BUSINESS PRIVACY STATEMENT

Business Privacy Statement

This American Academy of Mental Health Business Privacy Statement was updated on June 22, 2022.

In the course of providing American Academy of Mental Health Business and AcademyU (“AB”) services and related services to its corporate, non-profit organization, and governmental customers (“Customers”), the American Academy of Mental Health will receive and have access to personal data of individual users to whom customers grant access (“Users”). For the purposes of this privacy statement, Customers are data controllers and the American Academy of Mental Health is a data processor. American Academy of Mental Health’s processing of User data and the security measures implemented to protect such data are detailed in and governed by a written agreement between the American Academy of Mental Health and each of its Customers.

As a data processor, the American Academy of Mental Health will access, store and use the personal data of individual Users solely for the purpose of providing the AB services to its Customers and will process the data as instructed by its Customers.

As data controllers, Customers decide which of their employees or other authorized personnel are given access to the AB services. They do this by designating one or more AB account administrators or group administrators (“Administrator”) who act on behalf of the Customer and have the ability to customize the Customer account, manage individual User accounts, access the AB Insights tool and related reporting features, access the AB Administrator tools, and populate the Customer account with Customer-provided content. Customers are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, relating to the collection of personal information relating to individual Users selected by Customers for accessing the AB services. American Academy of Mental Health has no direct relationship with individual Users, who should contact Customers (their employer) for assistance with any requests or questions relating to processing their personal information.

For the avoidance of doubt, this Privacy Statement does not apply to:

any processing of data for the purpose of marketing the AB service to enterprise and corporate prospects;
persons participating in an AcademyU program as an individual (AcademyU Open); and
any other offerings available at American Academy of Mental Health.com separate from the AB services, for which the American Academy of Mental Health Privacy Policy is applicable. A User may already have an account with the American Academy of Mental Health to access the American Academy of Mental Health’s marketplace educational content, and data processed as a result of the use of the American Academy of Mental Health marketplace from a User account is governed by the American Academy of Mental Health Privacy Policy.

In the event where American Academy of Mental Health makes any material changes to the manner in which it processes User data to provide its services to Customers, it will notify Customers.

American Academy of Mental Health Business Privacy Statement

Information about Users collected and stored by the American Academy of Mental Health
Purpose of User Data Processing and Retention Period
Cookies and other Tracking Technologies
Sharing User Information
Processing of User Data outside of the EEA
General

1. Information about Users collected and stored by the American Academy of Mental Health

When a User is given access to the AB services by the Administrator, a User may set up an individual User account and the American Academy of Mental Health will collect information provided by the User or the Administrator. The Customer can customize the type of data requested to create an account, which may include the following:

first name, last name, country, and email address required
photo, areas of interest, job skills, goals, and role (optionally provided by User or Customer)
other personal data, as allowed by the Customer.

The American Academy of Mental Health assigns a unique identifying number upon the creation of a User account.
Individual User account information may be set to private or public, as selected by Users. If set to public, the information is searchable via search engines and viewable by anyone, including by other Users and the Customer.
Administrators may assign a User to group membership.
Customers may select to integrate with AB a Single Sign On (SSO) identity provider to enable Users to log in to AB User accounts without the need to disclose passwords to the American Academy of Mental Health. Users may log in by providing their individual SSO credentials to the SSO identity provider, which will authenticate them and allow or deny access to the Customer account. SSO identity providers share with the American Academy of Mental Health a unique cookie ID and authentication “token” information to recognize the User as an authorized user of Customer.
At the option of the Customer, the AB service may enable Administrators and Users to interact with others, including with instructors, teaching assistants, other students, and the Customer, by posting reviews about educational content, sending messages to or chatting with others, posting questions or answers, or posting other content. Posted content is stored by the American Academy of Mental Health and may be publicly available or viewable by others, including Administrators, Users, or instructors and teaching assistants, depending on where the content is posted.
At the option of the Customer, Administrators may enable the ability to “Share to Slack.” This optional feature allows Users to manually or automatically post a message to the Customer’s own instance of the Slack messaging service. To enable this optional functionality, Customer’s Slack administrators must grant the American Academy of Mental Health the ability to read the full list of public channels, private channels, and users in the Customer’s Slack instance. These lists may include individuals in Customer’s Slack instance who are not AB Users. Slack user lists and channels are briefly cached before being automatically purged from the American Academy of Mental Health’s systems.
American Academy of Mental Health stores information relating to the activities of Users as they use and interact with the AB services, such as content viewed, searched for, or accessed (and information relating to that content); interactions with instructors, teaching assistants, Administrators, and other Users; as well as answers, essays, and other items submitted by Users to satisfy the educational content requirements. This information is linked to a User’s unique account ID and is shared with Customers via the Customer Account reporting tools or upon request of the Customer.
The AB service enables Users to contact the American Academy of Mental Health Support Team for assistance or to report a problem, concern, potential abuse or other issues regarding the AB services or other users. American Academy of Mental Health may collect and store the User’s name, email address, location, operating system, IP address as well as the User’s activity on the American Academy of Mental Health platform and communications with the American Academy of Mental Health help desk team. American Academy of Mental Health may request additional information from Users in order to resolve any issue reported by a User or by another user.
When a User uses the AB services, the American Academy of Mental Health collects and stores certain information by automated means: (a) technical information about the User’s computer or wireless device, such as IP address, operating system type and version, unique device ID, browser, browser language, domain, and other operating systems or platform information. This information is collected through the use of server log files and tracking technologies, such as: (i) cookies, which are small files that websites send to a computer or wireless device to uniquely identify a browser or mobile device or to store information in a browser setting; and (ii) other tracking technologies (see below for more detailed information).
IP addresses received from browsers or devices of Users may be used to determine the approximate location of Users.
If a Customer makes purchases via credit card, the American Academy of Mental Health collects certain data about the purchase (such as name and ZIP code) as necessary to process the order. Customers must provide certain payment and billing data directly to the American Academy of Mental Health’s payment processing partners, including name, credit card information, billing address, and ZIP code. American Academy of Mental Health may also receive limited information, like the fact that Customers have a new card and the last four digits of that card, from payment service providers to facilitate payments. For security, the American Academy of Mental Health does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.

