PRIVACY POLICY
Oxbridge ETF Academy — All Courses, Programs, and Credentials
Last Updated: August 1, 2026
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This Privacy Policy describes how Oxbridge LLC, a Connecticut limited
liability company doing business as Oxbridge ETF Academy ("Oxbridge,"
"we," "us," or "our"), collects, uses, discloses, and protects
personal information in connection with your use of our website and your enrollment in any course,
program, or credential offered by Oxbridge ETF Academy
(collectively, the "Services").
Please read this Privacy Policy carefully. By using the Services, you
acknowledge that you have read and understood this policy. If you do
not agree, please do not use the Services.
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1. INFORMATION WE COLLECT
We collect personal information in the following categories:
1.1 Information You Provide Directly
(a) Account and Enrollment Information. When you create an account
or enroll in any Oxbridge ETF Academy program, we collect your full legal name,
email address, mailing address, phone number, and payment information.
Payment card details are processed directly by our third-party payment
processor and are not stored by Oxbridge.
(b) Identity Verification Information. If your course contains a proctored examination, our proctoring vendor collects a photograph of
your government-issued photo identification and a facial image for
identity matching purposes. This information is collected and
processed by the proctoring vendor on our behalf and is subject to
the proctoring vendor's data handling practices as well as our
contractual requirements.
(c) Examination Session Data. During a proctored examination
session, our proctoring vendor records webcam video, audio, and
screen activity for the duration of your session. These recordings
are reviewed by trained human proctors and AI-assisted monitoring
systems to verify compliance with examination policies.
(d) Communications. When you contact us by email or through our
website, we collect the contents of your communications and any
information you choose to provide.
(e) CE and Renewal Submissions. For CE-based courses, when you submit continuing education
logs or renewal documentation, we collect the activity records,
provider information, dates, and supporting documentation you
provide.
1.2 Information Collected Automatically
(a) Usage Data. When you access our website or learning platform,
we automatically collect information about your device and usage,
including IP address, browser type and version, operating system,
referring URL, pages visited, time spent on pages, and links clicked.
(b) Course Progress Data. We track your progress through any course you are enrolled in,
including modules completed, assessment scores, time spent
on each module, and completion dates.
(c) Cookies and Similar Technologies. We use cookies and similar
tracking technologies to operate and improve our website and learning
platform, to remember your preferences, and to analyze usage patterns.
You can control cookies through your browser settings; however,
disabling cookies may affect the functionality of the learning
platform. See Section 9 for more information on cookies.
1.3 Information from Third Parties
(a) Payment Processors. Our payment processor provides us with
transaction confirmation information which may include the last four digits
of your payment method, transaction date, and amount.
(b) Proctoring Vendor. For proctored courses, our proctoring vendor provides us with
examination session reports, behavioral flags, identity verification
results, and, where applicable, session recordings for review.
(c) Digital Credential Platform. Certifier.io, our digital badge provider,
provides us with information about whether you have accepted and
activated your credential badge.
2. HOW WE USE YOUR INFORMATION
We use personal information for the following purposes:
2.1 Program Administration. To process your enrollment in any course or program, provide
access to course materials, administer examinations, issue and
maintain credential records where applicable, process renewal
submissions, and manage your account.
2.2 Identity Verification and Exam Integrity. To verify your identity
before and during examination sessions, to detect and investigate
suspected academic dishonesty, and to maintain the integrity of the
CETFPM® credential program.
2.3 Communications. To send you enrollment confirmations, exam
scheduling information, score reports, credential issuance notices,
renewal reminders, and responses to your inquiries. We may also send you periodic updates about Oxbridge ETF Academy
programs, new course offerings, or credential-related news. You may opt out of non-essential
communications at any time by following the unsubscribe instructions
in our emails.
2.4 Public Credential Registry. To publish and maintain your credential record in the Oxbridge
ETF Academy public verification registry, including your name,
credential ID, credential status, issue date, and expiration date,
where applicable to a credentialing program. Publication in the
public registry is a condition of holding any Oxbridge-issued
credential as described in our Terms and Conditions.
2.5 Legal Compliance and Enforcement. To comply with applicable laws
and regulations, to respond to lawful requests from government
authorities, to enforce our Terms and Conditions, and to protect the
rights, property, and safety of Oxbridge, its users, and the public.
2.6 Program Improvement. To analyze usage patterns, course completion
rates, and examination performance data in aggregate and anonymized
form to improve course content and the credential program.
2.7 Legal Basis for Processing (GDPR). For users in the European
Union or United Kingdom, our legal bases for processing personal
information are as follows:
(a) Contract performance — processing necessary to fulfill our
obligations under your enrollment agreement;
(b) Legitimate interests — processing for program administration,
fraud prevention, and program improvement that does not override
your privacy rights;
(c) Legal obligation — processing required to comply with applicable
law;
(d) Consent — where we rely on consent (such as for marketing
communications), you may withdraw consent at any time without
affecting the lawfulness of prior processing.
