Privacy Policy

1. Welcome!

This is the Privacy Policy (“Policy”) of Trainual Inc., an Arizona Corporation (collectively, “we,” “us,” “our,” or “Trainual”). This Policy is here to help you understand how we collect, process, and share your Personal Data (as defined below). We also describe our security practices with respect to your Personal Data, as well as your rights & choices with respect to how we process that Personal Data. Please read this Policy carefully. 

2. Scope & Acknowledgment

This Policy applies to your use of our “Services,” which include the following:

• Our online employee training and learning management platform (“Platform”) which includes related mobile applications (“Mobile Apps”), browser extensions (“Extensions”), and integrations (“Integrations”) and community features (“Community Forum”);  

• Our website, located at https://www.trainual.com/ (the “Corporate Site”); &
• In-person services you use, such as when you contact us via phone or mail for ordering or support.

This Policy doesn’t apply to our Clients or Client Data: We process Personal Data on behalf of our clients who use our Platform (“Clients”). This Policy does not apply to the extent we process Personal Data on behalf of Clients, including where we act as a processor or service provider. For example, if you import an org chart into the Platform, we process the personal data in that org chart on behalf of the Client. 

To learn more about how our Clients process Personal Data, please review the Client’s privacy policy or contact that Client directly. We are not responsible for the privacy or data security practices of our Clients. 

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This Policy doesn’t apply to third party websites and services: Our websites and services may contain links to other websites, applications, and services maintained by third parties, e.g. via Integrations. The information practices of other services, or of social media services that host our branded social media pages, are governed by their privacy policies, which you should review to better understand their privacy practices.‍

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Your use of our Services indicates your acknowledgement of the notices provided in this Policy.

3. Contact Us

The controller of your Personal Data under this Policy is Trainual, Inc. You may contact our privacy team as follows:

• ‍General Inquiries and Data Updates: support@trainual.com 
• Opt-Out of Targeted Advertising /Sharing: Use our Cookie Preferences Tool 
• Regional Data Rights (access, deletion, opt-out of sale): Visit the Privacy Rights Request Form, mail to the address below, or email support@trainual.com.
• Direct Marketing Disclosure Inquiries: Mail to the address below or email support@trainual.com
• Physical Address: Trainual Inc., 410 S Mill Ave Ste 101, Tempe, AZ 85281
• Contact: support@trainual.com 

4. Categories and Sources of Personal Data

4.1 Categories of Personal Data we Process

We collect and process information that relates to identified or identifiable individuals (“Personal Data”) as part of our Services. We collect and process the following categories of Personal Data (note, specific Personal Data elements are examples and may change):

• ‍Audio/Visual Data- Audio files and records, such as voicemails, call recordings, and the like; images that you may provide through the Services.
• Biographical Data- Data relating to professional and employment history, qualifications, and similar biographic information.
• Contact Data- Identity Data used to contact an individual, e.g. email address, physical address, or phone number.
• Device/Network Data- Personal Data relating to your device, browser, or application e.g. device identifiers, identifiers from cookies, session history and website navigation metadata, and other data generated through applications and browsers, including via cookies and similar technologies. 
• General Location Data- Non-precise location data, e.g. location information derived from IP addresses.
• Identity Data- Personal Data about you and your identity, such as your name or IP address.
• Inference Data- Personal Data we create or use as part of a profile reflecting your preferences, characteristics, aptitudes, market segments, likes, favorites or your interests.
• Sensitive Personal Data- Personal Data deemed “sensitive personal information”  or “special categories of personal data” or similar terms under data protection laws. We collect the following categories of Sensitive Personal Data:
  
  • “Payment Data” Personal Data such as bank account details, payment card information, including similar data protected as Sensitive Personal Data under applicable law, and relevant information in connection with a financial transaction.
• Transaction Data- Information about the products and services we provide to you and about transactions you make with us and similar information.
  • User Content- Personal Data included in content provided by users of the Services in any free-form or unstructured format, such as a text in a “contact us” box, in a file or document, or any other message to us.

