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Legal · Privacy

Whitecoat Privacy Policy

Version 2.0Effective August 5, 2026Supersedes the version dated September 15, 2025

Whitecoat Technologies, Inc. (“Whitecoat,” “we,” “our,” or “us”) respects your privacy and is committed to protecting it through the practices described in this Privacy Policy (“Policy”). This Policy explains how we collect, use, retain, and disclose Personal Information when you visit our website (https://www.whitecoatai.com/) or use the Whitecoat Learning Platform application (https://app.whitecoatai.com/) (together, the “Services”).

We provide our Services to universities, schools, school districts, health care organizations, health systems, and other customers (each a “Program”). Whitecoat primarily acts as a service provider to these Programs and processes Personal Information on their behalf. Programs are responsible for obtaining any necessary consents and for responding to privacy rights requests related to data they control. Users include students and other learners, educators, administrators, preceptors, and other individuals whom a Program permits to access the Services (“Users”).

Information a Program creates about a learner, such as evaluations and competency ratings, belongs to that Program. Information a learner enters about themselves belongs to the learner. Section 1 explains this in more detail.

By using or accessing the Services, you acknowledge and accept this Policy. If you do not agree with it, do not use the Services.

1. Roles, Scope, and Definitions

Personal Information

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Our role

Whitecoat primarily provides the Services as a service provider to Programs and processes Personal Information pursuant to contracts with those Programs. With respect to the Platform, Programs determine the purposes and means of processing. For limited website interactions such as basic analytics and contact forms, Whitecoat may act as a business under certain state privacy laws.

FERPA

Where a Program is subject to the Family Educational Rights and Privacy Act, Whitecoat acts as a “school official” with a legitimate educational interest under 34 C.F.R. § 99.31(a)(1)(i)(B). We perform a function the Program would otherwise perform using its own employees, we remain under the Program’s direct control with respect to education records, and we do not redisclose education records except as FERPA permits or as the Program, learner, or a learner’s parent or guardian directs.

Who owns what

Information a Program or its faculty, staff, or preceptors create about a learner belongs to the Program and may also be an education record. Information a learner enters about themselves — profile details, self-assessments, portfolio work, credentials they upload, curriculum vitae, and stated career interests — belongs to the learner. System logs and usage data generated by operation of the Platform belong to Whitecoat.

Scope

This Policy applies to our website and the Platform, including communications with us and any digital properties we operate where this Policy is posted. It does not apply to a Program’s separate websites, systems, or services.

2. Information We Collect

Information we collect
CategoryExamples
Identifiers and Contact InformationName, email address, mailing address, phone number, account username. For a learner a Program identifies as under 18, the date on which the learner turns 18. We do not collect or request date of birth.
Parent or Guardian InformationWhere a learner is under 18: parent or legal guardian name, email address, phone number, and relationship to the learner, provided by the Program.
Employment and Educational InformationTitle, credentials, specialty, clinical affiliations, educational records, work status and history, rotation and placement records, assessments and competency ratings, pass or fail status of eligibility requirements (for example, pass or fail only of background checks or drug screenings).
Commercial InformationRecords of services used, surveys, assessments.
Visual InformationPhotograph or profile image, if a User chooses to upload one.
Internet and Network ActivityDevice data, IP address, general-level geolocation, log and usage data, interactions with the Services.
InferencesPreferences and usage trends derived from interaction with the Services, used to operate and improve the Platform. We do not create profiles of K-12 students except for a school purpose.
Consent and Authorization RecordsRecords of acceptance of our Terms of Use and of any authorization to share information with an employer, including the categories authorized, the recipient or class of recipients, the date, and any withdrawal.
Sensitive Personal Information (only if a Program directs it)We do not request Social Security numbers, financial account numbers, protected health information, or patient-identifying information. Where a Program directs collection of licensure numbers or similar identifiers, we process them only as that Program directs and not for our own purposes.

3. Sources of Personal Information

We collect Personal Information (a) directly from you, for example through account registration and communications; (b) from your Program, for example through account provisioning and program data; (c) from a parent or legal guardian, where a learner is under 18; and (d) automatically from your device and interactions with the Services, for example IP address and pages viewed. Your Program may instruct us to collect additional Personal Information through the Services for program, compliance, or accreditation purposes.

4. How We Use Personal Information

We use Personal Information as a service provider to your Program and, for limited website interactions, to operate our website. Typical uses include:

  • Providing, maintaining, securing, supporting, and troubleshooting the Services; creating and managing accounts; facilitating educational and clinical functions.
  • Customer support and service communications, including administrative notices and information about keeping your own account after your program ends.
  • Troubleshooting, security, fraud prevention, and integrity monitoring of the Services.
  • Producing aggregate statistics to understand and improve the Services, as described below.
  • Sharing with an employer, accreditation body, or licensing body, but only where you or your parent or guardian have authorized it. See Section 8.
  • Processing transactions through PCI-compliant payment processors when applicable.
  • Complying with law, enforcing terms, and protecting rights, safety, and property.

