Privacy Policy

Last updated June 23, 2023 - Bryan's Changes

This Privacy Policy, together with other statements about our privacy practices, describes how Tiber Health, Public Benefit Corp., and its affiliated entities (collectively TH or We) collects, shares, uses and protects information relating to individuals that are identified or are reasonably identifiable (Personal Information). Each individual to whom the Personal Information relates is called a Data Subject. The Privacy Policy covers situations where we collect Personal Information in providing a product or service. Please read through this Privacy Policy and contact us as described below if you have further questions.

How Personal Information is collected

Most Personal Information we collect is from Data Subjects seeking to obtain or learn about our services and about educational opportunities. This Personal Information generally is collected online through websites or apps. We may also collect Personal Information through entities that perform services for us, such as vendors or business partners.

Types of Personal Information collected

Consumers

Individuals seeking to obtain our services (Consumers) are asked to provide certain Personal Information. Personal Information may also be collected directly from your electronic device. We may also obtain Personal Information about a consumer from educational institutions. This Personal Information may include your name, Zip code, email address, telephone number, information about your educational background (including degrees you have earned and grade point average), interests, and the computer's IP and MAC address. 

Site Visitors

When you visit our online services, even if you do not provide us with information or choose to comment on materials, we and our third party vendors automatically collect other information about your use of our website such as your IP address, web browser and device type (Device Information). We do not link IP addresses to the Personal Information that we ask you provide when you click on a request for information form or comment on our materials. Your session and the pages you visit on our online services will also be tracked.

We use this Device Information for the primary purpose of conducting analyses to assist us with administering our website. To the extent beneficial, we share this information with third-party vendors, such as Google Analytics, to improve our online services. Please click here for information Google’s Privacy and Terms. Specifically, we use Google Analytics and, New Relic, Advertising features, including DoubleClick (DFP), Facebook Pixel, Simpli.fi, Remarketing with Google, Google Display Network Impression Reporting, Google Analytics Demographics and Interest Report.

Use and Sharing of Personal Information collected

We use Personal Information collected by us or on our behalf to provide requested services, improve our business, to meet legal and regulatory requirements and as otherwise permitted under applicable law. We collect and process this Personal Information in order to provide you resources tailored to help you plan your education (“Resources”). If you do not provide this personal information, we will be unable to provide you with the Resources.

Personal Information We collect or collected on our behalf may be shared with other entities. Our use and sharing of Personal Information will be for a lawful basis, which may be with your consent (as described below), as part of providing you with the Resources, as part of our normal business operations (such as to improve our services or let you know about products or services that may be of interest to you), to meet our contractual obligations with service providers or business partners, or to meet legal or regulatory obligations. We do not sell or rent Personal Information.

Sharing excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Sharing of Personal Information with Your Consent

If you seek to obtain the Resources, it might be necessary for you to consent for us to share your Personal Information with other institutions of higher education. The institutions may be ones you specifically designate or other institutions matching similar criteria to those you designate. As part of the registration process, you will be asked for your express consent for this sharing. You may withdraw your consent at any time, but we may not be able to provide you with the Resources.

Our website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Other information excluded from the scope of state privacy laws.

In particular, our website has collected the below categories of personal information from consumers within the last twelve (12) months. We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below

Category Whether Data is Collected and the Source of Collection Business or Commercial Purpose for Collection or Use Category of Third Party Recipients
A. Identifiers.

Ex.: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, or other similar identifiers.
Yes

From:
• You
• Your device
• Our Business Partners
• To provide the services you request
• Improve our services
• Inform you about our other services and offers that may be of interest to you
• Meet our contractual obligations with Service Providers or Business Partners
• Meet legal and regulatory requirements
• Provide customer service
• Detect and protect against security events and fraud
• Audit consumer interaction & transactions
• Service providers
•Business partners with which we jointly offer services
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Ex.: A name, address, telephone number, education, employment, employment history.
Yes

From:
• You
• Your device
• Our Service Providers or Business Partners
• To provide the services you request
• Improve our services
• Inform you about our other services and offers that may be of interest to you
• Meet our contractual obligations with Service Providers or Business Partners
• Meet legal and regulatory requirements
• Provide customer service
• Detect and protect against security events and fraud
• Audit consumer interaction & transactions
• Service providers
• Business partners with which we jointly offer services
C. Protected classification characteristics under California or federal law.

Ex.: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
No N/A N/A
D. Commercial information.

Ex.: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
No N/A N/A
E. Biometric information.

Ex.: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
No N/A N/A
F. Internet or other similar network activity.

Ex.: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Yes
From:
• You
• Your device
• Our Service Providers or Business Partners
• To Provide the services you request
• Improve our services
• Inform you about our other products, services and offers that may be of interest to you
• Meet our contractual obligations with Service Providers or Business Partners
• Meet legal and regulatory requirements
• Provide customer service
• Detect and protect against security events and fraud
• Audit consumer interaction & transactions
•Service providers
• Business partners with which we jointly offer services
G. Geolocation data.

Ex.: Physical location or movements.
Yes

From:
• You
• Your device
• Our Service Providers or Business Partners
• To provide the services you request
• Improve our services
• Inform you about our other products, services and offers that may be of interest to you
• Meet our contractual obligations with Service Providers or Business Partners
• Meet legal and regulatory requirements
• Provide customer service
• Detect and protect against security events and fraud
• Audit consumer interaction & transactions]
• Service providers
• Business partners with which we jointly offer services
H. Sensory data.