4.2 Sources of Personal Data

We collect Personal Data from various sources based on the context in which the Personal Data will be processed:

• ‍You- We collect Personal Data from you directly, for example, when you fill out a form, sign up for an account, or contact us directly.
• Your Employer or Colleagues- We may receive Personal Data from other individuals at your organization, for example, we might receive your business contact information for the purposes of validating your eligibility to use the Platform or to create an account, or when you collaborate with others in your organization.
• Automatic Collection- We may collect certain Personal Data automatically. For example, we collect Device/Network Data automatically using cookies and similar technologies when you use our Corporate Site or Platform, use our Extensions or Integrations, or when you open our marketing communications.
• Service Providers- We receive Personal Data from service providers performing services on our behalf, including payment processors, web hosting service providers, or our delivery and installation partners.
• Integrated services- We receive certain Personal Data when you use Integrations with third party platforms (“Integrated Services”), e.g. account or user information, or usage data.
  
  • Data we create or infer- We, certain partners, and third parties operating on our behalf create and infer Personal Data such as Inference Data based on our observations or analysis of other Personal Data processed under this Policy, and we may correlate this data with other data we process about you. 
• Social Media Companies- We receive Personal Data from LinkedIn and other social media companies  when you use social media sign on, or interact with that social media company on or in connection with our Services.

5. Data Processing Contexts/Notice at Collection

5.1 Our Platform

Account Creation; Subscription

We process Identity Data, Contact Data, Device/Network Data, General Location Data, and certain Inference Data when you sign up and create an account with us on the Platform. If you are an administrative user, we may also collect Transaction Data and Payment Data if you subscribe to our services or if you associate payment information with an account. 

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Trainual also allows you to log in to our Platform using Single Sign-On services. These services authenticate your identity and we may collect information, such as a tokenized ID, in order to maintain your login session and grant access to your account. Please refer to the Client or third party provider for information regarding their processing of your Personal Data for that third party account.

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We process this Personal Data to create and maintain your account, to provide the products and services you request, and for our Business Purposes, and where allowed by law, we may process Identity Data, Inference Data, and Contact Data in connection with Marketing Communications. We process Payment Data using third party payment processors, and Trainual does not generally store full payment card or payment account information. We use Payment Data only to facilitate the integration with our payment partners and process payments.

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Please Note: If you access our Platform as an authorized user (for example, as an employee of one of our Clients who provided you with access to our services), this Policy applies only insofar as we act as a controller of your Personal Data. For example, we process most content we receive from Client on behalf of our Client, and our Client’s privacy policy will apply to the processing of that Client data by that Client, and we when process it on their behalf.

Collaboration Features

We process Identity Data, Contact Data, Inference data, Device/Network Data, and User Content when you use the collaboration features of our Platform. For example, we may process comments and messages between users and related accounts. We may collect Audio/Visual Data if you include it in any of your posts in the community or as your profile photo. If you participate in a project, we might send you transactional communications about that project. 

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We process this Personal Data to provide our collaboration features, and for our Business Purposes. We may process Identity Data, Contact Data, Inference data, and Device/Network Data for our Commercial Purposes (which may include data sales/“sharing”).

Integrations

We automatically collect and process Identity Data, Device/Network Data and User Content when you use an Integration between our Platform and Integrated Services. We use this data as necessary to operate and maintain the Integration, monitor usage, initiate or fulfill your requests, to log activities for security purposes, and for other Business Purposes. Please note that we may share certain Personal Data (including User Content)  with the provider of the Integrated Service part of the function of an Integrated Service. Please review the privacy policy for Integrated Services to understand how the provider of the Integrated Service processes your Personal Data.

Extensions

We may also automatically collect and process Identity Data and Device/Network Data when you use our Extensions to access your Trainual account and Trainual content in your browser. We use this data as necessary to connect you with our Platform, authenticate access and maintain sessions, initiate or fulfill your requests, to log activities for security purposes, and for other Business Purposes.

Our Mobile App

We collect and process Identity Data, Contact Data, Device/Network Data, General Location Data, and Inference Data when you access and use our Mobile App. We use this Personal Data as necessary to operate our Mobile App, such as keeping you logged in, delivering content, for information security operations, and our other Business Purposes.

