Privacy Policy

FifthWhy, LLC, a Wisconsin limited liability company doing business as CEWisconsin ("CEWisconsin," "we," "us," or "our"), respects your privacy. This Privacy Policy describes how we collect, use, disclose, and protect personal information when you visit cewisconsin.com, create an account, enroll in a continuing education course, or otherwise interact with our services (collectively, the "Services").

CEWisconsin is a continuing education provider approved by the Wisconsin Office of the Commissioner of Insurance (the "OCI"), Provider #20781. Because we operate under state insurance regulatory oversight and report continuing education ("CE") credits to state regulators, the way we handle your personal information is shaped both by your privacy preferences and by what state law requires us to collect, retain, and report.

When you create an account, enroll in a course, contact us, or use the CEWiz chatbot, you may provide the following:

• Identity and contact information: full legal name, email address, mailing address, telephone number (if provided).
• Insurance licensing information: National Producer Number (NPN), state license number(s), license type, resident state, and (where required for state reporting) date of birth.
• Account credentials: username and password.
• Course activity: courses enrolled, time spent, test answers, test scores, and the electronically signed affidavit of completion.
• Payment information: billing name, billing address, and payment method details. Card numbers and bank details are processed by our third-party payment processor and are not stored on CEWisconsin servers.
• Communications: messages you send to support, comments submitted in feedback forms, and your conversations with the CEWiz chatbot.

When you visit the website, we automatically collect certain technical information, including:

• Internet protocol (IP) address, approximate geographic location derived from IP, browser type and version, operating system, device type, and screen resolution.
• Pages viewed, time spent on pages, referring URL, click activity, and session duration.
• Course-progress telemetry: pages completed, video watch time, quiz attempts, and timestamps used to verify time-on-content for OCI compliance.
• Email engagement: whether marketing or transactional emails were opened or clicked, captured through tracking pixels and unique link parameters.
• Cookies and similar technologies (see Section 5).

We may receive information about you from third parties, including:

• State insurance regulators and licensee databases (for example, the National Insurance Producer Registry and Sircon), to verify license status and ensure accurate CE credit reporting.
• Payment processors, who confirm whether a transaction succeeded and provide limited card metadata (such as the last four digits and card brand).
• Referral and affiliate partners (for example, partner CE programs that refer customers to courses on our website).

We use your information for the following purposes:

• Service delivery: to create and maintain your account, deliver the courses you enrolled in, track your progress, score tests, generate certificates of completion, and verify identity.
• CE credit reporting: to report completed CE credits to Wisconsin OCI and, where applicable, to other state insurance regulators with whom CEWisconsin has reciprocity. This is a regulatory requirement, not an optional use.
• Payment processing: to process course purchases, refunds, and chargebacks through our payment processor.
• Communications: to send transactional emails (receipts, course-progress notices, reporting confirmations, and account-related messages) and, with your consent, marketing emails (renewal reminders, new course announcements, special offers).
• Customer support: to answer your questions, respond to chatbot conversations, and resolve issues.
• Service improvement: to analyze usage, diagnose technical problems, evaluate course quality, and improve content.
• Legal and regulatory compliance: to comply with applicable laws, respond to lawful requests from regulators or law enforcement, defend our legal rights, prevent fraud, and enforce our Terms of Service.
• Business operations: recordkeeping, accounting, audits, business continuity, and (if applicable) preparation for or completion of a business transaction such as a sale, merger, or financing.

We share information with third-party service providers who perform services on our behalf and who are contractually obligated to protect your information. These include:

• Payment processor(s) for transaction processing and fraud prevention.
• Hosting and infrastructure providers that operate our servers and databases.
• Email delivery providers that send transactional and marketing messages.
• Analytics providers that help us understand site usage.
• Artificial intelligence (AI) providers that power features such as the CEWiz chatbot and license matching (see Section 6).
• Professional advisors (accountants, attorneys, auditors) acting under duty of confidentiality.

We may share your name, NPN, and license information with insurance regulator and licensee verification networks (for example, the NIPR and equivalent state systems) to verify your license and report CE credit accurately.

We may disclose information when we believe in good faith that disclosure is necessary to comply with a subpoena, court order, regulatory inquiry, or other legal process; to enforce our Terms of Service; to detect, prevent, or address fraud or security issues; or to protect the rights, property, or safety of CEWisconsin, our customers, or the public.

If CEWisconsin or its parent, FifthWhy, LLC, is involved in a merger, acquisition, financing, reorganization, sale of assets, or bankruptcy, your information may be transferred as part of that transaction. We will notify you (for example, by email or website notice) before your information becomes subject to a different privacy policy.

