Effective Date: October 17, 2021

Welcome! You have arrived at a website operated by CeriFi, LLC, or our affiliates (“CeriFi,” “we”, “our” or “us”). We are the recognized market leader in financial services education and training. With a combination of more than 235 years of experience, our superior training supports individuals, firms, and universities so that they benefit from the best instructional tools available. At CeriFi and the CeriFi family of companies, we take your privacy very seriously. This Privacy Notice (“Notice”) informs you how we handle privacy matters and collect, use and share your Personal Information (as defined below).

This Notice applies when you use or access the following websites, and their subdomains or portals (“Sites”) that are in the CeriFi family of companies, or otherwise provide Personal Information or interact with us online or in-person: CeriFi: www.cerifi.com Association of Certified Financial Crime Specialists (“ACFCS”): www.acfcs.org Bionic Turtle: www.bionicturtle.com CPMI Professional Development: www.cpmipro.com Dalton Education: www.Dalton-education.com Fast Forward Academy: www.fastforwardacademy.com Mark Meldrum: www.markmeldrum.com Money Education: www.money-education.com Pass Perfect: www.passperfect.com Solomon Exam Prep: www.solomonexamprep.com Spidell Publishing, Inc. www.caltax.com For the purpose of this Notice, "Personal Information" means any personal information relating to an identified or identifiable individual that is protected by applicable privacy laws. We refer to all of the above as “Services.” By using the Services, you agree to our Terms & Conditions. Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Services if that Personal Information is necessary to provide you with the Services or if we are legally required to collect it. If you have any questions about this Privacy Notice, please contact us at privacy@Cerifi.com.

This section describes what information we collect from you through our Sites and Services. We may receive information (including Personal Information) in the following ways:

As you interact with our Sites and Services, we collect Personal Information as follows: For all Sites:

• Contact information such as your first and last name, email address, login and password, home or business address, shipping address, telephone numbers, mobile numbers;

• Financial information such as your credit card or debit card number, bank account information and your payment, service and purchase history;

• Information that you share via the chat function on applicable Sites (please note that we do not collect consumer information via the Sites’ online chat or Contact Us function unless you provide it);

• Your course progress and any other information that you share in the course section of the Sites;

• If you apply for employment with us, your current or past employment or educational information;

• Social media information, such as social media handles, content and other data shared with us through third-party features that you use on our Sites and other service (such as tools, payment services, widgets and plug-ins offered by social media services like Facebook, Twitter and LinkedIn) or posted on social media pages (such as our social media page or other pages accessible to us); and/or

• Other information that could reasonably be used to identify you personally or identify your household or device.

For ACFCS:

• If you are seeking a job through the ACFCS Careers Portal, your current or past employment or education information;

We may also obtain Personal Information from you where you expressly provide us with the information. Examples of sources from which we collect information include telephone calls with you, letters, e-mails or other communications from you, information provided via web forms or inputs/uploads into our Sites, documents you have provided to us, or references and referrals provided to us in connection with your employment applications.Your decision to provide us with Personal Information is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all the features of the Sites or our Services.

Like many businesses, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Sites and Services (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Sites. Usage Information may include:

• Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;

• Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);

• Referring and exit web pages and URLs;

• The areas within the Sites that you visit and your activities there, including remembering you and your preferences;

• Your Device location or other location information, including the zip code, state or country from which you accessed the Services;

• Your Device characteristics;

• Certain other Device data, including the time of day you visit our Sites or other information used to provide analytics or other usage information;

• Information about your engagement with our emails; and

• Statistical information about how both unregistered and registered users, collectively, use the Sites and Services. This aggregate information is derived from Personal Information but cannot be tied back to you or your web browser.