Aggregate statistics

We compute statistics from information on the Platform to operate and improve the Services, develop new features, and produce benchmarking and research. Those statistics never describe fewer than five individuals, never contain an individual-level record, and are not attributed to a Program outside that Program without its permission. We do not attempt to re-identify anyone from them, and we contractually prohibit recipients from doing so.

What we do not do

We do not sell Personal Information. We do not share Personal Information for cross‑context behavioral advertising or targeted advertising. We do not use Personal Information to market other products to learners. We do not use Personal Information to build a profile about an individual for use outside the Services.

5. Artificial Intelligence

The Platform includes AI-assisted features, including the Grace assistant and automated assessment features.

  • AI processing happens inside Whitecoat’s own cloud environment, using managed model hosting on Amazon Web Services in United States regions. Information is not transmitted to a public model API.
  • No foundation model provider receives or has the ability to access information from the Platform.
  • We do not use your information to train, fine-tune, or improve any AI model that is available to anyone other than your Program.
  • Where we tune a model for a single Program, it serves only that Program and is deleted when that Program’s agreement with us ends.
  • When a Program’s data is retrieved to answer a question, retrieval is limited at the time of the query to that Program’s own information and to what the person asking is authorized to see.

We will tell any Program on request which Platform features involve AI processing and which service providers support them.

6. Cookies and Tracking Technologies

We and our service providers use cookies, pixels, and similar technologies to operate and improve our public website. You can manage preferences using your browser settings and through the cookie banner on our website.

Cookies and tracking technologies
Cookie typePurpose
NecessaryEnable core site functions and security.
PreferencesRemember settings such as language.
Statistics (analytics)Measure usage and improve performance.
MarketingSupport limited marketing and retargeting activity on our public website only. Enable or disable through the cookie banner.

Website cookies and Platform cookies are different

The cookies above are used on our public website at whitecoatai.com. Within the Whitecoat Learning Platform we use only cookies that are strictly necessary to operate the application and keep it secure. We do not use marketing or retargeting cookies inside the Platform, and we do not use them in connection with any K-12 student.

Do Not Track. Our systems do not respond to browser “Do Not Track” signals at this time.

Session replay and heatmaps. We may use session analytics tools such as Microsoft Clarity on our public website to understand aggregate usage, for example clicks and scrolls.

7. Disclosures of Personal Information

We disclose Personal Information in the circumstances below. We do not sell Personal Information.

Disclosures of personal information
RecipientPurpose of disclosure
Your ProgramTo enable and manage your participation in the Program’s activities and obligations.
Employers, accreditation bodies, and licensing bodiesOnly where you, or your parent or legal guardian if you are under 18, have authorized the disclosure. See Section 8.
Service providersWebsite hosting, content delivery, cloud infrastructure, and AI model hosting (Amazon Web Services), website form handling and lead storage (Cloudflare), identity and authentication, marketing and CRM for our website (for example, HubSpot), website analytics (for example, Google Analytics), demo scheduling (Calendly), email and messaging (for example, SendGrid), payment processing, and customer support (for example, Intercom). We maintain a current list of service providers that process Program information and make it available to any Program on request.
Affiliates and successorsIn connection with mergers, acquisitions, or asset transfers.
Legal and complianceTo comply with law, respond to lawful requests, enforce terms, and protect rights and safety.

Service providers are bound by written agreement to data-protection obligations no less protective than those we owe your Program, and may process information only to deliver the Services at our direction. Engaging a service provider on those terms is not a sale or an unauthorized sharing of your information.

8. Sharing With Employers at Your Direction

The Platform can share information from a learner’s record with a prospective or current employer, an accreditation body, or a licensing body. This never happens automatically.

  • It happens only where the learner, or the learner’s parent or legal guardian if the learner is under 18, has authorized it.
  • The authorization identifies the organization, or a defined group of organizations the Program partners with, and states the purpose.
  • The person authorizing selects which categories of information may be shared. Anything not selected is not shared.
  • The authorization can be withdrawn at any time, in whole or as to a single organization. Withdrawal stops further sharing but cannot retrieve information already delivered, and we say so before the authorization is given.
  • Where information created by a Program is shared, we label it with its source and date. Sharing is not a recommendation or endorsement by the Program.
  • Every recipient must first agree in writing to use the information only for the stated purpose and not to pass it on.
  • We keep a record of each authorization and withdrawal, and we provide the Program a record of what was shared, with whom, and when.

