1. Introduction
At Trainsmart Limited (“Trainsmart”), we respect and protect the privacy of our customers and those who use our Website under the domain name www.trainsmart.com (“the Website”). This privacy policy (“the Policy”) explains how your personal information is collected and used on the Website. By visiting the Website you shall be deemed to accept and consent to the data processing and privacy practices referred to in this Policy.

2. Information Collected
Trainsmart collects details provided by you on registration (or when you otherwise provide profile information to us) together with information we learn about you from your use of our services and your visits to the Website. We also collect information about the transactions you undertake including details of payment cards used. We also monitor customer traffic patterns and use of the Website which helps us to improve the services that we provide.

Trainsmart collects information from our users at several different points on the Website. From time to time you will be asked to submit personal information in order to receive or use goods or services on the Website (for example promotional and informational mailings, online “webinars” and resources; assistance in evaluating our software and services; forum participation; newsletters; promotions and competitions). These profile forms are often linked to Trainsmart’s mailing lists and require users to give contact information (such as name and email address). We collect information from you when you complete profile forms, provide feed-back and also from e-mails that you send us.

Users may opt-out of receiving future mailings at any time (see the choice/opt-out section below).
Trainsmart is the sole owner of information collected on the Website. We will only sell, share, or rent this information to others as set out in this Policy.

3. Use of your information
We will use your information to improve and personalise the Website and our services. We may also use your contact details to communicate with you and to send you offers and news about Trainsmart, the Website and our products and services (and occasionally those of other carefully selected companies which we think may be of interest to you). We may contact you by post, email, telephone or fax for these purposes.

Information about our customers is an important part of our business and in general any information you provide to us will only be used for the purposes of improving our services to you. Trainsmart may share your information with other group companies and any successors in title to our business. We may also disclose your information in the following circumstances:

• Suppliers: we engage various other companies and individuals to perform functions on our behalf. This might include fulfilling orders, delivering packages, sending post and email, removing repetitive information from customer lists, analysing data, providing marketing assistance, processing credit card payments, carrying out research and analysis and providing customer services. Such suppliers may require access to your personal information in order to perform such functions but may not use it for other purposes. Further, such suppliers must process the personal information in accordance with this Policy and relevant law.
• Business sales: as we continue to develop our business, we might sell or buy subsidiaries or business units. In such transactions, customer information is generally one of the transferred business assets but remains subject to the provisions of any pre-existing privacy policy unless, of course, you agree otherwise. Also, in the unlikely event that Trainsmart or substantially all of its assets are acquired, customer information may be one of the transferred assets. Accordingly, if our business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.
• Legal requirement: we may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required by law. For example, we may be required to disclose personal information in order to co-operate with regulators or law enforcement authorities or to comply with a legal process such as a court order, subpoena or search warrant.
• Protection of the Website and Trainsmart: we may release account and other personal information when we believe such disclosure is appropriate to enforce our terms and conditions of business or other agreement with you or to protect our rights, property and safety or those of our users or others. Accordingly, if you post or send offensive, inappropriate or objectionable content anywhere on the Website or otherwise engage in any disruptive behaviour on the Website, we may use whatever information is available about you to prevent such behavior continuing. This may involve informing relevant third parties about the content and behaviour. Similarly, it may be appropriate to exchange information with other companies and organisations to protect against fraud and reduce credit risk.

Finally, we may also use aggregate information and statistics for the purposes of monitoring usage of the Website for marketing and strategic development purposes (including development of the Website and our services). We may provide such aggregate information to third parties to assist us. These statistics will not include information that can be used to identify any individual.

4. Cookies/use of web technologies
As is standard on most business websites, our Website uses “Cookies” and other technologies to help us understand which parts of the Website are most popular, where our visitors are going and how much time you spend there.
Cookies are small text files transferred from the Website to the computer hard drives of our visitors via your browsers. Cookies are very widely used on websites and you can find out more about the way that Cookies work on http://www.aboutcookies.org. Trainsmart uses Cookies for a number of purposes, for instance to enable us to simplify the logging on process for our users, to help ensure the security and authenticity of our users, to provide the mechanisms for on-line purchasing and to enable traffic monitoring.

