Privacy Policy

Welcome to www.train321.com. Train 321, LLC (“Train,” “we” or “us”) is comprised of various websites, mobile applications, social media sites and handles, email, events, surveys, and research (our “Services”). Your privacy rights are important to us! We want you to know and understand: 1) What information we collect; 2) What we use your information for; 3) How we protect your information; 4) Details regarding our use of third-party cookies and other tracking technologies; 5) What information is shared with others and under what circumstances; 6) The choices you have regarding our collection, use and sharing practices. We also include specific disclosures for residents of Colorado and California. This Policy applies to Train and our Services. It also applies anywhere it is linked. It does not apply to non-Train websites and mobile applications that may link to the Services or be linked to from the Services; please review the privacy policies on those websites and applications directly to understand their privacy practices.

Information We Collect

Anonymous browsing. If you are merely visiting the Site, we do not collect any personally identifiable information from you.
Information you give us: Some of the Services may include features or services that permit you to enter contact information and other information about you. We collect and store any information you enter on our Services. This may include:

  • Registered Users. To become a Registered User of our Site, and participate in some of our online training programs, you will have to provide information such as your first and last name, email address, mailing address, phone number, and birthdate. Further, if you are participating in the Texas Seller- Server Alcohol course, you will be required to provide your social security number or other personal identifying number. That information will be provided to the State of Texas for the sole purpose of receiving and tracking your certification with the state. Once that information is provided to the state, it will be deleted permanently from our servers.
  • Payment Information. To become a Registered User of the Site, you may be required to provide payment information, which may include credit card and/or bank ACH information. We will use this information only as needed for processing and completing transactions. Some of our services include monthly automatic charges, which will also use the Payment Information you provide. Payment Information will only be disclosed to third parties as necessary to process the transaction.
  • Appointment bookings you carry out through our site.
  • Email address information when subscribing to our email bulletins.
  • Information you provide when you complete a survey administered by us or a service provider acting on our behalf.
  • If you contact us, we may keep a record of that correspondence and any contact information provided.
  • Information you provide when you apply for a certification or purchase or take a course or an exam.
  • Information submitted by or for our clients, including employers or franchisors–which may include employees’ business and personal contact details, job titles, and membership details.

Information We Collect Automatically: When you interact with the Services, certain information about your use of our Services is automatically collected. Much of this information is collected through cookies, web beacons, and other tracking technologies, as well as through your web browser or device. This may include:

  • Details of your visits to our site and information generated in the course of the use of our site (including the timing, frequency and pattern of service use) including, but not limited to, traffic data, cookies, location data, weblogs and other communication data, the resources that you access, and how you reached our site.
  • Details regarding the device you use to access our Services, including, but not limited to, your IP address, operating system and browser type.
  • Information that you make available to us on a social media platform (such as by clicking on a social media icon linked from our Services), including your account ID or username and other information included in your posts.

Please see below for more information about how our automatic collection of information works.

Cookies and How We Use Them

We use cookies to better assist your use of the Services. Cookies are small files that a site or provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information.
We use cookies for the following purposes:

  • Site Operations: Enabling features that are necessary for providing you the services on our site, such as identifying you as being signed in, tracking content views remembering your preferences and the number of times you have been shown an advertisement.
  • Analytics: Allowing us to understand how our services are being used, track site performance and make improvements
  • Personalized Advertising: Delivering tailored advertising based on your preferences or interests across services and devices and measuring the effectiveness of ads
  • Social Media: Enabling the sharing of content from our services through social networking and other sites

Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the Services may not be available, work, or work as designed. You may also be able to opt out of or block tracking by interacting directly with the third parties who conduct tracking through our Services.

How We Use and Protect Your Information

We may use the information we collect from you for the following purposes:

  • To provide client services, and to keep our client contact information up to date.
  • To provide you with our products and services, including to take steps to enter into a contract for sale or for services, process payments, fulfill orders, and send service communications.
  • To provide you with information about our products and services, or products or services of our commercial partners, that we believe may be of interest to you.
  • To communicate exam results, pending expiration dates or other information regarding your certificate, certification or similar status.
  • To provide information or other materials relating to an event you are currently or previously registered for, including information regarding exams, speakers, exhibitors, sponsors, or other attendees.
  • To enable additional features on our Services and to provide you with a personalized service.
  • To create custom audiences on social media sites.
  • To provide you with the best service and improve and grow our business, including understanding our customer base and purchasing trends and understanding the effectiveness of our marketing.
  • To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, and to comply with legal requirements regarding the provision of products and services.