Where an authorization covers a group of partner organizations, the current list of those organizations is available from the Program at any time.

9. Your Privacy Choices and Controls

  • Account controls. You or your Program can update certain account information in your profile. Some records are maintained by your Program and are not directly deletable by Whitecoat.
  • Employer sharing. You can withdraw an authorization at any time in account settings or by writing to support@whitecoatai.com. For a learner under 18, the parent or legal guardian makes this choice.
  • Email preferences. We send service and administrative communications about the Services you are using, and those cannot be opted out of while your account is active. We do not send marketing emails to learners.
  • Cookie preferences. Manage cookies through your browser and the cookie banner on our website.
  • Platform data requests. Because Whitecoat primarily acts as a service provider, privacy requests regarding Platform data should be sent to your Program. We will refer any request we receive directly to your Program within five business days and assist as required.

10. Minors and K-12 Students

Who may use the Services

The Services are available to individuals 18 years of age or older, and to individuals under 18 who are enrolled in a Program where a parent or legal guardian has accepted our Terms of Use on their behalf. We do not offer the Services to children under 13, and a Program may not enroll a learner under 13 without a separate written agreement with us addressing the Children’s Online Privacy Protection Act.

How we know a learner is under 18

We do not collect or request date of birth. The Program identifies to us any learner who is under 18 and tells us the date that learner turns 18. Absent that identification, we treat a learner as 18 or older.

Who makes decisions for a learner under 18

While a learner is under 18, the parent or legal guardian exercises the choices described in this Policy on that learner’s behalf, including any decision to share information with an employer. This follows FERPA, under which a parent’s rights transfer to the student when the student turns 18 or enrolls in a postsecondary institution. When a learner turns 18, those rights transfer to the learner, and any authorization previously given remains in effect until the learner changes it.

The Platform shows a learner, on a read-only basis, what has been shared about them and with whom. A learner cannot change a parent’s or guardian’s decision.

K-12 Programs

Where a Program serves students in kindergarten through grade twelve, the following applies to information about those students:

  • We do not use student information for targeted advertising.
  • We do not create a profile about a student except for a school purpose.
  • We do not sell student information.
  • We contractually prohibit our service providers from using student information for any purpose other than delivering the service to or on behalf of us, and from further disclosing it.
  • We disclose student information for a school, educational, or employment purpose only where the student, or the student’s parent or guardian, has requested it, and we do not use or further disclose it for any other purpose.
  • We delete student information at the Program’s direction.

For Programs in Tennessee, these commitments are intended to align with the Student Online Personal Protection Act, Tenn. Code Ann. § 49-1-708. Programs in other states may be subject to additional requirements, which we address in the Program’s agreement with us.

11. Notice to California Residents (CCPA/CPRA)

This section applies only to California residents. Whitecoat primarily acts as a service provider for Platform data; please direct requests about Platform information to your Program. For limited website interactions where Whitecoat acts as a business, the disclosures and rights below apply.

A. Notice at collection

Notice at collection for California residents
CategoryExamplesSourcesBusiness purposesDisclosed for a business purpose?Sold or shared?
Identifiers and contactName, email, phoneYou; ProgramAccount setup, support, security, communicationsYes, to service providers and your ProgramNo
Parent or guardian informationName, email, phoneProgram; parent or guardianConsent administration for learners under 18Yes, to your ProgramNo
Employment and educationTitle, credentials, records, assessmentsProgram; youProgram operations, complianceYes, to your Program and service providersNo
Commercial recordsTransactions, services usedYou; ProgramFulfillment, records, supportYes, to service providersNo
VisualProfile photo you uploadYouProfile display, identity confirmationYes, to your Program and service providersNo
Internet and networkIP, device, usage dataYour deviceSite operation, security, analyticsYes, to analytics and hosting providersNo
InferencesPreferences from useDerivedOperate and improve the ServicesYes, to service providersNo
Consent recordsAuthorizations and withdrawalsYou; parent or guardian; ProgramAdministering and evidencing consentYes, to your ProgramNo
Sensitive PI (only if a Program directs)Licensure IDs, background check statusProgram; youProgram and compliance needsYes, to your Program and service providersNo

Where a learner or a parent or guardian authorizes sharing with an employer, accreditation body, or licensing body under Section 8, that disclosure is made at their direction and is not a sale or a sharing for cross‑context behavioral advertising.

Retention. We retain Personal Information for the minimum period necessary to fulfill the purposes described above, or longer if required by law or by your Program. See Section 14.

