Effective: 19 September 2026
1. Who we are
1.1 This policy is issued by Cafe Iman West, LLC, doing business as CIWLEARNING
(“we“, “us“), 80 State Street, Albany, NY 12207, United States.
1.2 It covers drbill360.net (our website and store), portal.ciwlearning.com (our CIWLEARNING site), and lms.drbill360.net (our learning
portal, where courses, clinics, and coaching are delivered).
1.3 Questions or requests: support@ciwlearning.com or +1 (716) 579-7488.
1.4 This policy does not cover the STEP-Up youth program, which uses its own consent and privacy
documents.
2. What we collect
2.1 Account and learning information (learning portal): your name, email address, the courses
you take, your progress, your submissions, grades, and forum posts.
2.2 Clinic submissions. In a Capability Alignment Clinic you write about your work, your
organization, and yourself, and score yourself on a matrix. This can be sensitive. Section 4
explains exactly how it is handled.
2.3 Purchases. For merchandise: your name, shipping address, email, phone number, and order
details. For courses, clinics, and coaching: your name, email, and what you bought. We do not
receive or store your full card number; payments are processed by Stripe and PayPal.
2.4 Newsletter. Your email address and, if you give it, your name. You confirm your subscription
by email before we send anything, and you can unsubscribe from any message.
2.5 Forms and comments. What you type into a contact form or a comment, with the name and email
you provide.
2.6 Technical information. Your IP address, browser and device type, pages visited, and
cookies (section 9). We use this to run, secure, and understand the sites.
3. How we use it
3.1 To provide what you asked for: your account, your courses, your clinic reports, your orders,
and your newsletter.
3.2 To communicate with you about your purchases, your courses, and your reports.
3.3 To keep the sites secure and prevent fraud and spam.
3.4 To improve our programs, using aggregated, de-identified information that cannot identify
you (section 6).
3.5 To meet legal obligations, such as tax and accounting records.
3.6 We do not sell your personal information, and we do not share it for other companies’
advertising.
4. Clinic submissions and AI processing
4.1 Your clinic submissions are read by Dr. William E. Hamilton, Jr. and processed by an AI
system that drafts your report.
4.2 Your name is not sent to the AI. It works from your writing under a case number. Your name
is added to your report on our own systems, after the analysis.
4.3 Our AI provider is Anthropic. Under its commercial terms, the content we send is not used to
train its models.
4.4 Dr. Hamilton can correct or withdraw any report. Reports are released automatically unless a
submission raises a concern that needs a person first.
4.5 No other participant, and no one at your employer, sees your individual work. In the
Organizational clinic, a sponsoring organization receives only an aggregate group report, and only
where the group is large enough that no individual can be identified from it.
4.6 If you give permission in the Organizational clinic, your own earlier Personal or Professional
Clinic reports may inform your organizational profile. They are never used in a group report.
5. Who we share it with
We share personal information only with the service providers who help us run the sites, and only
what each needs:
| Provider | What for |
|---|---|
| Stripe (including through WooPayments) and PayPal | Processing payments |
| Printify, and the carriers it uses | Making and delivering merchandise orders |
| Anthropic | Drafting clinic reports (without your name) |
| Sending our email; site analytics (Google Analytics); spam protection (reCAPTCHA); storing encrypted site backups | |
| Automattic (Jetpack, Gravatar) | Site statistics, login protection, and comment avatars |
| MalCare | Firewall and malware scanning |
| Bitly | Shortening some links we share |
| GoDaddy | Domain and hosting products bought through our reseller store (GoDaddy processes those orders) |
| Gandi (gandi.net) | Hosting the servers the sites run on, in France |
We may also disclose information when the law requires it, or to protect our rights or someone’s
safety.
6. How long we keep it
6.1 Clinic matrices and reports: 12 months, then deleted. Thirty days before deletion we email
you so you can download anything you want to keep. What we keep after that is a de-identified
average (category scores and bands) that cannot be traced to you.
6.2 Accounts: for as long as you have an account, and a reasonable period after.
6.3 Orders and payment records: seven years, for tax and accounting purposes.
6.4 Newsletter: until you unsubscribe.
6.5 Backups: we keep the two most recent backups; each new one replaces the oldest.
7. Where your information is kept
Our servers are in France. Some of the providers in section 5 are in the United States. Where
information about people in the UK or EU is transferred outside those regions, we rely on the
safeguards those providers offer under UK and EU law.
8. How we protect it
All pages are served over encrypted connections. Clinic submissions and reports are held in private
storage that only the report system and Dr. Hamilton can reach. The sites run a firewall and malware
scanning, and are backed up. No system is perfectly secure; if a breach affected you, we would tell
you as the law requires.
9. Cookies
9.1 Necessary cookies keep you logged in, remember your cart, and protect forms from spam.
9.2 Analytics cookies (Google Analytics and Jetpack Stats) help us see which pages are useful.
For visitors in the United Kingdom, the European Economic Area, and Switzerland, Google Analytics is set not to use cookies. You can also block cookies in your browser settings.
9.3 You can block or delete cookies in your browser; the learning portal needs its login cookie to
work.
10. Your choices and rights
10.1 Anyone may ask us for a copy of their information, to correct it, or to delete it; and may
unsubscribe from the newsletter at any time. Clinic participants may ask for their material to be
removed at any time, without giving a reason.
10.2 If you are in the UK or EU, you also have the rights to restrict or object to processing,
to data portability, and to complain to your data protection authority (in the UK, the Information
Commissioner’s Office). Our legal bases are: providing the service you asked for (contract); our
legitimate interests in running and securing the sites; your consent, where we ask for it (such as
the newsletter and the Organizational clinic’s use of earlier reports); and legal obligations.
10.3 Email support@ciwlearning.com. We answer within 30 days.
11. Children
Our courses, clinics, coaching, and store are for adults. We do not knowingly collect information
from anyone under 16. If you believe we have, tell us and we will delete it.
12. Changes
We will post any change here with a new effective date, and tell account holders about significant
changes by email.
13. Contact
Cafe Iman West, LLC (CIWLEARNING) · 80 State Street, Albany, NY 12207 · support@ciwlearning.com ·
+1 (716) 579-7488