We retain your information in accordance with record retention policies, based on levels of business importance and internal guidance for compliance with auditing and legal requirements.

How We Secure the Information We Collect from or About You

We implement a variety of security measures to maintain the safety of your personal information entered by you when signing up for services or more information on our Site.
We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Services.
We offer the use of a secure server. All supplied sensitive/credit information is transferred via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway provider’s database only to be accessible by those authorized with special access rights to such systems and who are required to keep the information confidential.
While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

Our Sharing of Your Information
  • We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.
  • Service Providers: We engage vendors to perform functions on our behalf such as: website hosting, software development, data storage, content management, database management, technical integration, marketing automation, analytics, site optimization, conducting customer surveys, shipping and payment processing and providing other business services.
  • We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

There are limited circumstances in which the service provider collects data directly from you when their privacy policies may also apply.

  • Social Media Platforms: Where you choose to interact with us through social media, your interaction with these programs typically allows the social media company to collect some information about you through digital cookies they place on your device and other tracking mechanisms. In some cases, the social media company may recognize you through its digital cookies even when you do not interact with their application. Please visit the social media companies’ respective privacy policies to better understand their data collection practices and controls they make available to you.
  • Third parties involved in advertising: We partner with third parties who assist us in serving advertising regarding the Services to others who may be interested in the Services. We also partner with third parties who use cookies to display interest-based advertising to you on the Services. These third parties may use tracking technologies on our website to collect or receive information from the Services and elsewhere on the internet and use that information to provide measurement services and target ads. While Train will not share information that identifies you by name with unaffiliated third parties for their own uses, such third parties may, with sufficient data from other sources, be able to personally identify you.
  • Business Partners: We share data with affiliates or companies with whom we have affinity programs or similar commercial relationships in order to market and provide products, goods or services that may be of interest to you.
  • Employers: If you access our Services through your employer, we may share your name, email address, course information, and other information regarding your use of the Services with your employer.
Additional Information About our Data Collection and Sharing Practices
  • Sharing of Aggregated Data: We may analyze aggregated, de-identified data and share these analyses at our discretion, including with marketing agencies, media agencies, and analytics providers. These third parties will not be able to relate this data to identifiable individuals.
  • Combination of Information: We may combine information from the Services together and with other information we obtain from our business records. Additionally, information collected about you from a particular browser or device may be linked to information collected from another computer or device that we believe relates to you.
  • Personal Data Collected from You About Others: If you decide to invite others to the site, we will collect your and the other person’s names, e-mail addresses, and/or phone numbers in order to send an e-mail or text message and follow up with the other person. You hereby agree that you will obtain the other person’s consent to this before giving us their personal data. You hereby agree not to send us the contact details of any legal minor.
  • Change of Ownership or Corporate Organization: We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this policy.
Your Options and Rights

Please visit the login page on Train to update your contact information and payment method.
If at any time you would like to unsubscribe from receiving future emails, you can click the unsubscribe link at the bottom of any email bulletin, or email us at info@train321.com and we will promptly remove you from all correspondence.

Your Colorado Privacy Rights

Effective July 1, 2023, residents of the State of Colorado have the right to request Personal Data (described below) from Train, as described in more detail in this Section of the Privacy Policy. If you are a Colorado resident and would like to see the categories of Personal Data that we collect or sell, please see our Notice of Colorado Consumer Data Collection and Sharing Practices. If you are a Colorado resident and would like to make such a request to access your Personal Data, correct your Personal Data, delete your Personal Data, or request that we do not sell your Personal Data or use it for targeted advertising or certain kinds of profiling, please email info@train321.com, write to or call us at:

Train 321, LLC
PO Box 970684
Coconut Creek, FL 33097
561-325-7300

If you would like to appeal any decision we make not to comply with your request (in whole or in part), please respond to the email you received from info@train321.com notifying you of our decision, or write to us or call us at the above address within sixty (60) days of your receipt of our response.