5.2 Use of Software and Websites

Generally

When you access our Corporate Site or use our Platform, we automatically collect and process Identity Data (such as user IDs), Inference Data (such as usage data and analytics), General Location Data, and Device/Network Data (e.g. IP address). We use this data as necessary to provide our services, initiate or fulfill your requests made through our Corporate Site/Platform, to deliver webpages, and logging activities for security purposes. We may also process this Personal Data for our other Business Purposes and, in the case of activity on our Corporate Site, for Commercial Purposes (which may include data sales/“sharing”). See the Cookies and Similar Technologies section below for more information about how we collected data using cookies.

Cookies and Similar Tracking Technologies

We process Identity Data, Device/Network Data, Contact Data, Inference Data, Transaction Data, and General Location Data via cookies and similar technologies when you use our Corporate Site or Platform. We may collect this data automatically. 

We and authorized third parties may use cookies and similar technologies to process such data for the following purposes:

• for “essential” purposes necessary for our Corporate Site or Platform to operate (such as maintaining user sessions, content delivery, and the like);
• for “functional” purposes, such as to enable certain features of our Corporate Site or Platform (for example, to allow users to create custom layouts or store language preferences); 
• for “analytics” purposes and to improve our Corporate Site or Platform, such as to analyze the traffic to and on our Corporate Site or Platform (for example, we can count how many people have looked at a specific page, or see how users navigate the Corporate Site/Platform when they use it, to distinguish unique visits/visitors, and what websites users visited prior to visiting our Corporate Site, and we use this information to understand user behaviors and improve the design and functionality of the Corporate Site/Platform); 
• On our Corporate Site only: for “Targeted Advertising”, or other advertising and marketing purposes, including technologies that process Inference Data or other data so that we can deliver, buy, or target advertisements which are more likely to be of interest to you; and
• On our Corporate Site only: for “social media” integrations e.g. via third-party social media cookies when you use pages on our Corporate Site that integrate with social media websites and services.

We may also process this Personal Data for our Business Purposes and Commercial Purposes (which may include data sales/“sharing”). See the “Rights and Choices” section below for information regarding opt-out rights for cookies and similar technologies.

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Please note: in some cases, third parties may view, edit, or set their own cookies or place web beacons on our Corporate Site. We, or third party providers, may be able to use these technologies to identify you across websites, devices, and services. Third parties have their own privacy policies, and their processing is not subject to this Policy.

5.3 Contact Us; Chat

We process Identity Data, Contact Data, Device/Network Data, and any Personal Data contained within any User Content when you contact us via our contact us form, by phone, by email, or through our AI assistant to discuss our Services, ask a question, or request support. We may process certain Audio/Visual Data if you contact us via phone or leave a voicemail. 

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We process this Personal Data as necessary to communicate with you about the subject matter of your request and related matters. We may also process this Personal Data for our Business Purposes, and, where appropriate, for Commercial Purposes (which may include data sales/“sharing”).

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Note: if you use any AI assistant or chat features, we may use Personal Data you provide us to improve our Services, for example to train the models that power our AI assistant. Review your Rights & Choices for how you can opt out of our use of your Personal Data to train our models.

5.4 Professional Engagements

We process Identity Data, Contact Data, Government ID Data, Biographical Data, and any Personal Data contained in User Content in connection with your application for employment or to become an independent contractor. We may process Health Data, such as disability accommodations, if you provide it.

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We process this Personal Data as necessary to evaluate, establish, and maintain the employment relationship, including, but not limited to, to conduct background checks, to provide employment benefits, and for financial administration. We may also process this Personal Data for human resources purposes, such as managing identity and credentials, administering security and loss prevention, or analyzing and consolidated reporting. We may further process Personal Data in this context for our Business Purposes. We do not sell or “share” Personal Data processed in this context. We process Sensitive Personal Data only for Business Purposes permitted under applicable law.

5.5 Affiliate Program

We process Identity Data, Contact Data, Government ID Data, and Payment Data if you enroll in our affiliate marketing program. We may also collect certain Device/Network information using cookies and similar technologies if you generate or click on an affiliate marketing link, which we will use as necessary to associate conversions between affiliate marketing campaigns and certain key events, such as a click or subscription.  

