CE BROKER PRIVACY POLICY

Effective as of October, 2023

Introduction

CE Broker, Inc., d/b/a Propelus (“CE Broker,” “we,” “our,” or “us”) respects the privacy of your information. This Privacy Policy is designed to assist you in understanding how we collect, use and safeguard the information you provide to us in using our website (“Site”), the services provided through our Site, and the mobile application we offer (collectively, “Services”).

From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. Please review this Privacy Policy periodically. 

This Privacy Policy covers the following topics:

1. Collecting and Using Information

2. Cookies and Other Tracking Technologies

3. Third Party Processors

4. “Do Not Track” Signals

5. Choices About Your Personally Identifiable Information

6. Security

7. Third Party Links

8. Children’s Privacy

9. Notice to Nevada Residents

10. Notice to California Residents

11. Accessibility

12. How to Contact Us

1. Collecting and Using Information

Personally Identifiable Information We Collect Online

We collect Personally Identifiable Information from you through your use of the Site and Services. “Personally Identifiable Information” is individually identifiable information about an individual consumer that we collect online and that we maintain in an accessible form. We collect the following types of Personally Identifiable Information:

Information You Provide 

We may collect the following Personally Identifiable Information as well as other types of personal information that you voluntarily provide to us:

• Sign Up for Account. To sign up for the basic, professional, or concierge program you will create an account with a username and password. You will provide us with the state or country where you are licensed/certified and your license/certification number and e-mail address. 

• Purchase an Account. To purchase a professional or concierge account, you will provide us with your name and credit/debit card information. 

• Sign into Account. To sign into your account, you will provide us with your username or email address and password. 

• Activate Your Free Trial. To activate your free CE Broker trial, you will provide us with the state or country where you are licensed/certified and your license/certification number and credit or debit card number. 

• Registering as an Educational Provider. To register as an educational provider, you must set up a board profile. To set up a board profile, you will provide us with your company name, your company phone number and fax number, physical address, and your company website, course registration website, and course registration phone number. 

• Add New Users to an Educational Provider Account. To add new users to an educational provider account, you will provide us with the email address and name of the new user. The new user will receive an invitation to create their own username and password which will provide them access to the educational provider account. 

• Add Your Licenses Online. To add your licenses to your CE Broker account, you will provide us with the state where you are licensed/certified and your license/certification number for verification. If you have a professional or concierge account, you may upload copies of your licenses/certifications to your account.  

• Request a Demo. To request a demo, you will provide us with your name, company name, phone number, and email address. 

• Apply to Become a CE Partner. To apply to become a CE partner, you will provide us with your name, company name, phone number, and email address. 

• Subscribe to Our Blog. To subscribe to our blog, you will provide us with your email address.

• Online Chat. To send an online chat to our support team, you may provide us with a message, your name, email address, and license number. 

• Email Our Support Team. When you email our support team, you will provide us with your full name, email address, and license number or educational provider number. 

• Apply for a Job. To apply for a job, you will provide us with your name, email address, physical address, phone number, a resume, a cover letter, your education background, and your work preferences. 

Information as You Navigate Our Site

We automatically collect certain Personally Identifiable Information through your use of the Site and Services, such as the following:

• Usage Information. We collect information such as which of the pages on the Site you access, the frequency of access, and what you click on while on the Site.

• Device Information. We collect information about the device you are using, such as hardware model, operating system, application version number, and browser.

• Mobile Device Information. In addition to the Device Information listed above, when you access our Site via a browser on your mobile device, we collect and aggregate information about whether you are accessing the Site via a mobile device or tablet, device type, and carrier.

• Location Information. We collect location information from Site visitors on a city-regional basis. 

Third Party Information 

In some cases, we may receive certain Personally Identifiable Information from you about a third party. For example, when you request a demo, you may provide us with the name, company name, phone number, and email address of a third party. If you submit any Personally Identifiable Information about another individual to us, you are responsible for making sure that you have the authority to do so and to allow us to use their Personally Identifiable Information in accordance with this Privacy Policy. 

How We Use Your Personally Identifiable Information

We use the Personally Identifiable Information we collect to provide the Services to you, to improve our Services and Site, and to protect our legal rights. In addition, we may use the Personally Identifiable Information we collect to:

• Process your account registration;

• Process and fulfill your account purchase;

• Provide you with a demo;

• Email you our blog posts; 

• Contact you regarding our products and services that we feel may be of interest to you;

• Communicate with you about our Site or Services or to inform you of any changes to our Site or Services;  

• Provide support;  

• Maintain and improve our Site and Services;

• Defend our legal rights and the rights of others; 

• Efficiently maintain our business; and 

• Comply with applicable law.  

How We Share Your Personally Identifiable Information

We may share the information that we collect about you in the following ways:

• With service providers who perform data or Site-related services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.). Any such service providers will be under an obligation to us to maintain the confidentiality of your Personally Identifiable Information;

• To service providers to prepare, deploy and analyze advertising content;

• To the extent that we are required to do so by law;

• In connection with any legal proceedings or prospective legal proceedings;

• To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;

• To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personally Identifiable Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personally Identifiable Information;

• To any other person or entity as part of any business or asset sale; and

• To any other person or entity where you consent to the disclosure.

2. Cookies and Other Tracking Technologies

How We Use Cookies

Like many other companies, we use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”). “Cookies” are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets). 

We use Cookies to:

• Estimate audience size and usage patterns;

• Understand and save your preferences for future visits, allowing us to customize the Site and Services to your individual needs;

• Advertise new content and services that relate to your interests;

• Keep track of advertisements and search engine results;

• Compile aggregate data about site traffic and site interactions to resolve issues and offer better site experiences and tools in the future; and

• Recognize when you return to the Site. 

