CE BROKER PRIVACY POLICY

Effective as of October 2023

Last updated February 2025

Introduction

CE Broker, Inc., d/b/a Propelus (“CE Broker,” “we,” “our,” or “us”) respects the privacy of your information. This Privacy Policy is designed to assist you in understanding how we collect, use, share, and safeguard your information. This Privacy Policy applies to individuals who access this website and our mobile applications (collectively, “Site”) and any of our online and, where required, offline services (collectively, “Services”).

From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. Please review this Privacy Policy periodically.

This Privacy Policy covers the following topics:

Personal Data We Collect
How We Use Your Personal Data
How We Share Your Personal Data
Cookies and Other Tracking Technologies
Universal Opt-Out Mechanisms
Security
Third Party Links
Children’s Privacy
Your State Privacy Rights and Additional Disclosures
Notice to California Residents
Accessibility
How to Contact Us

1. Personal Data We Collect

We collect personal data from you through your use of the Site and Services. Personal data is information that is linked or reasonably linkable to an identified or identifiable individual. We collect the following types of personal data:

Personal Data You Provide

Depending on how you interact with our Site and Services, we will collect the following personal data that you voluntarily provide to us for the following purposes:

Sign Up for Account. To sign up for the basic, professional, or concierge program you will create an account with a username and password. You will provide us with the state or country where you are licensed/certified and your license/certification number, email address, mailing address and telephone number.
Purchase an Account. To purchase a professional or concierge account, you will provide us with your name and credit/debit card information. We use Stripe to process payments. Please review Stripe’s privacy policy here.
Sign In. To sign in to your account, you will provide us with your username or email address and password. If you request to recover access to your account, you will provide us with one or more of the following: your email address, the state where you are licensed/certified, and/or your license/certification number.
Activate Your Free Trial. To activate your free CE Broker trial, you will provide us with the state or country where you are licensed/certified and your license/certification number and credit or debit card number.
Registering as an Educational Provider. To register as an educational provider, you must set up a board profile. To set up a board profile, you will provide us with your company name, your company phone number and fax number, physical address, and your company website, course registration website, and course registration phone number.
Add New Users to an Educational Provider Account. To add new users to an educational provider account, you will provide us with the email address and name of the new user. The new user will receive an invitation to create their own username and password which will provide them access to the educational provider account.
Add Your Licenses Online. To add your licenses to your CE Broker account, you will provide us with the state where you are licensed/certified and your license/certification number for verification. If you have a professional or concierge account, you may upload copies of your licenses/certifications to your account.
Report Continuing Education Course Completions. To report completion of continuing education courses, whether purchased through the Site or otherwise, you will provide us with your name, license number, course completion date, number of hours completed, and in some cases you may need to upload a certificate of completion.
Request a To request a demo, you will provide us with your name, company name, job title, number of licensed employees at the company/organization, phone number, and email address.
Apply to Become a CE Partner. To apply to become a CE partner, you will provide us with your name, company name, phone number, and email address.
Subscribe to Our Blog. To subscribe to our blog, you will provide us with your email address.
Contact Sales. If you submit our online Sales Team contact form, you will provide us with your name, organization, email address, phone number, and any additional information you choose to provide in your submission.
Get Notified of Available Services. If you sign up to be notified when Services become available to you, you will provide us with your email address and profession.
We may use your contact information to market our Services to you. To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails. You also may submit a request to us at support@cebroker.com.
Online Chat. To send an online chat to our support team, you may provide us with a message, your name, email address, and license number. Our chat feature is provided by Zendesk. Zendesk may collect, record, and store the information you provide in the chat. Please review Zendesk’s privacy policy here.
If you submit a request for support, you will provide us with your name, email address, and license/certificate number or educational provider number, company, and any information you choose to provide in your description of the request.
Careers and Talent Community. If you apply for a job with us or sign up to join our talent community, you will provide us with your name, email address, resume, and any information you choose to provide in your submission. Our career portal is provided by Ashby. Please review Ashby’s privacy policy here.

To review or request changes to any of your personal data, please contact us at support@cebroker.com.

