TrainSec 

Privacy Policy

Last updated: October 7, 2026

Introduction

Scorpio Software LLC, operating as trainsec.net (“we”, “us” or “our”), is committed to protecting your privacy while providing our services (the “Services”). In this policy, “you” and “your” refer to any user or customer of the Services.

To become a customer, you need to register and open a personal account through our website. At registration, we ask you to provide certain personal information. Providing this information is voluntary, but without it you may not be able to receive our Services. By providing your personal information, you consent to our using it to deliver the Services to you.

Under applicable data protection laws, please note the following:

  • If you live in a country that is a member of the European Economic Area (EEA), the processing of your data and this Privacy Policy are governed by the General Data Protection Regulation (Regulation (EU) 2016/679, the “GDPR”).
  • If you live outside the EEA, the collection of your personal data is governed by the privacy laws of the State of California, USA.

The company responsible for your personal data is Scorpio Software LLC, 95 Newcomb Rd., Tenafly, NJ 07670, USA.

To contact our representative, Mickey Zelansky (Data Protection Officer), email [email protected].

To register and use the platform, you must be at least 16 years old. We may, but are not obliged to, use your personal information to verify your age and enforce this restriction.

What Personal Information Do We Collect?

Information provided by you: first name, username, email address, country, city, street address and ZIP/postal code.

How Do We Use Your Personal Data?

We may use your personal information in-house in order to:

  • provide and operate the Services;
  • develop, customize, expand and improve our Services;
  • provide you with customer assistance;
  • contact you with general or personalized service-related notices and promotional messages or emails;
  • enhance our data security and fraud prevention capabilities; and
  • comply with applicable laws and regulations.

On What Basis and for What Purposes Do We Process Your Data?

We use personal information collected through our Services for a variety of business purposes. We process it in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or to comply with our legal obligations. We use the information we collect or receive:

  • To facilitate account creation and login. We use the information you allow us to collect to create your account and let you log in, for the performance of the contract.
  • To send administrative information. We may send you product, service and related information, and information about changes to our terms, conditions and policies.
  • To fulfill and manage your purchases. We use your information to fulfill and manage purchases made through our website.
  • To enforce our terms, conditions and policies for business, legal and contractual purposes.
  • To manage your account. We use your information to manage your account and keep it in working order.
  • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond. We may disclose aggregate information about users for such legal purposes.
  • To deliver the Services. We use your information to provide you with the Services and products.
  • For other business purposes. These include data analysis, identifying usage trends, measuring the effectiveness of our promotional campaigns, and evaluating and improving our Services, products, marketing and your experience. We will not use identifiable personal information for these other purposes without your consent.

Will Your Information Be Shared with Anyone?

When you create an account with us, we may process and share your data on the following legal bases:

Legitimate interests: we may process your data when it is reasonably necessary to achieve our legitimate business interests.

Legal obligations: if we reasonably suspect that your account has been used for an unauthorized, illegal or criminal purpose, you authorize us to share information about you, your account and your transactions with law enforcement. We may also disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, a court order or legal process, such as a subpoena (including requests from public authorities to meet national security or law enforcement requirements).

Vital interests: we may disclose your information where we believe it is necessary to investigate, prevent or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person, illegal activities, or as evidence in litigation in which we are involved.

How Long Do We Keep Your Information?

We keep your personal information for at least 2 years, and otherwise only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (such as for tax, accounting or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize it. If this is not possible, we will securely store it and isolate it from any further processing until deletion is possible.

If you ask us to delete your personal information and cancel your account, we will cancel your account and delete the information associated with it, in line with your right to be forgotten.

Where Do We Store Your Data?

We store your data on our own servers and also use third-party storage providers. Third-party service providers that store or process your personal information are contractually committed to keep it protected and secure, in accordance with industry standards and regardless of any lesser legal requirements that may apply in their jurisdiction.

Your Data Protection Rights

Under the GDPR, the CCPA and similar laws, you may request access to the personal data we hold about you, correction of inaccurate data, a portable copy of your data, or deletion of your data. To exercise these rights, email [email protected] from the address registered to your account. We will verify your identity and respond within 30 days, or sooner where the law requires. You can also update much of your account information directly in your account settings.

Service Providers and Subprocessors

We use a limited number of third-party providers to operate our services, including Stripe for payment processing, Podia for course delivery and account management, MailerLite for email communications, Credly for issuing digital certificates, and Google for email and file storage. All providers are carefully vetted before use, and those that process personal data on our behalf are bound by Data Processing Agreements (DPAs) that require them to protect your data and use it only for the agreed purposes.

Data Breach Notification

We maintain documented procedures for detecting, assessing and responding to security incidents. If a personal data breach affects you, we will notify affected individuals and customers, and the relevant regulatory authorities where required by law, without undue delay and in accordance with applicable law.

Security

We protect personal data with technical and organizational measures, including access controls, multi-factor authentication, employee confidentiality agreements and regular security training. More information is available on our Security & Compliance page.

Account Information

You can review or change the information in your account at any time by logging into your account settings, or by emailing us at [email protected].

Opting Out of Email Marketing

You can unsubscribe from our marketing emails at any time by emailing us at [email protected]. You will then be removed from the marketing list. We will still send you service-related emails that are necessary for the administration and use of your account.

Users Outside the U.S.

To provide the Services to you, we may transfer your data to the location where the Services are provided and process it there. By visiting or using our Services, you consent to your data being stored on servers located in the United States, where we reside. In particular, personal data collected in the United Kingdom (“UK”), Switzerland and the EEA may be transferred to and stored outside those areas.

California Residents: Privacy Rights

This section applies if you are located in California. California Civil Code Section 1798.83 permits customers who are California residents to request and obtain from us, once a year and free of charge, information about the categories of personal information (if any) we disclosed to third parties for direct marketing purposes, and the names and addresses of all third parties with which we shared personal information in the preceding calendar year. To make such a request, please submit it in writing using the contact details below.

If you are under 18 years of age, reside in California and have a registered account on our website, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal, please contact us using the contact details below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that it may not be completely or comprehensively removed from our systems.

California Privacy Disclosure

Under the California Consumer Privacy Act (CCPA), we are required to inform you about the information we may collect, the purposes for which we collect it, the sources of that information, and the categories of third parties with whom we share it. Please see the “What Personal Information Do We Collect?” section above.

Notice to Residents of Nevada

If you are a resident of Nevada, you have the right to opt out of the sale of certain personal information to third parties who intend to license or sell it. You can exercise this right by emailing [email protected] with your name and the email address associated with your account. Please note that we do not currently sell your personal information as “sale” is defined in Nevada Revised Statutes Chapter 603A.

DMCA Rights

As required by law, we respond to all claims of intellectual property infringement. We promptly investigate notices of alleged infringement and take the actions required under the Digital Millennium Copyright Act, 17 U.S.C. § 512(c)(2) (“DMCA”), and other applicable intellectual property laws.

Under the DMCA, notifications of claimed copyright infringement must be sent to the service provider’s Designated Agent:

Name: Pavel Yosifovich
Address: 95 Newcomb Rd., Tenafly, NJ 07670, USA
Email: [email protected]

Changes to This Policy

From time to time, we may update this Privacy Policy. If we make a material change, we will notify you by email, through a notice posted on the Services, or as required by applicable law, and we will include a summary of the key changes. Unless stated otherwise, changes take effect on the day they are posted.

Where permitted by applicable law, if you continue to use the Services after a change takes effect, your access or use will be deemed acceptance of, and agreement to be bound by, the revised Privacy Policy. The revised Privacy Policy supersedes all previous versions.

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