EmbLLM Privacy Policy

EmbLLM, LLC (“EmbLLM,” “we,” “us,” or “our”) is committed to protecting your privacy. It is important for you to know how we collect, use, and disclose the information you provide when you interact with our services. This privacy notice for EmbLLM describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you: visit our website at http://www.embllm.com, or any website of ours that links to this privacy notice; download and use our mobile application (EmbLLM), or any other application of ours that links to this privacy notice; or engage with us in other related ways, including any sales, marketing, or events. Please read this Privacy Policy in full to understand what information we collect and how that information will be used and disclosed in connection with providing you with EmbLLM Services.

Information We Collect, and How We Use It.

Information you provide to create a profile and pay for Services. That is, your Name, National Provider Identifier (NPI) Number, Email, Date of Birth, Specialty, and Degree. If you purchase Services, to process your payment transaction, Stripe, Inc., the financial services company we partner with, will collect your payment information on its platform. This is all the personal and professional information that is needed to interact with the EmbLLM application. We use this information to verify your identity and your eligibility to receive services. We also use certain items of this information, such as your email and answers to password verification questions to validate your identity if you need to recover your account password.
Information we collect automatically. EmbLLM automatically collects the Internet Protocol (IP) address of the devices used to access our Services. An IP address is a number that is assigned to your device when you access the Internet. We use this information to understand how our site is being used and how we can better serve visitors. We also collect information about visitors to our site using "cookies" and similar technology such as Web beacons, Web bugs, pixel tags, and so on. We use this technology to recognize a repeat visitor and offer the visitor a set of services or information requested in a previous visit. We use session cookies to track a visitor's path through our site during a visit, to help us understand how people use our site.
We use Google Analytics, a web analytics service provided by Google, Inc., on our website. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the website, compile reports on the websites’ activity, and provide other services related to Websites activity and use. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. EmbLLM does not use Google Analytics to gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google click here.
Your browser or device may include “Do Not Track” functionality. At this time, we do not respond to browser “Do Not Track” signals.

How We May Share the Information You Provide.

a. We may share your personally identifiable information with a third party if we believe that disclosure is necessary to conform to legal requirements or to respond to a subpoena, search warrant or other legal process received by us; to enforce the Terms of Use or to protect our legal rights; or to protect the safety of members of the public.

We may share the information you provide to us and that we collect about you to those with whom we have engaged in a joint partnership agreement or accreditation or licensure for purposes of providing services.
We may share your personal information with third parties who we have engaged in helping us provide the services. In each case, we will ensure that these third parties have agreed to safeguard your data.

Protecting Children's Privacy. We are committed to protecting children’s privacy on the Internet. This site is intended for adults age eighteen (18) or older. We do not knowingly collect personal information from children.
Data Retention. We will retain your information for as long as your account is active or as needed to provide youwith services, comply with our legal obligations, resolve disputes, and enforce our agreements.
Data Processed and Stored in United States. You understand and agree that the information provided by you is transmitted to, processed in, and stored in the United States.
Users in the United States. Some states have enacted their own privacy laws, granting residents specific rights in regard to the accessing of their personal information.

What categories of personal information do we collect? We have collected the following categories of personal information in the past twelve (12) months:

Category

Examples

Collected

A. Identifiers

Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.

YES

B. Personal Information as defines in the California Customers Records Statute

Name, contact information, education, employment, employment history, and financial information.

YES

C. Protected Classification Characteristics Under State and Federal Law

Gender and date of birth.

YES

D. Commercial Information

Transaction information, purchase history, financial details, and payment information.

E. Biometric Information

Fingerprints and voiceprints.

F. Internet or Other Similar Network Activity

Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.

G. Geolocation Data

Device location.

H. Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information

Images and audio, video or call recordings created in connection with our business activities.

I. Professional or Employment-Related Information

Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us.

YES

J. Education Information

Student records and directory information.

YES

K. Interferences Drawn from Collected Personal Information

Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

L. Sensitive Personal Information

Account login information, debit or credit card numbers and racial or ethnic origin.

YES

We will use and retain the collected personal information as needed to provide the Services or for:

· Category A - As long as the user has an account with us

· Category B - As long as the user has an account with us

· Category C - As long as the user has an account with us

· Category I - As long as the user has an account with us

· Category J - As long as the user has an account with us

· Category L - As long as the user has an account with us

Category L information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You have the right to limit the use or disclosure of your sensitive personal information.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

· Receiving help through our customer support channels;

· Participation in customer surveys or contests; and

· Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information? We use and share your personal information in accordance with Section 1 and Section 2 above.