2. Purpose of User Data Processing and Retention Period

American Academy of Mental Health processes the information collected about Users and Administrators for the purpose of providing the AB services to its Customers, specifically:

Providing, administering, and facilitating access to the AB services, for Customers and Users, and managing Customer or User account preferences
Fulfilling Customer’s instructions with respect to personal data of Users
Displaying and sending via email notifications to Users for:

Responding to User questions or concerns
Making notifications to Users at the request of the Customer
Sending Users administrative messages and information, including confirmation of account creation, enrollment and progress in courses and related content, and notifications of responses from instructors to User questions
Providing information to Users about available content, new AB service features, and personalized content recommendations, which Users can opt out of at any time
Sending push notifications to User wireless devices to provide updates and other relevant messages, which can be managed from the “options” or “settings” page in the mobile application.

Enabling communications among Users and instructors or teaching assistants
Incorporating feedback into and improving the AB services
Resolving User support requests or claims

If we are not able to collect and process your personal information, we may be unable to provide some or all of the AB Services to you.

Email Preferences

Users can individually opt out of receiving non-transactional emails by: (i) following the unsubscribe instructions provided in the email communication; or (ii) managing User account email preferences. A Customer can also instruct the American Academy of Mental Health to configure email preference settings for all Users of a Customer.

Retention of Personal Data

American Academy of Mental Health will retain the data of Users for as long as instructed by the Customer and no longer than required to serve the purposes of processing. American Academy of Mental Health will delete certain or all personal data relating to Users upon request of the Customer. The American Academy of Mental Health may retain aggregated or anonymized data as set forth below.

Use of aggregated data

In addition, User data is aggregated with other American Academy of Mental Health marketplace user data to enable the American Academy of Mental Health to improve its products and services and develop new products and services, including:

Reviewing and analyzing User browser and wireless device technical information
Reviewing user activity across AB and the American Academy of Mental Health marketplace (for example, the American Academy of Mental Health analyzes trends and User traffic and usage information to identify popular content)
Facilitating the technical functioning of the AB services and American Academy of Mental Health marketplace, including to troubleshoot and resolve issues, secure the AB services, and prevent fraud and abuse
Developing a personalized content recommendation engine

When User data is used for the above purposes, it is aggregated and/or anonymized so that no personal data of Users is processed.

3. Cookies and other Tracking Technologies

Like many online platforms, the American Academy of Mental Health and its analytics vendors use server log files and automated data collection tools, such as browser cookies, pixel tags, scripts, and web beacons. These tools are used for analytics purposes to enable the American Academy of Mental Health to understand how Users interact with the AB services. American Academy of Mental Health and its analytics vendors may tie the information gathered by these means to the unique account ID of Users.

Cookies are small text files placed onto a computer or device while browsing the Internet. Cookies are used to collect, store, and share bits of information about User activities. The American Academy of Mental Health uses both session cookies and persistent cookies.

