Privacy Policy

This Privacy Policy explains how eGame Studio LLC, doing business as Train Lens (“Train Lens,” “we,” “us,” or “our”), collects, uses, discloses, and protects personal information when you visit our website, communicate with us, or use the Train Lens platform and related services (collectively, the “Services”).

Train Lens provides live training technology to businesses, schools, training providers, and other organizations. When an organization provides access to Train Lens, that organization may determine why and how information relating to its trainers and trainees is processed. In those circumstances, the organization generally acts as the data controller or business, and Train Lens acts as its service provider or data processor.

For information collected directly through our website, sales activities, account administration, billing, and our own business operations, Train Lens may act as the data controller or business.

By using the Services, you acknowledge the practices described in this Privacy Policy. If you are using Train Lens through an employer, school, training provider, or other organization, you should also review that organization’s privacy notices and policies.

We do not sell personal information. We do not currently share personal information for cross-context behavioral advertising. If our practices change, we will update this Privacy Policy and provide any legally required choices before beginning that processing.

Information you provide directly

We may collect information that you voluntarily provide when you request a demonstration, contact us, create an account, purchase the Services, communicate with our team, or otherwise use Train Lens.

This information may include:

• Your first and last name
• Work email address
• Company or organization
• Job title
• Expected monthly trainee-hours
• Training format, such as remote, hybrid, or onsite
• Information about your training workflow, goals, or challenges
• Communications you send to us
• Billing contact details and transaction information
• Account and authentication information, such as usernames, password hashes, authentication tokens, and account permissions
• Trainer names and other account-profile information

Training and session information

When the Train Lens platform is used, we may process:

• Session names, schedules, descriptions, and other session details
• Trainer and authorized user information
• The amount of time a user spends in a session
• Connection, performance, and diagnostic information
• Account activity and administrative records

Live screen, audio, and video transmission

Train Lens enables real-time connectivity during training. Live screen content and related audio or video communications may be transmitted temporarily between authorized participants and technical service providers solely to deliver the live session.

Train Lens does not currently intentionally record or retain the content of live screen, audio, or video transmissions. Limited technical metadata, such as connection times, participant identifiers, quality information, and error logs, may be processed to establish, secure, troubleshoot, and improve the connection.

Payment information

Payments may be made through Stripe, ACH, wire transfer, or other approved payment methods.

When Stripe is used, Stripe processes payment-card and related payment information under its own privacy policy and security practices. Train Lens generally receives transaction details such as payment status, amount, billing contact information, and limited payment-method information rather than complete payment-card numbers.

ACH and wire transfers may be processed by our financial institutions and payment providers. We retain the business and accounting records reasonably necessary to manage payments, reconcile accounts, prevent fraud, and comply with legal obligations.

Information collected automatically

When you visit our website or use the platform, we and our service providers may automatically collect information such as:

• Internet Protocol address
• Browser, operating system, and device information
• Approximate location derived from an IP address
• Referring pages and traffic source
• Pages viewed and features used
• ‍Dates, times, and duration of activity
• Session, performance, diagnostic, and security logs
• Cookie, local-storage, and similar identifiers

We use Google Analytics and Webflow Analyze to understand website traffic and performance. Google Analytics may use cookies to distinguish browsers and sessions. Webflow Analyze uses anonymous identifiers and browser local storage rather than cookies to recognize site activity.

Where required by law, we request consent before activating non-essential analytics or marketing technologies.

Information received from other sources

We may receive professional and business-contact information from:

• The organization that provides your Train Lens account
• Account administrators and other authorized users
• Payment processors and financial institutions
• Service providers and integration partners
• Publicly available business sources
• Apollo.io and similar business-to-business sales and marketing services

Information received through Apollo.io may include a person’s name, employer, business email address, business telephone number, job title, professional profile, employment information, and related business or firmographic information.

We use this information for legitimate business-to-business sales and marketing activities, subject to applicable law and the recipient’s communication preferences.

We may use personal information to:

• Provide, operate, maintain, and improve the Services
• Create and administer customer, trainer, and authorized-user accounts
• Authenticate users and manage account permissions
• Establish and deliver live training connections
• Display session details and track time spent in sessions
• Provide customer service and technical support
• Respond to demonstration requests and enquiries
• Customize demonstrations around an organization’s training needs
• Process payments and maintain accounting records
• Communicate administrative, security, billing, or service information
• Analyze website and platform usage and performance
• Diagnose technical problems and maintain connection quality
• Detect, investigate, and prevent fraud, abuse, and security incidents
• Conduct lawful business-to-business sales and marketing
• Measure the effectiveness of our website and communications
• Enforce our agreements and protect our legal rights
• Comply with legal, regulatory, tax, accounting, and reporting requirements
• Complete a merger, financing, acquisition, reorganization, or sale of assets

Marketing communications

We may use professional contact information to communicate with organizations and business professionals who may have an interest in Train Lens.

You may unsubscribe from marketing emails using the unsubscribe link included in the message or by contacting privacy@trainlens.com. Even if you opt out of marketing, we may continue sending necessary service, security, billing, or account-related messages.

We do not use information collected from children for behavioral advertising or unrelated commercial marketing.

Legal bases for processing

Where the laws of the European Economic Area, United Kingdom, Switzerland, or another jurisdiction require us to identify a legal basis, we rely on one or more of the following:

• Contract: Processing necessary to provide the Services or take steps requested before entering into a contract
• Legitimate interests: Operating, securing, improving, and marketing our business-to-business Services, provided those interests are not overridden by individual rights
• Consent: Processing based on consent, including certain analytics, marketing, and communications where legally required
• Legal obligations: Processing required to comply with applicable law
• Protection of rights and safety: Processing necessary to prevent harm, fraud, abuse, or security incidents and to establish, exercise, or defend legal claims

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing that occurred lawfully before consent was withdrawn.

We may disclose personal information only as reasonably necessary for the purposes described in this Privacy Policy.

Service providers

We use service providers that support our website, application, infrastructure, communications, analytics, sales, security, and payments. These providers may include:

• Webflow for website hosting and form submissions
• Cloudflare Turnstile for form security and spam prevention
• DigitalOcean for application and infrastructure hosting
• Twilio for real-time audio, video, and related platform connectivity
• Stripe for payment processing
• Google Analytics for website and application analytics
• Webflow Analyze for website traffic and performance analytics
• Apollo.io for business-contact information, prospecting, and business-to-business outreach
• Financial institutions used for ACH, wire transfers, and other direct payments
• Email, security, technical-support, monitoring, and professional-service providers

These providers may process information on our behalf or, in some circumstances, under their own privacy policies and legal responsibilities.

Customer organizations

If you use Train Lens through an employer, school, training provider, or other organization, we may disclose account, session, attendance, resource, and usage information to that organization and its authorized administrators.

The customer organization is responsible for determining who may access its accounts, sessions, reports, and resources.

Legal and safety disclosures

We may disclose information when we reasonably believe it is necessary to:

• Comply with applicable law, regulation, court order, subpoena, or lawful government request
• Protect the rights, property, security, or safety of Train Lens, our customers, users, or others
• Detect, investigate, or prevent fraud, abuse, illegal conduct, or security incidents
• Enforce our agreements and policies
• Establish, exercise, or defend legal claims

Business transactions

Information may be disclosed or transferred as part of an actual or proposed merger, acquisition, financing, restructuring, bankruptcy, sale of assets, or similar business transaction. Any recipient will be required to handle personal information consistently with applicable law.

Sale and sharing of personal information

Train Lens does not sell personal information.

Train Lens does not currently share personal information for cross-context behavioral advertising as that term is defined under applicable U.S. state privacy laws. If we introduce advertising technologies that constitute selling or sharing, we will update this notice and provide required opt-out mechanisms, including recognition of applicable Global Privacy Control signals.

Cookies and analytics technologies

Our website may use essential technologies required for security, forms, navigation, and site operation.

Google Analytics may use a first-party _ga cookie and related technologies to measure users, sessions, approximate location, browser and device information, traffic sources, and site interactions.

Webflow Analyze uses anonymous identifiers and browser local storage to measure aggregate site activity and does not use cookies to recognize visitors.

Where required, visitors will be able to accept or reject non-essential analytics and marketing technologies through our consent controls. Browser settings may also allow you to block or remove cookies, although doing so may affect some site functionality.

Third-party websites

Our Services may contain links to websites or services operated by other organizations. Train Lens does not control those third parties and is not responsible for their content, security, or privacy practices. Review the privacy notice of any third-party service before providing it with personal information.

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, to meet contractual requirements, and to comply with legal, accounting, security, and reporting obligations.

Our standard retention periods are:

• Live screen, audio, and video content: Not intentionally recorded or retained by Train Lens
• Demo requests and sales enquiries: 24 months after the last meaningful interaction
• Customer, trainer, and authorized-user accounts: For the duration of the account or customer relationship and up to 90 days afterward
• Session details and time-in-session records: For the customer relationship and up to 90 days afterward, unless the customer contract specifies another period
• Uploaded resources, when supported: Until deleted by Train Lens following an authorized customer request, or up to 90 days after account termination, subject to applicable legal and contractual requirements.
• Application, connection, security, and diagnostic logs: Up to 12 months
• Google Analytics user-level data: Up to 14 months, subject to the configured Google Analytics retention settings
• Webflow form submissions: Up to 24 months after submission unless deletion is requested or a longer period is legally required
• Payment, ACH, wire, tax, and accounting records: Up to seven years
• Marketing preferences, consent, objection, and suppression records: For the active relationship and up to five years afterward
• Backups: Removed through a rolling backup cycle generally not exceeding 90 days

We may retain information for longer when required by law, necessary to resolve a dispute, enforce an agreement, prevent fraud, preserve security records, or establish or defend legal claims.

A customer contract may establish a different retention period for customer-controlled data. When information is no longer required, we delete it, anonymize it, or isolate it from further use until deletion from backups is completed.

Depending on your location and applicable law, you may have the right to:

• Request confirmation of whether we process your personal information
• Access or obtain a copy of personal information we hold about you
• Correct inaccurate or incomplete information
• Request deletion of personal information
• Restrict or object to certain processing
• Withdraw consent where processing is based on consent
• Receive certain information in a portable format
• Opt out of targeted advertising, selling, or sharing where applicable
• Opt out of marketing communications
• Appeal a decision concerning a privacy request
• Lodge a complaint with an applicable privacy or data-protection authority
• Exercise your rights without receiving discriminatory treatment

To submit a request, email privacy@trainlens.com. Please describe your request and the account, email address, or organization involved.

Privacy and data-retention settings are currently managed by Train Lens and are not available as self-service controls. Customers and authorized users may request access, correction, deletion, or changes to the handling of their personal information by emailing privacy@trainlens.com. We assess requests in accordance with applicable law, contractual obligations, and the requesting person’s authority. Where information is controlled by a customer organization, we may need that organization’s instructions before making changes.

We may need to verify your identity before completing a request. Information collected for verification will be used only to process and secure the request. An authorized agent may submit a request where permitted by law, but we may require proof of authorization and identity verification.

If Train Lens processes your information solely on behalf of a customer organization, we may direct your request to that organization or assist it in responding.

California and other U.S. state rights

Where applicable, residents may request information about the categories and specific pieces of personal information collected, sources, purposes, retention, and categories of recipients. They may also request correction or deletion and may opt out of legally defined selling, sharing, targeted advertising, or certain profiling.

Train Lens does not sell personal information and does not currently share it for cross-context behavioral advertising.

EEA, UK, and Swiss rights

Where applicable, individuals may object to processing based on legitimate interests and may complain to their local data-protection authority. Individuals may also withdraw consent without affecting processing that occurred before withdrawal.

Children’s privacy

Train Lens is a business and educational training service and is not directed to children for independent consumer use.

A minor may use Train Lens only through an authorized customer organization and with any parental, guardian, school, or other authorization required by applicable law.

For children under 13 in the United States, Train Lens will obtain verifiable parental consent or rely on school authorization only where legally permitted. When a school provides authorization, children’s information must be used solely to provide the educational service for the school and not for unrelated commercial purposes.

Customer organizations are responsible for identifying when minors will use the Services and for obtaining and documenting required permissions. Train Lens may require additional contractual terms or a children’s-privacy notice before enabling such use.

We do not use children’s personal information for behavioral advertising, Apollo.io prospecting, or unrelated marketing. If we learn that a child’s personal information was collected without required authorization, we will take reasonable steps to delete it.

Parents, guardians, schools, and authorized organizations may contact privacy@trainlens.com to request access, correction, or deletion.

Train Lens maintains administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

These safeguards may include access controls, authentication protections, secure transmission, monitoring, backups, vendor controls, personnel practices, and other measures appropriate to the nature of the information and Services.

Live screen, audio, and video content is transmitted to provide real-time connectivity and is not currently intentionally recorded or retained by Train Lens.

No internet transmission, communications platform, or storage system can be guaranteed to be completely secure. Users are responsible for protecting their account credentials, using secure devices and networks, and notifying us promptly of suspected unauthorized access.

If a security incident occurs, we will investigate and provide legally required notifications to affected individuals, customers, regulators, or other parties.

International processing

Train Lens is based in the United States. Our providers may process information in the United States and other countries where they or their subprocessors operate.

We do not operate application servers in India. However, global providers may process limited information from other locations according to their infrastructure and privacy terms.

Where legally required for international transfers, we use recognized safeguards such as contractual protections, data-processing agreements, and approved transfer mechanisms.