PRIVACY POLICY
(Amended on July 18th, 2018 according to GDPR)
1. This privacy policy has been compiled to better serve the Users who are concerned with how their 'Personal Data' (PD) which means any information relating to an identified or identifiable natural person, according to the EU General Data Protection Regulation, are processed and used on MULTIEPORTAL LMS, MULTILEARNING Mobile Learning App for iOS/Android, MULTIWEBCAST Viewer, MULTITESTER, MULTIEPOSTER Viewer, MULTISUBMISSION and other software (hereinafter referred as this Platform) powered, owned and published by MULTILEARNING Group Inc (hereinafter referred as MLG). For the cases referred to hereunder, MLG acts as the data processor for the American Academy of PAs [AAPA] (hereinafter, referred to as AAPA), except for the cases where MLG, in order to improve the quality of education and the experience provided to Users, perform upgrades to the Platform which may also include new means and purposes of processing, acts as the joint controller with AAPA.
2. What personal data does MLG collect from the Users that visit the Platform? When registering or ordering on the Platform, as appropriate, the User may be asked to enter his/her name, email address, mailing address or other details to help with the experience. The Platform will respect the confidentiality of the data that is transmitted on it in accordance with the provisions of this Agreement. The Platform uses a random identifier, which is a session number attributed to the User as he/she enters the site. This session number is expunged in this Platform system as the User leaves. Please be advised that your visit to this Platform leaves a retrievable trace that allows this Platform to gather raw data on the User. Such technical retrieving system is necessary in order to secure this Platform system.
3. By using this Platform, the User agrees that his/her information may be archived in the database of this platform and be used by AAPA. MLG provides AAPA with live access to Users' profile information, material or communications posted and any user activity records, therefore data collected on the application and through this Platform may be stored and/or processed in a foreign country given that such country has adequate personal data protection regulations in place.
4. When does MLG collect information? We collect information from the User when he/she registers on the Platform, place an order, enter information, write posts/comments, add content to favorites, provide ratings or submit educational content (such as documents, videos, narrations and images), are active on a educational activity, download materials, create content (such as quizzes), and when the User uses mobile devices' resources (such as camera or microphone) to scan QR codes, submit photos, record narrations and send educational materials.
5. How does MLG use your information? MLG may use the information it collects from the User in the following ways:
5.1. To personalize the experience and to allow MLG to deliver the type of content and product offerings in which you are most interested.
5.2. To improve the Platforms in order to better serve the User.
5.3. To administer a survey or other site feature.
5.4. To quickly process the User’s transactions.
5.5. To ask for ratings and reviews of services or products.
5.6. To communicate with the User through e-mail regarding the User’s interaction with the educational content, to promote new educational content, to inform the User about the accreditation procedure, if relevant.
5.7. To save User’s information when he/she downloads, uploads and creates content on the Platform.
6. How does MLG protect the User’s information? MLG employs appropriate measures to ensure that both the software that it produces, as well as any third-party software that is required by its IT infrastructure, remains up to date, particularly in regard to security patches. These security patches are applied as soon as they are available from the upstream (i.e. third party) vendor, or as soon as a vulnerability is identified and consequently fixed (in MLG’s software).
7. The Personal Data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive information you supply is encrypted via Secure Socket Layer (SSL) technology. MLG implements a variety of security measures when a User places an order enters, submits, or accesses their information to maintain the safety of the User’s personal data. AAPA/MLG never asks for credit card numbers. All transactions are processed through a secure gateway provider and are not stored or processed on AAPA/MLG’s servers.
8 The User agrees and acknowledges that the Personal Data provided on the platforms of the MLG are stored on MLG databases for security, backup and archiving purposes, as well as facilitation of the performance of services provided by the AAPA. Since May 25th, 2018, the archive and backup retention period is between 6 months and 1 year. Archives and archived backups use encryption to protect the data both in transit and at rest.
9. Does MLG SOFTWARE use 'cookies'? Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through the User’s Web browser (if he/she allows) that enables the site's or service provider's systems to recognize the User’s browser and capture and remember certain information.
9.1. The MLG SOFTWARE are provided to you as pure educational platforms/services requiring cookies to operate. In the case of the MLG SOFTWARE, cookies are essential for the Platform to function properly for the provision of education for the following reasons:
9.2. All functionalities of this educational platform and embedded applications require the existence of a User session enabled by cookies (When you complete a case study, it allows MLG SOFTWARE to keep track of your progression and compile your results at the end of your activity, it also allows you to continue activities where you have left them)
9.3. All true educational interactions/activities Users are performing on MLG SOFTWARE (such as searching for and completing e-learning activities, downloading educational materials, posting within forums related to content, viewing educational lectures) are either captured for official accrediting bodies to allow Users who explicitly opted to obtain CME/MOC/CE and other types of professional accreditation credits/points/certificates from those accrediting bodies and/or for AAPA to evaluate the provision of education to their targeted audience and to establish their educational strategies/investment accordingly. The accrediting bodies and/or AAPA do not use the personal data gathered from the cookies for any other reasons stated herein.
