Dion Training Privacy Policy

This privacy policy (“ Privacy Policy”) describes how Dion Training Solutions, LLC (“Dion Training”, “we”, “us” or “our”) collects, protects and uses the personally identifiable information (“Personal Information”) which you (“User”, “you” or “your”) may provide on our website located at https://www.diontraining.com/ related subdomains and through the use of any of our products or services (collectively, “Website” or “Services”). It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. This Privacy Policy does not apply to the practices of companies that we do not own or control, nor to individuals that we do not employ or manage.

Residents of the European Union, Brazil and certain other states may have additional rights. Please see our GDPR Privacy Rights section and US and Brazil Disclosures following the main Privacy Policy.

PLEASE READ THE PRIVACY POLICY TO UNDERSTAND HOW YOUR PERSONAL INFORMATION WILL BE TREATED AS YOU MAKE FULL USE OF THE SERVICES. YOUR USE OF THE SERVICES IS SUBJECT TO YOUR ACCEPTANCE OF THIS PRIVACY POLICY AND THE TERMS OF SERVICE. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY OR THE TERMS OF SERVICE, PLEASE DO NOT USE THE WEBSITE OR SERVICES.

1. Collection of personal information

We collect information in several ways from different parts of the Services:

• Information you provide voluntarily

We receive and store any information you knowingly provide to us when you create an account, publish content, make a purchase, and fill any online forms on the Website.

This information may include the following: your email address, name, credit card information, bank information, or other Personal Information which may change from time to time depending on the Services provided.

You can choose not to provide us with identifying information, but then you may not be able to take advantage of some of the Website’s features or access our members’ only Services.

• Information collected automatically

When you visit the Website our servers automatically record information that your browser sends. This data may include information such as your device’s IP address, browser type and version, operating system type and version, language preferences or the webpage you were visiting before you came to our Website, pages of our Website that you visit, the time spent on those pages, information you search for on our Website, access times and dates, and other statistics.

• Information Collected When You Interact with Third-Party Websites

The Services may include functionality that allows certain kinds of interactions between the Website and your account on a third-party website or application such as a social media site. The use of this functionality may involve the third-party site providing information to us. For example, we may provide links on the Website to facilitate sending a communication from the Website. These third parties may retain any information used or provided in any such communications or activities and these third parties’ practices are not subject to our Privacy Policy. We may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should read the applicable third-party privacy policies before using such third-party tools through our Services

2. Tracking Technologies and Cookies.

We may use tracking technologies and cookies to track the activity and improve your experience on our website. We currently use tracking technologies from Salesforce and ZoomInfo.

In order to control ZoomInfo’s use of your data, please see https://www.zoominfo.com/privacy-center.

We also use Clicky and Google Analytics for website performance analysis.

In order to control Clicky’s use of your data, please see https://clicky.com/optout.

In order to control how Google Analytics uses your data, please see https://tools.google.com/dlpage/gaoptout.

Additionally, please note that while we do not store personal information directly, services such as our web hosting service and our payment processor may use cookies and process data as part of our store's functionality.

Third parties whose sites you may access from our Website may also use cookies and tracking technologies. We are not responsible for their use of your data or their use of cookies. To learn more about their use of cookies and similar technologies, you can visit https://about.ads.microsoft.com/en-us/resources/policies/opt-out-of-the-microsoft-advertising-optimization-program (Bing) and https://www.facebook.com/privacy/policies/cookies/?entry_point=cookie_policy_redirect&entry=0 (Facebook)

You can also learn more about cookies by reviewing our cookie notice at www.diontraining.com. The cookie notice on our website reads as follows.

“This website uses cookies to enhance your browsing experience. We utilize services such as Google Analytics, Clicky, AWS Cognito, Stripe, and ZoomInfo WebSights for website analytics and functionality. Please be aware that Dion Training itself does not directly store personal information, but our third-party service providers may process data as an integral part of our website's operations. By continuing to use our site, you consent to our use of cookies and acknowledge our practices in alignment with GDPR and CCPA regulations.”