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We process this Personal Data as necessary to evaluate, establish, and maintain the affiliate relationship, including, but not limited provide reporting and payment for affiliate earnings and related financial administration, and our Business Purposes. We process Payment Data using third party payment processors, and Trainual does not generally store full payment card or payment account information. We use Payment Data only to facilitate the integration with our payment partners and process payments. We process Government ID only as necessary for documentation and tax reporting purposes. We may process Identity Data and Contact Data for our Commercial Purposes, where permitted by law.

5.6 Transactional and Marketing Communications

We process Identity Data, Device/Network Data, and Contact Data in connection with email, SMS, phone, or fax communications that we send in relation to our Services. For example, we send transactional emails communications to you if you create an account on our Platform, subscribe to our Services, or in connection with our delivery of other products or services that you request. 

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Additionally, you may receive promotional email communications if you contact us, choose to receive them, or interact with us in way that allows us to send you those communications (“Marketing Communications”). We may also automatically collect Device/Network Data when you open or interact with our communications so that we can better understand engagement with our communications.

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We may also process this Personal Data for our Business Purposes, and, where appropriate, our Commercial Purposes (which may include data sales/“sharing”). You can opt out of Marketing Communications and other data collection related to our communications at any time as specified in the “Rights & Choices” section below. We do not share Contact Data collected in connection with Trainual’s SMS Marketing Communications with third parties, other than service providers acting on our behalf, unless you expressly consent.

5.7 Feedback, Surveys, and Reviews

We process Identity Data, Contact Data, and User Content collected in connection with customer surveys or questionnaires. We process this Personal Information as necessary to respond to customer requests/concerns, for our Business Purposes, and other legitimate interests, such as analyzing customer satisfaction and improving our Services. 

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Where appropriate, we may process this Personal Data for our Commercial Purposes (which may include data sales/“sharing”). We may share Feedback data relating to third party services (e.g. Integrated Service providers) with those providers, who may use it for their own purposes.

5.8 Events and Webinars

We process Identity Data, Contact Data, and Transaction Data when you register for and attend an event, webinar, or download certain content. We may also process User Content if you provide it to us as part of the event or your participation.

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We process this Personal Data to plan and host the event or webinar for which you have registered or that you attend, including sending related communications to you, to tailor the presentation, to respond to your requests, and for our Business Purposes and Commercial Purposes (which may include data sales/“sharing”).

5.9 Social Media 

We process Identity Data, Contact Data, and User Content if you interact with or identify us on social media (e.g. if you post User Content that engages with or tags our official accounts). We process this Personal Data for our Business Purposes and Commercial Purposes (which may include data sales/“sharing”).

5.10 Contests

We may collect and process Identity Data, Preference Data, certain Contact Data, and User Content when you enter a contest.

We process this Personal Data as necessary to provide the contest/promotion, notify you if you have won, or to process delivery of a prize, for our Business Purposes, and other legitimate interests, such as:

• verifying your identity for authentication, anti-fraud, and security purposes (in which case we may process Government ID Data to complete verification);
• to improve our Services and to create a personalized user experience; and
• to contact you about relevant products or services, and in connection with marketing communications and Targeted Advertising.

We may process Identity Data, Contact Data, and User Content information for our Commercial Purposes (which may include data sales/“sharing”).

Some programs and offers are operated/controlled by our third-party partners or their affiliates or partners. We may receive this data from third parties to the extent allowed by the applicable partner; otherwise, this Policy will not apply to data processed by third parties.

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Your Personal Data may be public. If you win a contest, we may publicly post some of your data. We do not post Personal Data without consent where required by law. See any program agreement(s) for additional details and terms.

6. Purposes of Processing

6.1 Business Purposes

In addition to the processing described above, we generally process Personal Data for several common purposes in connection with our business. Please see below for more information regarding the purposes for which we process your Personal Data.

Operate our Service and Fulfill Obligations

We process any Personal Data as is necessary to provide the Services, and as otherwise necessary to fulfill our obligations to you, e.g. to provide you with the information, features, and services you request.