Will your information be shared with anyone else? We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your California Privacy Rights. California Civil Code Section 1798.83, also known as the "Shine The Light" law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

California Consumer Privacy Act (“CCPA”) Privacy Notice. This section applies only to California residents.

The California Code of Regulations defines a "resident" as: (1) every individual who is in the State of California for other than a temporary or transitory purpose and (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose. All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information. Under the CCPA, if you are a California resident, you have the rights listed below:

1. Right to request deletion of the data — Request to delete. You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

2. Right to be informed — Request to know. Depending on the circumstances, you have a right to know:

a. whether we collect and use your personal information;

b. the categories of personal information that we collect;

c. the purposes for which the collected personal information is used;

d. whether we sell or share personal information to third parties;

e. the categories of personal information that we sold, shared, or disclosed for a business purpose;

f. the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;

g. the business or commercial purpose for collecting, selling, or sharing personal information; and

h. the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

3. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights. We will not discriminate against you if you exercise your privacy rights.

4. Right to Limit Use and Disclosure of Sensitive Personal Information. If the business collects any of the following:

a. social security information, drivers' licenses, state ID cards, passport numbers;

b. account login information;

c. credit card numbers, financial account information, or credentials allowing access to such accounts;

d. precise geolocation;

e. racial or ethnic origin, religious or philosophical beliefs, union membership;

f. the contents of email and text, unless the business is the intended recipient of the communication;

g. genetic data, biometric data, and health data; and

h. data concerning sexual orientation and sex life.

You have the right to direct that business to limit its use of your sensitive personal information to that use which is necessary to perform the Services. Once a business receives your request, they are no longer allowed to use or disclose your sensitive personal information for any other purpose unless you provide consent for the use or disclosure of sensitive personal information for additional purposes.

Please note that sensitive personal information that is collected or processed without the purpose of inferring characteristics about a consumer is not covered by this right, as well as the publicly available information.

To exercise your right to limit use and disclosure of sensitive personal information, please email info@embllm.com or submit a data subject access request.

5. Verification process. Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

6. Other privacy rights.

a. You may object to the processing of your personal information;

b. You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information;

c. You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA;

d. You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission; and

e. We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.

To exercise these rights, you can contact us by emailing us using the “Contact” link or by emailing us directly at info@embllm.com. If you have a complaint about how we handle your data, we would like to hear from you.

Your Colorado Privacy Rights. The Colorado Privacy Act (“CPA”) provides Colorado residents with the following rights:

1. Right to be informed whether or not we are processing your personal data;

2. Right to access your personal data;

3. Right to correct inaccuracies in your personal data;

4. Right to request deletion of your personal data;

5. Right to obtain a copy of the personal data you previously shared with us; and

6. Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling").

To submit a request to exercise these rights described above, please email info@embllm.com or submit a data subject access request.

These rights, however, are not absolute, and in certain cases, we may decline your request as permitted by law. If we decline to take action regarding your request and you wish to appeal our decision, please email us at info@embllm.com. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Your Connecticut Privacy Rights. The Connecticut Data Privacy Act (“CTDPA”) provides Connecticut residents with the following rights:

1. Right to be informed whether or not we are processing your personal data;

2. Right to access your personal data;

3. Right to correct inaccuracies in your personal data;

4. Right to request deletion of your personal data;

5. Right to obtain a copy of the personal data you previously shared with us; and

To submit a request to exercise these rights described above, please email info@embllm.com or submit a data subject access request.

These rights, however, are not absolute, and in certain cases, we may decline your request as permitted by law. If we decline to take action regarding your request and you wish to appeal our decision, please email us at info@embllm.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Your Utah Privacy Rights. The Utah Consumer Privacy Act (“UCPA”) provides Utah residents with the following rights:

1. Right to be informed whether or not we are processing your personal data;

2. Right to access your personal data;

3. Right to request deletion of your personal data;

4. Right to obtain a copy of the personal data you previously shared with us; and

5. Right to opt out of the processing of your personal data if it is used for targeted advertising or the sale of personal data.

To submit a request to exercise these rights described above, please email info@embllm.com or submit a data subject access request. These rights, however, are not absolute, and in certain cases, we may decline your request as permitted by law.

