Last Updated: February 17, 2023
Privacy Policy Last Updated: February 17, 2023 Privacy Policy This Privacy Policy describes the ways in which information about you may be collected, used, disclosed, transferred and stored by TTS (TTS entities listed below in section 1.1). The Privacy Policy applies to any interaction with TTS, including through any websites, platforms or applications (together hereinafter referred to as the “Site” or “Sites”). 1. Contents This Privacy Policy consists of the sections set out below. For ease of reference, please click on the relevant section to go directly to that section. 1.1 Who we are The TTS entities listed below are the joint data controllers of your personal data: When we refer to the “Company”, “we“, “us” or “our” in this Privacy Policy, we are referring to the relevant TTS entity that is processing your personal data. We are a leading provider of instructor-led courses and self-study in financial modelling, accounting, capital markets, Excel, financial statement analysis and corporate valuation training to investment banks, consulting firms, law firms, business schools, and colleges. We provide live classroom training, workshops at business and academic institutions and multimedia presentations and course materials that can be downloaded or accessed via the internet. 1.2 Purpose of this Privacy Policy We ask that you read this Privacy Policy carefully as it contains important information about: It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them. This Privacy Policy sits alongside the Terms of Use of our Sites which we also encourage you to read. 2. Children Our Sites are intended for use by adults and we do not knowingly collect information from or about children. If you are a parent or guardian and your child who is under 13 (or other ages as appropriate by country) may have provided personal data to our Site, please contact us. The age of consent for processing personal data in the United Kingdom (the “UK”) is 13 and such age varies from country to country and state to state. 3. What personal data we may collect from you We may collect and process the following personal data: 4. How we collect information from you We collect your personal data in a number of ways, including as follows: 5. How we use your personal data We have briefly set out below the purposes for which we may use your personal data. We have also identified one or more legal bases on which we rely for processing your personal data 6. Marketing We may collect your identity and contact details (such as your name, email address, phone number or address) in order to send you information about our products and services which you might be interested in. We may collect this directly from you, or through a third party. If a third party collected your name and contact details, we will process your professional data based on legitimate interests to send you a fair processing notice and then respect any communication preferences you give us. You always have the right to “opt out” of receiving our marketing. You can exercise the right at any time by contacting us. If we send you any marketing emails, we will always provide an unsubscribe option to allow you to opt out of any further marketing emails. If you “opt-out” of our marketing materials, you will be added to our suppression list to ensure we do not accidentally send you further marketing. Where you unsubscribe from any postal marketing, you may initially still receive some content which has already been printed or sent, but we will remove you from any future campaigns. We may still need to contact you administrative or operational purposes, but we will make sure that those communications do not include direct marketing. If you are an existing customer or are acting as a business we use your contact details as necessary for our legitimate interests in marketing to you and maintaining a list of potential customers. We never share your name or contact details with third parties for marketing purposes. We do use third party service providers to send out our marketing, but we only allow them to use that information on our instructions and where they have agreed to treat the information confidentially and to keep it secure. We retain your details on our marketing list until you “opt-out”, at which point we add you to our suppression list. We keep that suppression list indefinitely to comply with our legal obligations to ensure we don’t accidentally send you any more marketing. You can change your mind regarding your marketing preferences at any time by contacting us. 7. Retention of your data We will retain your personal data for as long as it is required to provide you with services or is necessary for legal reasons. When calculating the appropriate retention period for your data, we consider the nature and sensitivity of the data, the purposes for which we are processing the data, and any applicable statutory retention periods. Using these criteria, we regularly review the personal data which we hold and the purposes for which it is held and processed. After we have ceased to provide you with services, your data will be processed only for technical reasons (system integrity, back-ups) while it remains inactive in our systems. Where we need to retain your personal data to comply with our legal obligations, we will retain such personal data for the duration necessary to comply with such legal obligations. We store your personal data as long as you wish to receive marketing content from us (you have right to withdraw your consent or object processing at any time). We retain the details of your contract and history of your purchases and training for at least 7 years (or such longer period as required by applicable laws) after your account is closed so that you can have access to this information for future use and to enable us to deal with any after sales enquiries or claims and as required for tax purposes. This information may be stored in our archive for reference purposes for as long as our business needs require which we will review after 7 years. Visitor data and CCTV recordings are retained for the maximum periods permissible under applicable laws. We retain information collected by a cookie until that cookie expires or is disabled by you. For further information on cookies used please refer to our Cookie Policy. 8. Accuracy of your data It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. Once you have logged in to the Site, you may be able to change your personal data by clicking on the icon of a person in the upper right corner to access “My Account”. Under My Account, you may be able to access and change your personal data including your name, billing addresses, courses and order history. 