Internal Processes and Service Improvement

We may use any Personal Data we process through our Services as necessary in connection with our improvement of the design of our Services, understanding how the Services are used, for customer service purposes, in connection with the creation and analysis of logs and metadata relating to Service use, and for ensuring the security and stability of the Services. Additionally, we may use Personal Data to understand what parts of our Services are most relevant to users, how users interact with various aspects of our Services, how our Services perform or fail to perform, etc., or we may analyze use of the Services to determine if there are specific activities that might indicate an information security risk to the Services or our users. 

Security and Incident Detection

We may process Personal information in connection with our legitimate interest in ensuring that our Services are secure, identify and prevent crime, prevent fraud, and verify or authenticate users/individuals, and ensure the safety of our guests. Similarly, we process Personal information as necessary to detect security incidents, protect against, and respond to malicious, deceptive, fraudulent, or illegal activity. We may analyze network traffic, device usage patterns and characteristics, maintain and analyze logs and process similar Personal information in connection with our information security operations and related processes.

Aggregate Data

We process Personal Data as necessary in connection with our creation of aggregate analytics relating to how our Service are used, the pages and content users view, and to create other reports regarding the use and performance of our Platform and other Services, and other similar information and metrics. The resulting aggregate data will not contain information from which an individual may be readily identified. 

Compliance, Safety & Public Interest

Note that we may, without your consent or further notice to you, and to the extent required or permitted by law, process any Personal Data subject to this Policy for purposes determined to be in the public interest or otherwise required by law. For example, we may process information as necessary to fulfil our legal obligations, to protect the vital interests of any individuals, or otherwise in the public interest or as required by a public authority. Please see the data sharing section for more information about how we disclose Personal Data in extraordinary circumstances.

6.2 Commercial Purposes

We and certain third parties process Personal Data to further our commercial or economic interests (“Commercial Purposes,”) depending on the context of collection and your Rights & Choices. 

Please Note – We may require your consent, or we may not engage in processing of Personal Data for Commercial Purposes in some jurisdictions. Some of this processing may involve “sales” or “sharing” of Personal Data. See the “Regional Supplements” section below for more information.

Personalized Marketing Communications 

Our marketing communications may be personalized based on certain Inference Data that we create in certain contexts, as described above. In those contexts, we may also process your Personal Data to conduct marketing research, advertise to you, provide personalized information about us on and off our websites and to provide other personalized content based upon your activities and interests. 

Targeted Advertising 

We and our third party advertising providers may engage in display advertising or place third party advertisements for third parties’ products and services on our Services. Such advertising may involve the processing of Personal Data in order to tailor the advertisements you see based on your interests (“Targeted Advertising”). The profiles and interests used for Targeted Advertising may be inferred or derived from Personal Data that we or those third parties obtain or infer from your activities across non-affiliated websites, applications, or services (e.g. through Cookies and Similar Technologies). Note that Targeted Advertising includes various parties and service providers, including third party data controllers, engaged in the processing of Personal Data in connection with Targeted Advertising. These parties may be able to identify you across websites, devices, and over time. In some cases, these third parties may build or augment user profiles using your Personal Data, and may track whether you view, interact with, or how often you have seen an ad, or whether you purchased advertised goods or services.

7. Data Sharing

Personal Data we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer data to the categories of recipients or in connection with specific business purposes, described below.

Service Providers

In connection with our general business operations, product improvements, to enable certain features, and in connection with our other lawful business interests, we may share Personal Data with service providers or subprocessors who provide certain services to us, or process data on our behalf. For example, we may use third parties who provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment. 

Affiliates

In order to streamline certain business operations and develop products and services that better meet the interests and needs of our customers, we may share your Personal Data with any of our current or future affiliated entities, subsidiaries, and parent companies. 

Event Sponsors

If you attend an event or webinar organized by us, or download or access an asset on our service, we may share your Personal Data with sponsors of the event. If required by applicable law, you may consent to such sharing via the registration form.

Integrated Services

We share certain information with the providers of Integrated Services. For example, we may make available data relating to service use, or we may facilitate the sharing of Personal Data with that provider by virtue of an Integration. Please note that we do not control Client data or the privacy practices of our Clients or Integrated Service providers. Please see their respective privacy policies for more information.