A session cookie is used to identify a particular visit to the AB services and collect information about interaction with the AB service. These cookies expire after a short time, or when the User closes their web browser after using the AB service. American Academy of Mental Health uses these cookies to identify a User during a single browsing session, such as when you log into the AB services. This helps the American Academy of Mental Health improve the AB service as well as improve the Users’ browsing experience.
A persistent cookie will remain on a User’s device for a set period of time specified in the cookie. The American Academy of Mental Health uses these cookies to identify and recognize a specific User over a longer period of time. They allow American Academy of Mental Health to:

analyze the usage of the AB services (e.g. what links Users click on) in order to improve our AB offering,
test different versions of the AB services to see which particular features or content Users prefer to optimize the AB services
provide a more personalized experience to Users with more relevant and recommended content and
allow Users to more easily log in to use the AB services. Persistent cookies include:

preferences cookies to remember information about a User’s browser and settings preferences, such as preferred language. Preference cookies make User experience more functional and customized
authentication and security cookies to enable a User to log in or stay logged in and access the AB service, to protect User accounts against fraudulent log-ins by others, and help detect, fight, and protect against abuse or unauthorized usage of User accounts.
functional cookies to make the experience of using the AB service better, like remembering the sound volume level selected by the User.

American Academy of Mental Health uses tracking technology to: (i) determine if a certain page was visited (e.g. the landing page of an advertisement for AB services that is displayed on third party sites) or whether an email sent by American Academy of Mental Health was opened or clicked on by a User; and (ii) to customize the learning experience of individual Users by recommending specific courses and other content.

User Preferences with respect to cookies and other tracking technologies

Users can set their web browser to notify them about the placement of new cookies, limit the type of cookies or reject cookies altogether; if enabled, a User may not be able to use some or all of the features of the AB services (for example, may not be able to log in). General information about cookies and how to disable them can be found at https://cookiepedia.co.uk/all-about-cookies.

Various browsers may offer their own management tools for removing HTML5 LSOs.

Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a website should respond to this signal, and we do not take any action in response to this signal. Instead, in addition to publicly available third-party tools, we offer you the choices described in this policy to manage the collection and use of information about you.

4. Sharing User Information

In order to provide the AB services to its Customers, the American Academy of Mental Health shares data regarding Users with a number of third-party service providers. These third parties are contractually required to use User data solely as directed by the American Academy of Mental Health for the purpose of providing services to the American Academy of Mental Health. Administrators of existing Customers are able to access our list of current sub-processors on the left sidebar of this page while logged in to AB.

Instructors who upload content on the American Academy of Mental Health platform, as well as their teaching assistants, may receive names and account profile information of Users (excluding email addresses), to enable them to respond to user questions and feedback.
Other service providers of Customer may receive information as instructed by Customer.
To perform its services, the American Academy of Mental Health leases servers from data centers and uses cloud hosting services on which certain content and User data relating to AB is hosted.
American Academy of Mental Health’s help center platform vendor hosts and stores all communications between Administrators or Users and the American Academy of Mental Health support team. The help center vendor is contractually required to store and process User related data solely as directed by the American Academy of Mental Health for the purpose of providing services to the American Academy of Mental Health. American Academy of Mental Health also partners with a chat messaging vendor to provide support to Users and Administrators, to collect feedback, and to display in-app messages for feature announcements or onboarding new users.
American Academy of Mental Health shares User information with third-party companies that perform email services to enable the American Academy of Mental Health to send email communications to Users and to manage email preference settings of Users.
American Academy of Mental Health shares User information with third-party companies that perform data analysis services to enable the American Academy of Mental Health to better understand how Users use the AB service. These companies include Chartio, Google Analytics and Mixpanel. To prevent Google Analytics from collecting information for analytics, a User may install the Google Analytics Opt-Out Browser by clicking here, and may also use Mixpanel’s opt-out by clicking here.
For AcademyU users, certain features like chat rooms, message boards, news groups, or other public forums are available and are publicly visible to other participants, so confidential or proprietary information should not be shared through these features.

Any other sharing of User data is subject to the consent and instructions of the Customer.

5. Processing of User Data outside of the EEA

Our servers and sub-processors are located in the United States. In order to provide the Services to you, we transfer and process your data there. If personal data processed by the American Academy of Mental Health originates from a User or Administrator in the EEA, the American Academy of Mental Health will ensure that such processing will only take place if: (a) the non-EEA country in question ensures an adequate level of data protection; (b) the transfer is made pursuant to a Data Processing Agreement (“DPA”) executed between American Academy of Mental Health and the Customer and subject to the standard contractual clauses designed to facilitate transfers of personal data from the EEA to all third countries that have been adopted by the European Commission (known as the, “Model Clauses”), which have been incorporated into the DPA.