Effective Date: September 26, 2025

This 360training.com Privacy Policy (“Privacy Policy”) describes how 360training.com, Inc., including its affiliates and subsidiaries (“we,” “our,” or “us”), collects, uses, maintains, discloses, and otherwise processes Personal Information through 360training.com and any other websites that are controlled and operated by us that link to this Privacy Policy (collectively, the “Site”), or otherwise interact with us online through our Site or offline (the “Services”).

By using our Services, you acknowledge the disclosures in this Privacy Policy and agree to our Terms of Use. Different or additional terms and policies may apply to other services we provide. This Privacy Policy does not apply to other websites that we own, provide, or maintain, that do not link to this Privacy Policy.

Contents

1. Personal Information We Collect
2. Sources of Personal Information
3. How We Use Personal Information
4. How We Disclose Personal Information
5. Cookies and Other Similar Technologies
6. Social Features
7. External Links and Online Chat
8. Data Security
9. Your Choices
10. Additional Disclosures for Applicable U.S. States
11. Information for Visitors Outside the United States
12. Changes
13. Contact Us

1. Personal Information We Collect

“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, linked, or may reasonably be linkable, directly or indirectly, to you. “Personal Information” includes “Personal Data” and “Sensitive Personal Information” as defined under applicable privacy law. Personal Information does not include information that is publicly available, deidentified, or aggregated.

Generally, we or our vendors may obtain the following categories of Personal Information, depending on how you interact with us:

• Identifiers and Personal Records, including real name, alias, signature, postal address, telephone number, unique personal identifier, online identifier, Internet Protocol address, email address, account name and password, Social Security number, driver’s license number, or other similar identifiers; employment; and financial information.
• Demographic Information, including age, date of birth, and gender.
• Commercial Information, including records of products purchased, obtained, or considered, viewed, or other purchasing or consuming histories or tendencies.
• Internet or Other Electronic Network Activity Information, including browsing history, search history, and information regarding your interactions with our websites or advertisements.
• Geolocation Data, including approximate geolocation inferred from your device IP address.
• Sensory Data, including audio recordings of customer service calls, and recordings of webinars or live training events, proctoring, and image/video recordings of visitors to our offices or events.
• Professional or Employment-Related Information, including your employer, job title, professional license numbers, and similar information.
• Inferences reflecting consumers’ preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
• Other Personal Information, including any Personal Information you provide us in connection with signing up for newsletters, email communications, and surveys; Personal Information you permit us to see when interacting with us through social media; and Personal Information you provide us in relation to a question, request, inquiry, survey, contest, or promotion.

Some of the Personal Information we collect may be considered Sensitive Personal Information under state privacy laws, including Social Security number and driver’s license number.

2. Sources of Personal Information

Generally, we collect the categories of Personal Information described above from the following sources:

• Directly from you
• From our affiliated companies
• Automatically when you visit our Site (such as through cookies, pixels, and other tracking technologies)
• Created by us (for example, if assign you with a login or develop inferences about you)
• If you have a business relationship with us, from other companies we do business with, which may include your employer
• From service providers that help us to run our business
• From third parties including advertising networks, social networks, internet service providers, and data analytics providers

3. How We Use Personal Information

Generally, we use the Personal Information we collect for the following business or commercial purposes:

• To Provide Services You Request, including by operating and maintaining our Services; providing information about our Services; processing your payments and orders; communicating with you about our Services; and responding to your requests and questions.
• To Improve How We Do Business, including improving our Services; assessing our Services’ performance; tracking and responding to technical issues; and developing new or enhanced offerings.
• To Conduct Business Analytics, including forecasting and planning, developing statistics on engagement with our Services, and measuring how well marketing and promotional activities perform.
• For Security and Integrity, including protecting our Site from cyber risks; authenticating visitors to our Site; preventing, identifying, investigating, and responding to fraud, illegal or malicious activities, and other liabilities; enforcing our policies and terms; protecting our rights; fulfilling our legal obligations; and generally providing you with a secure experience when using our Site.
• For Quality, Safety, and Internal Research, including evaluating how our Services perform; repairing or improving the quality of our Services; tracking and responding to quality and security issues; and developing new or enhanced products and service offerings.
• To Advertise and Market, including measuring the use of our Services and effectiveness of our advertising and marketing; and uncovering insights to improve our Services and provide our users with enhanced features and functionalities, such as personalized experiences.
• To Operate Our Business, including performing system administration and technology management, including optimizing our Services; for recordkeeping and auditing purposes; for risk management, investigations, reporting and other legal and compliance reasons; identifying prospective customers, business clients, suppliers, and other vendors; administering our relationships with our customers, business clients, suppliers, and other vendors; fulfilling purposes that we describe to you at the time we collect your information and in connection with mergers, acquisitions, divestitures, or similar corporate transactions.

