Last updated March 1, 2023

Healthcare Quality Systems L.L.C.  wants you to know how we use and protect the important information you provide to us. The information provided below summarizes our policy, procedures and practices as further described in this Privacy Statement.

• Unless you tell us otherwise, when you provide your information, we will use your information as allowed by law and Healthcare Quality Systems L.L.C. policies to deliver the programs you are involved with and in furtherance of our mission.
• We recognize we must comply with all applicable privacy and data protection laws in the United Arab Emirates (“UAE”).
• If we ask for information, including certain types of sensitive information—such as health information—we will tell you how we intend to use and disclose that information and the purpose of personal data processing activities.
• Additional information about how we collect, protect, and use information in our research, outreach, consumer education and other “offline” programs may be found at our Privacy Policy & Standards.
• We will use—and require our data management vendors to use—reasonable and appropriate technical and regulatory procedures and security practices to safeguard your information, taking into account the risks associated with the data processing according to the best international standards and practices.
• If you change your mind about allowing us to use your information or have questions about our privacy practices, please use the contact options on our Contact Us page to let us know.

This Privacy Statement is an explanation of what we do with your information as well as for why we do these things:

Information We Collect

Personal Information

“Personal Information” means information that we can use to identify or contact you. It can include health and other information you submit when you use our interactive tools and services. We may collect Personal Information in the following ways:

• When you visit or use our online sales systems, whether web-based or mobile, we may collect your name, email address, mailing address, telephone number(s), account numbers, limited location information (for example, to help a mobile app determine the best means of connecting to the database or for shipping something you purchased) and user name and password (so you can log in);
• We may collect payment card or similar information when you provide it to us as part of a purchase;
• We may capture the IP address and ID of the device you use to connect to the online service, the type of operating system and browser you use, and information about the site you came from, the parts of our online service you access, the type of mobile device you use and the site you visit next (see also the Cookies, Tags & Remarketing Pixels Section);
• We or our service providers may also use cookies, web beacons or other technologies to collect and store other information about your visit to, or use of, our online services. We may later associate the usage and other information we collect online with Personal Information about you (see also the Cookies, Tags & Remarketing Pixels Section);
• When you register for or use certain interactive tools and services, such as many of our mobile Apps, or tools inside many of our Apps, we may collect your [e.g., email address, username, password and device information];
• When you sign-up for newsletters or other communications from us, we may collect your [e.g., name and general contact information];
• When you participate in an online survey, we may collect your [e.g., name and general contact information]; or
• When you provide Personal Information in a community area or other public forum, we may collect your [e.g., name, contact information and additional Personal Information you voluntarily disclose].

Children’s Privacy

With legal guardian consent, we may collect information from children under the age of 18 such as: name, address, email address, account information, school, messages sent to us through our chat interface, and content they create themselves. That information allows us to fulfill requested transactions, respond to questions about our website and programs, facilitate their participation in activities and other programs, keep records, or to otherwise customize or enhance the website experience for children. Children under the age of 18 may be able to make certain content such as content they create themselves visible to others or the public. This might include, for example, a webpage or parts of webpages operated by children that have been designed for group or public viewing, or photos of themselves involved in our programs or other activities.

In addition to information children provide us directly, we use cookies and similar tools on our web sites. Such tools store unique identification numbers or codes (i.e., “persistent identifiers”) that enable us to provide a personalized web experience to users, among other benefits. We use such persistent identifiers to support the internal operations of our web sites as described in more detail in the Section of this Privacy Statement on “Cookies, Tags & Remarketing Pixels.”

If you have questions about the involvement of third parties in providing our services, including their privacy practices, please contact our offices via the Contact Us page , or by phone or email (details are included at the bottom of this page).

Regardless of what is displayed or submitted, legal guardians can revoke their consent, request that information about the children be hidden or, in some cases, deleted, by contacting our offices by phone at the number at the bottom of this page or via email to the address showing at the bottom of this page. When a legal guardian revokes consent, we will stop collecting, using or disclosing information from that child. To comply with such a request, we must verify the identity of the requesting legal guardian. To respect the privacy of parents and other legal guardians, we dispose of information that is collected and used solely for obtaining verifiable legal guardian consent or providing notice after a reasonable time after legal guardian consent is declined or revoked.

Information from Other Sources

We, or our service providers, and other companies we work with may deploy and use cookies, web beacons, local shared objects and other tracking technologies for various purposes, such as fraud prevention and monitoring of our advertising and marketing campaign performance. Some of these tracking tools may detect characteristics or settings of the specific device you use to access our online services.