Social Media Companies 

We may share or make available certain Personal Data with social media companies when you interact with Trainual on social media. We may allow these third parties to operate through our Services, such as through a social media icon link on our homepage. We do not share Contact Data collected in connection with Trainual’s Marketing Communications with these parties.

Professional Advisers

In individual instances, we may share your Personal Data with professional advisers acting as service providers, processors, or independent controllers – including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share your Personal Data.

Public Disclosure

If you post on our community forum or otherwise interact with us or our Services via social media, we may make your post available on our Services or to the general public. We may share, rebroadcast, or redisplay Personal Data or other information in the post to the extent permitted by the relevant social media service.

Corporate Events

Your Personal Data may be disclosed to a third party in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.

Legal Disclosures

In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data, our correspondence with you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, or in the vital interests of us or any person. Note, these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Data as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Data to such parties.

Public Disclosure

If you post on our community forum, leave  a testimonial, or otherwise interact with us or our Services via social media, we may make the certain User Content, including nay Personal data in it, publicly available on our Services or pages we maintain on third party sites (e.g. social media) to the extent permitted by the relevant third party service.

8. Your Rights & Choices

8.1 Your Rights

You may have certain rights and choices regarding the Personal Data we process. Please note, these rights may vary based on the country or state where you reside, and our obligations under applicable law. All users may exercise the rights described in this section. If you reside in certain regions, please see the sections below for more information regarding your rights/choices in your region:

• US States/California
• EU/EEA/UK/Switzerland

Note: We are only able to fulfill rights requests regarding Personal Data that we control or that is processed on our behalf. We are not allowed to directly fulfill rights requests with respect to Personal Data controlled by our Clients, providers of Integrated Services, or other third-party data controllers. Please contact the third party directly to exercise your rights in third party-controlled information. 

8.2 Verification of Rights Requests

We verify all rights requests to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your Personal Data. For example, we may require that you verify that you have access to the email on file in order to verify your identity. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.

8.3 Your Choices

You may have the following choices regarding the Personal Data we process, to the extent required under applicable law:

Consent

If we rely on your consent to our processing of Personal Data, you may withdraw your consent at any time. You may be required to close your account in order to withdraw consent where your consent is necessary to perform essential aspects of our Services. 

Marketing  Communications

You can withdraw your consent to receive Marketing Communications by clicking on the unsubscribe link in an email (for email), by responding with “OPT-OUT”, "STOP", or other supported unsubscribe message (for SMS), or for other communications, by contacting us using the information below. To opt-out of the collection of information relating to email opens, configure your email so that it does not load images in our emails.

Cookies & Similar Technology

If you do not want information collected through the use of cookies, you can manage/deny cookies (and certain technologies) using your browser’s settings menu or our "Manage Cookie Preferences" page. You may need to opt out of third-party services directly via the third party. For example, to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Policy, or Google Analytics Opt-out.

Targeted Advertising

You may opt out or withdraw your consent to Targeted Advertising by visiting our Cookie Preferences Tool. In some cases, you may be able to opt-out by submitting requests to third party partners, including via the following platforms or services:

• Digital Advertising Alliance’s opt-out
• Network Advertising Initiative opt-out
• Google Ads
• Meta Pixel
• LinkedIn Ads
• TikTok Ads
• Bing Ads
• Amazon Ads
• G2 Ads

Global Privacy Control (GPC)

Our Services may support certain automated opt-out controls, such as Global Privacy Control (“GPC”). GPC is a specification designed to allow Internet users to notify businesses of their privacy preferences, such as opting-out of the sale/“sharing” of Personal Data. To activate GPC, users must enable a setting or use an extension in the user’s browser or mobile device. Please review your browser or device settings for more information regarding how to enable GPC.

Please note: We may not be able to link GPC signals to your Personal Data in our systems, and as a result, some sales/“sharing” of your Personal Data may occur even if GPC is active. See the “Regional Supplements” section below for more information regarding other opt-out rights.