3. HOW WE SHARE YOUR INFORMATION
We do not sell your personal information. We share personal
information only in the following circumstances:
3.1 Service Providers. We share personal information with
third-party vendors who provide services on our behalf, including:
(a) Thinkific — learning management system and course delivery
platform (learn.oxbridgeetfacademy.com);
(b) Our payment processor — for payment processing and fraud
prevention;
(c) Our remote proctoring vendor — for examination administration,
identity verification, and session monitoring;
(d) Certifier.io — for digital badge issuance and verification;
(e) Our email service provider — for transactional and
communications emails;
(f) Airtable or similar database provider — for credential record
management.
Each service provider is contractually obligated to use personal
information only for the purposes of providing services to Oxbridge,
to maintain appropriate security measures, and not to disclose
personal information to unauthorized parties.
3.2 Public Credential Registry. Where applicable to a credentialing program, your name,
credential ID, status, issue date, and expiration date are
published in our public verification registry and are accessible to
anyone who queries that registry. This is a condition of holding
the CETFPM® credential and is not limited to specific recipients.
3.3 Legal Requirements. We may disclose personal information if
required to do so by law, regulation, court order, or other legal
process, or if we believe in good faith that such disclosure is
necessary to protect the rights, property, or safety of Oxbridge,
our users, or the public.
3.4 Business Transfers. If Oxbridge is involved in a merger,
acquisition, sale of assets, or other business transaction, your
personal information may be transferred as part of that transaction.
We will notify you by email or prominent notice on our website if
your personal information becomes subject to a different privacy
policy as a result of such a transaction.
3.5 With Your Consent. We may share your personal information for
any other purpose with your explicit consent.
3.6 Employer Verification. If your employer requests verification of a credential or course
completion for reimbursement or compliance purposes, we will
direct them to the public credential registry. We do not provide
employers with any personal information beyond what is publicly
available in the registry without your explicit written consent.
4. DATA RETENTION
We retain personal information for the following periods:
4.1 Account and Enrollment Records. We retain your account and enrollment records for a minimum of
seven (7) years following the expiration, lapse, or revocation of
any credential earned, or seven (7) years following your last
enrollment in any Oxbridge ETF Academy program, whichever is later. This retention period supports
credential verification requests, legal compliance, and enforcement
of our Terms and Conditions.
4.2 Examination Session Recordings. Proctoring session recordings
are retained by our proctoring vendor for up to twelve (12) months
following your examination date, after which they are deleted unless
retained in connection with an active investigation, appeal, or legal
proceeding.
4.3 Identity Verification Data. Government ID images collected during
examination registration are retained by our proctoring vendor for
the minimum period required for identity verification purposes and
are deleted in accordance with the vendor's data retention policies.
4.4 Communications. We retain records of your communications with
us for a period of three (3) years.
4.5 Anonymized Data. We may retain anonymized and aggregated data
derived from your information indefinitely for program improvement
and analytics purposes.
4.6 Public Registry. Where applicable, your credential record in the public registry
is retained indefinitely in its last-known status (Active, Expired,
or Revoked) to support credential verification requests by employers
and compliance departments.
5. DATA SECURITY
Oxbridge implements commercially reasonable technical and
organizational measures to protect personal information against
unauthorized access, disclosure, alteration, or destruction. These
measures include encrypted data transmission (SSL/TLS), access
controls limiting personal information to authorized personnel,
contractual security requirements imposed on service providers, and
regular review of security practices.
No method of electronic transmission or storage is completely secure.
While we strive to protect your personal information, we cannot
guarantee absolute security. In the event of a data breach that is
likely to result in a risk to your rights and freedoms, we will
notify you and applicable regulatory authorities as required by law.
You are responsible for maintaining the security of your account
credentials. Please use a strong, unique password and notify us
immediately if you suspect
unauthorized access to your account.
6. YOUR RIGHTS AND CHOICES
6.1 All Users. Regardless of your location, you have the following
rights with respect to your personal information:
(a) Access. You may request a copy of the personal information we
hold about you.
(b) Correction. You may request correction of inaccurate or
incomplete personal information.
(c) Communication Preferences. You may opt out of non-essential
marketing communications at any time by clicking the unsubscribe
link in our emails.
To exercise these rights, contact us. We will respond within thirty (30) days. We may need to verify your
identity before fulfilling your request.
6.2 European Union and United Kingdom Users (GDPR). If you are
located in the EU or UK, you have additional rights under the General
Data Protection Regulation (GDPR) or UK GDPR:
(a) Right to Erasure ("Right to be Forgotten"). You may request
deletion of your personal information where it is no longer
necessary for the purposes for which it was collected, subject
to our legal retention obligations and our legitimate interests
in maintaining credential integrity records.
(b) Right to Restriction. You may request that we restrict
processing of your personal information in certain circumstances.
(c) Right to Data Portability. You may request a copy of the
personal information you provided to us in a structured,
commonly used, machine-readable format.
(d) Right to Object. You may object to processing of your personal
information based on our legitimate interests. We will cease such
processing unless we have compelling legitimate grounds that
override your interests.
(e) Right to Withdraw Consent. Where processing is based on consent,
you may withdraw consent at any time without affecting the
lawfulness of prior processing.
