PRIVACY AND COOKIE POLICY for Colltrain.com

Effective date: September 5, 2026

1. Introduction

Welcome to Colltrain.com.
This Privacy and Cookie Policy explains how we collect, safeguard, and disclose information resulting from your use of our website and software (hereinafter referred to as the “Service”).

The Service is operated by Centriqa Services & Solutions SRL (the “Manufacturer”) and Axioma Solutions UK Limited (the “Distributor”), collectively referred to as “the Company”, “us”, “we”, or “our”.

By using the Service, you agree to the collection and use of information in accordance with this policy.

2. Definitions

• SERVICE: The colltrain.com platform, an Experiential Learning Platform for Virtual and Classroom Training.
• PERSONAL DATA: Any information relating to an identified or identifiable natural person (“Data Subject”).
• USAGE DATA: Data collected automatically generated by the use of the Service (e.g., IP address, browser type, page visit duration).
• COOKIES: Small files stored on your device to improve user experience and security.
• DATA CONTROLLERS: Centriqa Services & Solutions SRL and Axioma Solutions UK Limited.
• DATA PROCESSORS: Third-party service providers (e.g., Stripe, Google Analytics, Brevo) who process data on behalf of the Company.

3. Information Collection and Use

3.1. Personal Data provided by the User While using our Service, we may ask you to provide:

• Email address, First and Last name, Phone number.
• Billing address, Country, State, Province, ZIP/Postal code, City.
• Organisation name and role (for Administrator/User management).

3.2. Authentication Data
If you authenticate using third-party providers (Microsoft, Google, or LinkedIn), we receive a unique identifier and basic profile information to facilitate access.

3.3. Automatically Collected Data (WordPress & Plugins)
Our website is powered by WordPress. We automatically collect certain information via the platform and its plugins (including Rank Math, Kadence, and CookiesYes), such as:

• IP address, browser type, and version.
• Pages accessed and navigation behavior (via Google Analytics and Brevo).
• Time spent on pages and referral sources.

4. Legal Basis for Processing

In accordance with GDPR, we process your data based on the following legal grounds:

• Consent: When you fill out contact forms, sign up for our newsletter, or accept cookies.
• Contractual Necessity: To provide the Service, manage your subscription, and process payments.
• Legal Obligation: To comply with tax laws and reporting requirements.
• Legitimate Interest: For site security, fraud prevention, analyzing traffic to improve the platform, and ensuring the technical functionality of the website.

5. Use of Data and Third-Party Tools

The Company uses the collected data for the following purposes:

• Provision of Service & CMS: Managed via WordPress to ensure the stability and maintenance of the platform.
• Billing & Payments: Processed via Stripe (including Stripe Payments Europe, Limited “SPEL” and Stripe Technology Europe, Limited “Stripe PSP”). See Stripe Legal.
• Marketing & Communication: Managed via Brevo. We send relevant and personalized communications only to users who have provided explicit consent.
• Analysis & Performance: Using Google Analytics to understand user behavior and optimize the user experience.
• Security: To monitor for fraud, manage Two-Factor Authentication (2FA), and protect the Service.

6. Retention of Data

We retain your Personal Data only for as long as necessary:

• Contact Forms: Data provided via contact forms is stored for a maximum of 12 months or until the request is fully resolved.
• Google Analytics: Data is stored according to Google’s specific retention terms.
• Payment/Tax Data: Retained according to statutory financial and tax obligations.
• General Account Data: Retained for the duration of the contract and the subsequent legal limitation period.

7. Data Access and Sharing

7.1 Data Access and Collaboration
To ensure seamless service delivery, technical maintenance, and high-quality customer support, your personal data may be accessed by authorized personnel from both Centriqa Services & Solutions SRL (Romania) and Axioma Solutions UK Limited (UK).
This collaborative access is strictly limited to the purpose of executing the Service and providing necessary assistance to our end users.

7.2
Data Protection Standards
Regardless of where the data is accessed from, we ensure that all processing is conducted in accordance with the GDPR (EU and UK) and other applicable data protection laws, using secure access controls to protect your information.

7.3
Disclosure to Third Parties
We may disclose your data to:

• Payment Processors: Stripe.
• Marketing Tools: Brevo (only for opted-in users).
• Analytics Providers: Google Analytics.
• IT Infrastructure: Cloud hosting and web maintenance providers.
• Legal Authorities: Tax authorities and law enforcement if required by law.

8. Security of Data

We implement modern encryption technologies, strict access controls, and continuous activity monitoring to detect suspicious behavior.
While we take all reasonable measures, no internet transmission is 100% secure.

9. Your Data Protection Rights (GDPR & CCPA)

• EU/UK Residents: You have the right to access, rectify, delete, restrict, or object to the processing of your data, as well as the right to data portability.
• US Residents (CCPA/CalOPPA): You have the right to request a list of categories of personal information collected and the right to request deletion.

To exercise these rights, please email: client_support@colltrain.com.

10. Children’s Privacy and Educational Use

• General Rule: Intended for users aged 18+.
• Educational Exception: Minors may use the Service exclusively when invited by an authorized educator/trainer. The inviting organization is responsible for obtaining parental consent.

11. COOKIE POLICY

11.1. What are Cookies?
Cookies are small text files saved on your device to ensure essential functionalities, analyze site behavior, and personalize content.

11.2. Categories of Cookies Used

• Essential: Necessary for the site to function (e.g., login sessions, consent preferences).
• Analytical: Collect anonymous data about site usage (e.g., Google Analytics).
• Marketing: Used for personalized advertising and communication (e.g., Brevo).
• Functionality: Enhance user experience, including SEO optimization (Rank Math), theme design (Kadence), and payment security (Stripe).

11.3. Detailed Cookie Inventory

Category	Cookie Name	Provider	Purpose	Duration
Essential	wpEmojiSettingsSupports	WordPress	Emoji display support	Session
Essential	cookieyes-consent	CookiesYes	Stores cookie preferences	1 year
Functional	sib_cuid	Brevo	Unique visitor tracking	6 months
Functional	yt-remote-* (various)	YouTube	Embedded video preferences	Session/Permanent
Analytical	_ga, _ga_*	Google Analytics	Visitor and session counting	1 year, 1 month
Marketing	YSC, VISITOR_INFO1_LIVE	YouTube	Video view tracking/bandwidth	Session/6 months
Marketing	yt.innertube::*	YouTube	Unique ID for video history	Permanent
Payment	__stripe_mid, __stripe_sid	Stripe	Secure payment processing	1 year
Other	__Secure-ROLLOUT_TOKEN	YouTube	Technical rollout/testing	6 months

11.4. Managing Cookies
You can control and delete cookies through your browser settings or via the Cookie Consent Banner that appears upon accessing the site. Please note that disabling certain cookies may affect the functionality of the website.

12. Changes to This Policy

We may update this policy from time to time. Changes will be notified by updating the “effective date” at the top of this page.

13. Contact Us

For any questions, please contact: client_support@colltrain.com.