Effective date: October 2, 2026
Last updated: October 2, 2026

CE HALO LLC (“CE HALO,” “we,” “us,” or “our”) provides continuing education, clinical-reference resources, and educational products for healthcare professionals, healthcare-professions students, and adult learners. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information, and how you can exercise privacy choices.

This policy applies to cehalo.com, CE HALO continuing-education courses, and CE HALO-operated Luma Educational Apps and other services that link to this policy, including Luma Anesthesia. These are collectively our “Services.” Features, account requirements, and providers can differ among Services; a description of a feature does not mean that it is available in every app or version.

• Free reference access: You can browse Luma Anesthesia’s free clinical-reference content without creating an account. Limited technical information is still processed to deliver and secure the Service.
• Accounts and CE: A free account is required for Luma Anesthesia CE purchases or enrollment, access to purchased courses, saved learning progress, and completion certificates. A clinical-reference subscription is not required to purchase or complete a CE course.
• Paid access: Creating an account does not by itself unlock subscription content or paid courses. We process purchase and access records to provide the content you are entitled to use.
• No advertising sale or tracking: We do not sell personal information, share it for cross-context behavioral advertising, or track users across other companies’ apps and websites for advertising. We do not use third-party advertising SDKs in our mobile apps.
• No patient information: Our Services are not intended to collect or maintain patient-identifiable information or protected health information. Do not submit patient information.
• Privacy requests: Contact info@cehalo.com to request access, correction, or deletion. Necessary CE, legal, and financial records may need to be retained after account deletion, as explained below.

CE HALO LLC, based in Buffalo, New York, United States, is responsible for the personal information we process in operating the Services. You can contact us at info@cehalo.com for privacy questions or to exercise your rights.

This policy applies alongside our Terms of Use and EULA, Medical Disclaimer, and Data Protection and HIPAA Statement. An independent website, app store, sign-in provider, accreditor, or payment provider may also process information under its own privacy notice.

When you create or use an account, we process information necessary to establish and secure it. Depending on the Service and sign-in method, this includes:

• Identity and contact information: Email address, name or display name, and optional profile information you provide.
• Account identifiers: Our internal user identifier and, where applicable, an identifier supplied by an authentication provider.
• Authentication information: Sign-in method, password-verification information for email/password accounts, session tokens, email-verification and password-recovery records, and security-related events.
• Account activity: Account creation, sign-in, and relevant account-change timestamps.
• Preferences: Settings, onboarding status, and policy-acknowledgment information.

Passwords for email/password accounts are handled by our authentication provider using password-verification protections rather than being stored by us as readable passwords. We will not ask you to send your password, a verification code, or a recovery link in a support message.

Where Apple or Google sign-in is enabled, we receive the information that provider makes available for authentication, such as an identifier, email address, and name. Apple may provide a private-relay address if you select Hide My Email; we do not receive your Apple or Google password.

When you register for, purchase, participate in, or complete a course, we process information needed to deliver the course, establish completion, issue a certificate, and meet reporting and recordkeeping obligations. This may include:

• Learner information: Your full name as it should appear on a certificate, email address, profession, professional credentials, and applicable license or certification information.
• AANA information: Your AANA membership or identification number when supplied or required for credit reporting.
• Participation information: Course enrollment, participation and completion dates, and the completion location you enter. A location entered on a certificate form is not a request for your device’s GPS location.
• Learning records: Module progress, assessment answers, scores, attempts, evaluations, attestations, completion status, and related activity timestamps.
• Certificate records: Certificate identifiers, learner details, course information, completion dates, credits awarded, and issuance or correction records.
• Reporting and support records: Credit-reporting status, reconciliation or correction information, and communications about your participation or certificate.

Please provide accurate certificate and professional-identifier information. Missing or incorrect information may delay reporting or require a correction; contact us if you need assistance.

We process product and course identifiers, order or transaction identifiers, receipt-verification results, purchase dates, subscription periods, entitlement status, restorations, cancellations, refunds, and related access records. We also maintain the information necessary to determine eligibility for complimentary access offered with a CE purchase and to prevent duplicate promotional grants.

Apple or Google processes payment credentials for purchases made through its mobile app store. For website or hosted-course purchases, the payment provider presented at checkout processes payment credentials; we receive the order, payment-status, and limited billing information needed to administer the purchase, not your full payment-card number.

                                                                       Subscribing Without an Account

You can buy or restore a Luma Anesthesia subscription without creating an account. When you tap Subscribe or Restore Purchases, we create a random guest identifier with our authentication provider (Supabase). We share it with RevenueCat to link your purchase to your device. A guest identifier contains no name, email address or password. If you later create a free account or sign in, your subscription moves to that account. If you delete the app, you can recover a subscription with Restore Purchases using the same Apple or Google account.