Your Virginia Privacy Rights. Under the Virginia Consumer Data Protection Act (“VCDPA”): “Consumer” is defined as a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context. “Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information. “Sale of personal data” means the exchange of personal data for monetary consideration. If this definition of “consumer” applies to you, we must adhere to certain rights and obligations regarding your personal data.

Under the VCDPA, Virginia consumers have the following rights:

1. Right to be informed whether or not we are processing your personal data;

2. Right to access your personal data;

3. Right to correct inaccuracies in your personal data;

4. Right to request deletion of your personal data;

5. Right to obtain a copy of the personal data you previously shared with us; and

6. Right to opt out of the processing of your personal data if it is used for targeted advertising the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling").

Virginia consumers may exercise their rights by contacting us via email at the “Contact” link or directly at info@embllm.com. If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at info@embllm.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

Other State Privacy Laws.

Minnesota Privacy Rights. The Minnesota Consumer Data Privacy Act (“MCDPA”) requires controllers to provide consumers with a reasonably accessible, clear, and meaningful privacy notice. Furthermore, the controller must take all reasonable electronic measures to provide such notification. The MCDPA also indicates that controllers must document and maintain a description of the policies and procedures developed to comply with the requirements of MCDPA. Those documents must (i) include the name and contact information for the individual with responsibility for the policies, and (ii) include a description of policies and procedures developed to implement different aspects of MCDPA including, for example, data minimization principles.

Maryland Privacy Rights. Maryland’s privacy policy law is unique in some contexts, including its protections of children and enacting a hard ban on the selling of sensitive information (e.g. race, religion, sexual orientation, etc.). Data collection must be reasonably necessary and proportionate to deliver a requested product/service regardless of consent.

Rhode Island Privacy Rights. Rhode Island requires controllers to disclose the identity of third parties to which they may sell personal data, in addition to the third parties to which they currently sell personal data.

7. Users in the European Economic Area (EEA) and Switzerland. If you are a resident of the EEA or Switzerland, the following information applies with respect to personal information collected through your use of our site.

a. Purposes of Processing and Legal Basis for Processing. As explained in our section about why we process personal information, we process personal information for a variety of reasons. We process personal information pursuant to the following legal bases: (1) processing is performed with consent, (2) processing is necessary for the purpose of our legitimate interests; more specifically, it is necessary for us to process personal information to provide our services to our users.

b. Transfers. Personal information we collect will be transferred to, and stored and processed in, the United States. We may also transfer to, store in, or process personal information in any other country in which we or our affiliates or processors maintain facilities. If your personal information is transferred from the EEA, Switzerland, or Iceland to the United States, we will utilize [describe safeguard]. If your personal information is transferred from the EEA, Switzerland, or Iceland to a country apart from the United States, we will ensure that the appropriate safeguards are utilized.

c. Privacy Rights. You are entitled to the following rights under Chapter III of the General Data Protection Regulation:

i. The right to access any of your personal information which we have in our possession;

ii. The right to rectification of inaccurate personal information;

iii. The right to erasure of your personal information;

iv. The right to impose restrictions on our processing of your personal information, under certain conditions;

v. The right to object to the processing of your personal information;

vi. The right to data portability;

vii. The right to withdraw consent to the processing of your personal information at any time; and

viii. The right to lodge a complaint with a supervisory authority.

To exercise any of the aforementioned rights, please email info@embllm.com or submit a data subject access request.

8. Complaint Process. If you have a complaint or problem, or if you believe your privacy rights have been violated, you may email us by clicking the “Contact” link or by emailing us https://www.embllm.com/contact directly. Please indicate the reason for contacting us.

Update Process. Changes to our Privacy policy will occasionally update this Privacy policy. You will see the word "updated" followed by the date next to the Privacy policy link near the bottom of all pages on the site. If the "updated" date has changed since you last visited, you're encouraged to review the policy to be informed of how this site is protecting your information.

10. Security. The security of any data you submit is very important to us. We use encryption technology, and we constantly review our security practices to help ensure that your data is maintained securely. However, no system can perfectly guard against risks of intentional intrusion or inadvertent disclosure of information sent to us. Moreover, when you transmit information via the internet, your information will be transmitted over a medium that is beyond our control, and therefore the security of the transmission may be compromised before it reaches us. Accordingly, EmbLLM makes no guarantee as to confidentiality or security.

