TRAILBLAZER CONSULTING, LLC, AND TRAILBLAZER LEARNING ACADEMY

Policy Overview

TrailBlazer Consulting, LLC, (TrailBlazer or the Company) including its affiliates, subsidiaries, and divisions, especially TrailBlazer Learning Academy (or TrailBlazer Academy), understands and appreciates the responsibility to secure and protect the personal data of its clients, customers, business partners, vendors, and users of the TrailBlazer Consulting website (trailblazer.us.com) and the TrailBlazer Learning Academy platform (trailblazerlearningacademy.com). This privacy policy outlines TrailBlazer’s standards for collection, use, maintenance, storage, disclosure, protection, and disposition of personally identifiable information (PII[1]) and payment card industry (PCI[2]) compliance information acquired in relation to the use of TrailBlazer’s online resources.

TrailBlazer is committed to safeguarding personal data. This privacy policy sets out our personal data collection, storage, and sharing practices for data captured online (e.g., via our website or platform) (collectively, the “Services”). This privacy policy operates in conjunction with TrailBlazer Consulting, LLC’s Website Terms of Use and TrailBlazer Learning Academy’s Terms of Use, and TrailBlazer Consulting’s Cookies Policy.

TrailBlazer Consulting and TrailBlazer Learning Academy leverage commercial platforms[3] including Go DaddyTM, Kajabi®, StripeTM, and WordPressTM to host parts of the website, Platform, Course, Services, Materials, Downloads, and Coaching. Backup and security of content is provided by these commercial platforms in accordance with their standard terms and conditions and subject to internet and web-based commerce standards.

The remainder of the policy describes

  • Personal Data Collection
    • How we collect personal information
    • Types of personal information we collect
  • Personal Data Use, Sharing, and Transmission
    • How we use your personal information
    • Sharing your personal information
    • Storage and security of your personal information
    • Links to other websites
  • Administration of the privacy policy
    • Your rights and choices
    • Relevant laws and regulations
    • Changes to our Privacy Policy

Personal Data Collection

How we collect personal information

TrailBlazer collects personal information from you when you:

  1. Submit or choose to provide information to us; for example, by completing or participating in:
    1. Contact Form
    1. Coaching Registration/Pre-Qualification Form(s)
    1. Course Purchase/Registration Form(s)
    1. Survey(s) or other optional data collection instrument
  2. Visit or use our online services
    1. Participate in a Course
    1. Use online handouts or data collection forms where you can store, analyse, or export your data
    1. Download handouts or other resources
    1. Participate in Community activities such as chat
  3. Participate in TrailBlazer programs or events
    1. Coaching
    1. Webinar
    1. Survey
    1. Community

We may also collect information about you from other sources, including:

  • Third-party service providers or business partners
  • Industry groups
  • Public sources including but not limited to social media and other websites that enable social sharing
  • Information from government agencies, public data bases and other third-party information sources

We may combine information we collect from a third-party with information we already have, and we may combine information that we have collected offline with information we collect online.

In circumstances where the information that TrailBlazer obtains is held by a third party, TrailBlazer will take reasonable efforts to acquire the business partner’s, vendor’s, or customer’s consent before it seeks this information from such sources (such permission may be provided directly by the entity or reasonably implied from the entity’s actions).

If you choose to submit any personal information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Policy.

Types of personal information we collect

  1. Information you submit
    1. Personal Identifying Information (PII) including your name, email address, and other contact details
    1. Payment Card Industry (PCI) information including credit card or other payment information provided to complete a purchase
    1. The content of correspondence between you and us including audio or video recordings of coaching sessions
    1. Survey or other information provided by you (e.g., in a form)
  2. Online usage information for our Services and our associated Services
  • To facilitate access and use of the website or platform
    • To optimize your access to and experience with the website or platform Website, app and communication usage including details of your visits to our websites and mobile apps and information collected through cookies and other tracking technologies
    • IP address and domain name, your browser version and operating system, traffic data, location data, device data, web logs and other communication data, and the resources that you access 
  • Anti-fraud information used to verify your identity including, for example, information that may be available in public databases.

Personal Data Use, Sharing, and Transmission   

How we use your personal information

We use personal information for the purposes set out below:

  • To conduct our business and provide our goods and services, including administration, management, and fulfilment of our contracts
  • To communicate with you including to respond to your queries and to otherwise communicate with you
  • To investigate and prevent fraud as may be required by applicable law and regulation and best practice at any given time. If false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies and may be recorded by us or by them.
  • To monitor certain activities, including queries and transactions; ensure service quality; comply with procedures; and combat fraud.
  • To notify you about changes to our goods and services.
  • To reorganize or make changes to our business; in the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your personal data to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organization. We may also need to transfer your personal data to that re-organized entity or third party after the sale or reorganization for them to use for the same purposes as set out in this policy.
  • To comply with legal or regulatory obligations to disclose your personal data to third parties, the court service, and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so.  Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.