(f) Right to Lodge a Complaint. You have the right to lodge a
complaint with your local data protection supervisory authority.
For UK users, this is the Information Commissioner's Office (ICO)
at ico.org.uk. For EU users, your local supervisory authority
depends on your country of residence.
Oxbridge LLC serves as the data controller for personal information
processed in connection with the Services. For GDPR inquiries,
contact us directly.
6.3 California Users (CCPA/CPRA). If you are a California resident,
you have the following rights under the California Consumer Privacy
Act (CCPA) as amended by the California Privacy Rights Act (CPRA):
(a) Right to Know. You have the right to request disclosure of the
categories and specific pieces of personal information we have
collected about you, the categories of sources from which it was
collected, the business or commercial purposes for collection,
and the categories of third parties with whom we share it.
(b) Right to Delete. You have the right to request deletion of
personal information we have collected, subject to certain
exceptions including our legal retention obligations and the
necessity of retaining information to complete transactions or
maintain credential records.
(c) Right to Correct. You have the right to request correction of
inaccurate personal information.
(d) Right to Opt Out of Sale or Sharing. We do not sell or share
personal information for cross-context behavioral advertising.
No opt-out is required, but you may contact us to confirm.
(e) Right to Limit Use of Sensitive Personal Information. To the
extent we process sensitive personal information (such as
government ID data collected during examination identity
verification), we use it only for the purpose of providing the
Services and do not use it for inferring characteristics.
(f) Right to Non-Discrimination. We will not discriminate against
you for exercising your CCPA rights. We will not deny you access
to the Services, charge different prices, or provide a different
quality of service because you exercised a privacy right.
To submit a CCPA rights request, contact us with the subject line "California
Privacy Request." We will respond within forty-five (45) days,
with one extension of an additional forty-five (45) days where
reasonably necessary. We will verify your identity before
fulfilling your request.
7. CHILDREN'S PRIVACY
The Services are intended for adults aged 18 and older. We do not
knowingly collect personal information from individuals under the age
of 18. If we become aware that we have inadvertently collected
personal information from a person under 18, we will delete that
information promptly. If you believe we have collected information
from a minor, please contact us at [email protected].
8. INTERNATIONAL DATA TRANSFERS
Oxbridge LLC is based in the United States. If you access the
Services from outside the United States, your personal information
will be transferred to and processed in the United States, where
data protection laws may differ from those in your country.
For users in the EU or UK, transfers of personal information to the
United States are made pursuant to Standard Contractual Clauses
approved by the European Commission, or other appropriate safeguards
as permitted under applicable data protection law. By using the Services, you acknowledge and consent to the
transfer of your personal information to the United States.
9. COOKIES AND TRACKING TECHNOLOGIES
9.1 Types of Cookies We Use.
(a) Strictly Necessary Cookies. These cookies are required for the
operation of our website and learning platform, including
maintaining your login session and enabling core platform
functionality. These cannot be disabled without affecting
platform performance.
(b) Analytics Cookies. These cookies help us understand how visitors
use our website and learning platform, which pages are most
visited, and how users navigate through the course. We use this
information to improve the Services.
(c) Preference Cookies. These cookies remember your settings and
preferences to improve your experience on return visits.
9.2 Managing Cookies. You can manage cookie preferences through
your browser settings. Most browsers allow you to block or delete
cookies. Note that blocking strictly necessary cookies will impair
the functionality of the learning platform. Our website does not
currently respond to browser "Do Not Track" signals.
9.3 Third-Party Cookies. Our service providers, including the
learning platform and analytics tools, may set their own cookies
subject to their respective privacy policies.
10. THIRD-PARTY LINKS
Our website or learning platform may contain links to third-party
websites or services, including the proctoring platform, Certifier.io,
and payment processors. This Privacy Policy does not apply to
third-party websites. We encourage you to review the privacy policies
of any third-party sites you visit. We are not responsible for the
privacy practices or content of third-party sites.
11. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect
changes in our practices, the Services, or applicable law. When we
make material changes, we will post the updated policy on our website
with a new "Last Updated" date and notify enrolled candidates by
email at least thirty (30) days before the changes take effect. Your
continued use of the Services following the effective date of any
changes constitutes your acceptance of the updated Privacy Policy.
We encourage you to review this Privacy Policy periodically. The
current version is always available at oxbridgeetfacademy.com.
12. CONTACT US
If you have questions, concerns, or requests regarding this Privacy
Policy or our handling of your personal information, please use the contact option on our website to contact us.
For EU/UK users wishing to exercise GDPR rights, please use the
same contact information and include "GDPR Request" in the subject
line of your email.
For California users wishing to exercise CCPA rights, please include
"California Privacy Request" in the subject line of your email.
We will acknowledge your request within five (5) business days and
respond fully within the timeframe required by applicable law.
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CETFPM® is a registered trademark of Oxbridge LLC.
© 2026 Oxbridge LLC. All rights reserved.
This policy applies to all courses and programs offered by Oxbridge ETF Academy.
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