Special Information for Colorado Residents

The Colorado Privacy Act (“CPA”) provides Colorado residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Data,” as well as rights to access and control Personal Data. The CPA defines “Personal Data” to mean “information that is linked or reasonably linkable to an identified or identifiable individual.” Certain information we collect may be exempt from the CPA because it is de-identified, considered public information (i.e., it is made available by a government entity), covered by a federal privacy law, such as the Gramm– Leach–Bliley Act, the Health Insurance Portability and Accountability Act, the Fair Credit Reporting Act, or otherwise excluded from the definition of Personal Data under the CPA.
From time to time in this section of the Privacy Policy, we may refer to the “processing” or Personal Data. “Process” or “Processing” means collecting, using, selling, storing, analyzing, deleting, or modifying Personal Data.
To the extent that we collect Personal Data that is subject to the CPA, that information, our practices, and your rights are described below.

Right to Information Regarding the Categories of Personal Data Collected, Sold, and Disclosed

You have a right to obtain information about the categories of Personal Data we collect, sell, and disclose. Please see our Notice of Colorado Consumer Data Collection and Sharing Practices.

Right to Access Information and Right to Data Portability

You have the right to confirm whether we are processing Personal Data collected about you and to access that Personal Data.
When exercising your right to access your Personal Data, you have the right to obtain your Personal Data in a portable format, and (to the extent feasible) a format that is readily usable and allows you to transmit the data to another entity. You may exercise this right up to two times per calendar year. To protect our customers’ Personal Data, we are required to verify your identity before we can act on your request, and we may redact any highly sensitive information (such as driver’s license numbers, social security numbers, or financial account numbers). If we redact any information, we will clearly describe what information we are redacting.

Right to Correction

You have the right to correct inaccuracies in your Personal Data. To protect our customers’ Personal Data, we are required to verify your identity before we can act on your request. We may not have to comply with this request based on the nature of the Personal Data you are asking us to correct or the purposes of processing that Personal Data. If that is the case, we will explain that to you in our response.

Right to Request Deletion of Personal Data

You have the right to request in certain circumstances that we delete any Personal Data that we have collected directly from you. To protect our customers’ Personal Data, we are required to verify your identity before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Right to Information Regarding Participation in Data Sharing for Financial Incentives

We may run promotions from time to time whereby we incentivize a consumer to share certain pieces of information with us; for example, we may offer a one-time discount if consumers sign up for our email marketing list. Participation in these incentives is voluntary, and you may opt out of the data sharing at any time. If we do so, we will disclose the categories of Personal Data that we collect through the program, the categories of third parties to whom we will share the Personal Data received, the value of the program benefits available to you whether or not you opt out of the sale of Personal Data or the processing of Personal Data for targeted advertising, and a list of any benefits that require the sale of Personal Data or processing of Personal Data for targeted advertising at the time such Personal Data is collected.

Right to Opt Out of Targeted Advertising, Sale of Personal Data to Third Parties, and Certain Profiling

You have the right to opt out of any targeted advertising or sale of your Personal Data by Train to third parties. You also have the right to opt out of profiling (described below) that is used in furtherance of decisions that result in providing or denying education enrollment or opportunity or employment opportunities. Profiling is the automated processing of your Personal Data to evaluate, analyze or predict things about your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. We do not engage in any of the profiling described above in furtherance of decisions that result in providing or denying education enrollment or opportunity or employment opportunities. To exercise this right, please email us at info@train321.com. Please note that your right to opt out does not apply to our sharing of Personal Data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the Personal Data only for that function.

Notice of Colorado Consumer Data Collection and Sharing Practices

The following is a description of our data collection practices, including the Personal Data we collect, the purposes for which we collect information, the categories of Personal Data that we share with third parties and the kinds of third parties we share Personal Data with. We may use any and all of the information for any of the purposes described in this Privacy Policy, unless limitations are listed.

