Privacy Policy 


General Information 

Thank you for using Cummings Graduate Institute for Behavioral Health Studies (“CGI”) websites. This privacy policy ("Privacy Policy") was created to inform you of the types of information CGI collects from you when you access and use the entire group of websites and webpages owned, operated, licensed, or controlled by CGI. 


This Privacy Policy governs your access to and use of [Thinkific Platform], including any content, functionality and services offered on or through [Thinkific Platform], whether as a guest or a registered user.


Please read the privacy policy carefully to get a clear understanding of how CGI collects, uses, protects or otherwise handles your Personally Identifiable Information in accordance with our website. By using the CGI website or by clicking to accept or agree to the Terms of Use when this option is made available to you, you acknowledge and agree to how CGI collects and uses information about you. If you do not want to agree to the Privacy Policy, you must not access or use the Website.


2. Changes to Our Privacy Policy

It is our policy to post any changes made to CGI’s privacy policy on this page. If CGI makes material changes to how CGI treats our users' personal information, CGI will notify you by email to the email address specified in your account and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the bottom of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes. 

 

Last Updated: May 2020. 

 

If the CGI site or course is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to inform you of additional products we have available. 

 

3. What Information Do We Collect?

When you enroll as a student or subscriber (“learner”) on our site or related courses, as part of the enrolling process, CGI collects:

 

Personally Identifiable Information (“PII”) in several ways;

 

Non-Personal Information (“NPI”): CGI may collect from users their IP address, browser type, domain name, the pages accessed, the time of access, the previous site before accessing this Site, statistics related to usage of educational tools, the length of time on the Site, the link that brought the user to the Site, and other non-personal related information.

Aggregate Information (“AI”): CGI may collect in aggregate form the number of users accessing the Site, the pages accessed, the clicks per page, the number of links accessed, and other non-personal aggregated information not tied to a specific user.

4. Email Information

If you choose to correspond with CGI through email, CGI may retain the content of your email messages together with your email address and our responses. CGI provides the same protections for these electronic communications that are employed in the maintenance of information received online, mail, and telephone. This also applies when you register for our website, sign up through any of CGI’s forms using your email address or make a purchase on this site. For further information see the email policies below.

 

5. Email Marketing

Consumers outside of the European Union (EU) will be automatically enrolled to receive CGI  marketing emails. You will be automatically added to a mailing list upon enrollment. CGI may send you emails about our site and related course(s), registration, course content, your course progress or other updates. CGI may also use your email to inform you about changes to the course, survey you about your usage, or collect your opinion. As a consumer you may opt-out at any time, please see Email Policies section below. 

For consumers within the EU your consent must be obtained prior to sending any email marketing. Consumers in the EU or non EU may opt-out at any time. 

 

6. Email Policies

CGI is committed to keeping your e-mail address confidential. CGI does not sell, rent, or lease our subscription lists to third parties, and will not disclose your email address to any third parties except as allowed in the section titled Disclosure of Personally Identifiable Information. 

 

CGI will maintain the information you send via email in accordance with applicable federal law.

 

In compliance with the CAN-SPAM Act, all emails sent from our organization will clearly state who the email is from and provide clear information on how to contact the sender. In accordance with CAN-SPAM we agree to the following; 

In addition, all e-mail messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further e-mail communication from CGI. CGI emails provide users the opportunity to opt-out of receiving communications from us and our partners by reading the unsubscribe instructions located at the bottom of any email they receive from CGI at any time.

7. How and Why We Collect the Information

For Personally Identifiable Information (PII), generally CGI collects it from the information you provide to the Site such as when you submit a user form, register for a product or service, when you contact CGI, or purchase a product or service. However, CGI may also collect such information from other sources including our affiliates and from third parties that we contract with to process credit cards or send communications.

 

CGI uses this information to track your preferences and to keep you informed about the products and services you have selected to receive and any related products and/or services. As a visitor to this Website, you can engage in most activities without providing any personal information. It is only when you seek to download resources and/or register for services that you are required to provide information.

 

CGI collects PII for multiple purposes that may include membership registration, event registration, help you update username/password, to look up your information if needed, for credit card processing, for collecting donations or fees, or educational opportunities, on user inputted forms for various purposes including but not limited to inquiries, for comments, suggestions, or other user forms, for mailing and communication purposes, and for access to tools CGI offers.

