Introduction

TrainHQ, Inc. ("TrainHQ", “we, “us”, or “our”) operates the site www.trainhq.ai to provide information regarding our business. We are dedicated to providing AI-based employee training solutions. This privacy policy explains how we collect, use, and protect information gathered from our website visitors and platform users.

For users in the United States and other non-EU countries:
TrainHQ, Inc., a Delaware corporation
279 Galeon Court
Miami, Florida 33143, United States
Email: privacy@trainhq.ai

For users in the European Union:
TrainHQ GmbH
Rollbertstraße 28A
12053 Berlin, Germany
Commercial Register: HRB 265491 B, Amtsgericht Charlottenburg
Managing Director: Adam Svet
Authorized Representative: Lukas Kramer
Email: privacy@trainhq.ai

For users in the European Union, this policy complies with the General Data Protection Regulation (GDPR) and provides information about your rights under applicable data protection laws.

We are committed to protecting our website visitors’ privacy and platform users data addressing potential privacy concerns. The following information has been posted to help you understand what information we collect and how it is used.

We process personal data based on the following legal grounds:

Consent: When you provide explicit consent for specific processing activities
Contract: To fulfill our contractual obligations with customers

Types of information collected

To best serve your needs, we collect the following types of information when you visit www.trainhq.ai and use our training platform: automatically collected information, voluntarily shared information and usage-related data.

Automatically collected information

We automatically collect data on how our users visit www.trainhq.ai, such as your IP address, company affiliation, location, browser, browser language, operating system, device identifiers, and cookies. Our website currently uses cookies to enhance its functionality. You may disable cookies in your web browser, but this may limit your ability to access www.trainhq.ai.

Voluntarily shared information

You may choose to share the following information should you want us to contact you directly: Name and Email address.

When you use our training platform, we may collect:

• Account Data: Name, email, username

• Voice Data: Audio recordings, transcriptions

• Usage Data: Session activity and progress

Policy on collecting sensitive personal information

We do not gather any of your sensitive personal information, such as your social security number, driver's license number, race, ethnicity, religion, health metrics, political associations, or details on your criminal background.

For EU users: Voice recordings are considered a special category personal data under GDPR. We process voice data based on your explicit consent and only for the purpose of providing AI training services. Voice data is automatically deleted after 90 days.

How the information collected is used 

We use your information gathered from our website to help us communicate everything we have to offer. This includes: communicating our sales and promotions, providing marketing and sales communications that are relevant to you, and evaluating analytics to see how our customers engage with www.trainhq.ai.

For training platform users, we use your data to:

• Provide AI training sessions

• Generate feedback and assessments

• Provide customer support

AI Safety and Ethics

TrainHQ uses best-in-class AI model providers and does not train proprietary AI models. Customer data is never used for AI model training purposes. Our AI implementations are designed to enhance human capabilities while respecting human dignity and privacy.

Apart from the information gathered from website traffic, we do not use our customer’s user information beyond what is essentially needed to operate TrainHQ’s application, including assigning users and organizing their data in a relevant fashion for customer needs.

Length of time personal information is stored

• Voice Recordings: Deleted after 90 days (processed on EU servers for EU users)

• Other Data: Until contract termination or consent withdrawal

Who the information is shared with

We may share your information with third party technology providers that support our website functionality and platform services. TrainHQ, Inc., along with its subsidiaries and affiliates, may employ and utilize certain third-party data processing entities, referred to as "Sub-Processors". These Sub-Processors may be granted access to personal data supplied directly by our clients or to which we may have access for the purpose of delivering the agreed-upon services or to facilitate related features.

EU user data is processed and stored exclusively within the European Union. US user data is processed and stored within the United States.

Information Security

We do our best to keep your  information secure and safe. Most of your information is encrypted and is therefore protected from being accessed by outside users. However, data leaks and malicious attacks do happen. Please understand that while we make reasonable efforts to protect your data, there is always the possibility of a security incident occurring.

We maintain SOC 2 Type II certification, demonstrating our commitment to enterprise-grade security controls and data protection.

In the event of a data breach, we will notify relevant authorities within 72 hours and inform affected individuals if the breach poses a high risk.

General information about Sub-Processors

TrainHQ, Inc., along with its subsidiaries and affiliates, may employ and utilize certain third-party data processing entities, referred to as "Sub-Processors". These Sub-Processors may be granted access to personal data supplied directly by our clients or to which we may have access for the purpose of delivering the agreed-upon services or to facilitate related features. This page offers crucial details about the identity, location, and function of each Sub-Processor.