For location information, some of our Sites and Services may include features based on users’ actual locations and may report on users’ current locations (“Location-Based Services”). To the extent you use any Location-Based Services, we may collect and store information about your location at the time you use those Location-Based Services (in addition to some automatically collected geolocation data). This information can come from a variety of sources depending on the device you use to access the Services; for example, a mobile phone may report its GPS location at the time Location-Based Services are used.If you no longer wish for us or our service providers to collect and use location information, you may disable the location features on your device. Consult your device manufacturer settings for instructions. Please note that if you disable such features, your ability to access certain Site features, services, content, promotions, or products may be limited or disabled.

The Sites may include functionality that allows certain kinds of interactions between the Sites and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we might obtain information about the traffic and usage of CeriFi from third parties. We might also provide links to facilitate sending a communication from the Sites, or we may use third parties to facilitate emails or postings to social media (like a “Share” or “Forward” button). These third parties also use cookies and other tracking technologies to capture information about your interactions with CeriFi. CeriFi does not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.

We may ask you to provide Personal Information for the following reasons:

• To respond to requests for information about CeriFi and our Services, we may ask you for contact information such as your name, email address and phone number;

• To provide products and Services to you;

• To help you register for an account with CeriFi;

• To verify your identity and to prevent fraud;

• To process your payments;

• To provide you with marketing communications such as emails and text messages about CeriFi and our Services, including job alerts from ACFCS;

• To provide you with updates and other information about Cerifi and our Services;

• To administer and allow you to participate in CeriFi sweepstakes, promotions, contests or surveys. When participating in surveys, any information you provide in the comments field will be shared with us, so please do not include any sensitive personal information or other information you do not wish to share;

• To evaluate your application for employment or administer employment benefits;

• To improve the effectiveness of our Sites and Services;

• To protect the security and integrity of our Sites and Services;

• To comply with the law and protect the safety, rights, property or security of CeriFi and the general public; and

• For other purposes disclosed at the time you provide your Personal Information or as otherwise set forth in this Notice.

We use cookies and other tracking technologies to personalize your experience, analyze user trends, and improve the Services. These tracking technologies allow us to collect information such as your device type, browser type, interactions with our Sites, geographic location, your web request, the date and time of your web request, your Internet Protocol address, the domain name of your Internet service provider and other data. If you can be identified from this information, for example by combination with other pieces of information, then we will treat this information as Personal Information. You can alter the configuration of your browser to refuse to accept cookies, but it is possible that doing so may cause limited functionality of the Sites. For example, we may not be able to recognize your computer or device, and you may need to log in every time you visit. We may use “cookies” (a small text file sent by your computer each time you visit our site) or similar technologies to record log data. Many browsers default to accepting cookies. You may be able to change this setting in your browser and you can also clear your cookies. If you do, you may lose some functionality of our site. Check your browser’s help function to learn more about your cookie setting options.We may use the following types of cookies:

• Advertising and analytics

• Essential cookies

• Functionality cookies

• Social Media cookies

• Advertising cookies

We might also use a pixel tag which is a small graphic file that allows us and third parties to monitor the use of the site and provide us with information based on your interaction with the site. These tags may collect the IP address from the device which you loaded the page, the browser type. Pixel tags are also used by our third parties to collect information when you visit our site, the links and other actions you take on our site, and we may use this information in combination with cookies to display targeted advertisements. Other data technologies may be used that collect comparable information for security and fraud detection purposes. If you have any questions about cookies or to generally find out more about cookies, visit this site.

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

• Internet Explorer

• Mozilla Firefox

• Google Chrome

• Apple Safari

Note, however, that if you reject our request to use cookies or turn cookies off, you may be unable to access certain parts of the Sites and you may not be able to benefit from the full functionality of the Sites. To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, visit www.allaboutcookies.org, and/or www.youronlinechoices.com.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites and platforms. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally agreed-upon standard for what a Cerifi should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.

To help us make e-mails more useful and interesting, we often receive a confirmation when you open e-mail from us if your computer supports such capabilities. You can opt out of receiving emails from us at any time. To manage your communications preferences with CeriFi — or to opt out of communications entirely — please unsubscribe at the bottom of our emails or contact us at privacy@Cerifi.com.