IN ADDITION, YOU HEREBY EXPRESSLY AND SOLELY ASSUME THE RISK OF ANY UNAUTHORIZED DISCLOSURE OR INTENTIONAL INTRUSION, OR OF ANY DELAY, FAILURE, INTERRUPTION OR CORRUPTION OF DATA OR OTHER INFORMATION TRANSMITTED IN CONNECTION WITH YOUR USE OF THE SERVICES.

You must keep your username and password confidential. Failure to do so may also compromise the confidentiality of your information.

11. No Warranties.

YOU UNDERSTAND AND AGREE THAT EMBLLM SERVICES ARE PROVIDED ON AN "AS IS" BASIS. EMBLLM DOES NOT MAKE ANY EXPRESS OR IMPLIED WARRANTIES, REPRESENTATIONS OR ENDORSEMENTS WHATSOEVER (INCLUDING WITHOUT LIMITATION WARRANTIES OF TITLE OR NONINFRINGEMENT, OR THE IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE) WITH REGARD TO THE SERVICE OR ANY MERCHANDISE, INFORMATION OR SERVICE PROVIDED IN CONNECTION WITH YOUR EMBLLM SERVICES ACCOUNT. IN ADDITION, EMBLLM DOES NOT GUARANTEE THAT USE OF THE SERVICES WILL BE FREE FROM TECHNOLOGICAL DIFFICULTIES INCLUDING, BUT NOT LIMITED TO, UNAVAILABILITY OF INFORMATION, DOWNTIME, SERVICE DISRUPTIONS, VIRUSES OR WORMS AND YOU UNDERSTAND THAT YOU ARE RESPONSIBLE FOR IMPLEMENTING SUFFICIENT PROCEDURES AND CHECKPOINTS TO SATISFY YOUR PARTICULAR REQUIREMENTS FOR ACCURACY OF DATA INPUT AND OUTPUT.

12. Limitation of Liability.

THE USE OF THE SERVICES IS ENTIRELY AT YOUR OWN RISK, AND IN NO EVENT SHALL EMBLLM BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY, PUNITIVE, OR ANY OTHER MONETARY OR OTHER DAMAGES, FEES, FINES, PENALTIES, OR LIABILITIES ARISING OUT OF OR RELATING IN ANY WAY TO EMBLLM SERVICES, OR SITES ACCESSED THROUGH THE EMBLLM SERVICES, AND/OR CONTENT OR INFORMATION PROVIDED HEREIN. YOUR SOLE AND EXCLUSIVE REMEDY FOR DISSATISFACTION WITH THE SERVICE IS TO STOP USING THE SERVICE.

13. User Agreements. You agree:

a. The information you provide in connection with the services is true and accurate and pertains to yourself;

b. You will not use the services for any illegal purpose, or in a manner which violates local, state, national or international laws;

c. You will not use the services to post or transmit material that may infringe or violate any rights of any party or is unlawful, obscene, defamatory, threatening, harassing, abusive, slanderous, hateful or embarrassing to any other person or entity; and

d. You will not use the services to attempt to disable, "hack" or otherwise interfere with the proper functioning of this website.

14. Discontinuance of Service. The Services are being provided by EmbLLM as a courtesy to you, and EmbLLM reserves the right to terminate, modify, discontinue, temporarily or permanently, the Services at any time, with or without notice. In addition, EmbLLM may terminate, modify or limit any or all of the services if you violate the terms of this Agreement or any other agreement with EmbLLM, you violate any law, or if we determine, for any other reason, that it is no longer appropriate for you to use those services.

15. Copyright and Trademark Information. The marks "EmbLLM," "EmbLLM LLC," and the EmbLLM logo are trademarks and/or service marks protected by U.S. and international trademark and copyright laws. You may not copy, reproduce, republish, upload, post, display, transmit, or frame any of these materials without prior written consent from EmbLLM, except that you may view, download, display and print a single copy of these materials on a single computer for personal, noncommercial use only, so long as: (1) you do not alter or modify the materials in any way; (2) you include all applicable notices and disclaimers (including copyright notices); and (3) you do not use the materials in a way that suggests an association with EmbLLM. You understand and agree that title to these materials shall not pass to you or any other user.

16. Dispute Resolution. You agree that any dispute or claim (including personal injury claims) related to your use of services is subject to the exclusive jurisdiction of the Commonwealth of Virginia, in the United States of America, and that any such dispute shall be governed by the laws of the Commonwealth of Virginia and the United States of America as applicable. This agreement also applies to anyone claiming on your behalf.