At present, we employ the Sub-Processors listed below to deliver services such as infrastructure support, customer assistance, service management services, and email alerts. For EU users, all training platform data processing occurs exclusively on EU-based infrastructure to ensure compliance with European data protection requirements. It's important to note that not all Sub-Processors are involved in delivering all the services we offer. Some may only assist in providing specific services. TrainHQ, Inc. enforces data protection terms with each Sub-Processor concerning their security measures and relevant regulations for the safeguarding of personal data.

List of Sub-Processors

Sub-Processor: AWS
- Location: Seattle, Washington, USA  (US and EU regions depending on customer)
- Description of processing: Provides cloud computing infrastructure and services
- Contact: https://aws.amazon.com/privacy

Sub-Processor: Microsoft Azure
- Location: Redmond, Washington, USA  (US and EU regions depending on customer)
- Description of processing: Provides cloud computing services and infrastructure
- Contact: https://privacy.microsoft.com/en-us/privacystatement 

Sub-Processor: Google
- Location: Mountain View, California, USA
- Description of processing: Provides cloud computing services, data analytics, and machine learning tools
- Contact: https://policies.google.com/privacy 

Sub-Processor: Slack
- Location: San Francisco, California, USA
- Description of processing: Provides communication platform services
- Contact: https://slack.com/intl/en-gb/privacy-policy 

Sub-Processor: HubSpot
- Location: Cambridge, Massachusetts, USA
- Description of processing: Provides marketing, sales, and service software
- Contact: https://legal.hubspot.com/privacy-policy

Affiliate Sub-Processors

Sub-Processor: TrainHQ d.o.o.
- Location: Belgrade, Serbia
- Description of processing: Provides research and development services to TrainHQ, Inc.
- Contact: https://www.trainhq.ai/legal/privacy-policy/

Updates to the list of Sub-Processors

Given the global scope of our operations and our continuous pursuit of service enhancement, our business requirements and service providers may occasionally shift. If you wish to stay informed about any additions or substitutions of Sub-Processors, you can subscribe to our email notifications. To do so, send an email to privacy@trainhq.ai with the subject line “Sub-Processor Notification Request”. In your email, please specify that you want to join the TrainHQ, Inc. Sub-Processor notification list on behalf of your organization, and provide your company name, your name, and your email address. If you choose to subscribe to these notifications, we will ensure to inform you at least 30 days before any such modification takes place.

You have the following rights regarding your personal data

- Right of Access: Request information about what personal data we hold about you
- Right to Rectification: Request correction of inaccurate personal data
- Right to Erasure: Request deletion of your personal data in certain circumstances
- Right to Withdraw Consent: Withdraw consent where processing is based on consent

To exercise these rights, contact us at privacy@trainhq.ai. We will respond within 30 days.

When participating in AI training sessions:

• Your voice will be recorded and processed in real-time

• Voice data generates AI-powered feedback

• Recordings are automatically deleted after 90 days (EU users)

• You can request immediate deletion of voice data

• You can withdraw consent for voice processing at any time

Information Security

We do our best to keep your information secure and safe. Most of your information is encrypted and is therefore protected from being accessed by outside users. However, data leaks and malicious attacks do happen. Please understand that while we make reasonable efforts to protect your data, there is always the possibility of a security incident occurring.

Consent

By using our website, you agree to the terms of this privacy policy. For platform registration, you provide explicit consent for all data processing activities described in this policy, including voice recording during training sessions.

Applicable Law

This privacy policy is governed by the laws of Delaware for US users and German law for EU users.

Your Right to Erasure (“Right to Be Forgotten”)

If you are located in the European Union, you have the right to request the deletion of your personal data in accordance with Article 17 of the General Data Protection Regulation (GDPR). Subject to any legal or contractual obligations, we will promptly delete or anonymize your personal data upon receiving a valid erasure request.

If you would like to exercise this right, please contact us at info@trainhq.ai and include the details necessary for us to identify the personal data you wish to be erased. Upon verifying your request, we will delete your data unless we have a legitimate legal or contractual ground to retain it (for example, compliance with legal obligations).

If you believe we have not adequately addressed your privacy concerns, you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.

Additional questions

If you have questions regarding this privacy policy, feel free to contact us at privacy@trainhq.ai. A TrainHQ representative will respond to your privacy policy questions as soon as possible within 30 days.

We may update this privacy policy from time to time. The current version will always be available on our website with the effective date clearly marked.