3 Why We Collect Personal Information

We may use your Personal Information for various purposes, including:

• Responding to requests for information,
• Providing, developing, customizing and improving your services,
• Fulfilling your requests for services,
• Verifying your identity and for fraud prevention,
• Creating accounts,
• Providing you with updates and information about services we provide,
• Creating user preferences regarding emails and other correspondence,
• Sending you marketing information about Dion Training and our affiliated entities,
• Sending you email and text communications such as electronic newsletters about our Services which may be of interest to you,
• Improving the effectiveness of our Website, our marketing endeavors, and our product and service offerings,
• Helping us address problems with and improve our Website and our products and services, including testing and creating new products, features, and services,
• Protecting the security and integrity of the Website, including understanding and resolving any technical and security issues reported on our Website,
• Resolving disputes,
• Engaging in analysis, research, and reports regarding the use of our Website and Services,
• For internal business purposes and our legitimate interests.
• Complying with the law and protecting the safety, rights, property or security of Dion Training, the Services, and the general public, and
• For purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

The parties to whom your Personal Information may be disclosed for the purposes above are described in greater detail below

4. Aggregated information

We may aggregate, de-identify, and/or anonymize any information collected through the Website or Services such that such information is no longer linked to your Personal Information. We may use and share this aggregated and anonymized information (non-Personal Information) to identify potential cases of abuse and establish statistical information regarding Website usage. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.

5. Retention of Personal Information

We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required in order to contact you about our Services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).

We regularly review collected data and set data retention policies in order to delete data in accordance with contractual agreements, legal obligations and applicable data protection laws.

6. Your control over your Personal Information

You are able to access, add to, update and delete certain elements of your Personal Information from your account page. The information you can view, update, and delete may change as the Website or Services change. When you update information, however, we may maintain a copy of the unrevised information in our records. Some information may remain in our private records after your deletion of such information from your account.

To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive or by changing the email preferences in your account.

Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.

7. Integrating Social Networking Services

One of our unique features allows you to enable or log in to the Services via various social networking services like Facebook, LinkedIn and Google, (“Social Networking Service(s)”). By directly integrating these services, we make your online experiences richer and more personalized. To take advantage of this feature, we will ask you to log into or grant us permission via the relevant Social Networking Service. When you add a Social Networking Services account to the Services or log into the Services using your Social Networking Services account, we will collect relevant information necessary to enable the Service to access that Social Networking Service and your data contained within that Social Networking Service. As part of such integration, the Social Networking Service will provide us with access to certain information that you have provided to the Social Networking Service, and we will use, store and disclose such information in accordance with this Privacy Policy.

You may also have the option of posting your activities to Social Networking Services when you access content through the Website; you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services you have enabled will be able to view such activity. Because we use social media plugins, if you visit our Website while logged in to a social networking account, personally identifiable information about your browsing activities on this Website may be transferred to the third party who operates that account. See the third party’s terms of service and privacy policy for more information on what information may be transferred and what you can do to avoid or limit the transfer of information.

8. Billing and payments

We use third-party payment processors to assist us in processing your payment information securely. Such third-party processors’ use of your Personal Information is governed by their respective privacy policies which may or may not contain privacy protections as protective as this Privacy Policy.

9. Privacy of children

We do not knowingly collect any Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through our Website or Service. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through our Website or Service without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through our Website or Service, please contact us.

10. Newsletters

We offer electronic newsletters to which you may voluntarily subscribe at any time. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. As indicated above, you will continue to receive essential transnational emails.

11. Affiliates

We may disclose information about you to our affiliates for the purpose of being able to offer you related or additional products and services. Any information relating to you that we provide to our affiliates will be treated by those affiliates in accordance with the terms of this Privacy Policy.

12. Links to other websites

Our Website contains links to other websites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other websites or third-parties. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every website that may collect Personal Information.

13. Information security

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our Website cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite best efforts.