 

NPI & AI: CGI collects Non-Personal and Aggregate Information in order to better understand how you use the Site, update CGI’s site content, understand trends, for demographic informational purposes, improve the site experience, and perform non-personal or aggregate statistics.

 

CGI may also use the information collected (including PII, NPI, and AI) to meet legal and regulatory obligations, to protect the property of the GCI, and to better offer our services or products.

 

8. Disclosure of Personally Identifiable Information

As a general rule, CGI does not sell, rent, lease or otherwise transfer any information collected whether automatically or through your voluntary action.

 

CGI may share or disclose any information collected about you including Personally Identifiable Information (PII) with our affiliates or third parties with whom we have contracted with for the purposes of carrying out the purposes of registration, marketing, communications or credit card processing. CGI may use information collected to help improve services, products, and offerings available and sent to you from CGI.

 

CGI may disclose your PII to a third party, including a lawyer or collection agency, when necessary to enforce our terms of service or any other agreement between you and CGI.

 

CGI may provide your information to any successor in interest in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CGI assets and/or business.

 

CGI may disclose information when legally compelled to do so, in other words, when CGI, in good faith, believe that the law requires it or for the protection of our legal rights or when compelled by a court or other governmental entity to do so, or if you violate our Terms of Service. 

 

9. Consent

When you provide CGI with PII to become a learner on our site, make a purchase, or participate in the course, you imply that you consent to our collecting it and using it for that specific reason only.

 

If CGI asks for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.

 

10. How Do I Withdraw My Consent?

You may withdraw your consent at any time, by contacting us via any of the following options: 

Email: privacy@cgi.edu 

Call: 480-285-1761

Mail: Cummings Graduate Institute for Behavioral Health Studies (CGI)

16515 S. 40th St. Suite143

Phoenix, AZ 85048

United States of America

 

Electronic request: submit this form by clicking here.

 

Upon your request to terminate your account, we will deactivate or delete your account and information from our active database. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use or comply with legal requirements. 

11. Cookies, Beacons, or Pixel Tags?

A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites.

 

Similar to other commercial websites, the CGI website utilizes a standard technology called “cookies” and server logs to collect information about how our site is used. Information gathered through cookies and server logs may include the date and time of visits, the pages viewed, time spent at our site, and the websites visited just before and just after our own, as well as your IP address;

 

 

Can you Opt Out – Cookies?

Cookies can be required, meaning they are necessary for the proper functioning of our site or a portion of our Site. CGI does not currently use flash cookies. You can opt-out of cookies by adjusting your browser settings. However, if you opt-out of cookies, portions of the site may not function normally or you may be prevented from utilizing certain aspects.

 

Google Analytics & Hubspot

From time to time we may use Google Analytics and/or Hubspot that will allow CGI to review anonymous data regarding the gender, age, browser device used, device used (including if it is a mobile device), domain name, date and time of access, and interests of Site users to adapt our Site content to better reflect such users’ needs and interests. Google Analytics & Hubspot uses cookies in achieving this. This information is collected through your Google ad settings but it is not providing any PII.

 

Opt Out – Google Analytics

You can opt-out of this feature using Google Ad settings or through the Google Analytics opt-out browser.

 

Web Beacons, Pixel Tags, Clear GIFs and Other Technologies

The Company reserves the right to use technological equivalents of cookies, including social media pixels in compliance with the policies of the various social media sites. These pixels allow social media sites to track visitors to outside websites so as to tailor advertising messages users see while visiting that social media website. From time to time CGI may use web beacons, pixel tags, clear gifs, or other technologies (“Other Technologies”) that allow your information to be tracked across sites.

 

12. Thinkific

The CGI course and site is hosted by Thinkific Labs Inc. (“Thinkific”). Thinkific provides CGI with the online course creation platform that allows CGI to sell our product/services to consumers.

 

Your data is stored through Thinkific’s data storage, databases and the general Thinkific application. They store your data on a secure server behind a firewall.

 

13. Payments

If you make a purchase on the CGI site, CGI uses two third party payment processors; Stripe and Paypal. Payments are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only until the purchase transaction is completed. 

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our site and related courses and its service providers.

 

14. Third Party Services

In general, the third-party providers used by CGI will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to CGI.

 

However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.

 

For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.

