Privacy Policy

Effective Date: August 17, 2018

Spear Education, LLC (“Spear”, “we”, “us”, or “our”, as applicable) values the privacy and personal information of our users and visitors, and is committed to combining the highest-quality services with the highest level of integrity in dealing with its valued visitors, and the companies, businesses and organizations they represent. This Privacy Policy, as modified from time to time, describes and governs your use of our <speareducation.com> website (together with all subdomains and related websites or mobile applications, collectively the “Website”); the content, products, and/or services purchased or accessed through the Website (individually and collectively, the “Services”); the information we collect from you when you visit or use the Website; how we use that information; and under what circumstances we disclose that information. This statement applies only to information we obtain from you when you are online while visiting or using the Website. It does not apply to information we have obtained or may obtain offline through other traditional means.

As a general principle, information you provide to us will only be used or shared by Spear as outlined in this Privacy Policy. PLEASE READ THIS ENTIRE PRIVACY POLICY CAREFULLY. This Privacy Policy is in addition to (not in lieu of) the User Agreement and any specific terms and conditions that apply to the particular Services or the Website, which are hereby incorporated by reference.

By visiting or using the Website, you agree to the practices and policies set forth in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, you may not use the Website.

As noted below under “Changes to Privacy Policy”, we reserve the right to amend this Privacy Policy from time to time in our sole discretion, and we will post and maintain the most recent version of the Privacy Policy on the Website.

  1. INFORMATION

    When you use the Website, we receive and collect certain information. The information we receive and collect depends on what you do when you visit the Website. Spear obtains information from and about you in a number of different ways, including:

    A. Automatically Collected Information. Some information is gathered or received automatically when you visit the Website. This “Non-Personal Information” may include information that does not personally identify you, but is collected on an aggregate basis as you and others interact with the Website. For example, Non-Personal Information may include some or all of the following items: the name of the domain and host from which you access the Internet, including the Internet protocol (IP) address of the device you are using and/or the IP address of your Internet Service Provider; the type and version of Internet browser software you use and your operating system; the type and version of your media player(s); and the date and time you access the Website, the length of your stay, and the specific pages, images, video or forms that you access while visiting the Website. We use this information to monitor the usage of our Website, assess performance, ensure technological compatibility with your device, and understand the relative importance of the information provided on the Website. We may also use this data to conduct statistical analyses on visitors’ usage patterns and other aggregated data.

    Cookies are pieces of data that are stored by a user's web browser on the hard drive of a user's computer. Cookies can “remember” what information a user accesses on one web page to simplify subsequent interactions with a website by the same user. The cookies that Spear uses do not capture your individual email address or any personally identifying information, but do permit Spear to maintain your Website log-in data. Spear may also set cookies when you register at the Website, and may do so without notice to or permission from you or any third party. Third-party websites which are accessible from the Website via links, banner ads, or “click-throughs” may also use cookies, and Spear shall have no responsibility whatsoever for such Cookies.

    Most browsers are initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information. Please note that by blocking any or all cookies, you may not have access to certain features, content, or personalization available through the Website.

    B. Voice and Video Recording. We take pride in providing our customers with high-quality service and strive to continuously improve our offerings. As part of our commitment to quality assurance, we may record voice or video calls with our customers for training and monitoring purposes.

    By continuing to use our product/service, you agree to the recording of your voice or video call with us. The recording will only be used for internal purposes, including training, coaching, and quality assurance, to improve our service to you.

    Please note that the recording of the call may be stored securely for a period of time to ensure that our team can provide you with the best possible service. We take the security and privacy of your personal information seriously and will ensure that any recordings are kept confidential and used only for the intended purposes

    In compliance with applicable laws and regulations, we will notify you before recording the call and obtain your consent. We may also inform you of your rights regarding the call recording, including the right to access, review, and request the deletion of the recording.

