PRIVACY POLICY

Updated: August 11, 2025

1. Introduction

This Privacy Policy (“Privacy Policy” or “Policy”) applies to the website (www.cnasimvr.com) and platform operated by Learn Care Together LLC doing business as CNA Simulations (“us,” “our,” “we”), and any other interactions we have with you online, over the phone, or in person (collectively, the “Services”). By using our Services, you accept this Privacy Policy and Terms of Use, which are hereby incorporated. If you disagree with this Privacy Policy, please do not use the Services.

Below we describe the personal data we collect, your privacy choices, and other relevant details about how we handle your information.

2. Information Collection – Categories and Sources

We collect the following categories of personal data: 

Identifiers: contact information including your name, email address, and phone number; user name and password; 

Educational and professional information: caregiver type (e.g., if you are a home healthcare provider; status as student or instructor or administrator and title; name of school or organization; courses taken on our platform and grades received; completed hours of coursework taken on our platform; performance data for classes taken on our platform; in-person courses taken in educational institutions in connection with certifications we facilitate and hours completed in such courses; information provided by our referral sources

Financial information: payment information

Electronic and network information: your IP address and other electronic information we collect about your interactions with the platform and courses taken 

We may collect personal data from the following sources: 

  • Visits to and interactions with our website or platform

  • Purchases and use of our Services, including our courses

  • Instructors or educational institutions we partner with

  • Governmental entities or their contractors, in connection with programs such as Caring4Cal

  • Referral agencies or organizations

  • Inquiries or requests for a demo of our Services

  • Questions, requests, or feedback submitted directly to us

  • Attendance at events we sponsor or participate in

  • Sign-ups for our waitlist or interest in future products or services

  • Sign-ups for our email newsletter and alerts

  • Purchase of access codes through bookstores or third-party course materials platforms

For students accessing CNA Simulations via bookstore access codes, CNA Simulations is the primary data controller for personal data provided to or collected through the platform.

3. Third-Party Service Providers

We use third-party service providers to collect, store, or process your personal data. For processing payments, we will use third-party providers such as payment gateways and other payment transaction processors, and will not retain your payment information on our systems. 

4. Use in Academic Settings (Bookstore Access Model)

If you access CNA Simulations using a code purchased from a bookstore or institutional course materials platform, your personal data will be collected and used by CNA Simulations in accordance with this Privacy Policy. If the platform is assigned by your instructor as part of a course, your performance and simulation usage data may be shared with your instructor to support educational outcomes. In such cases, CNA Simulations remains the data controller, unless your institution has separately entered into a direct agreement with us.

5. Instructor Access

When CNA Simulations is used as part of a course, instructors may access your name, course participation, simulation progress, performance metrics, and responses to simulation assessments. This information is used solely for instructional purposes and is not disclosed outside the course environment.

6. Cookies and Other Tracking Technologies

We collect information about your visit to our website and platform using cookies and similar technologies. A “cookie” is a small data file sent from a website to your device’s browser. Cookies help us personalize your online experience, recall your preferences for future visits, analyze how you use our site, and improve our services.

We may use, now or in the future, the following categories of cookies on our website (including, but not limited to, the examples below):

Strictly Necessary Cookies – These are essential for the operation of our site. They allow you to move around the site, log in, use secure areas, and access core features.

(a) Performance Cookies. These collect information about how you use our website, such as which pages you visit and how you arrived here. They help us understand and improve site performance. We may use analytics tools—currently including, but not limited to, Google Analytics and Microsoft Clarity—to better understand user behavior and optimize our Services.

(b) Functionality Cookies – These remember your preferences and choices on our site (for example, your preferred language or region). They may also be used to provide enhanced features and tailor your visit.

(c) Marketing Cookies. We may set marketing cookies, now or in the future, either directly or through third-party partners. These cookies may assist with our marketing efforts, provide more relevant advertising, track engagement with ads, facilitate ad delivery, or promote third-party products and services that may interest you. We and our partners may also use marketing and engagement tracking tools—currently including, but not limited to, ActiveCampaign and Meta/Facebook Pixel—to understand how users interact with our emails and website, measure campaign effectiveness, and deliver more relevant content or advertisements

If you do not wish to have cookies on your browser or device, you may manage or decline marketing cookies at any time through our cookie settings tool, or opt out of certain advertising cookies via industry association opt-outs. Visit  www.networkadvertising.org/managing/opt_out.asp to learn more. Declining these cookies will not affect essential site functionality.

7. Analytics and Tracking Tools

We may use, now or in the future, third-party analytics and tracking tools to better understand how users interact with our website and platform, improve our services, and support marketing efforts. These tools can help us measure site usage, identify trends, and enhance your experience.

(a) Google Analytics – We may use Google Analytics to understand how users interact with our website and improve our services. Google Analytics can collect information such as pages visited, time spent on pages, and how you arrived at our site. Google Analytics does not collect personal information unless you provide it to us. For more details on how Google collects and uses your data, please review Google’s Privacy Policy.

(b) Microsoft Tools. We also partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our Services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the frequency with which Services are accessed and other online activities. Additionally, we use this information for website optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

We may add or remove analytics and tracking tools over time, and will update this Privacy Policy to reflect any material changes in how we collect or use analytics data. If you wish to limit analytics tracking, you can manage or decline optional cookies through our cookie settings tool or adjust your browser’s privacy settings.

8. How We Use Your Personal Data

We collect and use your personal data based on your consent, the performance of a contract with you, our legitimate interests in providing and improving the CNA Simulations Services, and any other lawful basis available under applicable privacy laws.

