Privacy Policy

This Privacy Policy explains how GentleDraw collects, uses, discloses, and protects personal information when you visit method.gentledraw.com, communicate with us, use the linked GentleDraw certification portal, enroll in education, pursue or maintain a proprietary credential, or participate in an institutional relationship (collectively, the “Services”).

For this Policy, “GentleDraw,” “we,” “us,” and “our” mean GentleDraw Spa LLC, doing business as GentleDraw, and, where applicable, Novelle Innovative Ventures LLC as owner and licensor of GentleDraw intellectual property. A separate clinical-services privacy notice may apply when a person receives services through GentleDraw Spa. This Policy is not a HIPAA Notice of Privacy Practices.

1. Information we collect

Information you provide

Depending on how you interact with us, we may collect:

• name, email address, telephone number, mailing or billing address, and communication preferences;
• account credentials and profile information;
• professional role, employer, school, license or credential information, and institutional affiliation;
• enrollment, course activity, completion, assessment, certification, renewal, and support records;
• transaction details, order history, billing contact information, and payment status;
• messages, institutional inquiries, survey responses, accommodation requests, feedback, and other content you choose to provide; and
• records of consent, policy acceptance, and communications.

Payment-card information is generally collected directly by a payment processor. GentleDraw may receive transaction identifiers, payment status, card type, and limited card details, such as the last four digits, but does not need your full card number to administer an order.

Information collected automatically

When you use a website or online platform, we and our service providers may collect IP address, device and browser type, operating system, pages or features accessed, referring and destination pages, date and time, approximate location derived from IP address, error information, and security or diagnostic logs.

Information from other sources

We may receive information from an employer, school, institutional sponsor, referral source, course-platform provider, payment processor, communications provider, or other party involved in your enrollment or relationship. An organization that sponsors access may receive information about participation or completion as described below.

2. Sensitive and patient information

The public Method website and ordinary email channels are not designed to receive patient records, protected health information, or detailed medical histories. Please do not send such information through ordinary email or a public website channel.

We may receive limited information necessary to respond to an accessibility or learning-accommodation request. We use that information only as reasonably necessary to evaluate and provide the requested support, comply with law, and document the request. If a separate secure process is required, we will provide instructions.

3. How we use information

We may use personal information to:

• provide, administer, personalize, and support the Services;
• create and secure accounts;
• process enrollments, payments, refunds, extensions, assessments, completions, renewals, and credentials;
• verify identity, eligibility, professional information, or assessment integrity when applicable;
• communicate about purchases, access, deadlines, security, support, programs, and institutional relationships;
• provide requested accommodations and customer support;
• maintain records, enforce terms, protect intellectual property, prevent fraud, and secure our systems;
• analyze performance and improve content, accessibility, operations, and user experience;
• send marketing communications where permitted, subject to available choices;
• comply with legal obligations and respond to lawful requests; and
• establish, exercise, or defend legal claims.

Where law requires a legal basis, we rely as applicable on performance of a contract, steps requested before a contract, legitimate interests, compliance with legal obligations, protection of vital interests, and consent.

4. How we disclose information

We may disclose personal information to:

• service providers that support website hosting, course delivery, payment processing, email, customer support, security, analytics if later implemented, records, or professional services;
• institutional sponsors such as an employer or school that purchased or assigned your enrollment, limited to information reasonably necessary to administer the program, including enrollment, participation, completion, or credential status;
• GentleDraw affiliates and licensors as reasonably necessary to operate, protect, and improve the Services and intellectual property;
• professional advisers and authorities when reasonably necessary for legal, accounting, insurance, security, compliance, or dispute purposes;
• transaction participants in connection with a proposed or completed financing, merger, reorganization, sale, or transfer of relevant assets, subject to appropriate safeguards; and
• other parties at your direction or with your consent.

We may also disclose information when we reasonably believe disclosure is required by law; necessary to protect rights, safety, security, or property; or appropriate to investigate fraud, misuse, or a violation of our terms.