 

Certain providers may be located in or have facilities that are located in a different jurisdiction than either you or CGI. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

 

As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

 

Once you leave the CGI course website or are redirected to a third-party website or application, CGI takes no responsibility for those sites’ privacy policies, for the content on such sites, or for their policies of collecting information.

 

15. Links

When you click on links on the CGI course site, those links may direct you away from the CGI site. GCI is not responsible for the privacy practices of other sites and encourages you to read their privacy statements.

 

16. Data Protection & Security

In accordance with the applicable laws and regulations, CGI has taken adequate technical and organizational measures to safeguard the security of your personal information. CGI stores the personal information that CGI processes on a secure database that is protected by technical access controls. We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems and work only with reputable third party vendors.

 

If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.

 

Please be advised that while CGI strives to protect your personally identifiable data, CGI makes no guarantees or assurances about our ability to prevent any such loss, access, or misuse and are not responsible in the event that such loss or misuse occurs.

 

Email is not recognized as a secure medium of communication. For this reason, CGI requests that you do not send private information to us by email. However, doing so is allowed, but at your own risk. Some of the information you may enter on our website may be transmitted securely via a secure medium known as Secure Sockets Layer, or SSL. Credit Card information and other sensitive information is never transmitted via email.

 

The Company may use software programs to create summary statistics, which are used for such purposes as assessing the number of visitors to the different sections of our site, what information is of most and least interest, determining technical design specifications, and identifying system performance or problem areas.

 

For site security purposes and to ensure that this service remains available to all users, the Company uses software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage.

17. How Long Do We Keep Your Information?

We will keep your personal information for as long as you are an active user on the website for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

18. Data Breach 

A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when CGI or Thinkific believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that CGI or Thinkific becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information CGI or Thinkific will promptly investigate the matter and notify the applicable Supervisory Authority no later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

 

19. Age of Consent

CGI does not market specifically to children under the age of 13.

The CGI Website is not intended for children under 13 years of age. CGI does not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.

If CGI learns we have collected or received personal information from a child under 13 without verification of parental consent, CGI will delete that information. If you believe CGI may have any information from or about a child under 13, please contact us at support@cgi.edu

 

20. Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information:

 

21. International Visitors General Data Protection Regulation (GDPR) Rights 

The Site is available throughout the world for different purposes. The Site shall be operated in accordance with laws of the United States and visitors to the Site should be aware that the laws of the United States may differ from those of their respective countries of residence.

 

By providing your personal information as an international visitor or user, you are: 

(i) permitting the transfer of your personal information to the United States, which may not have the same data protection laws as the country in which you reside; 

(ii) permitting the use of your personal information in accordance with this Privacy Policy.

 

If you reside outside the United States, CGI will not use your personal information in any way except (i) insofar as such processing is necessary for the performance of a contract between you and CGI or (ii) as may be required by applicable law.

 

You can request to access, update, or correct your personal information. You may have additional rights pursuant to your local law applicable to the processing of your personal information. For example, if the processing of your personal information is subject to GDPR, and your personal information is processed based on legitimate interests, as described above, you have the right to object to the processing on grounds relating to your specific situation. Under GDPR you may also have the right to request to have your personal information deleted or restricted, and ask for portability of your personal information. To the extent that you provided consent to the Company’s processing of your personal data, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based upon consent that occurred prior to your withdrawal of consent.

 

CGI keeps your personal information for only as long as needed for the purposes for which CGI collects it, or as otherwise required or permitted by applicable law.

 

If you desire to exercise any of your rights under GDPR, please contact CGI at:

Email: privacy@cgi.edu 

Call: 480-285-1761

Mail: Cummings Graduate Institute for Behavioral Health Studies (CGI)

16515 S. 40th St. Suite143

Phoenix, AZ 85048

United States of America

 

Electronic Request: submit this form by clicking here

 

In the event you consider our processing of your personal information not to be compliant with the applicable data protection laws, you can file a complaint directly with CGI at the address noted above or with the competent data protection authority. The name and contact details of the Data Protection Authorities in the European Union can be found here.

22. Questions and Contact Information 

CGI welcomes your questions or comments regarding the Privacy Policy:

Email: privacy@cgi.edu 

Call: 480-285-1761

Mail: Cummings Graduate Institute for Behavioral Health Studies (CGI)

16515 S. 40th St. Suite143

Phoenix, AZ 85048

United States of America