When you contact us, submit a form, request support, or make a privacy request, we receive the contact details and message content you provide. Where a Service offers saved notes, bookmarks, study activity, or similar features, we process the information you choose to enter or save to provide that feature.

Do not include patient identifiers, payment-card details, passwords, or unnecessary sensitive information in these submissions. If you believe you submitted patient information accidentally, contact us without repeating the sensitive information in your message.

Our Services and their infrastructure providers process technical information needed to deliver content, secure accounts, prevent abuse, and troubleshoot problems. Depending on the Service, this can include IP address, browser or device type, operating system and app version, requested pages or API resources, timestamps, error information, and standard network or server logs.

App stores may provide crash reports, diagnostics, installation information, or aggregated usage information according to their platform practices and your settings. Website hosting and analytics tools may process page views, sessions, referring pages, and general location inferred from an IP address; an IP-derived general location is different from precise GPS location.

We use personal information for the following purposes:

• Service delivery: Create and authenticate accounts, deliver reference content and CE courses, save progress, and synchronize supported account features.
• Paid access: Verify purchases, provide or restore entitlements, administer subscriptions and complimentary access, and address purchase problems.
• CE administration: Grade assessments, evaluate completion, issue or correct certificates, report credits, and maintain required program records.
• Communications: Respond to support requests and send necessary account, security, purchase, course, certificate, or privacy-request messages.
• Service improvement and security: Diagnose errors, improve usability and reliability, prevent fraud and abuse, and protect the Services.
• Legal and administrative obligations: Maintain required records, resolve disputes, respond to valid legal requests, and enforce applicable terms.
• Optional marketing: Send product or course updates where you have opted in or another lawful basis permits them, with an opportunity to opt out.

We do not make access to purchased content conditional on agreeing to unrelated marketing or advertising tracking. Acknowledging this Privacy Policy does not itself subscribe you to marketing emails or authorize sharing personal information with a third-party AI provider.

We disclose information needed to operate the Services to providers that assist with hosting, authentication, databases, payments, email, support, and technical operations. We require providers acting on our behalf to process personal information for authorized purposes and to protect it consistently with this policy and applicable requirements, rather than use it for their own unrelated advertising.

The provider and data involved depend on the Service you use:

• Supabase: Authentication, databases, APIs, and storage for the Flutter version of Luma Anesthesia, including account, CE, entitlement, and certificate records. See the Supabase Privacy Policy.
• RevenueCat: Mobile-purchase verification and entitlement management, using app user identifiers, product identifiers, transaction and subscription information, and related technical information. See the RevenueCat Privacy Policy.
• Apple and Google: App distribution, in-app billing, platform diagnostics, and authentication where their sign-in options are enabled. These companies also process information for their own platform purposes under the Apple Privacy Policy and Google Privacy Policy.
• Resend and email providers: Delivery of service emails, using recipient addresses, message content, and delivery or error information. See the Resend Privacy Policy.
• GoDaddy and website-service providers: Hosting and operation of cehalo.com, including website forms, cookies, and related technical information. See the GoDaddy Privacy Notice.
• Thinkific, where used: Hosted-course enrollment, learning activity, assessments, and certificates for courses delivered through that platform. See the Thinkific Privacy Policy.
• Stripe or a hosted-course payment provider, where used: Website or hosted-course payment processing, billing, transaction records, and fraud prevention. The provider is identified during checkout; see the Stripe Privacy Policy.
• Other app infrastructure, where used: Other or earlier CE HALO Services may use Base44 or another hosting platform for account records and app data. The specific Service and its feature notices determine which infrastructure is involved.
• Authorized personnel and professional advisers: Access necessary for support, CE administration, security, accounting, legal advice, or other legitimate business responsibilities.

Independent providers such as app stores, payment services, and accreditors can have their own legal obligations and retention practices. A request to CE HALO does not automatically erase records that those organizations independently control.

We may also disclose information when reasonably necessary to comply with law or a valid legal process, investigate fraud or security incidents, protect rights or safety, or support a merger, acquisition, or transfer of the business subject to appropriate confidentiality and privacy safeguards. We will provide notices or obtain permission where required.

For applicable courses, we provide completion information to AANA or another relevant accreditor or regulator to report, reconcile, or verify credit. This can include your name, AANA number or other applicable professional identifier, course or program identifier, completion date, and credits earned.

CE HALO submits completed CE records to AANA in monthly reporting batches at the end of the month, with additional submissions or corrections when necessary to meet applicable reporting deadlines. Your certificate and the course’s approval statement describe the applicable credit; a purchase alone is not evidence of completion or an award of CE credit.

Accreditors or regulators may review supporting participation, assessment, evaluation, and certificate records as part of a legitimate audit or verification. We limit disclosure to the information needed for that purpose and the applicable requirements.

