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Privacy Policy

This Privacy Policy (the “Privacy Policy”) describes how Cogent Investments, Inc., doing business as Required Training Solutions (“RTS”, “”), California Required Training Solutions (“CalReq,” “”, “CRTS”),  Illinois Required Training Solutions (“Ilreq,” “”),  InteServ Solutions (“InteServ”) and other DBAs as such may exist from time to time (collectively, “the Solution,” “we,” “our” or “us”), collects, uses, and shares information in connection with your use of our websites (including, services, and applications (collectively, the “Solution” or ”Services”). This Privacy Policy (the “Privacy Policy”) does not apply to information our customers may process when using our Solution and/or Services.

We may collect and receive information about users of our Services (“users,” “clients”, “you,” or “your”) from various sources, including: (i) information you provide through your user account on the Services (your “Account”) if you register for the Services; (ii) your use of the Services; and (iii) from third-party websites, services, and partners.

We recommend that you read this Privacy Policy in full to ensure you are fully informed. If you have any questions about this Privacy Policy or RTS’s data collection, data use, and disclosure practices, please contact us at


There will be occasions where it will be necessary for RTS or our partners to disclose your personal information to third parties. We may be required by law to disclose the information, or we may be required to disclose your personal information to third parties to provide the service you have requested, for example, if you purchase products online from us, RTS will need to disclose your personal information to third parties in order to bill and deliver your products. However, the disclosure will only be made where it is necessary to fulfill the purpose for which you disclose your personal information (For example, if you pay through PayPal for our services then PayPal will need to know your billing details). Otherwise than stated herein, we do not sell or rent customer list(s) to third parties, nor will we disclose personal information that you may give us, such as your name, address, email address or telephone number, to any organization or person outside RTS or our partners unless you have authorized us to do so.

Your Choices

You may unsubscribe from receiving certain emails from us. If you wish to do so, simply follow the instructions found at the end of the email. Even if you unsubscribe, we may still contact you for transactional, account-related, informational, archival or similar purposes.

Many browsers have an option for disabling cookies, which may prevent your browser from accepting new cookies or enable selective use of cookies. Please note that, if you choose not to accept cookies, some features and the personalization of our Solution may no longer work for you.

Minimum Age Policy

As stated in our Terms of Use, our website and services are offered and available only to you if are 14 years of age or older. If you do not meet this eligibility requirement, you may not use our website or services. RTS does not knowingly collect or store any personal information from or about children under the age of 13. We will delete such information if we become aware that it has been submitted through our website. Parents or legal guardians who believe that RTS might have any information from or about a child under the age of 13 may submit a request to and request that such information is removed.


If you are a registered user, you may access certain information associated with your Account by logging into your My Account page or emailing

To protect your privacy and security, we may also take reasonable steps to verify your identity before updating or removing your information. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business for disaster recovery purposes. Your ability to access and correct your information may be temporarily limited where access and correction could: inhibit RTS’ ability to comply with a legal obligation; inhibit RTS’ ability to investigate, make or defend legal claims; result in disclosure of personal information about a third party; or result in breach of a contract or disclosure of trade secrets or other proprietary business information belonging to RTS or a third party.

We Use Google Analytics and Cookies

To better understand how prospective customers are locating and learning about us, we use cookies and tracking tags including Google Analytics and conversion tracking.  For more information on how Google uses information, see the site “How Google uses information from sites or apps that use our services”, currently located at (and may be relocated by Google from time to time).  If you do not consent to this tracking, please do not access our website(s) and refrain from using the Solution

Third-Party Services

You may access other third-party services through the Solution, for example by clicking on links to those third-party services from within the Solution. We are not responsible for the privacy policies and/or practices of these third-party services, and we encourage you to carefully review their privacy policies.

Data Retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, after four years from the date the last course was completed we will delete it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Client Responsibility for Document Retention

Reference is made to the Terms and Conditions for this Solution regarding client responsibility for document retention. 

Information We Request

Information You Provide

Account Registration. When you register for an Account, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number. Payment Information. When you add your financial account information to your Account, that information is directed to our third-party payment processor (Stripe and PayPal). We do not store your financial account information on our systems; however, we have access to and may retain, subscriber information through our third-party payment processor.

Communications. If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. We may also receive a confirmation when you open an email from us.

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

Information We Collect When You Use Our Solution

Cookies and Other Tracking Technologies. As is true of most websites, we gather certain information automatically and store it in log files. In addition, when you use our Services, we may collect certain information automatically from your device. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, landing page, and referring URL. To collect this information, a cookie may be set on your computer or device when you visit our Services. Cookies contain a small amount of information that allows our web servers to recognize you. We store information that we collect through cookies, log files, and/or clear gifs to record your preferences. We may also automatically collect information about your use of features of our Services, about the functionality of our Services, frequency of visits, and other information related to your interactions with the Services. We may track your use across different websites and services. In some countries, including countries in the European Economic Area (“EEA”), the information referenced above in this paragraph may be considered personal information under applicable data protection laws.

Usage of our Solution. When you use our Solution, we may collect information about your engagement with and utilization of our Solution, such as processor and memory usage, storage capacity, navigation of our Solution, and system-level metrics. We use this data to operate the Solution, maintain and improve the performance and utilization of the Solution, develop new features, protect the security and safety of our Solution and our customers, and provide customer support. We also use this data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business.