We may also collect information about you from additional online and offline sources including from social media activities and commercially available third-party sources. We may combine this information with the personal and other information we have collected about you.

How We Use Information We Collect

We use the information discussed above in a number of ways and for a number of purposes, such as:

• Processing purchase transactions;
• Verifying your identity (such as when you access your account information);
• Preventing fraud and enhancing the security of your account or our online services;
• Responding to your requests and communicating with you;
• Managing your preferences;
• Performing analytics concerning your use of our online services, including your responses to our emails and the pages and advertisements you view;
• Providing you tailored content and marketing messages;
• Operating, evaluating and improving our programs (including developing new products and services; improving existing products and services; performing data analytics; and performing accounting, auditing and other internal functions);
• Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies; and
• For any other purposes that we may specifically disclose at the time you provide or we collect your information.

We may also use data that we collect on an aggregate or anonymous basis (meaning it does not identify any individuals) for various purposes, where permissible under applicable laws and regulations, to help deliver products, services, and content that are better tailored to the users of our services and for other purposes.

What We Disclose to Others

We may share the information we collect from and about you within our organization and with certain third parties inside the UAE and outside the UAE, including but not limited to the United States of America. For example, we may share your information with:

• Credit card processing companies, to process your payments to us or entities within our group of companies;
• Our other websites in an effort to bring you improved service across our large range of products and services, to the extent you have given consent to such processing of your Personal Information, or when it is permissible under relevant laws and regulations;
• Other organizations we work with to provide services, research, products or programs; and
• Other third parties to comply with legal requirements such as the demands of applicable subpoenas and court orders; to verify or enforce our terms of use, our other rights, or other applicable policies; to address fraud, security or technical issues; to respond to an emergency or legitimate requests from concerned regulatory authorities; or otherwise to protect the rights, property or security of our customers or third parties.

Links to Third-Party Websites

Healthcare Quality Systems L.L.C.  may provide links to websites that are owned or operated by others (“third-party websites”).  When you use a link online to visit a third-party website, you will be subject to that website’s privacy and security practices, which may differ from ours. You should familiarize yourself with the privacy policy, terms of use and security practices of the linked third-party website before providing any information on that website.

Updating Your Information and Contacting Us with Questions

Keeping your account information and preferences up-to-date is very important. You may review your information, request that we stop using it, or update certain account information by logging in and accessing the account profile section of each online service for which you have registered. If you cannot locate, access or make changes to the information or permissions online, you may send a request using our online form or use the Contact Us page. Of course, we cannot track down “de-identified” information to change it or undo any prior use of data we already used with your actual consent.

In certain cases you may also have the right to request the personal information usage to be restricted or deletion of your personal data, for any such request you may send a note using our online form or use the Contact Us options on our site. We will consider any such request and its legitimacy on a case by case basis and comply with our statutory obligations in regards to limiting processing activities as well as deleting Personal Information.

To the extent that we provide you with direct marketing communications on the basis of your consent provided for such purpose, you have control regarding our use of your Personal Information for such reasons. If you no longer wish to receive any direct marketing communications, you can opt-out at any time. To do so you may use the unsubscribe link within a marketing email received from us or use the contact options on our Contact Us page to let us know.

Changes to This Privacy Statement

We may change this Privacy Statement from time to time. When we do, we will let you know by appropriate means such as by posting the revised policy on this page with a new “Last Updated” date. In some cases, you may be asked to agree again to our Privacy Statement or other terms, even if you have already agreed to accept them, because there were changes. Any changes to this Privacy Statement will become effective when posted unless indicated otherwise.

Other Privacy Policies and Practices

This Privacy Statement describes our practices related to our most common data collection activities. We have other policies, procedures and statements that apply to other activities and programs.  If you have a question about privacy protections related to “offline” programs, please use the contact options on our Contact Us page.

Information Security

Healthcare Quality Systems L.L.C.  takes the security of your personal and financial information that you provide to us very seriously and we take reasonable technical and regulatory procedures and measures to safeguard your information consistent with our Privacy Statement.

Our network is composed of access-controlled measures, security monitoring tools, vulnerability management program, SSL encryption, scheduled network scans, and internal and external penetration tests. When it is necessary for our service providers to have access to your information, we expect the same level of data security, integrity and confidentiality standards as Healthcare Quality Systems L.L.C.  itself provides. Additionally, we conduct security awareness training for our staff.

While Healthcare Quality Systems L.L.C.  uses its best efforts to maintain this level of security across all of our systems we cannot guarantee or warrant that our systems or our service providers are not vulnerable to viruses, hacking or other security threats.