4. How We Disclose Personal Information

We may disclose Personal Information to other parties for the following purposes:

• Service Providers and Vendors. We may share your information with vendors and service providers that we engage to provide services to us on our behalf, such as support for the internal operations of our Services (including payment processors we use to process orders on our behalf); electronic mail; conducting analysis to improve our Services; research; digital marketing; managing payments; and answering your questions.
• Ad Tech Companies and Other Providers. We may share certain Personal Information (such as Internet or Other Electronic Network Activity) with ad tech companies and other online providers of services.
• Business Partners. We may disclose or otherwise make your information available to business partners for an approved business purpose.
• Corporate Transactions. We may disclose Personal Information to prospective or actual purchasers, investors, or successor entities in connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transactions involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction.
• Legal Compliance. We may disclose Personal Information as necessary for legal compliance and law enforcement or public safety purposes, including to law enforcement, government or regulatory bodies, or other authorized parties in order to comply with laws, regulations, subpoenas, court orders, or other legal obligations; to assist in investigations; to protect and defend our rights and property or the rights or safety of other parties; to enforce our Terms of Use, this Privacy Policy, or agreements with others; or for crime-prevention purposes.
• With Notice or Consent. We may also disclose information about you, including Personal Information to other parties, where we have provided specific notice to you or asked for your consent, as applicable.

We may combine your Personal Information with data we obtain from our Site, our Services, or from other parties. We reserve the right to convert, or permit others to convert, your Personal Information into deidentified, anonymized, or aggregated data, as permitted by law.

5. Cookies and Other Similar Technologies

We and our vendors may use cookies, web beacons, pixels, APIs, and other similar technologies (collectively, “Cookies”) to collect information when you interact with our Site. These Cookies may collect usage information (such as the browser you are using, IP address and device identifier, length and time of visit, and pages visited), general geolocation data (to deliver content based on your location), and details about how you interact with our Site (including clicks, cursor movement, scrolls, and keystroke activity).

This information is used by us and our vendors for a variety of purposes, including to store your preferences and settings, enable you to sign in, analyze how our Site performs, track your interactions with our Site, develop inferences about you, deliver and tailor cross-context and/or interest-based advertising, combat fraud, and to fulfill other business purposes.

We may engage analytics services (such as Google Analytics) to help us understand and analyze how visitors interact with our Site. We use such data to understand and analyze how visitors use our Site, help us administer and improve the quality of our Site. For more information on how Google Analytics uses data, visit support.google.com/analytics/answer/6004245. To opt out of aggregation and analysis of data collected by Google Analytics, please visit tools.google.com/dlpage/gaoptout.

We also may use social media technologies to conduct marketing campaigns. To change your privacy and advertising settings with a social media company, log in to your social media account and follow the instructions provided by the social media company.

Our online tracking technology vendors may include:

• Google. We use Google Analytics, through which we may implement Google advertising features such as dynamic remarketing, interest-based advertising, audience targeting, behavioral reporting, demographics and interests reporting, user segment analysis, device reporting, display advertising, video ads reporting, and impression reporting. To adjust your Google advertising settings, visit adssettings.google.com.
• Microsoft Advertising. For information on how Microsoft collects or receives Personal Information to provide services through Microsoft Advertising, visit microsoft.com/en-us/privacy/privacystatement.