We may share your information for any other purpose with your consent.

We use cookies, web beacons, tracking pixels, and similar technologies for the following purposes:

• Strictly necessary cookies that enable login sessions, cart functionality, and security.
• Functional cookies that remember your preferences.
• Analytics cookies that help us understand how customers use the site.
• Email tracking pixels and unique URL parameters (such as UTM tags) that tell us whether marketing emails were opened, which links were clicked, and which campaigns generated visits to the site.

Most browsers allow you to refuse or delete cookies through browser settings. Disabling strictly necessary cookies may prevent you from logging in or completing course content. You may also opt out of marketing emails using the unsubscribe link in those messages; opting out of marketing does not stop transactional or regulatory messages.

Our website does not currently respond to "Do Not Track" browser signals because no industry standard has been finalized for how websites should interpret them.

CEWisconsin uses third-party AI services to power certain features, including the CEWiz customer-service chatbot and the license-matching tool that helps verify customer licensing information. These AI services are provided by reputable AI vendors operating under their own privacy and security commitments.

When you interact with CEWiz or use a feature powered by AI, the content of your message and the relevant context may be transmitted to the AI provider so that a response can be generated. CEWisconsin instructs its AI providers not to use customer conversations to train their general-purpose models, and we do not knowingly send sensitive information (such as Social Security numbers or full payment card numbers) to AI providers. You should not enter sensitive information into the chatbot.

AI responses may be incomplete or incorrect. CEWiz is not a substitute for direct human support, regulatory guidance from OCI, or professional advice. For authoritative answers about your CE status, license, or compliance obligations, contact Wisconsin OCI directly at oci.wi.gov.

We retain your personal information for as long as necessary to (a) provide the Services, (b) comply with our regulatory recordkeeping obligations to Wisconsin OCI and other state regulators, (c) maintain accounting and tax records, and (d) defend or assert legal rights. Specifically:

• Account information is retained while your account is active and for a reasonable period thereafter.
• Course completion records, test scores, and affidavits are retained for at least the period required by Wisconsin OCI and any applicable state regulator.
• Payment and tax-related records are retained for the period required by federal and Wisconsin tax law.
• Marketing-engagement and analytics data are retained for as long as they remain useful for business analysis.

After applicable retention periods expire, we will delete, anonymize, or aggregate your information.

CEWisconsin uses commercially reasonable administrative, technical, and physical safeguards designed to protect your information, including transport encryption (HTTPS/TLS), restricted server access, account-level password protection, server-side rate limiting, and protection against common web vulnerabilities such as SQL injection and cross-site request forgery.

No method of transmission over the internet or method of electronic storage is one hundred percent secure. We cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for promptly notifying us if you suspect unauthorized account access.

You may log in to your account at any time to review and update your personal information, license details, and contact preferences. You may also request a copy of the personal information we hold about you by emailing the address in Section 13.

You may request deletion of your account and personal information at any time. Please note that we are required by Wisconsin OCI and other state regulators to retain certain records (including completion records and affidavits) even after account deletion. We will delete or anonymize what we can while retaining what regulation requires.

You may opt out of marketing emails by clicking the unsubscribe link in any marketing message or by contacting us. Opting out of marketing does not stop transactional, regulatory, or account messages.

If you are a resident of a state with a comprehensive consumer privacy law (such as California, Colorado, Virginia, Connecticut, or Utah), you may have additional rights, including the right to know, the right to correct, the right to delete, the right to opt out of certain processing, and the right to non-discrimination for exercising these rights. To exercise any such right, contact us at the address in Section 13. We will respond consistent with applicable law.

Where applicable law allows, you may use an authorized agent to make a privacy request on your behalf. We may require verification that the agent is authorized to act for you and that the request is genuine.

The Services are intended for adults aged eighteen (18) and over. CEWisconsin does not knowingly collect personal information from children under thirteen (13). If we learn that we have collected information from a child under thirteen, we will delete it. Parents or guardians who believe their child has provided personal information to us should contact us at the address in Section 13.

CEWisconsin operates from the State of Wisconsin in the United States. If you access the Services from outside Wisconsin or outside the United States, your information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those of your jurisdiction. By using the Services, you consent to this transfer.

CEWisconsin may update this Privacy Policy from time to time. The current version will be posted at cewisconsin.com with an updated "Last Updated" date. For material changes, CEWisconsin will provide reasonable notice by email or through the website. Your continued use of the Services after the effective date of changes constitutes your acceptance of the revised Policy.

This Privacy Policy is incorporated by reference into the CEWisconsin Terms of Service. Capitalized terms not defined here have the meanings given in the Terms of Service.