Luma Anesthesia retrieves supplemental drug-shortage information from FDA and human prescription-label information from DailyMed. These are reference-data connections, not AI chat services; they do not automatically replace our reviewed clinical content.

For these integrations, our backend sends medication search terms and ordinary connection information to the source service. It does not send your name, email address, AANA number, CE records, account credentials, or patient information as part of those source queries.

Our systems may retain source results and refresh timestamps, and the app may save previously viewed results on your device. When you open an external FDA, DailyMed, or other source link, your browser connects directly to that website, which may receive your IP address, browser information, and the requested URL under its own privacy practices.

Live Luma AI chat and AI-credit purchases are not enabled in the current Luma Anesthesia release covered by this policy. We do not send Luma Anesthesia user prompts to an AI model through an inactive feature.

Before enabling a feature that sends information to a third-party AI provider, we will identify the provider, explain what information is sent and for what purpose, describe relevant storage or other data-use practices, and obtain separate permission where required. A general policy acknowledgment is not a substitute for that disclosure or permission; do not submit patient-identifiable information to any AI feature.

Any AI feature offered in another CE HALO Service must be used in accordance with that Service’s feature-specific disclosures. This policy does not grant blanket permission for undisclosed AI processing or model training.

The app may store authentication/session information, preferences, onboarding status, a policy-version acknowledgment and its date, and downloaded reference content on your device. Luma Anesthesia’s protected reference downloads are account-linked and subject to periodic access verification; signing out removes protected reference downloads, while public reference caches may remain.

An offline download does not make account operations, purchases, CE synchronization, or external source websites available without internet. Clearing app data or uninstalling the app may remove local information, but does not by itself delete your server-side account, copies of PDFs you exported elsewhere, or an app-store subscription.

Our website and hosted Services may use cookies or similar storage for security, session management, preferences, and usage measurement. You can use available website controls and browser settings to manage cookies; blocking necessary storage may prevent sign-in or other functions from working.

Where nonessential cookies or similar technologies require consent, that consent is separate from your acceptance of the app’s terms or policies. We do not use website or app data for cross-context behavioral advertising.

Luma Anesthesia does not require access to your precise GPS location, contacts, microphone, camera, or health-platform records for its clinical-reference and CE functions. System file or sharing controls may be used when you choose to save or share a certificate or document; if another feature needs an additional device permission, its purpose will be explained when requested.

We retain personal information only for as long as reasonably necessary for the purposes described in this policy, including providing the Services and meeting applicable legal, accreditation, financial, security, and dispute-resolution obligations. We consider the type and sensitivity of information, why it is needed, required recordkeeping periods, and whether it can be deleted or de-identified.

• Account and ordinary app data: Retained while needed to operate your account or the feature you use. Following a verified deletion request, we delete or de-identify associated information that is not subject to a necessary retention exception.
• Required CE program records: For AANA-approved provider-directed independent-study activities, required program records must be securely stored and retrievable for at least 60 months (five years) under the AANA recordkeeping guidance. This includes required program and learner evidence, not just a certificate, and may include participation, assessments, evaluations, completion, and reporting records.
• Longer required retention: A longer period may apply to a particular activity or record because of a law, accreditation condition, audit, or legal hold. We restrict retained records to the necessary purposes rather than keeping unrelated profile information indefinitely.
• Purchase and financial records: Retained as needed for accounting, tax, fraud prevention, refunds, disputes, and applicable recordkeeping requirements. App stores and payment providers also maintain records under their own obligations.
• Support and privacy-request records: Retained as needed to resolve a request, document our response, maintain security, and demonstrate compliance.
• Technical logs and backups: Retained as needed for security, reliability, and recovery. Deleted information may remain temporarily in restricted backups until those backups are overwritten or expire; it is not used for ordinary active processing, and applicable deletion instructions are reapplied if a backup is restored.
• On-device information: Retained until it is removed, overwritten, expires, or is cleared through the applicable account, device, or browser controls. Files you export to another location remain under your control there.

Deletion of your account does not cancel the obligation to preserve necessary CE records. Contact us if you want an explanation of which records must be retained in your particular case.

You can request account deletion without installing or signing in to the app by emailing info@cehalo.com with the subject “Luma Anesthesia Account Deletion.” Include the email address associated with your account and the name of the Service; do not send your password, a verification code, or patient information.

Where your app version provides an enabled My Account → Delete account option, you may also submit your request there. If that option is unavailable or does not work, use the email request method above; you do not need to wait for a subscription to expire to request deletion.

For access, correction, a copy of your information, or another privacy request, email the same address with the subject “Privacy Request.” Tell us which Service and request your message concerns.