Additional options for opting out of interest-based advertising are available through tools provided by the Network Advertising Initiative (NAI) and the Digital Advertising Alliance (DAA). Your browser or extension may also allow you to automatically transmit Do Not Track signals. Our Site may not respond to Do Not Track signals.

We are not responsible for the effectiveness of external parties’ opt out options or programs, or the accuracy of their statements regarding their programs. Note that opting out of these types of technologies may result in certain online features not functioning properly.

We or our vendors may collect Personal Information about your online activities over time and across different devices and online websites when you access our Site.

6. Social Features

Certain functionalities on our Site permits interactions that you initiate between us and certain social networks (“Social Features”). Examples of Social Features include enabling you to log into our services using your external account. If you use Social Features, information you post or provide access to may be publicly displayed on our Site or by the Social Feature provider that you use. Similarly, if you post information on a Social Feature that references us (e.g., by using a hashtag associated with us or our affiliates), your post may be used on or in connection with our Services or otherwise by us and/or our affiliates. Also, both we and the Social Feature provider may have access to certain information about you and your use of our Services and any Social Feature.

7. External Links and Online Chat

Our Site may contain links to, or features facilitated by, other online services. For example, you may voluntarily choose to interact with a chat feature on our Site for customer service purposes. When you use this interactive chat, we and our vendors may process the information obtained through the chat, including capturing and keeping the contents of the chat. By using these features, you understand that our vendors may process the information obtained through the feature to provide the service on our behalf. Note that our chat features may incorporate generative artificial intelligence services, including any website chatbot functionality, and our vendors may use various online tools, like Cookies, to collect certain information about you and your use of our chatbot or the website.

This Privacy Policy does not apply to the practices of companies that we do not own or control. If you choose to connect an external account to our Site, you should refer to that party’s privacy policy for information on how your Personal Information is collected, used, and protected.

8. Data Security

We maintain appropriate administrative, technical, and physical safeguards designed to help protect Personal Information collected or received through our Services. Although we take commercially reasonable and appropriate steps to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration, or destruction, please keep in mind that there is no such thing as perfect security, and no internet transmission is ever 100% secure or error-free.

9. Your Choices

If you hold an account with us, you can delete your account by submitting a request to customer support at https://www.360training.com/contact.

You can also opt out of receiving certain communications from us. If you sign up to receive emails from us, we may periodically send you emails regarding promotions and special offers. If you no longer want to receive our promotional email communications, you can unsubscribe by clicking on the “unsubscribe” link found in our emails. If you opt out of our promotional emails, we may still send you email messages related to your account or any products or services you request from us.

10. Additional Disclosures for Applicable U.S. States

This section applies to Personal Information we collect through our Services from residents of states with comprehensive privacy laws, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia (collectively “Applicable States”).

In the event of a conflict between this section and the Privacy Policy, this section will govern Applicable State residents’ privacy rights.

Unless otherwise noted, the disclosures in this section cover our activities in the twelve (12) months preceding the Effective Date of this Privacy Policy, as well as our current practices.

1. Targeted Advertising, Sales, and Sharing of Personal Information

Although we do not sell Personal Information in exchange for money, some of the ways in which we disclose Personal Information for targeted advertising or analytics may be considered “sales” or “sharing” for targeted and cross-context behavioral advertising (“Targeted Advertising”). You have the right to opt out of both practices. Information on how to exercise your opt out rights, as well as other rights you may have are described below.

We may sell or share for Targeted Advertising the following categories of Personal Information: Identifiers and Personal Records, Internet or Other Electronic Network Activity, and Geolocation Data.

The types of third parties to which Personal Information is sold or shared are third-party advertisers and some analytics vendors. The purposes for which we sell/share this information include: showing you relevant ads while you browse the internet or use social media; marketing, advertising, certain types of analytics, and similar purposes.

We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.

2. How to Exercise Your Privacy Rights

If you are a resident of an Applicable State, you may, depending on your state of residency, have the right to submit a request relating to your Personal Information by emailing us at privacy@360training.com or calling us at 877-881-2235.

