (10) business days.

3. 8.3

   Even if you unsubscribe, we may still contact you about an inquiry you have made or a course in which you are enrolled.

4. 8.4

   Telephone calls. We telephone people only in response to their inquiry or at their request. We do not make unsolicited telemarketing calls or use automated dialing systems or prerecorded or artificial-voice messages [owner to confirm]. If you ask us to stop calling you, we will stop.

5. 8.5

   No text messaging program. JHI does not operate a text-message (SMS) marketing program, and giving your telephone number does not enroll you in one. If we introduce one, we will first ask for your separate express consent, which will not be a condition of enrolling in any course. [owner to confirm whether staff ever reply to an inquiry by individual text message; if so, describe that practice here]

9.Data Retention

We keep Personal Information no longer than necessary for the purposes for which it was collected, including legal, accounting, and record-keeping requirements, and then delete or de-identify it. Subject to that rule:

1. 9.1

   Inquiry Form submissions, Enrollment Applications, Call Bookings, and notification emails: [RETENTION PERIOD — owner to confirm, e.g., a fixed period after our last contact if you do not enroll].

2. 9.2

   Session Alerts records: while you remain subscribed; after you unsubscribe, we keep your email address and the date of your request for [SUPPRESSION PERIOD — owner to confirm] solely so that we do not email you again.

3. 9.3

   Records of consent: [RETENTION PERIOD — owner to confirm].

4. 9.4

   Rate-limiting files: needed only for a rolling one-hour period, and deleted [DELETION SCHEDULE — owner and developer to confirm].

5. 9.5

   Server Logs: according to our hosting provider’s log-rotation practice, currently [LOG RETENTION PERIOD — owner to confirm with the hosting provider].

6. 9.6

   Analytics information: held by Google for [ANALYTICS RETENTION — owner to confirm the data-retention setting in the Google Analytics property, e.g., 14 months], after which user-level data is deleted automatically; aggregated reports that identify no one may be kept longer.

7. 9.7

   Correspondence: [RETENTION PERIOD — owner to confirm].

8. 9.8

   We may keep information longer where needed to comply with law or to establish, exercise, or defend legal claims, and only while that need continues. If you enroll, information you gave us may become part of your student record and is then retained as your enrollment agreement describes.

9. 9.9

   Certificate records: for as long as JHI operates, so that a certificate can still be verified years after it was issued [owner to confirm].

10.Data Security

1. 10.1

   We use administrative, technical, and physical safeguards that we consider reasonable for the information we hold, including:

   1. (a)

      storing form submissions in directories on our hosting account that are outside the public part of the Site and cannot be retrieved over the internet;

   2. (b)

      serving the Site only over encrypted (HTTPS) connections;

   3. (c)

      limiting access to personnel who need it [ACCESS CONTROLS — owner to confirm who can access the hosting account and the info@ mailbox, and whether multi-factor authentication is enabled]; and

   4. (d)

      validating form input and applying the anti-spam measures described in Section 4.2(b) [ADDITIONAL MEASURES — owner to confirm].

2. 10.2

   No method of transmitting or storing information is completely secure, and email is not always encrypted end to end. We cannot guarantee the security of information you send us, which is one reason we ask you not to send sensitive information (Section 4.5).

3. 10.3

   If we become aware of unauthorized access to Personal Information that we hold, we will investigate, take reasonable steps to contain it, and notify affected individuals, government authorities, and others where and when applicable law, including Florida law, requires. Any notice to you will be given without unreasonable delay and within the time the law allows, and may be sent by email.

4. 10.4

   When we delete records containing Personal Information, we take reasonable steps to ensure that the information cannot be read or reconstructed.

11.Your Choices and Rights

Some state laws give residents specific privacy rights, and many apply only to businesses above size or activity thresholds. Whether or not any such law applies to JHI, we extend the choices in this Section 11 to everyone who has submitted Personal Information through the Site, wherever they live.

1. 11.1

   Subject to Section 11.4, you may ask us to:

   1. (a)

      confirm whether we hold Personal Information about you and give you a copy (access);

   2. (b)

      correct inaccurate Personal Information (correction);

   3. (c)

      delete Personal Information (deletion);

   4. (d)

      stop sending you Session Alerts, or stop contacting you about an inquiry (opt-out); and

   5. (e)

      withdraw any consent, without affecting anything we did in reliance on it beforehand.