Sharing your personal information

TrailBlazer may share your information with its affiliates and subsidiaries.

We may also transfer or assign your personal data to third parties as a result of or in connection with a sale, merger, consolidation, change in control, transfer of assets, reorganization, or liquidation.

TrailBlazer may also disclose aggregate or de-identified data that is not personally identifiable to third parties for any purpose.

Storage and security of your personal information

Storage limits

Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing and other purpose(s) for which the information was collected, and any other permissible, related purpose, as described in this privacy policy. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When personal data is no longer needed, we either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the data.

Security

TrailBlazer maintains physical, electronic and procedural safeguards to protect your personal data in accordance with data protection legislative requirements and technical applicability. However, all such measures are subject to external factors related to the internet and cloud computing, so we cannot guarantee that your personal data will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such data. Users are responsible for maintaining the secrecy of their own passwords.

International Data Transfers

Any information you provide to TrailBlazer may be stored and processed, transferred between and accessed from the United States, where TrailBlazer is headquartered, and other countries which may not guarantee the same level of protection of personal data as the one in which you reside. However, TrailBlazer will handle your personal data in accordance with this privacy policy regardless of where your personal data is stored/accessed.

Links to Other Websites

Our online services may contain links or references to third-party websites. These websites are outside of our control, and the privacy policies of these sites may differ from our own. Please be aware that we have no control over these third-party websites and our Privacy Policy does not apply to such websites. We encourage you to check the terms of use and privacy policies of such websites before disclosing any personal data via such websites.

This Privacy Notice applies only to the TrailBlazer Platform. This Platform may contain links to other web sites not operated or controlled by TrailBlazer[4] (collectively, “Third-Party Sites”), including, but not limited to Facebook, Twitter, Instagram, YouTube, LinkedIn, and TikTok. The policies and procedures we describe here do not apply to Third-Party Sites. The links from this Platform do not imply that TrailBlazer endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Administration of the Privacy Policy

Your rights and choices

You may have certain rights available when it comes to your personal data collected or processed under this Policy. Depending on your jurisdiction, applicable law may entitle you to additional consumer rights, including the right, with certain limitations and exceptions, to:

  • Know the categories and/or specific pieces of personal information collected about you, including whether your personal information is sold or disclosed, and with whom your personal information was shared.
  • Access a copy of the personal information we retain about you.
  • Request deletion of your personal information.

We reserve the right to verify your identity in connection with any requests regarding personal information. Verification helps ensure that we provide the information we maintain only to the individuals to whom it pertains and allow only those individuals or their authorized representatives to exercise rights with respect to that information. If you are an authorized agent making a request on behalf of a consumer, we may require and request additional information to verify that you are authorized to make that request.

We reserve the right to deny your request if we cannot verify your identify. Where we deny your request in whole or in part, we will endeavor to inform you of the denial and provide an explanation of our actions and the reasons for the denial.

We will not restrict or deny you access to our goods or services because of choices and requests you make in connection with your personal data. Please note, certain choices may affect our ability to deliver services.

Relevant laws and regulations

TrailBlazer will implement and enforce this policy in a manner that complies with all applicable United States (US) federal, state, and local laws, rules, and regulations, as well as pertinent Canadian, UK, and EU regulations, as noted below.

If you have any questions in relation to this policy, please contact info@trailblazer.us.com or support@trailblazerlearningacademy.com.

Changes to our Privacy Policy

Our Privacy Policy may change from time to time in the future.  The current Privacy Policy can be found at all times on TrailBlazer.us.com and TrailBlazerLearningAcademy.com.

[1] The term “Personally Identifiable Information (PII)” in this policy refers to any representation of information that permits the identity of an individual to whom the information applies to be reasonably inferred by either direct or indirect means. Further, PII is defined as information: (i) that directly identifies an individual (e.g., name, address, social security number or other identifying number or code, telephone number, email address, etc.) or (ii) by which an [entity] intends to identify specific individuals in conjunction with other data elements, i.e., indirect identification. (These data elements may include a combination of gender, race, birth date, geographic indicator, and other descriptors). Additionally, information permitting the physical or online contacting of a specific individual is the same as personally identifiable information. This information can be maintained in either paper, electronic or other media. https://www.dol.gov/general/ppii

[2] “The Payment Card Industry Data Security Standard (PCI DSS) was developed to encourage and enhance payment account data security and facilitate the broad adoption of consistent data security measures globally. PCI DSS provides a baseline of technical and operational requirements designed to protect account data. While specifically designed to focus on environments with payment account data, PCI DSS can also be used to protect against threats and secure other elements in the payment ecosystem.” https://www.pcisecuritystandards.org

[3] See Go DaddyTM Trust Center, Kajabi® Terms and Policies, StripeTM Privacy Policy, WordPressTM Terms of Use, and WordPressTM (Automattic) Privacy Policy for more information.

[4] As noted above, TrailBlazer leverages the following commercial platforms: Go DaddyTM, Kajabi®, StripeTM, and WordPressTM.