Additional U.S. State Privacy Disclosure

 

Updated May 18, 2023

These Additional U.S. State Privacy Disclosures supplement the above information by providing additional information about our personal data processing practices relating to individual residents of the States of California, Colorado, Connecticut, Nevada, Utah, and Virginia. Unless otherwise expressly stated, all terms defined in our Privacy Notice retain the same meaning in these Disclosures.

Additional Personal Data Disclosures
Sensitive Information
The following personal data elements we collect may be classified as “sensitive” under certain privacy laws (“sensitive information”): 

• Social Security number, driver’s license number, and passport number;
• Credit/debit card number plus expiration date and security code (CVV), and financial account number and routing number; and
• Username and password

We use this sensitive information for the purposes set forth in the “What We Collect” section of our Privacy Notice, to register you for training courses and to comply with legal and regulatory requirements. 

We do not sell your sensitive information, and we do not process or otherwise share sensitive information for the purpose of targeted advertising.

Deidentified Information
We may at times receive or process personal data to create de-identified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified data, we will maintain and use the data in deidentified form and not attempt to reidentify the data except as required or permitted by law. 

Your Privacy Choices
Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

The Right to Know. The right to confirm whether we are processing your personal data and, under some state laws, to obtain certain personalized details about the personal data we have collected about you, including:

• The categories of personal data collected;
• The categories of sources of the personal data;
• The purposes for which the personal data were collected; 
• The categories of personal data disclosed to third parties (if any), and the categories of recipients to whom the personal data were disclosed;
• The categories of personal data shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for those purposes; and
• The categories of personal data sold (if any), and the categories of third parties to whom the personal data were sold.

The Right to Access & Portability. The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

The Right to Correction. The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.

The Right to Deletion. The right to have us delete the personal data we maintain about you.

The Right to Opt-Out of Sales or Sharing of Personal Data. The right to direct us not to “sell” your personal data to third parties for monetary or other valuable consideration, or “share” your personal data to third parties for cross-context behavioral advertising purposes and targeted advertising purposes.  Good news about that – we don’t sell personal data or share it for targeted advertising purposes.  Cross-context behavioral advertising means in essence that we would share your information with a third party which would then use that information to advertise in places unrelated to 360training.   We don’t do that.  

“Shine the Light.” California residents that have an established business relationship with us have rights to know how their personal data is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law, or the right to opt out of such practices (Civ. Code §1798.83).

Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights.

Submitting Privacy Rights Requests
To submit a request to exercise one of the privacy rights identified above, please email us at privacy@360training.com.

Before processing your request we may need you to log in to your account with us so we can verify your identity. If you can’t log in or don’t have an account, we may not be able to link you to any personal data of yours on our systems, but we’ll do our best. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. We will only use personal data provided in connection with your request to review and comply with the request.

We may reject requests that are unreasonable or not required by law, including those that would be extremely impractical, could require disproportionate technical effort, or could expose us to operational risks. We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes and to fulfill the purposes described in this Privacy Policy.

Submitting Authorized Agent Requests
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf.  The authorized agent can submit a request on your behalf at privacy@360training.com  along with a statement signed by you certifying that the agent is authorized to act on your behalf. In order to verify the request and your identity, we may ask you to verify your identity. 

Appealing Privacy Rights Decisions
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted via email to privacy@360training.com. 

Minors
If you are under the age of 18 and you want to remove your name or comments from our website or publicly displayed content, please contact us directly at privacy@360training.com. We may not be able to modify or delete your information in all circumstances.
If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child’s behalf (i.e., you are the child’s legal guardian or authorized representative).

California-Specific Disclosures
The following disclosures only apply to residents of the State of California.

California Categories of Personal Data
California law requires that we provide disclosures to you about what personal data we collect by reference to the enumerated categories of personal data set forth within California law. To address this obligation, we have identified the relevant enumerated California personal data category for the personal data, sources and purposes described in the “What We Collect” section of our Privacy Notice.

• Identifiers, including account registration and profile information, information related to your feedback, inquiries, and communications,, credit and identity information relating to data used to identify you, full name, IP address, and government identification number (including Social Security number, passport number and driver’s license number).
• Customer Records, including account registration and profile information, security/authentication information, and payment information.
• Protected Classification Characteristics, including age, date of birth, and gender. 
• Commercial Information, including account registration and profile information relating to your purchases, profile information relating to your transactions, preferences, and interests, and feedback information.
• Internet/Network Information, including information about how you access and use the services, log data, and analytics data.
• Geolocation Data, including general geographic location or more precise location when permitted by law.
• Sensory Information, including, where permitted by law, recordings of phone calls between us and individuals and image and video recordings of visitors to our offices or events.
• Profession/Employment Information, including the business or organization you represent, your title with that business or organization and information relating to your role with the business or organization.
• Sensitive Information, including Social Security number, driver’s license number, passport number, credit/debit card number plus expiration date and security code (CVV), financial account number and routing number, username and password, and precise geolocation.
• Other Personal Data, including any information you provide us in connection with signing up for newsletters, email communications, and surveys, personal data you  permit us to see when interacting with us through social media, and personal data you provide us in relation to a question, request, inquiry, survey, contest, or promotion.
• Inferences, including our predictions about interests and preferences.

We collect this data from the following sources: directly from you, from our business partners and affiliates, from your browser or device when you use our services, or from third parties that you permit to share information with us. Please see the “What We Collect” section of our Privacy Notice for more information about the sources of personal data we collect.

Personal Information Disclosed for a Business Purpose To Third Parties
While we don’t “share” your personal information for cross-context behavioral advertising (see the section above titled “The Right to Opt-Out of Sales or Sharing of Personal Data” for what we mean by that), we may share your personal information for certain business purposes or at your direction. For example, we share your personal information with our data hosting and storage providers and other service providers. We enter into agreements with those service providers which specify that they can only use your information for 360training.com’s purposes specified here: 

Partner	Purpose
Advertising Partners	Advertising
Cloud Storage Providers	Data storage
Content Providers	Content delivery Content streaming Content storage Content review
Customer Support Providers	Customer support Account verification Password recovery
Data Analytics Providers	Data analytics
Data Management Providers	Machine learning and algorithms
Data Solution Providers	Research
State Regulatory Agencies	Notice of Course Completion
Logistics Providers	Shipping products
Marketing Partners	Email marketing
Measurement Partners	Mobile measurement Pixel tracking Targeting
Payment Providers	Payment services

We may also share with third parties that provide services to us or perform business purposes for us aggregated, non-personally identifiable, or de-identified information.

Retention of Personal Data 
See the Privacy Policy section titled “How Long We Keep Your Information”

“Shine the Light” Disclosures
The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. To opt out of this type of sharing, please email us at privacy@360training.com.

Consumer Rights Metrics 2022
You can find data that reflects the California consumer rights requests that we have processed in the 2022 calendar year (January 2022 – December 2022) below.

	Received	Complied	Denied*	Days to Complete
CCPA Right to Know	0	n/a	n/a
CCPA Right to Delete	0	n/a	n/a
Do Not Sell or Share**	0	n/a	n/a

* Denied means that the request was not verifiable or was denied on other grounds.

** We don’t sell your data, so we don’t process, or collect metrics on, opt-out requests for the sale or sharing (as defined by CCPA) of consumer data.