2. 11.2

   How to make a request. Email [PRIVACY CONTACT] or info@judehealthinstitute.com, telephone (407) 606-7964, or write to the address in Section 2, telling us which choice you wish to exercise and the email address or telephone number you used on the Site. An authorized agent may make a request for you; we may ask for proof of authority. We will take reasonable steps to verify your identity, usually by contacting you at the email address or telephone number we hold.

3. 11.3

   Response time. We will acknowledge your request within [ACKNOWLEDGMENT PERIOD — owner to confirm] and respond within [RESPONSE PERIOD — owner to confirm, e.g., 45 days]. If we need more time, we will tell you why. We will not charge a fee [owner to confirm].

4. 11.4

   Limits. We may decline or limit a request if we cannot verify your identity, if we must keep the information to comply with law or to establish, exercise, or defend legal claims, or if fulfilling it would reveal another person’s information. Server Logs held by our hosting provider may not be searchable or deletable individually; they are deleted in the ordinary course under Section 9.5. If we decline a request, we will explain why. If you ask us both to delete your email address and to stop emailing you, we may keep a minimal record of the address solely to ensure that we do not email you again.

5. 11.5

   Non-discrimination. We will not deny you services, charge you a different price, or give you a different quality of service because you exercised any choice described in this Policy.

6. 11.6

   If you are not satisfied with our response, you may ask for it to be reviewed by [REVIEWING PERSON — owner to confirm] or contact your state’s consumer protection authority, which in Florida is the Office of the Attorney General.

12.Children’s Privacy

1. 12.1

   The Site is intended for adults, and our courses are offered to individuals aged at least [MINIMUM AGE — owner to confirm]. The Site is not directed to children under 13, and we do not knowingly collect Personal Information from them. If we learn that we have, we will delete it promptly. If you believe a child under 13 has given us Personal Information, please contact us (Section 17).

2. 12.2

   [If the minimum age is below 18: a parent or legal guardian should submit an inquiry on behalf of an individual under 18 — owner and counsel to decide.]

13.Educational Records

1. 13.1

   Information submitted through the Site is inquiry and marketing information, not an education record. Records of enrolled students, such as attendance, assessment, and completion records, are governed by the enrollment agreement and [STUDENT RECORDS POLICY].

2. 13.2

   [FERPA — counsel to confirm and select one. OPTION A: “JHI does not receive funds under any program administered by the U.S. Department of Education, so the Family Educational Rights and Privacy Act (FERPA) does not apply to JHI’s student records.” OPTION B: “Education records of enrolled students are protected under the Family Educational Rights and Privacy Act (FERPA); JHI’s annual FERPA notice is available at [URL].”]

14.Third-Party Links and Services

1. 14.1

   The Site links to websites and services that we do not own or control, including Google (reviews and map directions), Facebook, Instagram, LinkedIn, YouTube, X, CE Broker, and government and regulatory websites. Once you leave the Site, the third party’s own privacy policy and terms govern any information it collects, and we are not responsible for its practices.

15.Visitors from Other States and Countries

1. 15.1

   JHI is based in Florida, and the Site is intended for people in the United States. Personal Information collected through the Site is stored on our hosting provider’s servers [SERVER LOCATION — owner to confirm the data-center region; if outside the United States, revise this Section] and accessed by JHI in the United States.

2. 15.2

   If you live in a state whose laws give residents additional privacy rights, you may use Section 11 to exercise them. We do not Sell or Share Personal Information, use it for targeted advertising or profiling, or disclose it to third parties for their direct marketing.

3. 15.3

   If you use the Site from outside the United States, your information will be processed in the United States, where data protection laws may differ from those of your country. The Site is not directed to individuals in the European Economic Area, the United Kingdom, or Switzerland [owner to confirm].

16.Changes to This Policy

1. 16.1

   We may update this Policy from time to time. The “Last Updated” date shows when it last changed. We will post any material change on the Site [at least [NUMBER] days before it takes effect — owner to decide] and, where it materially affects how we use an email address we hold, notify that address. Where the law requires consent to a new use of information collected earlier, we will not make that use without it.

17.Contact Us

1. 17.1

   Questions about this Policy, or requests under Section 11, may be sent to [PRIVACY CONTACT], Jude Health Institute, Suite 251, 6100 Lake Ellenor Drive, Orlando, Florida 32809; info@judehealthinstitute.com [or a separate privacy address]; or (407) 606-7964.

2. 17.2

   If you need this Policy in an alternative format, contact us and we will work with you to provide it. Our Accessibility Statement is at [ACCESSIBILITY STATEMENT URL]. [owner to confirm whether help with this Policy is available in Haitian Creole and Spanish]