Ex.: Audio, electronic, visual, thermal, olfactory, or similar information.
No N/A N/A
I. Professional or employment-related information.

Ex.: Current or past job history or performance evaluations.
No N/A N/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Ex.: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Yes
From:
• Grades , assignments and Attendance from LMS • Score, performance and answers from Exam Software
•Demographic data, entrance exam performance from Student Information Systems
• Student Analytics
• Student Performance Alerts
• Accreditation and legal reporting and requirements.
• Consulting and student services
• Student Monitoring
• Accreditation and legal reporting agencies.
• University and medical opportunities
K. Inferences drawn from other personal information.

Ex.: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Yes
• Creation of performance scores through artificial mechanisms based on data collected in section J.
• Entrance readiness
• Student monitoring and intervention systems
• Consulting and student services
• Universities, residency hospitals, and other possible student opportunities. • Accreditation and legal reporting agencies.

Cookies

Cookies are small files that are stored on your computer. We use cookies to understand and save your preferences for future visits to our website and to offer you personalized information and products from our third-party business partners that may be of interest to you.

Children’s privacy

Our website is intended for use only by individuals planning their post-college education. Our website is not intended to be used by children under the age of 13.  If you are under the age of 13, please do not use our website.

­Retention of your personal information

We will retain your personal information for as long as is necessary to fulfill any of the uses and disclosures identified in this notice or to comply with applicable legal obligations.

Information protection

We have implemented reasonable administrative, physical and technical safeguards to protect your personal information from unauthorized access, alteration, and disclosure.

Supplemental Notice to Data Subjects for Residents of Certain US States (including California)

Residents of certain states (including California) may have certain rights regarding your personal information under state law. This section describes privacy rights applicable to residents of certain states and explains how to exercise those rights. These rights apply only where applicable by law.

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  • The specific pieces of personal information we collected about you (also called a data portability request).

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

If you choose to exercise these rights, we ask you to provide sufficient information, including the services you have used in the past, your state and country of residence, and contact information, in order for us to verify your identity and process your request. Depending on the types of requests, additional information may be requested. We will only use personal information provided in this retest to verify the requestor’s identity or authority to make it.

You may use an authorized agent to submit a request on your behalf related to your personal information. If you choose to use an authorized agent, you should supply your agent with written permission to act on your behalf in relation to your request, and your agent must provide us with proof of such authorization before we process your request.

To exercise a right related to your personal information, please contact us by email toprivacy@tiberhealth.com.

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact: +1-314-328-5718. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We will not discriminate against you for exercising any of your state-specific privacy rights. Unless permitted by law, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by applicable law that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Browser Do Not Track Signals

At this point, our website does not respond to browser “do not track” or similar signals.

Changes to this Privacy Policy

We may revise this Privacy Policy based on changes to our business practices, the services we offer, changes in the law, or for other reasons. Please check back here periodically for any changes.  We will indicate the effective/amendment date at the top of the Privacy Policy.

Contact us

If you have questions about this notice, please contact us privacy@tiberhealth.com.

Notice about cookies and similar technology

This Cookie Notice is effective June 23, 2023

When you access our online services, We, or service providers we hire to track how our online services are used, may place small data files called “cookies” on your browser or other access device. Cookies are pieces of data stored on your device and are assigned by a web server to the browser on your device. When you return to a site you have visited before, your browser gives this data back to the server.

Information about your session may be sent to your computer or other access device when you access our online services as a “Session Cookie” or other technologies such as the browser’s session storage. This type of information or cookie recognizes you if you visit multiple pages on a site during the same session and may provide authentication data so that you do not need to be prompted for your password on each page. Once you log out or close your browser, this information expires and no longer has any effect.

“Persistent” or longer-lasting data, stored as cookies or in the brewer’s local storage, can be used for other purposes, such as to record user experience preferences when you use our online services and to inform you about products and services during and after you visit our online services, a process known as remarketing. These cookies do not expire once you log out or close your browser. You are free to decline our cookies if your browser permits, but doing so may interfere with your use of our online services.

We use Service Providers to perform remarketing on our behalf. In the remarketing process, a unique ad-serving cookie is placed on your browser that uses information about your browser and your activity on our online services to serve ads on places such as the Google content network. As a result, you may notice ads about our products and services elsewhere online when browsing. Please click here for more information about remarketing or to opt out of the Google remarketing cookie. In addition, please click here for Google Analytics’ currently available opt-outs for the webFurther information on Google Ads Settings can be accessed by clicking here. To learn more about this type of advertising in general, and to opt out of seeing interest-based advertisements on participating sites, visit the Network Advertising Initiative home page. Please note that, even if you choose to remove your information, you will still see advertisements while you're browsing online. However, the advertisements you see may be less relevant to you and your interests.

You can control the use of certain cookies and similar technologies by:

If you choose to reject certain cookies and similar technologies, you may still visit our online services.

We and our Service Providers may also use technologies similar to cookies to track your interaction with our online services. Some of these technologies include web beacons, pixels, tags and other objects. As with cookies, you are free to decline such technologies if your browser permits. You should refer to your browser’s instructions to remove cached history and images from your device. Deleting or disabling cookies will not remove other objects. You should refer to Adobe’s website (http://www.adobe.com) for more information on how to disable these objects.

We and the Service Providers who assist in operating our online services do not respond differently or limit their practices under the terms of this policy when you access those online services with a browser that uses a do not track signal or similar mechanism.

Updates to this Cookie Notice

We may update this Cookie Notice from time to time. Please check here for such updates. We will indicate the effective/amendment date at the beginning of this Cookie Notice.