14. Legal disclosure

We will disclose any information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account and personal data will likely be among the assets transferred.

15. Visitors to the Website Outside of the United States

If you are visiting the Website from a location outside of the U.S., your connection will be through and to servers located in the U.S. Information you receive from the Website will be created on servers located in the U.S., and information you provide will be maintained on web servers and systems located within the U.S. The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Website or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information in the United States as set forth in this Privacy Policy.

16. International Data Transfers

Because Dion Training works with global companies and technologies, we may transfer your Personal Information outside of the country in which it was originally provided. This may include transfers to third parties, such as developers, service providers or affiliated entities who are location outside the United States or the European Union or United Kingdom, where data protection laws may not offer the same level of protection as those in the U.S., U.K., E.U. or European Economic Area. When we transfer personal data outside of these areas, we take steps to make sure that appropriate safeguards are in place to protect your Personal Information.

17. California Privacy Rights

Under the Shine the Light law, California residents may request certain information regarding Caspio’s disclosures in the prior calendar year, if any, of their Personal Data to third parties for their own direct marketing purposes. If you are a California resident, you can make such a request by contacting us at legal@diontraining.com. You must clearly state the nature of your California Privacy Rights request and provide sufficient information for us to process your request; at a minimum your name, email address, and California postal address. We will respond to your request within 30 days.

18. Nevada Privacy Rights

If you are a Nevada resident, you have the right to request certain information from us regarding the collection and sale of your personal information (as defined in Nevada Revised Statutes 603A.320) during your visit to our websites or when you otherwise interact with us online. If you have sought or acquired, by purchase or lease, any goods or services for personal, family, or household purposes from the Caspio Website, you may ask us to disclose whether we have sold (for monetary consideration) certain information about you (including your first and last name, physical address, email address, telephone number, an identifier that allows you to be contacted either physically or online, or other contact information that allows us to identify you personally).

As a Nevada resident, you may also request to opt out of us sharing such information about you. To make this inquiry, please submit a request by contacting us at legal@diontraining.com.

You must include your full name, email address, and attest that you are a Nevada resident by providing a Nevada postal address in your request. Please state whether you are requesting information and/or opting out.

We will process your request within 60 days, or we will let you know if we need additional time. We may require additional information to verify your identity before we can respond.

19. Do Not Track

Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally-agreed upon standard for what a company should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms.

20. How to exercise these rights

Any requests to exercise your rights can be directed to us through the contact details provided below in this Privacy Policy. These requests can be exercised free of charge and will be addressed by us as soon as possible and always within one month.

21. Changes and amendments

We may modify this Privacy Policy at any time, effective upon posting of an updated version of this Policy on the Website. When we do, we will revise the updated date at the top of this page. Continued use of the Website and Services after any such changes shall constitute your consent to such changes.

21. Contacting Us

If you have any questions about this policy, please contact us as follows:

Email: legal@diontraining.com

Mailing address: 2151 Consulate Drive, Suite 5 Orlando, FL 32837

GDPR Privacy Rights

If you are a resident of or located within the EU or European Economic Area (“EEA”) or the United Kingdom, you have certain additional data protection rights under the General Data Protection Regulation (“EU GDPR”) or the UK GDPR (collectively “GDPR”). These rights include:

• The right to access, update or delete the information we have on you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Information.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine- readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.

Legal Basis for Processing Personal Information under GDPR

Dion Training’s legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it.

Dion Training may process your Personal Information because:

• We need to perform a contract with you;
• You have given us permission to do so;
• The processing is in our legitimate interests, and it is not overridden by your rights; or
• To comply with the law.