B. California privacy rights

  • Right to know or access the categories and specific pieces of Personal Information we collected, the sources, the purposes, and the categories of recipients.
  • Right to delete Personal Information we collected from you, subject to exceptions such as security and legal obligations.
  • Right to correct inaccurate Personal Information.
  • Right to opt out of sale or sharing. Whitecoat does not sell Personal Information and does not share Personal Information for cross‑context behavioral advertising. Where marketing cookies on our public website constitute “sharing,” you can opt out through the cookie banner.
  • Right to limit use and disclosure of Sensitive Personal Information. We do not use Sensitive Personal Information to infer characteristics. Sensitive information on the Platform is processed only as your Program directs.
  • Right to non-discrimination for exercising your rights.

C. How to submit requests

Platform data: submit requests to your Program. Whitecoat will assist as required by law. Website data: write to support@whitecoatai.com. We will verify your identity, and the authority of any authorized agent, before fulfilling a request, and will respond within 45 days, with a possible 45‑day extension where permitted.

D. Disclosures for a business purpose (past 12 months)

Disclosures for a business purpose in the past 12 months
Category of Personal InformationCategories of recipientsPurpose
Identifiers and contactService providers; your ProgramProvide Services, support, security, communications
Parent or guardian informationYour ProgramConsent administration for learners under 18
Employment and educationYour Program; service providers; and, at your direction, an employer or accreditation or licensing bodyProgram operations, compliance, and authorized employer sharing
Commercial recordsService providersFulfillment, records, support
VisualYour Program; service providersProfile display, identity confirmation
Internet and networkHosting and analytics providersOperation, security, analytics
InferencesService providersOperate and improve the Services
Consent recordsYour ProgramAdministering and evidencing consent
Sensitive PI (only if a Program directs)Your Program; service providersProgram and compliance needs
Disclosures for a business purpose, past 12 months.

E. Shine the Light (Civil Code § 1798.83)

We do not disclose Personal Information to third parties for their own direct marketing purposes. To inquire further, contact support@whitecoatai.com.

F. Financial incentives

We do not offer programs that provide financial incentives or price or service differences related to the collection, retention, sale, or sharing of Personal Information.

12. Notice to Residents of Other U.S. States

Residents of states with comprehensive privacy laws, including Colorado, Connecticut, Virginia, Utah, Tennessee, and others, may have rights to access, correct, delete, and obtain a copy of Personal Information, and to opt out of targeted advertising, sale, and certain profiling. For Platform data, submit requests to your Program. For website data, contact support@whitecoatai.com. We will verify and respond within applicable timeframes. You may appeal a denial by writing to support@whitecoatai.com with “Privacy Appeal” in the subject line.

Several states also have laws specific to student information. Our commitments for K-12 Programs are described in Section 10.

13. Data Security and Location

We implement technical, organizational, and physical safeguards designed to protect Personal Information, including role-based access controls, individual named credentials, encryption in transit and, where stored, at rest, logging of access by our personnel, and background screening and confidentiality obligations for staff with access. We review our security program at least annually. No method of transmission or storage is fully secure.

Access by Whitecoat personnel to identifiable Program information is limited to defined support purposes such as responding to a support request, diagnosing errors, provisioning accounts, and investigating security incidents. That access is logged. It does not extend to product improvement or marketing.

Information is stored and processed within the United States. We do not transfer information outside the United States, or permit access to it from outside the United States, without the Program’s written consent.

Please maintain the confidentiality of your credentials and notify your Program promptly of any unauthorized access. Security concerns may also be sent to security@whitecoatai.com.

14. Data Retention

We retain Personal Information for the minimum period necessary to fulfill the purposes described in this Policy, or longer if required by law or by your Program. Retention periods may be determined by regulatory, accreditation, or program requirements applicable to a Program.

  • When a Program’s agreement with us ends, the Program may export its information, after which we delete or return identifiable information within a commercially reasonable period.
  • A learner who has activated an individual account may keep the information they entered about themselves, and anything previously shared at their direction, in an account they control, even after the Program’s agreement ends.
  • We retain records of consents and withdrawals for not less than five years, so that we can show what was authorized and when, even after the underlying information is deleted.
  • We may retain aggregate statistics that do not identify any individual.

15. Third-Party Websites and Services

The Services may contain links to third-party websites or platforms. Their privacy practices are governed by their own policies. Review those policies before submitting information to third parties.

16. Changes to this Policy

We may update this Policy from time to time. If we make material changes, we will post the updated Policy, update the version and effective date above, and provide additional notice as required by law. Where a Program has an agreement with us, that agreement governs the effect of any change to this Policy on that Program.

17. Contact Us

Questions about this Policy or our privacy practices may be directed to support@whitecoatai.com, or to Whitecoat Technologies, Inc., 753 Glen Oaks Dr., Franklin, TN 37067. For requests about Platform data, please contact your Program Administrator.