Do Not Track

Our websites do not respond to your browser’s do not track signal. ‍

9. Security

We implement and maintain reasonable security measures to safeguard the Personal Data you provide us. We do not warrant perfect security and we do not provide any guarantee that your Personal Data or any other information you provide us will remain secure. 

10. Data Retention

We retain Personal Data for so long as it is reasonably necessary to achieve the relevant processing purposes described in this Policy, or for so long as is required by law. What is necessary may vary depending on the context and purpose of processing. We generally consider the following factors when we determine how long to retain data (without limitation):

• Retention periods established under applicable law;
• Industry best practices;
• Whether the purpose of processing is reasonably likely to justify further processing;
• Risks to individual privacy in continued processing;
• Applicable data protection impact assessments;
• IT systems design considerations/limitations; and
• The costs associated with continued processing, retention, and deletion.

We will review retention periods periodically and may pseudonymize or anonymize data held for longer periods.

11. International transfers 

We operate in and use service providers located in the United States and other countries. If you are located outside the U.S., your Personal Data may be processed in the U.S. and other locations where our service providers may be located. The U.S. may not provide the same legal protections guaranteed to Personal Data in foreign countries. Contact us for more information regarding transfers of data to the U.S.

‍12. Children

Our Services are neither directed at nor intended for use by persons under the age of 18. We do not knowingly collect information from such individuals. If we learn that we have inadvertently done so, we will promptly delete such Personal Data if required by law. Do not access or use our Services if you are not of the age of majority in your jurisdiction.

13. Changes to Our Policy

We may change this Policy from time to time. Please visit this page regularly so that you are aware of our latest version. Your use of our Services following notice of any changes indicates acceptance of any changes.

14. Regional supplements

14.1 US States /Your California Privacy Rights

Click the following link to review our disclosure relating to Data Retention.

Data Rights

Under the California Consumer Privacy Act (“CCPA”) and other state privacy laws, residents of certain US states may have the following rights, subject to your submission of an appropriately verified request:

• Confirm- Right to confirm whether we process your Personal Data. ‍
  
  • Access/Know- Right to request any of following:
    
    • (1) the categories of Personal Data we have collected, sold or “shared,” or disclosed for a commercial purpose;
    • (2) the categories of sources from which your Personal Data was collected;
    • (3) the purposes for which we collected or sold or “shared” your Personal Data;
    • (4) the categories of third parties to whom we have sold or “shared” your Personal Data, or disclosed it for a business purpose; and
    • (5) the specific pieces of Personal Data we have collected about you.‍
  • Portability- Right to request that we provide certain Personal Data in a common, portable format. ‍
  • Deletion- Right to delete certain Personal Data that we hold about you.‍
  • Correction- Right to correct certain Personal Data that we hold about you.‍
• Opt-Out (Sales, Sharing, Targeted Advertising, Profiling) - Right to opt-out of the following: 
  
  • If we engage in sales of data (as defined by applicable law), you may direct us to stop selling Personal Data.
  • If we engage in Targeted Advertising (aka “sharing” of personal information or cross-context behavioral advertising,) you may opt-out of such processing. 
  • If we engage in certain forms of “profiling” (e.g. profiling that has legal or similarly significant effects), you may opt-out of such processing.‍

• Opt-out or Limit Use and Disclosure of Sensitive Personal Data- right to opt-out of the processing of certain Sensitive Data, or request that we limit certain uses of Sensitive Personal Data. This right does not apply in cases where we only use Sensitive Personal Data where necessary, or for certain business purposes authorized by applicable law.

• ‍Opt-Out of Targeted Advertising /Sharing‍
  
  • You may visit our Cookie Preferences Tool  
  • Note: You may enable Global Privacy Control (GPC) to opt out of data sales or “sharing” using Cookies and Similar Technologies. Services supporting GPC (or similar standards) will treat the request as a request to opt-out of such sales or “sharing”
• Access/Know; Confirm Processing; Portability; Deletion; Opt-Out; Correction; Limit use of Sensitive Personal Data‍
  
  • You may visit our Privacy Rights Request Form‍
  • Contact us via email at support@trainual.com‍
  • Mail to: Trainual Inc., Attn: Privacy, 410 S Mill Ave Ste 101, Tempe, AZ 85281 ‍
• List of Direct Marketers; Remove Minors’ User Content
  