Personal Data as You Navigate Our Site

We automatically collect certain personal data through your use of the Site and our use of cookies and other tracking technologies, such as the following:

Usage Information. For example, the pages on the Site you access, the frequency of access, and what you click on while on the Site.
Device Information. For example, hardware model, operating system, application version number, and browser.
Mobile Device Information. Aggregated information about whether the Site is accessed via a mobile device or tablet, the device type, and the carrier.
Location Information. Location information from Site visitors on a city-regional basis.

For more information on our cookie usage see our “Cookies and Other Tracking Technologies” section below.

Personal Data We Collect About You from Other Sources

In some cases, we may receive personal data about you from other sources. This includes continuing education course providers and licensing or governmental organizations or associations, advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, employers, and third parties from whom you make purchases or engage with through the Site and Services.

2. How We Use Your Personal Data

In addition to the purposes stated above, we may use the personal data we collect in accordance with applicable law such as to:

Communicate with you about our Site or Services or to inform you of any changes to our Site or Services;
Maintain and improve our Site and Services;
Protect the security and integrity of our Site and Services;
Investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our Terms of Use, and to otherwise fulfill our legal obligations;
Monitor compliance with and enforce this Privacy Policy and any applicable agreements and policies;
Defend our legal rights and the rights of others;
Fulfill any other purposes for which you provide it;
For any purpose that is reasonably necessary to or compatible with the original purpose for which we collected the personal data as disclosed to you; and
Comply with applicable law.

3. How We Share Your Personal Data

We may share the personal data that we collect about you in the following ways:

With vendors who perform data or Site-related services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.);
With vendors to prepare, deploy and analyze advertising content;
With applicable continuing education course providers and licensure and professional regulatory boards and associations for whom CE Broker facilitates the reporting and management of continuing education course credits through the Services;
To the extent that we are required to do so by law;
In connection with any legal proceedings or prospective legal proceedings;
To establish, exercise, or defend our or a third party’s legal rights, including providing information to others for the purposes of fraud prevention;
With any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal data;
With any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition, bankruptcy, liquidation, or similar proceeding, or in preparation for any of these events;
With any other person or entity where you consent to the disclosure; and
For any other purpose disclosed by us when you provide the personal data or for any other purpose we deem necessary, including to protect the health or safety of others.

4. Cookies and Other Tracking Technologies

How We Use Cookies

Like many other companies, we use cookies and other tracking technologies (collectively, “Cookies”). Cookies are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).

We use Cookies to:

Estimate audience size and usage patterns;
Understand and save your preferences for future visits, allowing us to customize the Site and Services to your individual needs;
Advertise new content and services that relate to your interests;
Keep track of advertisements and search engine results;
Compile aggregate data about site traffic and site interactions to resolve issues and offer better site experiences and tools in the future; and
Recognize when you return to the Site.

We set some Cookies ourselves, while separate entities set other Cookies. We use Cookies other entities set to provide us with useful information to help us improve our Site and Services, to conduct advertising, and to analyze the effectiveness of advertising. For example, we use Cookies from Google and other similar companies.

How You Can Opt Out of Cookies

Browser Settings

You can block Cookies by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Site.

You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org or www.allaboutcookies.org.

Platform Controls

You can opt out of Cookies set by specific entities by following the instructions found at these links:

Google: https://adssettings.google.com
LinkedIn: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
Microsoft: https://account.microsoft.com/privacy/ad-settings/
Yahoo: https://policies.yahoo.com/xa/en/yahoo/privacy/topics/opt-outfaq/

Advertising Industry Resources

You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.

Please note that these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies to help us analyze how users interact with the Site and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. 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.

Google reCAPTCHA

We use Google reCAPTCHA, a free service provided by Google, Inc., to protect our Site from spam and abuse. Google reCAPTCHA uses advanced risk analysis techniques to decipher humans and bots. Google reCAPTCHA works differently depending on what version is deployed. For example, you may be asked to check a box indicating that you are not a robot or Google reCAPTCHA may detect abusive traffic without user interaction. Google reCAPTCHA works by transmitting certain types of information to Google, such as the referrer URL, IP address, visitor behavior, operating system information, browser and length of the visit, cookies, and mouse movements. Your use of Google reCAPTCHA is subject to Google’s Privacy Policy and Terms of Service. More information as to Google reCAPTCHA and how it works is available here.