    If you do not agree to the recording of the call, please let us know before the call begins, and we will make every effort to accommodate your request. However, please note that we may not be able to provide you with certain services if the call is not recorded.

    C. Information You Submit. Some information that may be identifiable as yours is not gathered automatically at the Website. This “Personal Information” is any information you voluntarily submit that can individually identify you and includes, for example and without limitation, your name, email address, username, telephone number, postal address, company name, tracking and usage information about your location, and demographics. The following are some of the types of Personal Information that Spear gathers:

    1. Registration Information. When you register at the Website, you will be asked for certain Personal Information, such as your name, your email address, practice information (e.g., street address, credit card number, email address, zip code, and gender), and other information, and will create a username and password.

    2. Email Information. We may contact you by email or other means at an email address that you have provided to us. For example, we may send you account information, order updates, or promotional offers, and may also send you responses to inquiries, questions, or other direct requests. If you do not want to receive email from us, please let us know through the “unsubscribe” feature included in our communications, or by contacting us via the Website. When you send email messages to Spear, we may retain the content of your email messages, together with your email address and our response to you.

    3. Submissions. When you submit, upload, download, or stream any content (e.g., text, discussion board entries, blog entries, commentary, postings, photographic content, video content, etc.), Spear may retain such content together with your registration information.

    4. Personal Information about Children. The Website is intended for use by healthcare professionals. Accordingly we do not knowingly collect any personal information from children under the age of 13. However, we advise all visitors to our Website under the age of 13 not to disclose or provide any information on the Website. In the event that we discover that a child under the age of 13 has provided information to us, in accordance with the Children’s Online Privacy Protect Act (see the Federal Trade Commission’s website at ftc.gov/privacy/privacyinitiatives/childrens.html for more information about this Act), we will delete the child’s information from our files to the extent technologically possible.

  2. GENERAL USE AND DISCLOSURE OF INFORMATION

    Spear uses and discloses your information as follows:

    A. Generally. Spear (and/or third party vendors acting on our behalf) will use or disclose information that we collect from you to help us personalize and improve your experience, including for example:

    • To process, complete or otherwise act upon or respond to your request or reason for submitting that information.
    • To register and/or verify you in connection with a Service or feature that you are attempting to access or obtain.
    • To communicate with you about your request or reason for submitting that information.
    • To provide additional information to you about our respective Services that may interest you.
    • To personalize the content and advertising that you see on the Website.
    • To study and analyze the use of information, Services, and features available on our Website.
    • To assist, when necessary, in protecting our rights or property, enforcing the provisions of our Privacy Policy, User Agreement, or Cancellation Policy, and/or preventing harm to you or others.

    We do not sell your information to third parties for use outside of the Website. Except where we otherwise obtain your express permission, we (and/or the third party vendors who make materials, features, products, or the services available on or through the Website) share your information with third parties only under the limited circumstances stated below:

    • We may make your information available to certain third-party service providers, such as contractors, agents, or sponsors, who help us manage or provide services offered on the Website.
    • Spear will abide by the United States of America data privacy laws. We may use or disclose your Personal Information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the Website; (b) respond to requests from public and government authorities; (c) protect and defend our rights or property, the Website, or our users; and (d) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, or the users of the Website, or the public.
    • If information is subject to disclosure to protect our respective rights or property, to enforce the provisions of the Privacy Policy, the User Agreement, or the Cancellation Policy, and/or to prevent harm to you or others.
    • If we sell all or part of our business, or make a sale or transfer of our assets, or are otherwise involved in a merger or transfer of all or a material part of our business, or are involved in a bankruptcy, we may transfer your information to the party or parties involved as part of that transaction.
    • If you communicate with us via email, we will share your correspondence, including any information provided in the email, with employees, representatives, or agents most capable of addressing your correspondence. We will retain your communication until we have done our very best to provide you with a complete and satisfactory response and may subsequently retain your communication for our records.
    • If you are a California resident and have an established business relationship with us, California Civil Code Section 1798.93 permits you to request a notice disclosing the categories of personal information we have shared with third parties, for the third parties’ direct marketing purposes, during the preceding calendar year. To request a notice, please submit your request by using the contact information provided below.
    • Spear may securely share “encrypted”/”hashed” information collected from user activity on https://speareducation.com with third parties to perform ad measurement services.