9.4. However, the MLG SOFTWARE do not capture non-essential activities such as menu items and listings you click on or pages viewed.
9.5. The User has the right to choose to have his/her computer warn him/her each time a cookie is being sent, or the User can choose to turn off all cookies, through their browser settings. Since each browser is a little different, we suggest that you look at your browser's Help Menu to learn the correct way to modify your cookies.
9.6. If the User disables cookies in his/her browser: a large subset of the functionality provided by the Platform will either be unavailable or cease to work as expected.
9.7. When third party services using cookies such as Google Analytics and Google Tag Manager embedded tracking functionalities are enabled by our clients (Data Controller) are enabled by our clients on the platform (AAPA in the case of this platform) to compile aggregate data about traffic, interaction, engagement time, demographics, and more, MLG Software will allow you to opt-in to this service before May 25th, 2018.
10. The User has the right to choose to have his/her computer warn him/her each time a cookie is being sent, or the User can choose to turn off all cookies, through their browser settings. Since browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies.
11. If the User disables cookies in his/her browser: Cookies are essential for the Platform to function properly. If the User disable cookies, a large subset of the functionality provided by the Platform will either be unavailable or cease to work as expected.
12. Third-party disclosure: MLG does not sell, trade, or otherwise transfer to outside parties the User’s Personal Data unless MLG provide users with advance notice often specified in the Platform registration agreements such as MLG clients and/or accrediting bodies. This does not include cloud infrastructure providers and other parties the assistance of which is essential for operating MLG’s website, conducting business, sending out newsletters or push notifications or serving MLG’s Users, so long as those parties agree to keep this information confidential and secure. MLG may also release information when its release is appropriate to comply with the law, enforce site policies, or protect MLG’s or others' rights, property or safety. Other than as outlined in this Agreement, all the data collected on the User cannot be accessed by any persons other than the User, AAPA, the accrediting body of course(s) the User has started/completed, MLG and platform administrators and e-learning program managers/contributors and trainers.
13. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
14. Third-party links: Occasionally, at MLG’s clients’ discretion, MLG may include or offer third-party products or services on its website. These third-party sites have separate and independent privacy policies. MLG therefore has no responsibility or liability for the content and activities of these linked sites. Nonetheless, MLG seeks to protect the integrity of its site and welcomes any feedback about these sites.
15. Google: Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users. We have implemented the following:
15.1. Demographics and activity Reporting
16. AAPA may choose to use Google Analytics for user behaviour tracking/reporting. Google Analytics works in parallel and independently from MLG’s features. Google Analytics relies on cookies and these cookies can be used by Google to track users across different platforms/services. Neither MLG nor AAPA has access to the data collected through the cookies implemented by Google Analytics. Likewise, Google Analytics does not have access to the data MLG collects through cookies implemented in accordance with this Privacy Policy.
17. PIPEDA legislation and regulations: In addition to its obligations under privacy regulations such as the General Data Protection Regulation, MLG is a Canadian corporation primarily subject to the Personal Information Protection and Electronic Documents Act (PIPEDA) available at: http://laws-lois.justice.gc.ca/eng/acts/P-8.6/index.html or subsequent replacement data protection Acts in effect in Canada.
18. The User will be notified of any Privacy Policy changes:
18.1. On the Privacy Policy Page
18.2. And/or when the User logs in
19. The User can change his/her personal data:
19.1. By emailing MLG
19.2. By logging in to his/her account
20. If at any time the User wishes to unsubscribe from receiving future emails,
20.1. He/she can email MLG at [support@multilearning.com] or
20.2. Follow the instructions at the bottom of each email.
and MLG will promptly remove the User from ALL correspondence.
21. Contacting MLG
If there are any questions regarding this privacy policy, please contact MLG using the information below.
MULTILEARNING Group Inc.
8782 Lajeunesse
Montreal, Quebec H2M1R6
Canada
support@multilearning.com
Last Edited on 2018-07-18
REF:MULTIEPORTAL V.GDPR2 July 2018
https://www.multilearning.com
©2018 MULTILEARNING Group Inc.