We may access and set cookies using web beacons, also known as single-pixel GIFs which are invisible graphical images. These web beacons provide us useful information regarding our site such as which pages users access. When we send you emails, we may include a single-pixel GIF to allow us to determine the number of people who open our emails. When you click on a link in an email, we record this individual response to allow us to customize our offerings to you.

We also keep track of activity on the Website via log files stored on our web servers. We collect information such as IP address, browser type and version, and pages you view. We also keep track of how you got to the Website and any links you click on to leave. Once you leave the Website, we do not track you. We use your website activity to assist us in offering you a personalized Web experience, assist you with technical support, diagnose problems with our server, administer our websites and to tailor our product and service offerings to you.

Users may set their computers to accept all Cookies, to notify the user when a Cookie has been issued or to not receive Cookies at all. If you set your browser not to receive Cookies at all, this will mean that certain personalized services and content cannot be provided to you. Accordingly you may not be able to take full advantage of all of the services and features available on the Website and you may have limited access to certain areas of the Website.

5. Links/other websites
Our Website may provide links to third-party websites, such as those of our business partners or online advertisers. While on these sites, Trainsmart or its partners may collect information about you. Because Trainsmart does not control the information policies or practices of these third parties, you should review their privacy policies to learn more about how they collect and use personally identifiable information.

6. Security
Trainsmart takes precautions (including administrative, technical and physical measures) to protect the confidentiality and security of your personal information. We use industry-recognized security safeguards such as firewalls, coupled with carefully developed security procedures to protect your information from loss, misuse or unauthorized alteration. When we (or agents on our behalf, such as secure payment processors) ask for sensitive information, such as credit card numbers, your information is protected is through the use of encryption during transmission, such as the Secure Socket Layer (SSL) protocol.

Trainsmart takes care to reinforce the importance of our visitors' security and privacy among our employees. Our employees are trained and required to safeguard your information and, using physical, electronic and procedural safeguards, we restrict access to personal information to those employees and agents for business purposes only. Additionally, we use internal and external resources to review the adequacy of our security procedures.

You may help us by also taking precautions to protect your personal data when you are on the internet. You should change your passwords often using a combination of letters and numbers and make sure that you use a secure web browser. You should also be aware that, if you access the forum on the Website (or any other chat-room or bulletin board that may be made available), any information that you share is visible to other users. Personally identifiable information that you submit to such forums can be read, collected and used by other individuals to send you unsolicited messages. Trainsmart is not responsible for the personally identifiable information you choose to submit to such forums.

7. Choice/Opt-out
Trainsmart provides users the opportunity to opt-in, opt-out or change preferences via a link in the footer of most email messages. These options are made available when you sign-up for our email lists and in email messages delivered from us. Alternatively, you may email us at info@trainsmart.com.

Some communications (e.g. important account notifications and billing information) are necessary for all Trainsmart customers. You must cancel your Trainsmart account to unsubscribe from these communications. To cancel your Trainsmart account, please email us at info@trainsmart.com.

8. Notification of Changes
As our business changes and develops we may decide to change the provisions of this Policy. If we do so, we will post those changes on the Website so that you will continue to be aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We may also e-mail you periodic notices of reminders of the Policy and our terms and conditions of business (or changes to any of these), unless you have instructed us not to.

9. Access Rights
You have a right to access the personal data that is held about you and to have any inaccuracies corrected. We charge £10 (ten pounds) for information requests. Please address requests to: the Website Administrator, Trainsmart Limited, Heathfield, Potters Heath Road, Welwyn, Hertfordshire AL6 9TA or email: info@trainsmart.com. You will need to provide us with your postal address and a remittance for the fee (payable to Trainsmart Limited).

10. Contacting Trainsmart
We welcome your views about the Website, the Policy, our Terms of Use. If you would like to contact us with any queries or comments, please send an e-mail to:info@trainsmart.com.