  • Personal Identifiers:
    • We may collect your name, phone number, and email address and contact address when you create an account, register for events, or complete a transaction. If you choose to create an account, you may also be asked to create a username and password, and we may assign one or more unique identifiers to your profile.
    • You may provide us with payment information, which may be your credit card number or a bank account, when you complete a transaction or set up a recurring payment.
    • We may collect your Social Security number to verify your identity.
    • We may collect your IP address automatically when you use our Services, and may use it for marketing and sales purposes, as described below.
    • We may collect your Device ID automatically when you use our Services, and may use it for marketing and sales purposes, as described below.
  • Protected Classifications: We may collect your age in order to comply with laws that restrict collection and disclosure of personal information belonging to minors.
  • Commercial Information: When you engage in transactions with us, we may create records of goods or services purchased or considered, as well as purchasing or consuming histories or tendencies for financial recordkeeping purposes and marketing purposes.
  • Biometric Information: We may collect information about your physiological, biological, and behavioral characteristics.
  • Internet or Other Electronic Network Activity Information: We may collect information about your browsing history, search history, information regarding your interaction with websites, and applications or advertisements automatically when you utilize our Services for marketing purposes.
  • Geolocation Data: As described above, we may collect your IP address automatically when you use our Services. We may be able to determine your general location based on the IP address.
  • Audio, electronic, visual, thermal, olfactory, or similar information: If you contact us via phone, we may record the call for customer service and quality control purposes. We will notify you if a call is being recorded at the beginning of the call. If you take an examination, we may video record. We may collect your image, thermal, and olfactory similar information for exam security purposes.
  • Professional or employment-related information: We may collect information about your current employer and your employment history for marketing purposes.
  • Education information: We may collect information about the institutions you have attended and the level of education you have attained for marketing purposes.
  • Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We may analyze your actual or likely preferences through a series of computer processes for marketing purposes. On some occasions, we may add our observations to your internal profile.
Sensitive Data

We do not collect any Personal Information that falls under the definition of “Sensitive Data” under the CPA.

Special Information for California Residents

Residents of the State of California have the right to request information from certain business entities regarding third parties to whom the company has disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes pursuant to the CCPA and CPRA (discussed below).
The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CPRA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to access and control Personal Information with respect to certain business entities. The CPRA defines “Personal Information” to mean “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CPRA because it is considered public information (i.e., it is made available by a government entity) or covered by a federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.
To the extent that we collect Personal Information that is subject to the CPRA, that information, our practices, and any rights you may have under the CPRA are described below.

Right to Information Regarding the Categories of Personal Information Collected, Sold, and Disclosed

To the extent that we collect Personal Information that is subject to the CPRA, you may have a right to obtain information about the categories of Personal Information we collect, sell, and disclose. Please see our Notice of California Consumer Data Collection and Sharing Practices.

Right to Access Information

To the extent that we collect Personal Information that is subject to the CPRA, you may have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request.

Right to Request Deletion of Information

To the extent that we collect Personal Information that is subject to the CPRA, you may have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Right to Correction

To the extent that we collect Personal Information that is subject to the CPRA, you may have the right to correct inaccuracies in your Personal Information. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request. We may not have to comply with this request if we determine that the contested information is more likely to be accurate than not, if such a request would conflict with federal or state law, or if compliance would be impossible or involve disproportionate effort, or for other reasons permitted under the CPRA. If that is the case, we will explain that to you in our response.

Right to Information Regarding Participation in Data Sharing for Financial Incentives

We may run promotions from time to time whereby we incentivize a consumer to share certain pieces of information with us; for example, we may offer a one-time discount if consumers sign up for our email marketing list. Participation in these incentives is voluntary, and you may opt out of the data sharing at any time.

Right to Opt Out of Sale of Personal Information to Third Parties and Targeted Advertising

To the extent that we collect Personal Information that is subject to the CPRA, you may have the right to opt out of any sale of your Personal Information or sharing of your Personal Information for cross-context behavioral (targeted) advertising purposes by Train to third parties. To exercise this right, please email us at info@train321.com. Please note that your right to opt out does not apply to our sharing of Personal Information with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the Personal Information only for that function.

Notice of California Consumer Data Collection and Sharing Practices.

The following is a description of our data collection practices, including the Personal Information we collect, the sources of that information, the purposes for which we collect information, and whether we disclose that information to external parties. We may use any and all of the information for any of the purposes described in this Privacy Policy, unless limitations are listed. The categories we use to describe the information are those enumerated in the CPRA.

