Trainy procurement policy evidence
Only topics backed by verified findings appear below. Each row preserves the platform's exact policy words and capture provenance.
| Topic | Plan or tier | Risk | Their words | Source |
|---|---|---|---|---|
| DPA, audit rights & data residency | All applicable tiers | unknown | “ when the transfer is necessary for the execution of a public policy or legal attribution of public service;” | Captured 2026-09-26Open source →Finding permalink → |
| DPA, audit rights & data residency | All applicable tiers | unknown | “ Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.” | Captured 2026-09-26Open source →Finding permalink → |
| DPA, audit rights & data residency | All applicable tiers | unknown | “Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.” | Captured 2026-09-26Open source →Finding permalink → |
| DPA, audit rights & data residency | All applicable tiers | unknown | “ The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.” | Captured 2026-09-26Open source →Finding permalink → |
| DPA, audit rights & data residency | All applicable tiers | unknown | “Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.” | Captured 2026-09-26Open source →Finding permalink → |
| DPA, audit rights & data residency | All applicable tiers | unknown | “ when the transfer results from a commitment undertaken in an international cooperation agreement;” | Captured 2026-09-26Open source →Finding permalink → |
| DPA, audit rights & data residency | All applicable tiers | unknown | “ when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.” | Captured 2026-09-26Open source →Finding permalink → |
| DPA, audit rights & data residency | All applicable tiers | unknown | “ We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:” | Captured 2026-09-26Open source →Finding permalink → |
| DPA, audit rights & data residency | All applicable tiers | unknown | “ when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;” | Captured 2026-09-26Open source →Finding permalink → |
| DPA, audit rights & data residency | All applicable tiers | unknown | “ when the transfer is authorized by the ANPD;” | Captured 2026-09-26Open source →Finding permalink → |
| DPA, audit rights & data residency | All applicable tiers | unknown | “ when the transfer is necessary to protect your life or physical security or those of a third party;” | Captured 2026-09-26Open source →Finding permalink → |
| Data retention | All applicable tiers | unknown | “ Ask us to be forgotten (delete the information we hold on you) ” | Captured 2026-09-26Open source →Finding permalink → |
| Data retention | All applicable tiers | unknown | “ Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.” | Captured 2026-09-26Open source →Finding permalink → |
| Data retention | All applicable tiers | unknown | “ Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.” | Captured 2026-09-26Open source →Finding permalink → |
| Data retention | All applicable tiers | unknown | “ the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;” | Captured 2026-09-26Open source →Finding permalink → |
| Data retention | All applicable tiers | unknown | “ Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.” | Captured 2026-09-26Open source →Finding permalink → |
| Data retention | All applicable tiers | unknown | “ The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.” | Captured 2026-09-26Open source →Finding permalink → |
| Data retention | All applicable tiers | unknown | “Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.” | Captured 2026-09-26Open source →Finding permalink → |
| Data retention | All applicable tiers | unknown | “ This type of service helps the Owner to manage tasks, collaboration and, in general, activities related to productivity. In using this type of service, Data of Users will be processed and may be retained, depending on the purpose of the activity in question.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ PostHog, Inc., Calendly, LLC, Google Ireland Limited, Cloudflare, Inc.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “These services may be integrated with a wide range of third-party services disclosed within this privacy policy to enable the Owner to import or export Data needed for the relative activity.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | low | “ Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration , as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc. The way Cloudflare is integrated means that it filters all the traffic through Trainy, i.e., communication between Trainy and the User's browser, while also allowing analytical data from Trainy to be collected.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ obtain information about the third parties with whom we share your personal information;” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ PostHog feature flags and A/B testing is a feature flags and A/B testing service provided by PostHog, Inc.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ Personal Data processed: various types of Data as specified in the privacy policy of the service” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ various types of Data as specified in the privacy policy of the service” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ PostHog product analytics is an analytics service provided by PostHog, Inc. that gives the Owner insight into the use of Trainy by Users.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ Google Workspace is an integrated suite of cloud-based productivity, collaboration and storage services provided by Google Ireland Limited. Gmail or other G Suite services are not scanned by Google for advertising purposes. In addition, Google does not collect or use data inside these services for advertising purposes in any other way.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “ Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising , whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of Trainy and features thereof.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ PostHog surveys is a form builder and data collection platform provided by PostHog, Inc. The service also allows the Owner to perform analyses and get insights on User response to and interaction with such forms.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ This type of service has the purpose of hosting Data and files that enable Trainy to run and be distributed or to provide a ready-made infrastructure to run specific features or parts of Trainy.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ This type of service allows you to view content hosted on external platforms directly from the pages of Trainy and interact with them. Such services are often referred to as widgets, which are small elements placed on a website or app. They provide specific information or perform a particular function and often allow for user interaction.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ Calendly Widget is a calendar content visualization service provided by Calendly, LLC that allows Trainy to incorporate content of this kind on its pages.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “ The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Trainy (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ In Minnesota and Maryland Users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer's personal data” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ PostHog session replay is a session recording service provided by PostHog, Inc.” | Captured 2026-09-26Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.” | Captured 2026-09-26Open source →Finding permalink → |
Informational only, not legal advice. Terms can change; verify every cited source and capture date during procurement review.
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