Our Sites might use Google Analytics to help us understand how our customers use the Sites. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

With your consent, some of our Sites share Personal Information such as your contact information with our webinar and virtual event partners. You can withdraw your consent at any time by contacting us at privacy@Cerifi.com.

We share your Personal information such as contact information with various University Partners to help them with enrollment. Some of our Sites also share your information with other partners such as professional boards, including the Certified Financial Planner Board of Standards, Inc.

We share your Personal Information with our third-party service providers who provide services such as website hosting, payment processing, online chat functionality, data analysis, information technology, customer service, email delivery, online advertising, auditing, event planning and other services. We use Big Commerce to power the online stores on our Sites. You can read more about how Big Commerce uses your Personal Information here: https://www.bigcommerce.com/privacy/.

We share information about your use of our Sites and Services, your purchases, and your interaction with our ads on other websites with our advertising partners to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. You can opt out of targeted advertising by visiting the following:

• Facebook -

   

  https://www.facebook.com/settings/?tab=ads

• Google -

   

  https://www.google.com/settings/ads/anonymous

• Bing -

   

  https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

• LinkedIn -

   

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

Aside from the instances described above, we will only share your personal information:

• to comply with the law;

• to respond to claims or comply with legal process served on CeriFi (e.g., a lawful subpoena, warrant, or court order);

• to enforce or apply our policies or agreements;

• to protect and defend our rights or property or that of our customers, employees, visitors, or the public;

• in connection with a business transfer, sale, liquidation, or merger;

• if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure; and

• with your consent.

Our Sites may contain links to other websites such as social media platforms, other websites, and event and partner websites. These websites are not covered by this Privacy Notice. Please review the Privacy Notices or Policies of those websites to understand the privacy practices of these third parties.

Our Sites are operated in the United States. If you are located in another jurisdiction, please know that your information will be transferred to, stored, and processed in the United States. By using this Sites and providing us with information, you consent to this transfer, processing and storage of your information in the United States. It is important to note that the privacy laws in the United States may not be as comprehensive as those in other countries such as those in the European Union (“EU”). Our service providers use appropriate safeguards to transfer your Personal Information to the United States.

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Where we have given you (or where you have chosen) a password so that you can access certain areas of our site, you are responsible for keeping this password confidential. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us at privacy@Cerifi.com.

This section of our Privacy Notice applies if you are a data subject who resides or is located in the European Economic Area (“EEA”). We adopted this Policy to comply with European privacy laws, including the General Data Protection Regulation (“GDPR”). Any terms defined in the GDPR have the same meaning when used in this Section. In most instances, CeriFi is the data controller for processing Personal Information provided to us through the Sites.We hope to ensure that the Personal Information we possess are always accurate and therefore we encourage you to update your information in your own account in case any changes have occurred. We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Information, subject to applicable law. We take every reasonable step to ensure that the Personal Information that we process are limited to the Personal Information that are reasonably required in connection with the purposes set out in this Privacy Notice.If you are a resident of or located within the EEA, you have certain data protection rights. These rights include:

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Information by contacting us at the contact information below.

• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

• The right to object. You have the right to object to our processing of your Personal Information.

• The right of restriction. You have the right to request that we restrict the processing of your Personal Information.

• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.

• The right to withdraw consent. You also have the right to withdraw your consent at any time where CeriFi relied on your consent to process your Personal Information.

We rely on the following legal bases for processing your Personal Information:

• Processing of your Personal Information that you provide to us when you interact with our Services, such commenting in our community blog, watching our videos or making a purchase, is necessary to respond to or implement your request prior to entering into a contract with us.

• When you apply for employment through our Sites, processing of your contact details and data about your employment history and education (as needed to evaluate your job application, to conduct job interviews, and as is otherwise needed for recruitment) is necessary to respond to your request to process your application for employment. If you do not provide this data, we will not be able to process the application that you send through our Sites.