  • Personal Identifiers:
    • We may collect your name, phone number, and email address and contact address when you create an account, register for events, or complete a transaction. If you choose to create an account, you may also be asked to create a username and password, and we may assign one or more unique identifiers to your profile.
    • You may provide us with payment information, which may be your credit card number or a bank account, when you complete a transaction or set up a recurring payment.
    • We may collect your Social Security number to verify your identity.
    • We may collect your IP address automatically when you use our Services, and may use it for marketing and sales purposes, as described below.
    • We may collect your Device ID automatically when you use our Services, and may use it for marketing and sales purposes, as described below.
  • Protected Classifications: We may collect your age in order to comply with laws that restrict collection and disclosure of Personal Information belonging to minors.
  • Commercial Information: When you engage in transactions with us, we may create records of goods or services purchased or considered, as well as purchasing or consuming histories or tendencies for financial recordkeeping purposes and marketing purposes.
  • Biometric Information: We may collect information about your physiological, biological, and behavioral characteristics.
  • Internet or Other Electronic Network Activity Information: We may collect information about your browsing history, search history, information regarding your interaction with websites, and applications or advertisements automatically when you utilize our Services for marketing purposes.
  • Geolocation Data: As described above, we may collect your IP address automatically when you use our Services. We may be able to determine your general location based on the IP address.
  • Audio, electronic, visual, thermal, olfactory, or similar information: If you contact us via phone, we may record the call for customer service and quality control purposes. We will notify you if a call is being recorded at the beginning of the call. If you take an examination, we may video record. We may collect your image, thermal, and olfactory similar information for exam security purposes.
  • Professional or employment-related information: We may collect information about your current employer and your employment history for marketing purposes.
  • Education information: We may collect information about the institutions you have attended and the level of education you have attained for marketing purposes.
  • Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We may analyze your actual or likely preferences through a series of computer processes for marketing purposes. On some occasions, we may add our observations to your internal profile.
Sensitive Personal Information

Some of the Personal Information we collect falls under the definition of “Sensitive Personal Information” under the CPRA. The following is a description of our data collection practices with respect to Sensitive Personal Information, including the Sensitive Personal Information we collect, the sources of that Sensitive Personal Information, the purposes for which we collect Sensitive Personal Information, and whether we disclose that Sensitive Personal Information to external parties. We may use any and all of the Sensitive Personal Information for any of the purposes described in this Privacy Policy, unless limitations are listed. The categories we use to describe the information are those enumerated in the CPRA.

  • Government Identifiers:
    • If you take an examination, we may collect images of your driver’s license, state identification card, or passport to verify your identity.
    • We may collect your Social Security number to verify your identity or use it to report training completions to state certification agencies.
    • Complete account access credentials (usernames, account numbers, or card numbers combined with required access/security code or password). We may collect this information for security purposes.
Right to Limit Use or Disclosure of Sensitive Personal Information

To the extent that we collect Personal Information that is subject to the CPRA, you may have the right to limit the use or disclosure of your Sensitive Personal Information to just actions to those that:

  • help to ensure security and integrity, if the use of your Sensitive Personal Information is reasonably necessary and proportionate to the purpose of ensuring security and integrity;
  • are for short-term, transient use, so long as your Sensitive Personal Information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience;
  • are involved in the performance of services on behalf our business, such as maintaining or servicing accounts, verifying customer information, processing payments, providing financing, providing analytic services, and/or providing storage; and
  • are used to undertake activities to verify or maintain the quality or safety of the Services.

We may share any of the above-listed Personal Information with “Service Providers”, which are external parties that we engage for business purposes and are restricted from using Personal Information for any purpose that is not related to our engagement. The categories of Service Providers with whom we share information and the services they provide are described in this Privacy Policy.

Special Information for Nevada Residents

Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to third parties who will sell or license their information to others. If you are a Nevada resident and would like to make such a request, please email us at info@train321.com or write to or call us at:

Train 321, LLC
PO Box 970684
Coconut Creek, FL 33097
561-325-7300

We may make changes to this Policy from time to time. We will post any changes, and such changes will become effective when they are posted unless otherwise required by law. Your continued use of our Services following the posting of any changes will mean you accept those changes. For questions about our privacy practices, contact us at:

Train 321, LLC
PO Box 970684
Coconut Creek, FL 33097
561-325-7300
Email: info@train321.com

Last Updated March 25, 2024