Cookies, Tags & Remarketing Pixels

A cookie, tag, or pixel (collectively, “cookie”) is a small piece of text or technology sent to your browser by a website you visit or stored on your device. It helps the website to remember information about your visit, like your preferred language and other settings. Cookies are also used by web sites for authenticating users, tracking a user’s session, and/or for storing other essential textual information. Healthcare Quality Systems L.L.C.  tracks your interests on our sites so that we can provide you with additional content that might be of importance to you. Providing you with fresh and engaging content is important to us, as we know it is important to you.

We use tools, cookies and services such as AdWords, Google Analytics, Hubspot and CrazyEgg for tracking, reporting and analyzing website activity. Some cookies are used to measure conversion events. Pixel tags might be used together with some of the advertising cookies described above, to operate, evaluate, and improve our programs, and to perform data analytics, accounting, auditing, and other internal functions.

We do not run interest-based advertising campaigns that collect Personal Information including, but not limited to, email addresses, telephone numbers, and credit card numbers, nor do we use or associate Personal Information with remarketing lists, cookies, data feeds, or other anonymous identifiers. We do not use or associate targeting information, such as demographics or location, with any Personal Information collected from the ad or its landing page. Healthcare Quality Systems L.L.C.  does not share Personal Information with Google through our remarketing tag or our product data feeds that might be associated with our ads. Healthcare Quality Systems L.L.C.  will not send Google precise location information without obtaining your consent.

To see how Google may use information collected through your use of Google’s search services visit Google’s Ads Help Center.

If you want to opt out of Google’s use of cookies visit Google’s Ads Setting Site.

If you want to opt out of CrazyEgg’s creating of a user profile, CrazyEgg’s storing of data about your usage of our site, and CrazyEgg’s use of tracking cookies on other websites by following CrazyEgg’s opt-out link.

To learn more about other cookies used for interest-based advertising, including through cross-device tracking, and to exercise choices regarding such cookies, please visit the following websites (or your device settings for mobile applications):

• Digital Advertising Alliance (http://optout.aboutads.info/)
• Network Advertising Initiative (http://optout.networkadvertising.org/)
• European Union Interactive Digital Advertising Alliance (http://www.youronlinechoices.eu)
• Digital Advertising Alliance-Canada (http://youradchoices.ca/choices/)

Cross-Border-Processing

We may transfer some of your Personal Information to countries outside the UAE or otherwise process part of your Personal Information outside the UAE. As and when we do so we shall only:

• transfer your information to a jurisdiction permitted by the concerned regulatory authority and which has laws or regulations for protection of your Personal Information in it, which include the most important provisions, measures, controls, requirements and rules of protection of the privacy and confidentiality of your Personal Information, and your ability to exercise your rights; or
• transfer your information to another country
  • when the transfer is necessary to perform obligations and to prove, exercise or defend rights before the judicial authorities; or
  • when the transfer is necessary to enter into or perform a contract entered into between you and us, or between us and third parties to achieve your interest; or
  • when you have given your explicit approval to transfer your Personal Information outside the UAE in a manner that does not conflict with the public and security interests of the UAE; or
  • when a transfer is otherwise permitted by law.

We use reasonable physical, technical, and administrative measures designed to secure and protect Personal Information within our organization and in the event of transfer. We incorporate industry standard security controls (like firewalls) and protocols (like SSL/TLS) to maintain an environment that is resistant to standard internet-based threats. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.

Other Issues

What is the legal basis of processing?

• We have several different legal grounds on which we collect and process Personal Information, including: (a) as necessary to perform a transaction under a contract entered with you or for your benefit (such as when we respond to your requests or provide the services you purchased); (b) as necessary to comply with a legal obligation (such as when we use Personal Information for recordkeeping to [e.g., substantiate tax liability or eligibility for a course completion credential]); and (c) consent (where you have provided consent as appropriate under applicable law, such as for marketing or certain cookies).

What are the consequences of not providing Personal Information?

• You are not required to provide all Personal Information identified in this Privacy Statement, but certain services will not be available if you do not provide Personal Information. For instance, if you refuse to provide proof of identification you may not receive certain products you purchase.

Do we engage in automated decision-making without human intervention?

• We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.

Does Healthcare Quality Systems L.L.C.  honor do-not-track (“DNT”) signals sent via browsers?

• Given the divergent practices of organizations that offer browsers and the lack of a standard in the marketplace, we generally do not respond to DNT signals at this time.