9. Security of your data In order to protect your personal data, we put in place appropriate organisational and technical security measures. These measures include ensuring our internal IT systems are suitably secure and implementing procedures to deal with any suspected data breach. In the unlikely event of a data breach, we will take steps to mitigate any loss or destruction of data and, if required by law, will notify you and any applicable authority of such a breach. Although we use appropriate security measures once we have received your personal data, you will appreciate that the transmission of data over the internet (including by e-mail) is never completely secure. We endeavour to protect personal data, but we cannot guarantee the security of data transmitted to or by us. 10. Transfer of your data to third parties, international transfers of personal data and sharing your personal data Please read this section if you are accessing our services from the UK, the European Economic Area (the “EEA”) or Switzerland. Our business and that of the third parties we use to deliver our services to you is international in nature. Training The Street and AMT Training are a global brand and TTS entities operate from a number of locations around the world. Consequently, TTS entities may transfer data between them to ensure the most efficient data processing. However, TTS entities will comply by national and other regulation and ensure adequate and appropriate technical, organizational and legal safeguards for international data transfers. If we transfer data to countries or organisations outside of the UK, the EEA or Switzerland which the EU or the UK do not consider to have an adequate data protection regime in place, we will ensure that appropriate safeguards (for example, standard contractual clauses approved by the EU, UK or a data protection authority) are put in place where required. If you would like more information regarding the safeguards we put in place for international data transfers from the UK, EEA or Switzerland please contact us. Our business and operations (including data servers) are primarily based in the United States of America (the “USA“). When you access our services and register for our courses and provide us with your personal details (by logging in online), you will in effect be providing us your personal data for processing in the USA. Your personal data is shared with third party service providers who process the information on our behalf so that we can provide our services to you. Our third party providers may use their own subcontractors who may be given access to your personal data in order to provide our services to you. Our main third party providers are located outside of the UK, EEA and Switzerland and therefore your personal data will be transferred to countries outside of the UK, EEA and Switzerland. We may also share with your employer details regarding your participation in training sessions if your employer is paying for our services on your behalf. Details that we may share with your employer include, but are not limited to, your training progress, performance and completion of training. We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business where necessary in connection with the purposes which your information was collected for. We may also need to share your personal data with a regulator or to otherwise comply with the law. 11. Third party links Our Sites contain links to and from other applications, plug-ins and websites of other networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that they (and any services that may be accessible through them) have their own privacy policies and, unless we have expressly agreed otherwise with you, we do not accept any responsibility or liability for the content of these applications or websites or their policies or for any personal data that may be collected through these applications, websites or services. We encourage you to read these privacy policies before you submit any personal data to these applications or websites or use such services. 12. Your United Kingdom, European Economic Area and Switzerland Rights If you are located in the UK, the EEA or Switzerland, you may have certain rights in relation to the personal data we process and hold about you. These rights are: With the exception of lodging a compliant directly with a supervisory authority (such as the Information Commissioner’s Office), if you would like to contact us to exercise any of the other rights set out above, please put your request in writing; include proof of your identity (such as a copy of your driving licence or passport) and address (such as a recent utility or credit card bill) and specify the right you wish to exercise. 13. Exercising Data Subject Access Rights for non-California U.S. Residents If you are a resident of Colorado, Connecticut, Utah or Virginia, in 2023 your state will begin to afford you certain rights with respect to knowing whether we hold your personal data, what personal data we hold about you, accessing your personal data, requesting copies, correcting errors, and in some cases requesting it be deleted. These states also grant their residents the right to opt-out of targeted advertising, sale of data (note, we do not sell personal data), and, in the case of Colorado, Connecticut and Virginia, to opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects. To exercise these rights, please email us at info@trainingthestreet.com. We will provide a full response to your request (or notice that additional time to respond is needed) within 45 days of your request. If your request is denied and you believe the denials is in error, you may appeal the decision by submitting your reasons [describe process]. We will response to your appeal submission within 45 days of receipt, or will notify you within that timeframe that we need additional time to respond. If your appeal is denied, you have the right to contact your state Attorney General with any concerns about the result of the appeal. 14. Your California Privacy Rights This section supplements the other parts of this Privacy Policy, and provides additional information for California residents pursuant to the California Consumer Privacy Act (“CCPA”). Within the past 12 months, we have collected the following categories of personal information about California consumers as described by the CCPA. Note that the specific pieces of personal information we collected about you may vary depending on the nature of your interactions with us, and may not include all of the examples listed below. Some personal information included in this category may overlap with other categories. More info for job applicants can be found here More info for job applicants can be found here Our uses of your personal information are described under Section 5 of this Privacy Policy (How we use your personal data). Submitting Requests Under the CCPA. If you are a resident of California, your right to submit certain requests relating to your personal information is described below. Please note that when submitting a request, you will be asked to provide information to verify your identity before action is taken. You may designate an authorized agent to make the requests below on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. Exclusions. Some personal data is not subject to the CCPA such as consumer credit reports and background checks, publicly available data lawfully made available from state or federal government records, and any other personal data exempt from the CCPA. This Privacy Policy does not apply to our employees. Right to Opt-Out of the Sale of Your Personal Information. California residents have the right to opt-out of the sale of their personal information. However, because we do not sell personal information, there is no need to submit such a request to us. If you have any questions, please contact us by email to info@trainingthestreet.com, or by