    In order to carry out certain business functions, such as e-mail delivery, marketing, referrals, or making products, features, information, or Services available through our Website, we may hire other companies to perform services on our behalf, or we may provide information to customers to facilitate referrals. We may disclose information that we collect about you to these companies or customers to enable them to perform these services, but they are required to safeguard the information and are not authorized to use it for any purpose inconsistent with the purposes or uses described above.

    B. Not Subject to HIPAA or Other Laws Governing Health Information. Spear is not a healthcare provider, covered entity, or business associate and is therefore not subject to compliance with the Health Insurance Portability and Accountability Act (HIPAA) or to other U.S. federal or state laws related to patient health information. Our Website and Services are not represented to be HIPAA compliant, and you may not use them for such purposes. Users are solely responsible for any applicable compliance with HIPAA or other U.S. federal or state laws related to patient health information. Users are required under this Privacy Policy and our User Agreement to avoid providing individually identifiable health information (as defined by HIPAA) to the Website.

  3. SECURITY.

    We are concerned about ensuring the security of your information. In connection with your use of the Website, your Personal Information is collected and stored in secured databases and servers. We use industry-wide, standard, commercially reasonable efforts to protect your personal information collected through the Website from access, loss, misuse, alteration, or destruction by any unauthorized party. Due to the nature of security practices (there is no 100% secured platform available in the industry), we cannot guarantee the security of our databases, nor can we guarantee that information you supply in connection with use of the Website will not be intercepted while being transmitted to us over the Internet or wireless communication. Therefore, any information you transmit to the Website is at your own risk. We do not promise, and you should not expect, that your personal information or private communications will always remain private.

    You have several options when deciding how you can best protect your information. One option is simply not to volunteer it. As stated above, this approach would allow you to still visit our Website – although it will prevent you, for example, from taking advantage of some of our Website’s features, Services, and information. The Federal Trade Commission’s website, https://www.ftc.gov, also offers useful information about how to protect information that you provide to websites or applications.

  4. LINKS TO OR FROM THIRD-PARTY WEBSITES.

    The Website may provide links to other websites, applications, or resources over which Spear does not have control. Such links do not constitute an endorsement by Spear of those third-party websites. While we support the protection of privacy on the Internet, we cannot be responsible for the actions of any third-party websites. Your use of third-party websites is subject to the terms of use and privacy policies (if any) located on such third-party website and is at your own risk. We encourage you to read the posted privacy policy of any and every site you visit, whether you are linking from our Website or browsing on your own.

  5. SUSPECTED VIOLATIONS OF THIS PRIVACY POLICY.

    If at any time you believe that we or any third-party vendor who is providing a service on or through the Website has not adhered to the policies and principles set forth in this Privacy Policy, please notify us using the contact information provided below. We will make all commercially reasonable efforts to promptly address your concerns.

  6. CHANGES TO PRIVACY POLICY.

    We reserve the right to amend this Privacy Policy from time to time in our sole discretion, and will post and maintain the most recent version of the Privacy Policy on the Website. We may not notify Website visitors of any such amendments by e-mail or other personal contact. You are responsible for reviewing this Privacy Policy upon each visit to the Website. You can determine if the Privacy Policy has been revised since your last visit by referring to the “Effective Date” at the top of this document.

  7. CONTACT US.

    If you have any questions about this Privacy Policy or its implementation, please contact:

    By Email:
    info@speareducation.com

    By Mail:
    7201 E Princess Boulevard
    Scottsdale, AZ 85255