Disclosure of Personal Information under GDPR

Legal Requirements

Dion Training may disclose your Personal Information in the good faith belief that such action is necessary to:

• To comply with a legal obligation;
• To protect and defend the rights or property of Dion Training;
• To prevent or investigate possible wrongdoing in connection with the Service;
• To protect the personal safety of users of the Service or the public; or
• To protect against legal liability

Disclosure for Law Enforcement

Under certain circumstances, Dion Training may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

As specified above, to exercise any of these rights, you can submit your request by contacting us at legal@diontraining.com. We will respond to your privacy requests within 30 days and notify you of the action(s) we have taken or required steps to fulfill the request.

Please note that the above individual rights are not absolute, and we may be entitled to refuse requests where certain exceptions apply.

Please note that where our processing of your Personal Information relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services. Should you wish to raise a concern about our use of information (without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.

GENERAL STATEMENT FOR US RESIDENTS

Residents of certain states in the United States may have additional rights in the future and Dion Training will update this policy as and when such laws become applicable to us.

This Supplemental Policy describes Dion Training’s practices regarding the collection, use, and disclosure of Personal Information and provides instructions for submitting data subject requests.

This Notice does not apply to personal information that we process as a service provider on behalf of our customers.

Your Rights to Your Personal Information

Generally, the rights available to residents of the United States under various privacy laws can be categorized as follows:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Data portability.
• Opt-out of personal data processing for targeted advertising and sales
• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects

Processing of Sensitive Information: We must obtain your express consent prior to collecting and processing certain categories of sensitive personal data such as precise geolocation data, data about protected characteristics and genetic or biometric data.

Non-Discrimination: Dion Training will not discriminate against customers who exercise their rights under state privacy laws.

Personal Information of Minors

Our Services are not intended for children or minors under the age of 16. Accordingly, we do not knowingly store information from minors under the age of 16 except as required pursuant to applicable law.

Financial Incentives for Consumers

We do not have any programs which provide financial incentives for consumers.

Exercising Access, Data Portability, and Deletion Rights

To exercise any of these rights, you can submit your request by contacting us at legal@diontraining.com

We will respond to your privacy requests within 30 days’ and notify you of the action(s) we have taken or required steps to fulfill the request.

Only you or a person registered with the appropriate state authority that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Your LGPD Privacy Rights

If you are resident in Brazil, you may be able to exercise the following rights with respect to your personal information that we have collected, subject to certain limitations:

The right to confirmation of the existence of the processing. You have the right to ask that we confirm whether we process your personal data.

The right to access the data. You have the right to access the personal data we hold about you and certain information about how we use it and who we share it with, including information about any public and private entities we have shared your personal data with. The right to correct incomplete, inaccurate or out-of-date data.

The right to anonymize, block, or delete unnecessary or excessive data or data that is not being processed in compliance with the LGPD. Please note that, depending on the request, this may result in a suspension or discontinuation of certain services and is also governed by legal and/or contractual retention guidelines.

The right to the portability of data to another service or product provider, by means of an express request.

The right to delete personal data processed with the consent of the data subject. You have a right to request the permanent deletion of your data, subject to certain exceptions.

However, please note that exercising this right may result in a suspension or discontinuation of services and is also governed by legal and/or contractual retention guidelines. The right to information about the possibility of not giving consent and about the consequences of the refusal. You have the right to ask us to provide information about the possibility of not giving consent for the processing of your personal data and the consequences of such refusal.

The right to revoke consent. Please note that not all of these rights listed above are absolute, and limitations/exceptions apply in some cases. For example, we may not be able to fully comply with your request if we are bound by certain legal restrictions or contractual requirements, but in those circumstances, we will still respond to notify you of such a decision.

Exercising Data Portability and Deletion Rights To exercise the data portability and deletion rights described above, please submit a verifiable consumer request to us at legal@diontraining.com

We will need to verify your identity before processing your request. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or a legal representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request, response timing and format

We endeavor to respond to a verifiable consumer request within 15 days of its receipt but no more than 30 days. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request. You shall immediately inform us when our cooperation is necessary to alter, update, supplement, correct or exclude personal data that has been made available by you to us (e.g. personal data of third parties). You shall provide all the relevant information so that we may take the necessary provisions within a reasonable time.