calling us at 1-800-887-1320. Right to Request Information. If you are a California resident, you have the right to request information regarding the following, up to two times in a 12-month period, to the extent applicable: You may submit a request for the information above by email to info@trainingthestreet.com, or by calling us at 1-800-887-1320. In connection with submission of your request, we will need to take steps to verify your identity before action is taken. We respond to all verifiable requests for information as soon as we reasonably can and no later than legally required. Right to Request Deletion of Your Personal Information. California residents also have the right to request that we delete personal information collected or maintained by us. Following receipt of a request to delete, we will let you know what, if any, personal information we can delete from our records, and we will direct any service providers that may have collected personal information about you through our website to delete your personal information from their records. There may be circumstances where we cannot delete your personal information or direct service providers to delete your personal information from their records. For example, if we need to: (1) retain your personal information to complete a transaction or provide services; (2) detect security incidents; (3) protect against unlawful activities; (4) identify, debug or repair errors; or (5) comply with a legal obligation. You may submit a request to delete your personal information by email to info@trainingthestreet.com, or by calling us at 1-800-887-1320. In connection with submission of your request, we will need to take steps to verify your identity before action is taken. Verification of Requests for Further Information or to Delete Personal Information. Upon submission of a request for information or a request to delete information, we will take reasonable steps to confirm that the person submitting the request to know or request to delete is the person to whom the information relates (or his or her authorized agent), and to prevent unauthorized access to or deletion of information. The specific steps taken to verify the identity of the requesting person may vary based on the nature of the request, including the type, sensitivity and value of the information requested, the risk of harm posed by unauthorized access or deletion, the likelihood that fraudulent or malicious actors may seek the information, the robustness of personal information provided to verify your identity, the nature of our business relationship with you, and available technology for verification. We will generally try to avoid requesting additional information from you for the purpose of verification, but we may need to do so if we cannot verify your identity based on the information already maintained by us. If we request additional information to verify your identity, it will be for that purpose only, and will be deleted as soon as practical after processing the request, except as otherwise provided by law. If there is no reasonable method by which we can verify your identity, we will state so in response to a request to know or delete personal information, including an explanation of why we have no reasonable method to verify your identity. Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of the privacy rights conferred by the California Consumer Privacy Act of 2018, you also have the right not to receive discriminatory treatment by us. This means that, consistent with California law, we will not deny providing our products or services to you, charge you different prices or provide a different level or quality of products or services to you unless those differences are related to the value of your personal information. How to Contact Us. If you have any questions about how we collect or use your personal information, please contact us. 15. Cookies We employ “cookies” to provide visitors with tailored information to facilitate your use of the website. A “cookie” is an element of data that a website sends to a visitor’s browser which, in turn, may store that element on the visitor’s hard drive or memory. Any cookies sent by us will be marked so that they will be accessible only by our websites. A visitor may block or delete our cookies from the hard drive. However, by disabling cookies, certain features and functionality of our websites may no longer work properly, or at all. See our Cookie Policy for more information about data collected online from cookies and similar technologies. Amendments to this Privacy Policy We may at any time change, modify, or otherwise update this Privacy Policy without prior notification. The latest applicable version can be accessed at all times at https://trainingthestreet.com/privacypolicy. This privacy policy was last updated: February, 17th 2023. 16. How to contact us You should be aware that you have the right to raise any concerns with the Information Commissioner’s Office in relation to how we process your personal data if you are in the UK or, with your local supervisory authority if you are anywhere else in the EEA or Switzerland. Alternatively, you may also contact us if you have questions or concerns about this Privacy Policy, our Terms of Use, the website or if you wish to update, correct or delete any information you have provided to us. Please contact us via info@trainingthestreet.com or through the details provided below. Training The Street LLC
1. Introduction
TTS Entities
Country of Incorporation
Business Address
Training The Street, LLC
USA
275 Madison Avenue, Suite 1201, New York, NY 10016, United States of America
StreetMasters Inc.
USA
Training the Street UK, LLC
USA
Training the Street HK Limited
Hong Kong
Adkins & Matchett (UK) Limited
UK
Adkins, Matchett & Toy Ltd
USA
Adkins, Matchett & Toy (Hong Kong) Ltd
Hong Kong
Category
Examples
Collected by us?
Identifiers
Name, alias, title, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name.
Yes
Personal information described in Cal. Civ. Code § 1798.80(e)
Name, signature, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.
Yes
Protected classification characteristics under California or federal law
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Only for employees and job applicants
Commercial information
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Yes
Biometric information
Physiological, biological, or behavioral characteristics that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. For example, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
No
Internet or other similar network activity
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
Yes
Geolocation data
Physical location based on your IP address.
Yes
Sensory data
Audio, electronic, visual, thermal, olfactory, or similar information.
Yes
Professional or employment-related information
Current or past job history or performance evaluations, resumes, education information.
Yes
Non-public education information (as defined by federal law)
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Yes
Inferences drawn from other personal information
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Yes
275 Madison Avenue
Suite 1201
New York, New York 10016
United States of America
+1 (800) 887-1320 (in the United States)
+1 (704) 927-9688 (outside the United States)