HCEsquared Privacy Policy 

Effective Date: 10/06/2026 

1 · Scope and summary 

1.1   Who this covers 

This policy explains what personal information HCEsquared, LLC ("HCE²," "we," "us," or "our") collects about you, how we use it, to whom we disclose it, and the rights and choices available to you. It applies to the websites, applications, events, learning systems, communities, journals, newsletters, and related services covered by the Terms of Use § 1.2 (collectively, the “Platform”), to our events, and to information we receive when you contact us. The Cookie and Tracking Technologies Policy describes cookies and similar technologies. 

1.2   The short version 

HCEsquared is a U.S.-only joint provider of accredited continuing medical education for clinicians. We collect professional information and information about how you use the Platform. We use it to operate and secure the Platform, report continuing education credit, personalize content, build and measure audiences, and deliver sponsored programs and advertising. We may sell, license, and share personal information with sponsors, exhibitors, advertising partners, accreditation bodies, service providers, and other recipients described in § 4. You can opt out of sale, sharing, targeted advertising, and marketing uses at any time. Your accredited continuing education record and private messages are excluded from our commercial data products as described in §§ 4.2 and 4.3. 

1.3   Who is responsible 

HCEsquared, LLC, 201 Tom Hall Street, PO Box 1299, Fort Mill, South Carolina 29715, is responsible for this policy. Contact privacy@hcesquared.com or our privacy officer at the same address. We are a U.S. company. We collect, store, and process information in the United States; see § 7.2. 

2 · What we collect 

Category 

Examples 

Where it comes from 

Identifiers and contact data 

Name, email, phone, work and mailing address, account ID 

You 

Professional identifiers 

Degree, specialty and subspecialty, license number and state, NPI, board certifications, institution, practice setting, years in practice 

You; credentialing and provider reference sources 

Education and credit records 

Registrations, attendance, sessions entered, activities completed, test responses and scores, evaluations, credits claimed and reported 

You; the platform; learning systems 

Engagement data 

Pages viewed, videos watched and watch duration, searches, clicks, saves, downloads, content and exhibitors engaged with, email opens and clicks 

The platform; cookies and similar technologies 

Device and online identifiers 

IP address, device and browser identifiers, cookie and pixel IDs, approximate location from IP address 

Automatically 

Content you submit 

Posts, comments, questions, ratings, free-text evaluation responses, Source Material you submit, and private messages 

You 

Commercial interactions 

Badge scans, exhibitor engagement, responses to commercial messages and research invitations, sample and information requests 

You; event systems 

Payment data 

Billing name and address, transaction records, last four digits 

You, via our payment processor — full card data does not reach us 

Images, recordings, and likeness 

Photographs and video of you at our events, session and presentation recordings, your voice, and any image you upload 

Captured by us at events; you 

Inferences 

Therapeutic-area affinity, professional interests, audience segments, content recommendations 

Derived by us 

Third-party data 

Professional and practice attributes, list and society data, advertising and identity-graph matches 

Data partners, list providers, event and society partners 

 

2.2   Your professional identifiers, including NPI 

Your National Provider Identifier, license numbers, and board certification identifiers are professional identifiers that we use to keep your profile accurate and to support the functions described below. We use them to: 

•   verify you as a licensed professional and keep your profile accurate (Terms of Use § 2.3); 

•   deliver and report continuing education credit to accreditation bodies, boards, and certifying organizations (Terms of Use § 6.5 and Terms of Use Schedule B); 

•   prevent fraud and secure your account; and 

•   build, define, and target audiences, and measure advertising and sponsored programs — including audience data we license to third parties for a fee under Terms of Use § 7.14. This use is subject to your opt-out (§ 5.1), and your accredited continuing education record is excluded from it entirely (§ 4.3). 

What we never do with them: infer anything about your own health. Your NPI tells us you are a clinician and what you practice. It tells us nothing about your health, we do not treat it as if it did, and we do not build any audience on a health inference about you. 

We do not ask for and do not want your own health information, and you may not submit, upload, or transmit patient information through the Service. Terms of Use §§ 4.3 and 5.6 apply. 

2.3   Consumer health data 

Our clinical content, including ungated condition pages, is professional reference material for clinicians. We do not treat your reading of it as information about your own health, do not infer your health status from it, and do not build advertising audiences on that basis. We infer professional interest only. We do not ask for your own health information and will delete it if you send it to us. 

