iTRAIN Privacy Policy
(Rev. 11/08)

iTRAIN LLC, a California limited liability company (“iTRAIN”), thanks you for visiting www.iTRAIN.com (the “Site”). iTRAIN is committed to protecting your privacy and maintaining a safe online experience for all of our users and customers while providing a quality user experience. Because we gather certain types of information about and from you, our users and customers, in order to fulfill your requests and better serve your needs, you should fully understand the terms and conditions surrounding the collection and use of this information. This Privacy Policy discloses what information we gather, how we use it, how to correct or change it, and what steps we take to safeguard personal information provided to us both online and offline.

iTRAIN’s Privacy Policy (“Privacy Policy”) is set out below and explains how iTRAIN collects, uses, and discloses any personal information that you provide or which iTRAIN collects (“Personal Information”). It also explains the steps iTRAIN has takes to ensure that your Personal Information is secure. Finally, the Privacy Policy explains your choices regarding iTRAIN’s collection, use, and disclosure of Personal Information.

ITRAIN IS NOT RESPONSIBLE FOR THE CONTENT OR PRIVACY PRACTICES OF ANY NON-ITRAIN WEB SITE TO WHICH THE SITE LINKS AND THIS PRIVACY POLICY DOES NOT APPLY TO ANY OF THOSE OTHER SITES. YOU SHOULD CHECK EACH OTHER SITE FOR ITS OWN PRIVACY POLICY.

INFORMATION COLLECTION AND USE

1. Information Collection.

(a) Collection. iTRAIN collects information from you at several different points and in different ways on the Site. iTRAIN will ask you for your permission before it collects any information that personally identifies you. iTRAIN’s primary goal in collecting personal information from you is to provide you with an efficient, meaningful, and customized experience, and to process transactions you initiate.

For example, iTRAIN may use Personal Information :

• to make the Site easier for you to use by not having to enter information more than once.
• to help you quickly find information and services of interest to you.
• to help iTRAIN create content on the Site that is most relevant to you.
• to alert you to updated information and services offered by iTRAIN.
• to fill your orders, to process credit and debit card transactions for your orders, and to contact you if iTRAIN has a problem filling your order or processing your card transaction.

(b) Registration. To use the Site, you may be required first to complete an online registration form. During registration, you will be prompted to provide to iTRAIN certain Personal Information. This Personal Information will include your name, address, phone number, and e-mail address, and may include credit-related information. In addition, iTRAIN may also ask you to verify your country of residence so it can comply with country-specific laws and regulations. For example, users who reside outside the United States will not be able to purchase audio and video files (“Files”).

(c) Ordering. To purchase Files on the Site, you will also be required first to provide to iTRAIN certain Personal Information. This Personal Information will include your name, shipping address, and credit or debit card account number, expiration date, and billing address. As in any transaction, your credit card company will have all relevant information about the name of the vendor, item(s) purchased, date, total cost and other information necessary to process the transaction. iTRAIN will not otherwise provide any personal data to your credit card company without your permission.

(d) Cookies and Other Technology. The Site uses “cookies” and other technology, such as “web beacons”, to recognize you as a user, store your access privileges, speed your navigation of the Site, and tracks your usage of the Site, and also to collect aggregated site-visitation statistical information. iTRAIN does not consider such aggregated statistical information to be Personal Information because it does not identify You individually or provide any personal information about You.

(i) “Cookies” are small information files that are stored by your Internet browser on your computer’s hard drive. Most Internet browsers are initially set to accept cookies. You may set your browser to refuse cookies, but if you do so, you may not be able to access or use certain parts of the Site. iTRAIN’s cookies do not infiltrate your computer or, except as noted above, gather any Personal Information.

(ii) “Web beacons” assist in delivering cookies and help iTRAIN determine whether a web page on the Site has been viewed and, if so, how many times. For example, any electronic image on the Site, such as an ad banner, can function as a web beacon. We also may include Web beacons in promotional e-mail messages or newsletters in order to count how many messages have been opened and acted upon. Web beacons are not used to access your personally identifiable information but they are a technique we use to compile aggregated statistics about Site usage. Web beacons collect only a limited range of information including the time and date of page view, cookie number and description of the page on which the Web beacon resides.

(e) Log Files. The Site’s server automatically recognizes the Internet URL from which you accessed the Site. iTRAIN may log your Internet protocol (“IP”) address for system administration and troubleshooting purposes. An IP address indicates the location of your computer on the Internet. iTRAIN does not link an IP address to any personally-identifiable information.