• We use account-related data to set up accounts for users in our platform and to administer and support those accounts (such as usernames, email address and billing information), provide you with access to the Services, contact you regarding your use of the Services or to notify you of important changes to the Services. Such use is necessary for the performance of the contract between you and us.

• We will send you information by email on our new services or other promotions only with your consent or if you otherwise opt-in to receiving those communications. If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent at any time as described below.

• Our use of data relating to your use of the Sites and/or the Services, described above, is necessary for our legitimate interests in understanding how the Sites and the Services are being used by you, to improve your experience on it and our Services offerings. We have also a legitimate interest in aggregating and/or anonymizing the information that we collect through our Sites and/or the Services and using this information for our business purposes, as described above. When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below.

CeriFi will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.All information you provide to us is stored on our secure servers or those of our third-party data storage providers.

If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the contact details below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA in order to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us as follows:E-Mail: privacy@Cerifi.com

This section of our Privacy Notice applies to consumers who reside in California. We adopt this section to comply with the California Consumer Privacy Act (“CCPA”) and California Privacy Reform Act (“CPRA”). If you are a California resident, you may be able to exercise the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law. 

You have the right to request that we disclose to you the categories and specific pieces of Personal Information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:

• The categories of Personal Information we have collected about you;

• The categories of sources from which the Personal Information is collected;

• Our business or commercial purpose for collecting or selling Personal Information;

• The categories of third parties with whom we share Personal Information;

• The specific pieces of Personal Information we have collected about you;

• The categories of Personal Information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of Personal Information for each third party to which we disclosed the Personal Information; and

• The categories of Personal Information about you that we disclosed for a business purpose.

You have the right to request that we delete Personal Information about you that we have collected from you. There may be certain exceptions to our obligation to delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information.

You have the right to opt out of the sale of your Personal Information. To do so, please email privacy@Cerifi.com.

We may not discriminate against you because you have exercised any of the aforementioned rights, including by:

• Denying you goods or services;

• Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

• Providing you a different level or quality of goods or services; or

• Suggesting that you will receive different price or rate for goods or service or at a different level or quality of goods or services.

However, as permitted by the CCPA, we may offer you certain financial incentives by signing up for our newsletter or completing one of our surveys. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

On our Sites and through our Services, we collect certain types of Personal Information about you during your relationship with us, as stated above. In particular, we collected the following categories of Personal Information from California consumers within the last twelve (12) months:

You or your authorized agent may make a request to access, correct, delete or opt-out of the disclosure of your Personal Information for business purposes. You may also make a verifiable consumer request on behalf of your minor child if you believe we have received their information inadvertently. You may request to exercise the aforementioned rights by:

• Submitting a request to privacy@Cerifi.com

Please note that we may take steps to verify your identity and residency before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. If you use an authorized agent, we may require proof of written authorization you have given to make the request. We may limit our response to your exercise of the above rights as permitted by law. We will confirm receipt of the request within 10 business days describing our verification process. We will respond to your request within 45 days or let you know if we need additional time.

California Civil Code § 1798.83 further permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at privacy@Cerifi.com.

Our Sites and Services are not directed at children under 18 years of age, and we do not knowingly collect or receive Personal Information from them. If we learn that we have received Personal Information from a child who is under 18, we will delete this information. If you believe that we have received Personal Information from a child under the age of 18, you may contact us at privacy@Cerifi.com to request deletion of that information.

We may change this Privacy Notice at any time. We will post all changes to this Privacy Notice on this page and will indicate at the top of the page the modified notice's effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy notice. If required by the applicable law, we will notify you of the changes. By continuing to use the Sites and/or the Services or providing us with information following such a replacement Notice being uploaded, you agree that you will be deemed to have agreed to be bound by the Privacy Notice as changed.

If you have any questions or suggestions regarding this Privacy Notice, please contact us at:

CeriFi
3625 Brookside Pkwy., Suite 450
Alpharetta, GA, 30022
Email: privacy@Cerifi.com