Microsoft Clarity

We use Microsoft Clarity to understand how users interact with our Site. Microsoft may collect personal information from individuals visiting our Site. Microsoft’s privacy policy is available here.

5. Universal Opt-Out Mechanisms

The Site recognizes the Global Privacy Control (“GPC”) signal. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

6. Security

We maintain commercially reasonable security measures to protect the personal data we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security.

7. Third Party Links

The Site may contain links that will let you leave the Site and access another website. Linked websites are not under our control. We accept no responsibility or liability for these other websites.

8. Children’s Privacy

The Site and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal data from children under 13.

9. Your State Privacy Rights and Additional Disclosures

Depending on the state in which you reside, you may have certain privacy rights regarding your personal data. If you are a California resident, please see our “Notice to California Residents” section below. For other state residents, your privacy rights may include (if applicable):

The right to confirm whether or not we are processing your personal data and to access such personal data and the categories of personal data we are processing or have processed;
The right to obtain a copy of your personal data that we collected from and/or about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
The right, at our option, to obtain a list of specific third parties, other than natural persons, to which we have disclosed your personal data or any personal data;
The right to obtain a list of categories of third parties to which we have disclosed your personal data;
The right to delete personal data that we collected from and/or about you, subject to certain exceptions;
The right to correct inaccurate personal data that we maintain about you, subject to certain exceptions;
The right, if applicable, to opt out of the processing of your personal data for purposes of (1) targeted advertising; (2) the “sale” of your personal data (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
If we are required by applicable law to obtain your consent to process sensitive personal data, the right to withdraw your consent; and
The right not to receive discriminatory treatment by us for the exercise of your privacy rights.

We use Cookies to display advertisements about our products to you on nonaffiliated websites, applications, and online services. This is “targeted advertising” under applicable privacy laws. When we engage in those activities, we sell personal data (i.e., information from cookies) to third-party advertisers and analytics companies. We do not use personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning individuals.

To exercise your rights, please submit a request at support@cebroker.com. If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request. To do so, we will ask you to verify data points based on information we have in our records. If you are submitting a request on behalf of another individual, please use the same contact method described above. If we refuse to take action regarding your request, you may appeal our decision by replying to the email you received from us in response to your request. If you would like to opt out of targeted advertising, you may alter your cookie preferences via the popup window visible once you access the Site.

10. Notice to California Residents

The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (CCPA), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this Section does not apply to you and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”

Notice at Collection of Personal Information

We currently collect and, in the 12 months prior to the Last Updated Date of this Privacy Policy, have collected the following categories of Personal Information:

Identifiers (name, alias, postal address, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, other similar identifiers (professional license/certification number))
Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)
Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) (telephone number, education, employment, credit card number, debit card number, as well as the categories listed in “Identifiers” category above)
Commercial information (records of products or services purchased, obtained or considered; other purchasing or consuming histories or tendencies)
Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement)
Geolocation data
Audio, electronic, or similar information
Professional or employment-related information (including employment history)
Education information
Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
Sensitive Personal Information (Personal Information that reveals a consumer’s Social Security or driver’s license number; account log-in, and password)

We collect Personal Information directly from California residents and from continuing education course providers and licensing or regulating boards, associations and other bodies, advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, employers, and third parties from whom you make purchases or engage with through the Site and Services. We do not collect all categories of Personal Information from each source.

In addition to the purposes stated above in the section “How We Use Your Personal Data” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
Debugging to identify and repair errors that impair existing intended functionality
Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us, provided that your Personal Information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytic services, or providing similar services
Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the Personal Information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with Personal Information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you
Undertaking internal research for technological development and demonstration.
Undertaking activities to verify or maintain the quality or safety of a service that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service that is owned, manufactured, manufactured for, or controlled by us
Advancing our commercial or economic interests, such as by inducing another person to buy or subscribe to services, or enabling or effecting, directly or indirectly, a commercial transaction

Sale, Sharing, and Disclosure of Personal Information

The following table identifies the categories of Personal Information that we sold or shared to third parties in the 12 months preceding the Last Updated Date of this Privacy Policy and, for each category, the categories of third parties to whom we sold or shared Personal Information:

Categories of Personal Information	Categories of Third Parties
Identifiers (email address, name, postal address, IP address) Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; telephone number) Geolocation data	Data analytics providers; advertising networks; application monitoring providers; support services
Internet or other electronic network activity information (information regarding consumer’s interaction with website, application or advertisement)	Data analytics providers; advertising networks

We sold or shared Personal Information to third parties to advance our commercial and economic interests.