We collect and use your data for purposes including, but not limited to:

  • to provide you with our Services;

  • to process your payments for goods or services;

  • to communicate with you;

  • to provide assistance in obtaining financial incentives in connection with our Services;  

  • to respond to your queries or requests;

  • for marketing and advertising, in accordance with your preferences as managed through our cookie settings tool;

  • to conduct surveys and market research;

  • to manage our business operations and to improve our Services;

  • to investigate any wrongdoing or abuse in relation to our Services or relating to our rights or property; 

  • for legal purposes, including obtaining legal advice, managing disputes and risks, complying with any laws; and

  • any other purposes permitted by law that are consistent with this Privacy Policy.

By registering for CNA Simulations, you consent to our collection and use of personal data, including performance data and simulation activity logs. Where CNA Simulations is assigned as part of a course, we may share performance-related data with the course instructor.

9. SMS Communications & Privacy

9.1. SMS Messaging & User Consent

By providing your phone number, you consent to receive SMS/MMS messages from CNA Simulations related to our services, including updates, reminders, and relevant communications.

9.2. How We Use Your Information

Your phone number will be used solely to communicate important information about our services. We handle your information responsibly and do not share or sell mobile phone numbers to third parties for marketing purposes.

9.3. Opting Out

You may opt out of receiving SMS messages at any time by replying “STOP” to any message or contacting us at [insert contact method]. Standard message and data rates may apply.

9.4. Compliance

We comply with all applicable laws and regulations, including the Telephone Consumer Protection Act (TCPA).

9.5 SMS Terms & Conditions

Upon messaging opt-in, the end user agrees to receive messages from CNA Simulations regarding communications and marketing. End users can opt-out by replying STOP or request more information by replying HELP. Message frequency varies. Message and data rates may apply. If you need assistance or have questions about our SMS service, reply with "HELP" to any SMS message you receive, or contact our customer support team at  (240) 213-3050.

10. Data Sharing

We share personal data with educational institutions and instructors in those institutions; governmental entities and contractors that participate in grant programs such as Caring4Cal; third parties you designate, and organizations or entities we believe may be of professional interest to you. If you are enrolled in a course that uses CNA Simulations, your instructor will  have access to view your simulation performance, participation, and progress data

We may also disclose your personal data as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our or others’ rights, property, or safety, including to law enforcement agencies, and judicial and regulatory authorities. Additionally, we may disclose your personal data to third parties to help detect and protect against fraud or data security vulnerabilities.  We may transfer or disclose your personal data to a third party in the event of an actual or proposed sale, merger, reorganization of our entity, or other restructuring. 

11. Third-Party Access Platforms

If you access CNA Simulations through a third-party bookstore or course materials platform (such as RedShelf, VitalSource, or a similar service), we may exchange limited information with that platform to facilitate access and user authentication. However, CNA Simulations is not responsible for the privacy practices or data handling of such third-party platforms. We encourage you to review their privacy policies directly.

If your institution integrates CNA Simulations with a learning management system (LMS), such as Canvas, Moodle, or a similar platform, we may share limited personal data with the LMS to support account syncing, authentication, grade reporting, or other instructional functions. This may also apply to future integrations that facilitate delivery or tracking of course activities.

12. Third-Party Websites

Our Services provide links to websites and online resources. These links are provided for your convenience, but this Privacy Policy does not govern these websites and resources. You should carefully review the privacy policy and terms of use for any website you access through a link from our website.

Unless specifically stated, we do not intend to imply any approval, association, sponsorship, endorsement, or affiliation with any linked website. We are not responsible for examining or evaluating, and we do not warrant the offerings of, any businesses or individuals or the content of their websites. We do not assume any responsibility or liability for any other third parties' actions, products, services and content.

13. International Transfers

CNA Simulations is based in the United States.  If you are an international user, the information you submit to us and that we automatically collect due to your website use may be transferred to the United States, where the privacy and data protection rules may differ from those in your country.

14. Information Security

To protect your personal data, we put in place reasonable security measures appropriate to the nature of the Personal Information that we collect, use, or retain.  However, we cannot fully guarantee the security of personal data from cyber-attacks, such as hacking, spyware, and viruses.  You also have a shared responsibility for information security, and you should make sure to use unique and strong passwords, not share passwords with your user accounts. Alert us if you have any concerns about the security of your account.

15. Your Privacy Rights

The Family Educational Rights and Privacy Act (FERPA) is a federal law that affords parents, or students over the age of 18, the right to have access to certain education records, the right to seek to have the records amended, and the right to have some control over the disclosure of personally identifiable information from the education records.  To exercise your rights in this regard, contact your educational institution.  

California’s “Shine the Light” law permits California residents to request, once a year, free of charge, information about certain categories of personal data we disclosed to third parties in the preceding calendar year for those third parties’ direct marketing purposes.  

To exercise your rights, you can contact us at hello@cnasimvr.com.

16. Children’s Information

CNA Simulations is not intended for use by individuals under the age of 14. If you are under 14, you may not use the CNA Simulations Services or register for an account. We do not knowingly collect personal information from individuals under 14 years of age.

17. Accessibility 

If you need accessibility assistance, please contact us at hello@cnasimvr.com.

18. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify you about material changes to this Policy by placing a notice on our website. We encourage you to periodically check back and review this Policy so that you are aware of our current privacy practices.

19. Contact Us

If you have any questions about this Policy, please contact us at hello@cnasimvr.com.