Privacy Policy

2.1 Information You Provide Directly

When you register for an account, request a demo, submit an inquiry, or use the Platform, we may collect:

• Account information: name, work email address, job title, organization name, phone number, and password.
• Billing and payment information: billing address and payment method details. Payment processing is handled by a third-party payment processor; we do not store full card numbers.
• Profile information: role, department, reporting relationships, and preferences you configure in the Platform.
• Communications: messages you send to us via email, support tickets, or contact forms.
• Customer-uploaded content: training courses, learning paths, coaching notes, performance documentation, or other materials you upload to the Platform.

2.2 Information Collected Automatically

When you use the Platform, we automatically collect certain technical and usage information, including:

• Log data: IP address, browser type and version, operating system, referring URLs, pages visited, and timestamps.
• Device information: device type, unique device identifiers, and network information.
• Learning and training activity data: course enrollments, launch records, completion status, assessment scores, time spent on content, ILT session attendance, and certification records. This data is used to provide reporting, compliance tracking, and analytics services.
• Coaching and performance data: coaching session records, goal progress, feedback submissions, and development plan activity, where applicable to the modules you have licensed.
• Cookies and similar technologies: we use cookies and similar tracking technologies to maintain sessions, remember preferences, and analyze usage. See Section 9 for more details.

2.3 Information from Third Parties

We may receive information about you from:

• Your employer or organization (our Customer), which may provide your name, email, role, and organizational structure when provisioning your access to the Platform.
• Third-party HRIS, payroll, or HR platforms that you connect to the Platform via API or integration, which may pass user context data as part of the connection.
• Performance management and related systems that feed data into or receive data from the Platform as part of a Customer's integrated HR technology stack.
• Marketing and analytics partners who provide aggregated insights to help us improve our services.

2.4 Sensitive Information

We do not intentionally collect sensitive personal information such as racial or ethnic origin, religious beliefs, health information, or financial account numbers. Please do not submit such information through the Platform.

3.1 Providing and Improving the Platform

• Creating and managing your account.
• Delivering training content, LMS functionality, ILT scheduling, coaching programs, and credential tracking.
• Generating completion records, certificates, and compliance reports.
• Providing HRIS and third-party system integration services.
• Powering TrAI™ analytics, recommendations, and manager insights.
• Troubleshooting technical issues and providing customer support.
• Improving the Platform's features, performance, and user experience.

3.2 Communications

• Sending transactional emails such as account creation confirmations, password resets, course enrollment notifications, and certification expiry reminders.
• Sending administrative notices related to your account or the Platform.
• Sending marketing communications about our products and services, where you have given consent or where we have a legitimate interest to do so. You may opt out at any time by clicking the unsubscribe link in any marketing email or by contacting us at support@trainery.ai.

3.3 Analytics and Research

• Analyzing usage patterns to understand how the Platform is used and to identify areas for improvement.
• Generating anonymized and aggregated statistics that do not identify individual users ("Aggregate Data"). Aggregate Data may be used internally or shared with partners.

3.4 Legal and Compliance

• Complying with applicable law, regulation, legal process, or government request.
• Enforcing our Terms of Use and other agreements.
• Protecting the rights, property, and safety of Trainery, our users, and the public.

3.5 Legal Basis for EEA and UK Users

If you are located in the European Economic Area (EEA) or the United Kingdom, we process your personal data on the following legal bases: (a) performance of a contract, to provide the Platform and Services you have requested; (b) legitimate interests, to improve our Platform, communicate with you, and prevent fraud; (c) consent, for marketing communications; and (d) legal obligation, to comply with applicable laws. You may withdraw consent at any time without affecting the lawfulness of prior processing.

4.1 With Your Organization

If you access the Platform as an employee or learner under a Customer account, your learning activity data, ILT attendance, coaching records, completion records, and certification status may be visible to your organization's administrators. We are a data processor in this context and act on your organization's instructions as the data controller.

4.2 With Service Providers

We share information with third-party vendors who help us operate the Platform, including:

• Cloud hosting and infrastructure providers.
• Payment processors for billing and subscription management.
• Email and communication service providers.
• Analytics and performance monitoring tools.
• Customer support platforms.

All service providers are bound by contractual obligations to protect your information and use it solely for the purposes for which they have been engaged.

4.3 Business Transfers

If Trainery is involved in a merger, acquisition, asset sale, or restructuring, your information may be transferred to the acquiring entity. We will notify registered users of any such transfer and any material changes to how your information is used.

4.4 Legal Disclosures

We may disclose your information if required by law, legal process, or government request, or if we believe in good faith that disclosure is necessary to: (a) comply with a legal obligation; (b) protect the rights or property of Trainery; (c) prevent or investigate fraud or security incidents; or (d) protect the safety of our users or the public.

4.5 With Your Consent

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

7.1 General Rights

• Access: request a copy of the personal information we hold about you.
• Correction: request that we correct inaccurate or incomplete information.
• Deletion: request that we delete your personal information, subject to legal retention requirements and any obligations under your organization's data processing agreement.
• Restriction: request that we restrict processing of your information in certain circumstances.
• Data portability: request your personal information in a structured, machine-readable format.
• Objection: object to our processing of your information where we rely on legitimate interests.

7.2 California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including the right to:

• Know what personal information we collect, use, and disclose about you.
• Delete your personal information.
• Opt out of the sale or sharing of your personal information. (We do not sell personal information.)
• Non-discrimination for exercising your privacy rights.
• Limit the use of sensitive personal information.

To exercise your California privacy rights, submit a request to support@trainery.ai or call 800.397.5215. We will respond within forty-five (45) days as required by law.

7.3 EEA, UK, and Switzerland Residents (GDPR)

If you are located in the EEA, UK, or Switzerland, you have rights under the General Data Protection Regulation (GDPR) or equivalent legislation, including those listed in Section 7.1. You also have the right to lodge a complaint with your local data protection authority. We aim to respond to rights requests within thirty (30) days.

7.4 How to Submit a Request

To exercise any of the rights described in this Section, please email support@trainery.ai with the subject line "Privacy Rights Request." We may need to verify your identity before processing your request. We will not discriminate against you for exercising your privacy rights.

9.1 Managing Cookies

You can control cookies through your browser settings. Disabling essential cookies may prevent certain features from functioning. Most browsers allow you to refuse third-party cookies. For more information on managing cookies, visit your browser's help section.

We do not currently respond to Do Not Track (DNT) signals, as there is no established industry-standard interpretation. We will update this position if a recognized standard is established.