  • Contact us via email to our privacy team at support@trainual.com

Submission of Requests

You may submit requests, as follows (please our review verification requirements section). If you have any questions or wish to appeal any refusal to take action in response to a rights request, contact us at support@trainual.com. We will respond to any request to appeal within the time period required by law:

• Opt-in/Opt-out of Sale/Sharing of Minors’ Personal Data- To the extent we have actual knowledge that we collect or maintain personal information of a minor under age 16 in California, those minors must opt in to any sales or “sharing” of personal information (as defined under CCPA), and minors under the age of 13 must have a parent consent to sales or “sharing” of personal information. All minors have the right to opt-out later at any time.Non-Discrimination
  
  • Non-Discrimination- California residents have the right to not to receive discriminatory treatment as a result of your exercise of rights conferred by the CCPA.
  • List of Direct Marketers- California residents may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year.
  • Remove Minors’ User Content- Residents of California under the age of 18 can delete or remove posts using the same deletion or removal procedures described above, or otherwise made available through the Services. If you have questions about how to remove your posts or if you would like additional assistance with deletion, contact us using the information below. We will work to delete your information, but we cannot guarantee comprehensive removal of that content or information posted through the Services.

14.2 EU/EEA/UK/Switzerland/Cayman Islands

Scope

This section applies only to individuals located in the EEA, UK, Switzerland, and other countries (excluding the US and Australia) where individuals have a right to the information or to exercise rights in Personal Data as specified below (“Non-US Individuals”). 

Controller

The controller of Personal Data collected under this Policy is: Trainual Inc., 410 S Mill Ave Ste 101, Tempe, AZ 85281

Rights & Choices 

Residents of the EU/EEA, UK, Switzerland, and the Cayman Islands have the following rights. Please review our verification requirements. Applicable law may provide exceptions and limitations to all rights.

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Access- You may have a right to access the Personal Data we process.

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Consent– To the extent we rely on your consent to process Personal Data, you may withdraw your consent at any time. We may continue processing on alternative or additional legal bases. Withdrawal of consent does not affect the lawfulness of processing undertaken prior to withdrawal.

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Deletion - You may request that we delete your Personal Data. We may delete your data entirely, or we may anonymize or aggregate your information such that it no longer reasonably identifies you.

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Data Export - You may request that we send you a copy of your Personal Data in a common portable format of our choice.

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Fate of your data - If you live in France, you have the right to set guidelines for your Personal Data after your death.

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Restriction - You may request that we restrict the processing of Personal Data to what is necessary for a lawful basis.

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Objection - You may have the right under applicable law to object to any processing of Personal Data based on our legitimate interests. We may not cease or limit processing based solely on that objection, and we may continue processing where our interests in processing are appropriately balanced against individuals’ privacy interests. In addition to the general objection right, you may have the right to object to processing:

• for Profiling purposes (if we engage in such processing);
• for direct marketing purposes, e.g. Marketing Communications (we will cease processing upon your objection); and
• involving automated decision-making with legal or similarly significant effects (if any)

Rectification - You may correct any Personal Data that you believe is inaccurate.

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Regulator Contact - You have the right to file a complaint with regulators about our processing of Personal Data. To do so, please contact your local data protection or consumer protection authority. 

Submission of Requests

• Withdraw consent to Targeted Advertising 
  
  • You may disable Targeted Advertising as described in the Cookies and Similar Technology Choices section above.
  • You may enable Global Privacy Control (GPC) to opt out of Targeted Advertising/“sharing”. Services supporting GPC (or similar standards) will treat the request as a request to opt-out of Targeted Advertising/“sharing” on the device where the GPC setting is active.
• Access, Rectification, Data Export, Deletion, Restriction, Correction, or to Withdraw Consent, or, for French residents, Fate of Data (see above for withdrawing consent in specific contexts)
  
  • You may visit our Privacy Rights Request Form‍
  • Contact us via email at support@trainual.com‍
  • Mail to: Trainual Inc., Attn: Privacy, 410 S Mill Ave Ste 101, Tempe, AZ 85281