As of the effective date, GentleDraw does not sell personal information for money and does not knowingly share personal information for cross-context behavioral advertising. If our practices change, we will update this Policy and provide any choices required by law before the new practice begins.

5. Cookies and similar technologies

The public Method website does not intentionally deploy advertising pixels or nonessential analytics cookies as of the effective date. Essential hosting, security, load-management, or diagnostic technologies may operate to deliver and protect the Site. The separate certification portal and other linked services may use their own cookies under their own notices. See the Cookie Policy for details.

6. Marketing choices

You may opt out of promotional email by using the unsubscribe link in the message or contacting us. Even after opting out, you may receive transactional or relationship communications concerning purchases, security, course access, assessments, credentials, support, or institutional administration.

Browser “Do Not Track” signals do not have a uniform legal or technical standard, and the public Method website does not currently respond to them as a separate setting. Where legally required and technically applicable, we will recognize valid opt-out preference signals, such as Global Privacy Control, for practices subject to those signals. Because we do not currently sell personal information or use it for cross-context behavioral advertising, there may be no applicable sale or sharing to opt out of.

7. Data retention

We retain personal information for as long as reasonably necessary for the purpose collected, including to provide course access, maintain completion and credential records, administer renewals, support institutional reporting, comply with tax and accounting rules, resolve disputes, enforce agreements, and protect intellectual property and security.

Retention periods vary by record type. We may retain core transaction, credential, consent, and completion records after an account becomes inactive because those records help verify what was purchased, earned, represented, or agreed. When information is no longer reasonably needed, we take reasonable steps to delete, de-identify, or securely dispose of it, subject to backup cycles and legal holds.

8. Security

We use administrative, technical, and organizational measures designed to protect personal information in light of its nature and the risks involved. No internet transmission, email, platform, or storage system is completely secure, and we cannot guarantee absolute security. Use a unique password, protect your account credentials, and notify us promptly if you suspect unauthorized access.

9. Children’s privacy

The online education Services are not directed to children under 13, and we do not knowingly collect personal information directly from children under 13 through the Method website or certification portal. If you believe a child provided personal information, contact us so we can investigate and take appropriate action.

This section does not prevent GentleDraw from providing lawful institutional education or separate clinical services involving minors through appropriately authorized adults and separate processes.

10. Your privacy rights

Depending on where you live and subject to applicable exceptions, you may have rights to request access to, correction of, deletion of, or a copy of certain personal information; to withdraw consent; to object to or restrict certain processing; or to appeal a decision concerning a privacy request.

To submit a request, email Info@GentleDraw.com with the subject line “Privacy Request.” Describe the request and the email address associated with your relationship. We may verify identity and authority before responding. Authorized agents may be required to provide proof of authority. We will not discriminate against you for exercising a right protected by law.

Some information may be exempt from a request or retained as required for legal, security, transaction, credential-integrity, or recordkeeping purposes. If a request is denied, we will provide an explanation and any appeal method required by applicable law.

11. International users

GentleDraw is based in the United States. If you access the Services from another country, your information may be processed in the United States and other locations where our service providers operate. Those locations may have different data-protection laws. Where required, we use appropriate transfer mechanisms and honor applicable rights.

12. Third-party and institutional privacy practices

The certification portal, payment processor, social networks, and other linked services may collect information under their own privacy notices. An employer, school, or institutional sponsor may also process information as an independent organization. Review their notices and direct questions about their independent practices to them.

If an institutional agreement requires GentleDraw to process personal information on behalf of an organization, the agreement may supplement this Policy and allocate privacy responsibilities for that relationship.

13. Changes to this Policy

We may update this Policy to reflect changes in the Services, technology, vendors, or law. The effective date above identifies the current version. We will provide additional notice or obtain consent when required for a material change.

14. Contact us

Privacy questions and requests may be sent to: