1. Introduction

Online Tobacco Training, LLC (”Company” or “We”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. The Company runs a digital platform where visitors can learn about our service offerings, and registered users can purchase one or more training courses from us.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the website www.onlinetobaccotraining.com (our “Website”), regardless of whether you have engaged our services or not, and our practices for collecting, using, maintaining, protecting, and disclosing that information, when you register with the Website and when you use our services, including the use of our Website, an e-newsletter, email notifications, and any related applications (collectively, the “Services”).

This Privacy Policy applies to information we collect:

  • On this Website when you register an account to use our Services;
  • In email, text, and other electronic messages between you and this Website;
  • Through mobile and desktop applications you download from this Website which provide dedicated non-browser-based interaction between you and this Website and
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.

It does not apply to information collected by:

  • us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
  • any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

2. Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at the email address provided at the end of this Privacy Policy.

3. Information we collect about you and how we collect it

We collect several types of information from and about users of our Website, including information:

  • by which you may be personally identified, such as name, postal address, e-mail address, telephone number, and date of birth (”personal information”);
  • that is about you but individually does not identify you, such as gender, year of birth, job title and industry; and/or
  • about your internet connection, the equipment you use to access our Website and usage details.

We collect this information:

  • Directly from you when you provide it to us;
  • Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and
  • From third parties, for example, our business partners.

4. Information You Provide to Us.

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, or requesting further Services. We may also ask you for information when you report a problem with our Website;
  • Records and copies of your correspondence (including email addresses), if you contact us; and
  • Your responses to surveys that we might ask you to complete for research purposes.

5. Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website; and
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). We do not currently participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of information. We may engage third parties, such as marketing or analytics partner who may collect information about your online activities over time and across different websites when you use this Website.

The information we collect automatically is statistical data and may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns;
  • Store information about your preferences, allowing us to customize our Website according to your individual interests;
  • Speed up your searches; and
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices about How We Use and Disclose Your Information.
  • Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

6. Third-Party Use of Cookies and Other Tracking Technologies.

Some content or applications, including advertisements, on the Website may be served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices about How We Use and Disclose Your Information. 

7. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you;
  • To provide you with information, products, or Services that you request from us;
  • To provide you with notices about your account/subscription, including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • In any other way we may describe when you provide the information; and
  • For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, then email us at the email listed at the end of this Privacy Policy to opt out of this portion of the Website.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

8. Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

  • To our subsidiaries and affiliates;
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred;
  • To the New York State Department of Heath in connection with any inquiry from them as to whether you have taken the course with us and what date and time you watched the training;
  • To fulfill the purpose for which you provide it and for any other purpose disclosed by us when you provide the information; and
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
  • To enforce or apply our Terms of Use at onlinetobaccotraining.com/terms and other agreements, including for billing and collection purposes; and
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

9. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email stating your request to the email address at the end of this Privacy Policy.
  • Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to the email address at the end of this Privacy Policy. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
  • Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an email stating your request to the email address at the end of this Privacy Policy.
  • We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website.

10. Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website and visiting your account profile page.

You may also send us an email at the email address listed at the end of this Privacy Policy to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

11. Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

12. Data Retention

If you create an account with the Company, we will retain your information for as long as your account is active or as needed to provide you with Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. If you are a visitor to the Website, we will retain your information as necessary but for no longer than one (1) year after your last visit to the Website.

13. Changes to Our Privacy Policy

It is our Privacy Policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account and/or through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

14. Governing Law

This Privacy Policy shall be governed by the laws of the State of Connecticut. To the extent that you are a user who resides outside of the United States, please be advised that any information provided will be transferred to the United States. By visiting and using the Website and submitting any information through the Website, you are therefore authorizing this transfer of information to the United States. If any part of this Privacy Policy is determined to be invalid or unenforceable pursuant to applicable law, then the invalid or unenforceable provision or part will be deemed suspended by a valid, enforceable provision that most closely matches the intent of the original provisions or part, and the remainder of this Privacy Policy shall continue in full force and effect.

Contact information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

Online Tobacco Training LLC
190 Hurd Street
Fairfield, CT 06824
Phone: 1-877-276-8395
onlinetobaccotraining@gmail.com