2.4   Images and recordings at our events 

We photograph, film, and audio-record our events, and we record sessions. You may appear in audience and exhibition footage, and we use that material for reporting, archival, educational, and promotional purposes. We post notice at registration and at the entrance to recorded rooms, and you can ask not to be featured — see the Attendee Terms. 

We do not use your image or voice to endorse a commercial product or a sponsor without your separate written consent, and we do not create a synthetic or digitally generated version of your voice or likeness without your specific written consent. Terms of Use § 8.4 governs both. Session recordings of faculty are governed by the speaker's own agreement. 

2.5   No protected health information 

HCEsquared DOES NOT COLLECT OR PROCESS PROTECTED HEALTH INFORMATION. Protected health information (“PHI”) has the meaning given in 45 C.F.R. § 160.103. You may not submit, upload, or transmit PHI through the Service, including in case discussions, images, recordings, or messages. You represent and warrant that, for any information you provide, you have obtained all consents, authorizations, and permissions required by applicable law, including HIPAA and applicable state law, and that any patient information is de-identified in accordance with 45 C.F.R. § 164.514. We may remove content that contains PHI or patient information and delete it. Because we are not subject to HIPAA with respect to the Platform, HIPAA protections do not apply to information you submit. 

2.6   Children 

The Platform is for adults aged eighteen (18) and over. We do not knowingly collect information from children. If we learn that we have collected information from a child, we will delete it. 

3 · What we use it for 

Purpose 

Categories used / U.S. choices 

Creating and running your account; delivering the platform and events 

Account and contact information; professional information 

Verifying your professional credentials 

Professional identifiers and verification information 

Awarding and reporting continuing education credit (Terms of Use § 6.5) 

Professional identifiers; education and credit records; participation data 

Personalizing content and recommendations 

Professional profile; engagement data; device and online identifiers 

Marketing our own programs to you 

Contact data; professional profile; engagement data 

Building and targeting audiences; delivering and measuring advertising and sponsored programs on and off the platform 

Professional profile; engagement and device data; content submitted 

Licensing audience data, including NPI-keyed data, to third parties for a fee (Terms of Use § 7.14) 

Notice and your right to opt out at any time 

Closed-loop measurement of whether education changes practice (Terms of Use § 7.13) 

Education and credit records; participation data 

Reporting to sponsors and supporters 

Education and credit records; participation data 

Product research, analytics, and improving the platform 

Product, engagement, and device data 

Producing derivative educational material and knowledge products (Terms of Use Article 11) 

Content submitted; professional information; education and credit records 

Security, fraud prevention, and enforcing our terms 

Account, device, engagement, and content data 

Complying with law and responding to legal process 

Information relevant to legal and compliance requests 

 

3.2   Automated processing 

We use automated systems to recommend content, to tag and classify content, to assess material you submit to a Creation Tool, and to detect abuse. None of this produces a legal or similarly significant effect on you, none of it decides your access to credit, and you can turn personalization off in your settings. Terms of Use §§ 5.7, 5.8, and 9.4 explain the limits of automated assessment. 

4 · How we disclose personal information 

Recipient 

What they get 

Processors acting for us 

What each needs for its function  

Accreditation and certifying bodies, boards, LMS/LRS 

Credit records and identifiers — Terms of Use Schedule B 

Commercial supporters of accredited activity 

Aggregate, de-identified only, unless you separately consented — Terms of Use § 6.7 

Sponsors, exhibitors, advertisers 

Registration and engagement data for labelled promotional programs, badge scans you allow, and responses to their messages — Terms of Use §§ 10.2, 12.3 

Advertising, analytics, and identity partners 

Online identifiers, hashed contact identifiers, engagement signals — a "sale"/"share", subject to your opt-out 

Licensees of our audience data 

Professional profile including NPI, segments, and non-accredited engagement — a "sale", subject to your opt-out (§ 4.2) 

Third-party data and measurement partners 

Matching keys for closed-loop measurement; outputs return aggregate only — Terms of Use § 7.13 

Event co-hosts, joint providers, societies, journal partners 

Registration and participation data for the joint program 

Knowledge licensees 

Attributed clinical assertions and, subject to Terms of Use § 11.4, images — contributor material, not member browsing data 

Your employer or institution 

Completion confirmation only, unless its agreement and the law permit more — Terms of Use § 2.7 

Professional advisers, acquirers in a corporate transaction 

As needed, under confidentiality 

Law enforcement, regulators, courts 

Where legally required or to protect rights and safety 

 

We disclose personal information to service providers and contractors that perform services for us, including hosting, security, analytics, communications, event operations, payment processing, accreditation and credit reporting, and customer support. We require these recipients to use the information only for contracted purposes and to maintain appropriate security. We may also disclose personal information in connection with a merger, acquisition, financing, reorganization, or sale of assets, or to comply with legal process, enforce our agreements, protect rights and safety, or investigate fraud and security threats. 