We set some Cookies ourselves and others are set by other entities. We use Cookies set by other entities to provide us with useful information to help us improve our Site and Services, to conduct advertising, and to analyze the effectiveness of advertising. For example, we use Cookies from Google and other similar companies. 

We use technology with third party vendors such as Hotjar and LogRocket to better understand our users’ needs and to optimize our Services and your experience. The technology helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our Services with user feedback. The technology uses cookies and other tools to collect data on our users’ behavior and their devices. This may include a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, and the preferred language used to display our Site. 

How You Can Opt-Out of Cookies

Browser Settings

Cookies can be blocked by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Site.

You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org or www.allaboutcookies.org.

Platform Controls  

You can opt out of Cookies set by specific entities by following the instructions found at these links:

• Google: https://adssettings.google.com

• Twitter: https://twitter.com/personalization

• LinkedIn: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

Advertising Industry Resources 

You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt-out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.

Please note that these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Site and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The technologies used by Google Analytics do not gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.

3. Third Party Processors

To ensure that your Personally Identifiable Information receives an adequate level of protection, we have put in place appropriate procedures with the service providers we share it with to ensure that it is treated consistent with applicable data security and privacy laws. For example, we use Stripe for payment processing and HubSpot for marketing, Amazon Web Service, and Redis Labs for cloud data storage, and MongoDB for database services.

4.  “Do Not Track” Signals

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals. 

5. Choices About Your Personally Identifiable Information

Review and Request Changes to Your Personally Identifiable Information

To review or request changes to any of your Personally Identifiable Information, please contact us at support@test.cebroker.com.

Marketing Communications 

To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails. You also may submit a request to us at support@test.cebroker.com. 

6. Security

We maintain commercially reasonable security measures to protect the Personally Identifiable Information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee absolute security.

7. Third Party Links

The Site and Services may contain links that will let you leave the Site and Services and access another website. Linked websites are not under our control. Except as stated below, this Privacy Policy applies solely to Personally Identifiable Information that is acquired by us on this Site and Services. We accept no responsibility or liability for these other websites. 

8. Children’s Privacy

The Site and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 13.

9. Notice to Nevada Residents

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to support@test.cebroker.com

10. Notice to California Residents

The California Consumer Privacy Act (CCPA) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this does not apply to you and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”

The CCPA contains an exception that is relevant to us. Some of the CCPA’s privacy rights explained below do not apply to personal information collected in a business-to-business context.  That is information reflecting a written or verbal communication or a transaction between us and a consumer, where the consumer is acting as an employee, owner, director, officer, or contractor of another entity and when the communication or transaction occur solely within the context of us conducting due diligence regarding, or providing or receiving a product or service to or from such entity. 

Right to Know About Personal Information Collected, Disclosed, or Sold

If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you in the 12-month period preceding your request. This right includes the right to request any or all of the following:

1. Specific pieces of Personal Information that we have collected about you;

2. Categories of Personal Information that we have collected about you;

3. Categories of sources from which the Personal Information was collected;

4. Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;

5. Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and

6. The business or commercial purpose for collecting or, if applicable, selling Personal Information.

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

Collection of Personal Information

We currently collect and, in the 12 months prior to the Effective Date of this Privacy Policy, have collected the following categories of Personal Information:

The Personal Information is collected from California residents directly and from advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, and data brokers. Not all categories of Personal Information are collected from each source.

In addition to the purposes stated above in the section “Collecting and Using Information” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

• Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

• Debugging to identify and repair errors that impair existing intended functionality

• Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction

• Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider

• Undertaking internal research for technological development and demonstration.

• Undertaking activities to verify or maintain the quality or safety of a service that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service that is owned, manufactured, manufactured for, or controlled by the business

• Advancing a person’s commercial or economic interests, such as by inducing another person to buy or subscribe to services, or enabling or effecting, directly or indirectly, a commercial transaction

Disclosure or Sale of Personal Information

The following table identifies the categories of Personal Information that we disclosed for a business purpose to service providers or sold to third parties in the 12 months preceding the Effective Date of this Privacy Policy and, for each category, the category of service providers or third parties to whom the Personal Information was sold or disclosed:

We do not knowingly collect or sell the Personal Information of minors under 16 years of age.

Right to Request Deletion of Personal Information

If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected. However, per the CCPA, we are not required to comply with a request to delete if it is necessary for us to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

How to Submit a Request to Know or Delete

You may submit a request to know or delete by emailing support@test.cebroker.com or mailing a written request to CE Broker at 525 N 3rd St. Unit 105, Jacksonville Beach, Florida 32250.

Our Process for Verifying a Request to Know or Delete

If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure or deletion as applicable. 

For requests to access categories of Personal Information and for requests to delete Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities. 

For requests to access specific pieces of Personal Information or for requests to delete Personal Information that is sensitive and poses a risk of harm by unauthorized deletion, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Right to Opt-Out of Sale of Personal Information

If you are a California resident, you have the right to direct businesses to stop selling your Personal Information. We do not sell Personal Information as it is defined in the CCPA.

To opt-out of our use of third-party advertising Cookies, please see the section “How You Can Opt-Out of Cookies” above. 

Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights

We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section “Notice to California Residents.”  

Authorized Agents

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.

Shine the Light Law

No third-party disclosure for direct marketing purposes. We do not disclose personal information obtained through our Site or Services to third-parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.

11. Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below. 

12. How to Contact Us

To contact us for questions or concerns about our privacy policies or practices please email us at support@test.cebroker.com or call us at 1-877-434-6323 or at

CE Broker Inc. 

Attn: Support Center

525 N 3rd St. Unit 105

Jacksonville Beach, FL 32250