We may take reasonable steps to verify that you control the account or are authorized to act for its owner. We request only the information reasonably necessary for verification and do not require you to provide your password.

Our standard turnaround for account-deletion requests is seven calendar days after we have reasonably verified the request. We will confirm completion by email; if a legally permitted exception or necessary verification issue prevents completion within that period, we will explain the reason and expected timing, while honoring applicable legal deadlines.

Submitting a request is not the same as immediate deletion. Account access may remain available while the request is being processed, and required retained records remain subject to the protections and limitations described in this policy.

Account deletion removes your ability to sign in and use account-linked features through that account. Save certificates and other documents you want to keep before requesting deletion; you may still contact us to request verification or copies of CE records that we are required to retain.

Deleting an account or uninstalling an app does not automatically cancel an Apple or Google subscription or issue a refund. Manage subscriptions through your Apple or Google account to prevent future renewals, and use the applicable store’s refund process; you can still request deletion while a subscription is active.

We delete or de-identify associated personal information we control that is not subject to a necessary retention exception, including addressing relevant data held by providers acting on our behalf. Revocation of connected sign-in credentials is handled where applicable; independent records held by an accreditor, app store, or payment provider remain subject to that organization’s own obligations.

Depending on your location and the law that applies, you may have rights to access, correct, delete, or receive a portable copy of personal information; restrict or object to certain processing; withdraw consent; and appeal a refusal to act on a request. You may also have the right to complain to a relevant data-protection authority or state regulator.

• Consent: You can withdraw consent to optional processing by contacting us or using the relevant feature settings. Withdrawal does not affect processing that was lawful before withdrawal or processing supported by another lawful basis.
• Marketing: Use an email’s unsubscribe control or contact us to stop marketing messages. Necessary security, account, purchase, course, and privacy-request communications may still be sent.
• Authorized agents: Where permitted by law, an authorized agent may submit a request. We may verify the agent’s authority and your identity.
• Appeals: If we decline a request, we will explain the reason where required. You may email us with the subject “Privacy Request Appeal,” and we will review the decision in accordance with applicable law.
• No discrimination: We do not unlawfully discriminate against you for exercising privacy rights. Some requested deletions or restrictions may make an account-dependent feature unavailable.
• Sale, advertising sharing, and sensitive information: We do not sell personal information or share it for cross-context behavioral advertising, and we do not use sensitive personal information to infer characteristics for advertising. Where applicable, we honor legally required opt-out preference signals.

Where European, UK, or similar data-protection law applies, our processing relies on appropriate legal grounds: performing a contract to provide requested Services; complying with legal obligations; pursuing legitimate interests such as security, fraud prevention, support, and service improvement where those interests do not override your rights; or consent where required. We do not treat merely visiting our website as consent to every possible use of information.

CE HALO is based in the United States, and information may be processed in the United States or other countries where our providers operate. Where applicable law requires safeguards for international transfers, we use the required lawful arrangements; contact us for information about the safeguards applicable to your information.

We use reasonable administrative and technical safeguards designed to protect personal information, including protected communications, account-access controls, and restricting access to operational needs. No transmission or storage system is completely secure, and this policy is not a guarantee against every security incident.

Use a strong password, protect your device, and contact us promptly if you suspect unauthorized account access. We provide notices about security incidents when required by applicable law.

The Services are intended for healthcare professionals, healthcare-professions students, and other adult learners aged 18 or older. We do not knowingly collect personal information from children under 13, or under a higher age where applicable law requires it; contact us if you believe a child has submitted information so we can take appropriate action.

The Services are educational and clinical-reference tools, not electronic health records or a service for storing patient-identifiable information. Do not enter patient names, medical record numbers, dates of birth, patient images, identifiable case details, or other protected health information; if such information is inadvertently received, we will assess and appropriately restrict, remove, or otherwise address it.

Using the Services does not establish a healthcare-provider relationship or create a HIPAA business-associate agreement. Professional identifiers and CE records are handled under this policy, but that does not mean the app is authorized for clinical patient-data processing.

Luma Anesthesia is a reference tool intended to support, not replace, clinical judgment. Always verify dosing with your institution’s protocols and consult appropriate resources before administering any medication.

We may update this policy to reflect changes to our Services, providers, practices, or legal obligations. We will revise the date above and provide additional notice or seek consent when required; continued use alone is not a substitute for legally required consent to a new use of personal information.

For privacy questions, account deletion, access, correction, appeals, or concerns:

• Company: CE HALO LLC.
• Location: Buffalo, New York, United States.
• Email: info@cehalo.com.
• Website: cehalo.com.
• Privacy policy: cehalo.com/privacy-policy.

Please identify the app, course, or website involved so we can direct your request appropriately. Public privacy requests go to the business contact above; internal notification routing does not change that contact.