4.2   Sale, license, and sharing of personal information 

WE MAY SELL, LICENSE, AND SHARE PERSONAL INFORMATION. YOU MAY OPT OUT AT ANY TIME THROUGH YOUR ACCOUNT SETTINGS OR THE "DO NOT SELL OR SHARE MY PERSONAL INFORMATION" LINK IN THE FOOTER. 

We sell, license, and share personal information with third parties for monetary or other valuable consideration under written data use agreements consistent with Terms of Use §§ 7.5 and 7.14. Those agreements limit each recipient’s use to the purposes stated in the agreement; prohibit onward resale, re-identification, or patient identification; prohibit use for employment, credentialing, insurance, credit, or licensure decisions; require recipients to honor opt-outs that we pass through; and require appropriate security safeguards. In the preceding twelve (12) months, we have sold or shared the categories of personal information below. In the preceding twelve (12) months, we also disclosed the categories of personal information described in § 2 to service providers and contractors for business purposes, including hosting, security, analytics, communications, event operations, payment processing, accreditation and credit reporting, and customer support. 

Category that maybe shared 

To whom 

Identifiers and contact data 

Users, Manufacturers, agencies, advertising and identity platforms 

Professional identifiers, including NPI 

As above 

Engagement data — non-accredited content, sponsored programs, advertising, exhibitors, events, journals 

As above 

Inferences and audience segments 

As above 

Device and online identifiers 

Advertising, analytics, and identity partners 

Material you submit to a Creation Tool 

Users, Manufacturers, agencies, advertising and identity platforms 

 

 

 

Category that MAY NOT shared 

To whom 

Accredited continuing education records 

Not sold or licensed in identifiable form; accreditation reporting only (Terms of Use Schedule B) 

Private message content 

— 

Sensitive personal information 

Used only for the purposes in § 2.2 

 

We do not knowingly collect or share the personal information of anyone under eighteen (18). 

4.3   What we never do 

We do not give commercial supporters identifiable participation data for accredited continuing education without your separate consent, and accredited-education records are excluded from every data product we license. We do not use the content of your private messages for advertising, audience building, or data licensing. We do not license or sell anything you submit to a Creation Tool. We do not use prescriber-identifiable data for sales-representative marketing where you have registered an AMA restriction. We do not receive, hold, or license your individual prescribing or claims records, and no data product we sell reports what any individual clinician prescribed. 

5 · Your rights and choices 

5.1   Choices available to everyone 

•   Unsubscribe from marketing email at any time. 

•   Manage commercial messages and research invitations in your account settings. 

•   Manage cookie and tracking preferences through the preference center linked in the footer of every page. 

•   Opt out of sale, sharing, and targeted advertising at any time through your account settings or the “Do Not Sell or Share My Personal Information” link in the footer. We process opt-out requests within fifteen (15) business days and pass the opt-out to recipients where required. 

•   Turn off personalization in your settings. 

•   Access, correct, delete, or obtain a portable copy of your personal information by using the request form linked in the footer or contacting privacy@hcesquared.com. 

We honor the Global Privacy Control and other recognized opt-out preference signals as a valid opt-out of sale, sharing, and targeted advertising for the browser sending the signal and, if you are signed in, for your account. We display on our site whether the signal has been processed. You may also request that we limit the use of sensitive personal information. We do not retaliate against you or discriminate against you for exercising privacy rights, and opting out does not stop service delivery, CME credit reporting, security, legal compliance, or our use of de-identified and aggregated information. 

5.2   Your California privacy rights 

If you are a California resident, you may request to know: (a) the categories of personal information we collect, use, sell, or share; (b) the categories of sources; (c) the business or commercial purposes for collection, sale, or sharing; (d) the categories of recipients; and (e) the specific pieces of personal information we collected about you. Where applicable, you may request information beyond the preceding twelve (12) months, including back to January 1, 2022. You may also request deletion or correction of your personal information and opt out of the sale or sharing of personal information, including sharing for cross-context behavioral advertising. 