Information We Receive from Third Parties

Information is collected from you only if your consent is given. For example, if you sign up for free email updates on a certain mandate developments or course availability changes, you will be required to give us your email address. This email address will be used for the sole purpose of sending your free updates and nothing else. Any information you provide us with will not be sold or distributed to any third party and will not be used by RTS for anything other than the original purpose intended.

We will specifically ask for personal information about you when you sign up to purchase our products. Certain information may be required, such as your name, internet address or screen name, billing address, type of computer, credit card number, in order to provide our Solution to you.

How We Use Information

We use the information we collect in various ways, including to:

  • Provide, operate, and maintain our Solution
  • Improve, personalize, and expand our Solution
  • Understand and analyze how you use our Solution
  • Develop new products, services, features, and functionality
  • Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the Solution, and for marketing and promotional purposes
  • Process your transactions
  • Find and prevent fraud
  • For compliance purposes, including enforcing our Terms and Conditions, Terms of Service, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

RTS will only use the personal information you have chosen to provide us for the purpose for which you provided it. We will not use it for any other purpose without your consent. We do not provide information on organizations and individuals using the Solution, with the exception being if the users permit us to highlight/showcase their use, for example with a featured company logo or in the context of a course review.

How We Share Information

We may share the information we collect in various ways, including the following:

Vendors and Service Providers. We may share information with third-party vendors and service providers that provide services on our behalf, such as helping to provide our Solution, for promotional and/or marketing purposes, and to provide you with information relevant to you such as curriculum revision announcements, platform updates, special offers, or other information.

Aggregate Information. Where legally permissible, we may use and share information about users with our partners in aggregated or de-identified forms that cannot reasonably be used to identify you.

Third-Party Partners. We also share information about users with third-party partners in order to receive additional publicly available information about you.

Information We Share When You Sign Up Through a Referral. If you sign up for our Services through a referral from a friend, we may share information with your referrer to let them know that you used their referral to sign up for our Services.

Analytics. We use analytics providers such as Google Analytics. Google Analytics uses cookies to collect non-identifying information. Google provides some additional privacy options regarding its Analytics cookies at

Business Transfers. Information may be disclosed and otherwise transferred to any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

There will be occasions where it will be necessary for RTS to disclose your personal information to third parties. We may be required by law to disclose the information, or we may be required to disclose your personal information to third parties to provide the service you have requested, for example, if you purchase products online from us, RTS will need to disclose your personal information to third parties in order to bill and deliver your products. However, the disclosure will only be made where it is necessary to fulfill the purpose for which you disclose your personal information (For example, if you pay through PayPal for our services then PayPal will need to know your billing details). Otherwise than stated here we do not disclose personal information that you may give us, such as your name, address, email address or telephone number, to any organization or person outside RTS unless you have authorized us to do so.

As Required by Law and Similar Disclosures. We may also share information to

  • satisfy any applicable law, regulation, legal process, or governmental request;
  • (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof;
  • (iii) detect, prevent, or otherwise address fraud, security, or technical issues;
  • respond to your requests; or
  • protect our rights, property or safety, our users and the public.

This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

With your consent, we may share your information. Under no circumstances will RTS sell or receive payment for licensing or disclosing your personal information or your students’ information on the platform.

Collection and Processing of Personal Information

We will normally collect personal information from you only:

  • where we need the personal information to perform a contract with you;
  • where the processing is in our legitimate interests and not overridden by your rights; or
  • where we have your consent to do so.

We have a legitimate interest in operating our Solution and communicating with you as necessary to provide these Services, for example when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities.

In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).


RTS is committed to protecting your information. To do so, we employ a variety of security technologies and measures designed to protect information from unauthorized access, use, or disclosure. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

RTS operates secure data networks that are designed to protect your privacy and security.  Our e-commerce partners (WooCommerce, Stripe) have their own Security and Privacy Issues documents which can be found on their websites.  We do not store any sensitive information such as credit card numbers within the Solution.  Credit card numbers are stored on our payment processor’s server encrypted at rest with AES-256.  This service is PCI compliant, audited and certified to PCI Service Provider Level 1.   

However, please bear in mind that the Internet cannot be guaranteed to be 100% secure. You are responsible for creating strong password(s), protecting password(s) at all times, and for not sharing password(s) or allowing another to use administrator nor student accounts.  Weaker passwords may be targeted by hackers which is not within RTS’ control. 

International Data Transfers

Should RTS or our partners transfer personal information to countries other than the country in which the data was originally collected, these countries may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information to other countries, we will protect that information as described in this Privacy Policy.

Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have the following data protection rights:

If you wish to access, correct, update, or request deletion of your personal information, you can do so at any time by emailing

In addition, you can object to the processing of your personal information, ask us to restrict the processing of your personal information, or request portability of your personal information. Again, you can exercise these rights by emailing

You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt-out of other forms of marketing, please contact us by emailing

Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Changes to This Privacy Policy

This Privacy Policy may be modified from time to time, so please review it frequently. Changes to this Privacy Policy will be posted on our websites. If we materially change the ways in which we use or share personal information previously collected from you through our Services, we will notify you through our Services, by email, or other communication.

Contact Us

If you have any questions or concerns about this Privacy Policy, please email us at

The data controller of your personal information is InteServ Solutions, a dba of Cogent Investments Inc..