2. Information Use and Disclosure.

(a) Internal Use. iTRAIN may identify you in connection with your use of certain aspects of the Site. For example, iTRAIN may identify you by your purchase history. iTRAIN may internally use Personal Information to improve its marketing and promotional efforts, to improve the Site’s content or layout, and to determine general marketplace information about visitors to the Site. We also use information you provide to fulfill your requests and improve our Site, products and services. We may, from time to time, produce generic reports for advertisers, sponsors and vendors containing anonymous, aggregate information about our users and customers, such as demographic, age and online usage information. This information allows us to provide content and offers that are most relevant to our users and customers to work more closely with advertisers. We do not include any personally identifiable information of our users in these reports.

(b) External Use. iTRAIN does not sell, rent, license, or otherwise disclose Personal Information (except as needed to process orders or credit or debit card transactions) to any third parties, but iTRAIN may be required to disclose such information in response to a court order or applicable law, including in response to investigations conducted by law enforcement agencies. If iTRAIN were ever to combine with another company and iTRAIN were not the surviving company in the merger, or if it were ever to sell its assets or experience a change in ownership, all Personal Information would become property of the surviving merger company or asset purchaser, or new owner, as the case may be. If iTRAIN were to become a debtor in a bankruptcy case, it might also sell or otherwise distribute Personal Information in accordance with applicable bankruptcy law. iTRAIN does not presently use any outside companies to process customer orders or to ship iTRAIN products, but if it decided to do so, it would need to provide Personal Information to its outside processor or shipper. iTRAIN’s credit and debit card transactions are processed through third-party processors and the credit and debit card processing systems, and Personal Information is provided in connection with the processing of these transactions.

3. Data Security.

The Site uses various physical, electronic, and administrative procedures to safeguard the confidentiality of Personal Information, including Secure Sockets Layer (“SSL”) for all financial transactions through the Site. Detailed information about SSL is available from GeoTrust, Inc., at http://www.verisign.com/ssl/ssl-information-center/how-ssl-security-works/index.html(Verisign ownes GeoTrust Inc.). While iTRAIN uses SSL encryption to protect your Personal Information online, iTRAIN also takes several additional steps to protect Personal Information in iTRAIN’s facilities. Access to Personal Information is restricted to iTRAIN’s employees who need access to the particular Personal Information required to perform a specific job. Further, the servers where iTRAIN stores Personal Information are kept in a locked cage in a secure facility, and electronic access to iTRAIN’s servers is through an electronic firewall. WHILE ITRAIN HAS TAKEN COMMERCIALLY REASONABLE PRECAUTIONS TO SAFEGUARD PERSONAL INFORMATION, ITRAIN CANNOT AND DOES NOT GUARANTEE COMPLETE SECURITY OF PERSONAL INFORMATION BECAUSE COMPLETE SECURITY DOES NOT PRESENTLY EXIST ON THE INTERNET.

4. Opt Out/Corrections.

Upon your request, iTRAIN will, to the maximum extent possible, (a) remove Personal Information from iTRAIN’s database (which might cancel your subscription to the Site or a portion of the Site); or (b) correct or update Personal Information. You may request that iTRAIN remove, correct, or update Personal Information by e-mailing your request to iTRAIN’s Customer Support department at cs2@iTRAIN.com.

5. Changes to Privacy Policy.

iTRAIN may change or update this Privacy Policy from time to time. If iTRAIN decides to do so, it will post the changes or updates on the Site so that you will always be aware of what Personal Information iTRAIN collects and how it uses or distributes it. iTRAIN encourages you to review this Privacy Policy from time to time so that you will know if the Privacy Policy has been changed or updated. If you have any questions about iTRAIN’s Privacy Policy, please contact iTRAIN’s Customer Support department at cs2@iTRAIN.com.

6. Your California Privacy Rights.

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask iTRAIN for a notice describing what categories of personal customer information iTRAIN shares with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: 9903 Santa Monica Blvd, Suite 291, Beverly Hills, CA 90212. In your request, please specify that you want “Your iTRAIN California Privacy Rights Notice”. Please allow at least 30 days for a response.

7. Children’s Policy.

iTRAIN is strongly committed to protecting the safety and privacy of children who visit the Site. iTRAIN does not knowingly collect Personal Information online from children under 13 and has adopted techniques to age-screen users on the Site to ensure compliance with this Privacy Policy and the Children’s Online Privacy Protection Act of 1998 (“COPPA”). COPPA and its accompanying regulations under United States federal law protect the privacy of children using the Internet. This Site may include content that iTRAIN believes to be unsuitable for children under 13 and which is not necessarily monitored. iTRAIN encourages all parents to talk to their children about online safety and to monitor their children’s use of the Internet.