Please note that we may need to verify your identity before your request can be processed. In some states and for some types of requests, you may designate an authorized agent to make a request on your behalf; however, you may still need to verify your identity directly with us before your request can be processed.

An authorized agent may submit a request on your behalf by emailing us at privacy@360training.com or calling us at 877-881-2235.

We will not discriminate against you if you choose to exercise any of your privacy rights under the Applicable State privacy laws.

Request to Access and Data Portability. You may request that we confirm whether we are processing your Personal Information and request to obtain a copy of your Personal Information in a portable format.

Request to Correct. You may request that we correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and our purposes for processing it.

Request to Delete. You may request that we delete your Personal Information.

Request to Opt Out of Sales and Targeted Advertising. You may request to opt out of sales and/or Targeted Advertising. To opt out of sales and/or targeted advertising via cookies, please contact us at donotsell@360training.com. Please also note that if you choose to use the Global Privacy Control (GPC) browser signal, you will need to turn it on for each browser you use.

Request to Appeal. Sometimes we are unable to process requests relating to your Personal Information, in which case, your request will be denied. If you believe we denied it in error, you may appeal for reconsideration of your request by emailing us at privacy@360training.com or calling us at 877-881-2235.

Minnesota and Oregon Residents – Third-Party Disclosures. If you live in Minnesota or Oregon, you also have the right to request a list of third parties to which we disclosed Personal Information.

Delaware and Maryland Residents – Categories of Third Parties. If you live in Delaware or Maryland, you have the right to request a list of the categories of third parties with whom we disclose your personal data.

We do not use Personal Information for automated decision-making in furtherance of decisions that produce legal or similarly significant effects.

We will comply with your request as soon as reasonably practicable, in accordance with applicable legal requirements. We will not discriminate against you for choosing to exercise any of your privacy rights.

3. Additional Disclosures for California Residents
   1. How We Collect, Use, and Disclose Personal Information

We collect, use, and disclose the Personal Information described in the “Personal Information We Collect” section above as follows for California residents:

2. How Long We Keep Personal Information

We keep the categories of Personal Information described above for as long as necessary for the purposes described in this Privacy Policy or as otherwise authorized or required by law. This generally means holding Personal Information for as long as one of the following apply: 

• Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
• Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected; 
• The Personal Information is reasonably required to protect or defend our rights or property (which may legally require that we limit actions in a particular case, such as the ability to delete Personal Information); or 
• We are otherwise required or permitted to keep your Personal Information by applicable laws or regulations. 

Where Personal Information is used for more than one purpose, we will retain it until the purpose with the latest period expires.

3. Additional California Privacy Rights

Right to Know. California residents have the right to know:

• The categories of Personal Information we have collected about you, including:
  • The categories of sources from which the Personal Information was collected;
  • Our business or commercial purposes for collecting selling, or sharing Personal Information;
  • The categories of recipients to which we disclose Personal Information;
  • The categories of Personal Information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of Personal Information; and
  • The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information.
• The specific pieces of Personal Information we have collected about you.

We do not use or disclose Sensitive Personal Information for purposes of which the right to limit use and disclosure of Sensitive Personal Information applies.

California’s Shine the Light Law. California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of certain personal information to third parties for their own direct marketing purposes. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us by email at privacy@360training.com or postal mail at 6504 Bridge Point Parkway Suite 100, Austin, TX, 78730, Attention: General Counsel. Any such request must include “California Shine the Light Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each calendar year.

11. Information for Visitors Outside the United States

If you access the Site from outside of the United States, please be aware that Personal Information collected through the Site may be transferred to, processed, stored, and used in the United States. Data protection laws in the United States may be different from those of your country of residence. Your use of the Site or provision of any Personal Information to us constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the United States as set forth in this Privacy Policy.

12. Changes

We may periodically update this Privacy Policy and will notify you by revising the Effective Date at the top of this page. Please refer back to this Privacy Policy from time to time to ensure you are aware of our most current privacy practices.

13. Contact Us

If you have any questions about this Privacy Policy, you may contact us at privacy@360training.com.