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Last Updated Date of this Privacy Policy and, for each category, the categories of recipients to whom we disclosed Personal Information:

Categories of Personal Information	Categories of Recipients
Identifiers (name, alias, postal address, online identifier, Internet Protocol address, email address) Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; telephone number) Commercial information (records of products or services purchased, obtained or considered Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement) Geolocation data	Data storage providers; marketing vendors; customer relationship management software providers
Professional license/certification number	Government entities; licensing authorities; professional regulatory boards and associations; continuing education course providers; data storage providers; support services
Credit/debit card number	Payment processors
Audio, electronic, or similar information Professional or employment-related information (including employment history) Education information Account log-in and password	Data storage providers; support services

We do not knowingly collect, sell, or share the Personal Information of consumers under 16 years of age. We do not use Sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations.

Retention of Personal Information

We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.

Your Rights

If you are a California resident, you have the following rights with respect to your Personal Information:

The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
The right to delete Personal Information that we collected from you, subject to certain exceptions;
The right to correct inaccurate Personal Information that we maintain about you;
If we sell or share Personal Information, the right to opt out of the sale or sharing;
If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.

How to Submit a Request to Know, Delete, and/or Correct

You may submit a request to know, delete, and/or correct by calling us toll free at 1-877-434-6323, by emailing support@cebroker.com, or mailing a written request to CE Broker at 525 N 3rd St. Unit 105, Jacksonville Beach, Florida 32250.

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.

Our Process for Verifying a Request to Know, Delete, and/or Correct

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.

We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.

Right to Opt Out of Sale or Sharing of Personal Information

If you are a California resident, you have the right to direct us to stop selling or sharing your Personal Information.

You may submit a request to opt out of sales or sharing by calling us toll free at 1-877-434-6323, emailing support@cebroker.com, or mailing a written request to CE Broker at 525 N 3rd St. Unit 105, Jacksonville Beach, Florida 32250. Please see the “Universal Opt-Out Mechanisms” section above for more information.

Notice of Financial Incentive

From time to time, you may have the opportunity to provide Personal Information in exchange for discounts and price differences. For example, we may provide discounts and price differences in exchange for you subscribing to our mailing list. Categories of Personal Information that we may collect when you subscribe to receive discounts and price differences include your email address.

How to Opt In and Right to Withdraw

Signing up for discounts and price differences is optional. By providing your email address during the discount sign-up process, you affirmatively opt in to receiving the financial incentive and to joining our mailing list. You have the right to withdraw from the financial incentive at any time. If you opt out of receiving a financial incentive, we will not reduce the value of any financial incentives you previously received from us. If you wish to withdraw from receiving the financial incentive, you may submit such a request at any time by clicking the unsubscribe link at the footer of each e-mail, or emailing us at support@cebroker.com.

How the Financial Incentive is Reasonably Related to the Value of Your Personal Information

The financial incentive or price difference is reasonably related to the value provided by your Personal Information. We take into consideration, without limitation, the anticipated revenue generated from such information, the anticipated expenses which we might incur in the collection, storage, and use of such information, and the anticipated expenses which we might incur related to the offer, provision, and imposition of any financial incentive or price difference. Based on this analysis, the value of your Personal Information that allows us to make these offers and financial incentives is the value of the offer itself.

Shine the Light Law

We do not disclose personal information obtained through our Site or Services to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.

11. Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

12. How to Contact Us

To contact us for questions or concerns about our privacy policies or practices please email us at support@cebroker.com or write us at

CE Broker, Inc. d/b/a Propelus

Attn: General Counsel

525 N 3rd St. Unit 105

Jacksonville Beach, FL 32250