You may request to limit the use and disclosure of sensitive personal information. We do not use sensitive personal information for purposes that would require this right. You may use an authorized agent to submit a request on your behalf. We will not discriminate against you for exercising these rights or change the price or quality of our services because you exercised them. 

5.3   Other state privacy rights 

Residents of other states with comprehensive privacy laws may have rights to access, correct, delete, obtain a portable copy of, or opt out of the sale, sharing, targeted advertising, or qualifying profiling of personal information. We will honor applicable rights and explain any exception required by law. 

5.4   How to make a request 

Use the request form linked in the footer, your account settings, or write to privacy@hcesquared.com. Tell us which right you want to exercise and where you live. We will confirm receipt within ten (10) business days. We verify identity before acting, usually by confirming control of the account email and, for higher-risk requests, by asking for additional proof. We use information provided for verification only and delete it when verification is complete. An authorized agent may act for you with written permission, and we may require proof of that permission. 

We respond within forty-five (45) days. Where necessary, we may extend the response period once by a further forty-five (45) days and will explain the reason for the extension. We process sale and sharing opt-outs within fifteen (15) business days. Access and portability requests may be limited only as permitted by applicable law. 

5.5   Appeals and complaints 

If we refuse a request, you may appeal by replying to our decision or writing to privacy@hcesquared.com with "APPEAL" in the subject. We respond within forty-five (45) days with our decision and reasons. If we refuse the appeal, we will tell you how to complain to your state attorney general. You may also complain to the Federal Trade Commission. 

6 · Retention 

We retain personal information for as long as reasonably necessary for the purposes described in this policy, including to provide the Platform, maintain professional and credit records, complete transactions, support accreditation, comply with legal obligations, resolve disputes, enforce agreements, prevent fraud, and protect security. The periods below reflect the applicable purpose, the nature and sensitivity of the information, operational needs, and legal or accreditation requirements. At the end of the applicable period, we delete the information or de-identify it so it can no longer reasonably identify you, unless a legal hold or another lawful exception applies. 

What 

How long 

Account and profile 

While your account is open, then 7 years 

Continuing education and credit records 

At least six years, as accreditation requires — retained after account closure 

Private messages 

Until deleted; 90 days after account closure 

Creation Tool Source Material and output 

Until you delete them; 7 years after account closure 

Engagement and analytics data 

7 years months in identifiable form, then aggregated 

Cookie and advertising identifiers 

Per the Cookie and Tracking Technologies Policy table 

Payment and tax records 

Seven years 

Archived educational material and knowledge corpus 

Indefinitely, under Terms of Use Article 11 

Anything under legal hold 

Until the hold lifts 

 

At the end of the applicable period, we delete the information or de-identify it, except where retention is required for accreditation, legal compliance, security, dispute resolution, or a legal hold. 

7 · Security, processing location, and breach 

7.1   Security 

We maintain administrative, technical, and physical safeguards appropriate to the information we hold. These safeguards may include encryption in transit and at rest, access controls and role-based authorization, logging and monitoring, security testing, vendor security reviews, contractual security obligations for service providers, and employee training. No system is perfectly secure, and we do not guarantee that information will never be accessed, disclosed, altered, or destroyed improperly. You are responsible for protecting your credentials, using available security features, and promptly notifying us at security@hcesquared.com of suspected unauthorized use or a security incident. 

7.2   Where we process 

We collect, store, and process information in the United States. The Platform is offered only to individuals in the United States. 

8 · Third-party sites, changes, and contact 

8.1   Third-party sites and services 

The Platform may link to or integrate with websites, applications, learning systems, payment platforms, video services, and other services operated by third parties. Their terms and privacy notices apply to your use of those services. We do not control or endorse third-party services and are not responsible for their privacy or security practices. 

8.2   Changes We review this policy at least every twelve months and update it when our practices change. We will post a revised policy with a new effective date. We will notify you by email and in the Platform at least thirty (30) days before material changes take effect, unless a shorter period is required by law or the change is necessary to address a new feature, security issue, or legal requirement. 

8.3   Contact Privacy and data rights: privacy@hcesquared.com · HCEsquared, LLC, 201 Tom Hall Street, PO Box 1299, Fort Mill, South Carolina 29715 

8.4   Governing law 

This policy is governed by the laws of South Carolina, without regard to its conflict-of-laws rules. The dispute-resolution provisions in Terms of Use §§ 18.1–18.10 apply to disputes relating to this policy.