Treadstone 71 . Data Protection
Privacy and GDPR Notice
This notice explains what personal data Treadstone 71 collects, why, on what legal basis, how long we keep it, who receives it, and what rights you have. It covers treadstone71.com, the Cyber Intelligence Training Center at cyberinteltrainingcenter.com, our browser workbenches and downloads, our in-person and live online classes, and inquiries you send us.
01Who We Are
424.234.3629
We have not appointed a Data Protection Officer. GDPR Article 37 requires one only for large-scale monitoring of individuals or large-scale processing of special-category data, and we do neither.
02When the GDPR Applies
We are based in the United States. The EU General Data Protection Regulation (GDPR) applies to our processing when we offer training or services to people in the European Union or European Economic Area. The UK GDPR applies in the same way to people in the United Kingdom. Because we offer training and consulting in Europe and the UK, we treat the GDPR and the UK GDPR as applying to personal data of anyone located there, and we extend the same rights to every user.
03What We Collect, Why, and For How Long
| Data | Purpose | Legal basis (GDPR Art. 6(1)) | How long we keep it |
|---|---|---|---|
| Name, email, organization, country, courses taken, enrollment and payment status, course submissions | To enroll you, deliver training, issue completion records and CPE letters, and answer your questions | (b) performance of a contract | While your account is open, then 5 years |
| License acceptance record: name, email, organization, date and time, IP address, country derived from the IP address, browser, the page used, the EULA version, and the exact statement you accepted | To record and prove your agreement to the End-User License Agreement and to enforce it | (b) performance of a contract; (f) our legitimate interest in proving and enforcing our agreements | For the life of the agreement and its covenants, then 5 years |
| Class check-in records and paper sign-in sheets | To record attendance and acceptance of the agreement for in-person classes | (b) performance of a contract; (f) legitimate interest in proving our agreements | For the life of the agreement and its covenants, then 5 years |
| Name, organization, and country checked against U.S. government restricted-party lists | To comply with U.S. export control and sanctions law before we grant access to course material | (f) our legitimate interest in complying with U.S. law that binds us | For as long as U.S. export rules require us to keep screening records |
| Billing records | To keep tax and accounting records | (b) performance of a contract; (f) legitimate interest in complying with U.S. tax law | For as long as U.S. tax law requires |
| Email address for updates and announcements | To send occasional Treadstone 71 news, only if you checked the optional updates box | (a) consent | Until you withdraw consent |
| Inquiries sent through our contact form or by email | To answer you and, if you ask, to prepare a proposal | (b) steps taken at your request before a contract; (f) legitimate interest in answering inquiries | 2 years after our last exchange |
| Website usage statistics from Google Analytics: pages viewed, approximate location, device and browser type | To understand which pages and resources visitors use | (a) consent, given in the cookie banner | No longer than 14 months |
| Technical data: IP address, browser, and request times in server and security logs | To keep the sites secure, limit abuse, and fix faults | (f) our legitimate interest in running secure sites | For the short period our hosting provider keeps standard logs; our own rate-limit data clears after 1 hour |
We do not collect special-category data such as health, religion, or political opinions, and we do not ask for it. We do not make decisions about you by automated means that have legal or similarly significant effects, and we do not sell personal data. Our services are for adults 18 and older.
Your name and email are required to enroll, accept the license, or check in to a class. Without them we cannot provide the service. All other fields are optional unless the form says otherwise.
Where we rely on legitimate interests, we have weighed them against your rights. You may ask us for that assessment.
04Cookies and Analytics
We use two kinds of cookies on treadstone71.com.
Strictly necessary
When you accept the license, we set a cookie named t71eula_ followed by the item name. It records that you accepted, so you are not asked again until the license changes. It contains no tracking data and expires after 365 days. Your cookie choice is also stored so we can respect it. These cookies do not need consent.
Statistics (Google Analytics)
With your consent only, we use Google Analytics 4, provided by Google LLC, to count visits and see which pages are used. It sets the cookies _ga and _ga_ followed by our property ID, which expire after 2 years. Google states that Google Analytics 4 does not log or store IP addresses. We keep analytics data for no longer than 14 months. Google Analytics loads only after you click Accept in the cookie banner. Our legal basis is your consent (GDPR Art. 6(1)(a)).
You can change or withdraw your choice at any time through the Cookie settings link in the site footer. Withdrawing consent does not affect processing that took place before.
The Teachable platform sets its own cookies on cyberinteltrainingcenter.com, as described in its policies.
05Who Receives Your Data
We share personal data only with providers that help us run our services, and only as far as each needs it:
- Teachable, which hosts the Cyber Intelligence Training Center and handles checkout, and its payment processor, which handles card payments. We do not see or store full card numbers.
- Our website hosting provider, which stores treadstone71.com and its records.
- Our email provider, which carries our messages and acceptance receipts.
- Google LLC, which provides Google Analytics, only if you consent to statistics cookies.
We may also disclose data when the law requires it, or to establish, exercise, or defend legal claims.
06International Transfers
Treadstone 71 and its providers operate in the United States. When you send personal data to us, it is processed in the United States, where data protection law differs from the law of the EU and the UK. Where a provider moves EU or UK personal data on our behalf, it relies on the safeguards in its own terms, such as Standard Contractual Clauses or the EU-U.S. Data Privacy Framework. Google LLC participates in the EU-U.S. Data Privacy Framework. You may ask us for details.
07Your Rights
Under the GDPR and the UK GDPR, you have the right to:
- access the personal data we hold about you and receive a copy;
- correct inaccurate data;
- have your data erased;
- restrict our processing;
- receive your data in a portable, machine-readable format;
- object to processing based on legitimate interests, and object at any time to direct marketing;
- withdraw consent at any time, without affecting processing that took place before; and
- lodge a complaint with a supervisory authority.
Some rights have limits. For example, we may keep a license acceptance record after an erasure request when we need it to establish, exercise, or defend legal claims (GDPR Article 17(3)(e)).
How to make a request
Email
Complaints
Please contact us first so we can try to resolve the issue. You may also complain to the data protection authority in the EU country where you live or work (list of authorities) or, in the UK, to the Information Commissioner's Office.
08Security
Our pages use TLS encryption. License acceptance records are stored outside the public web folder, access is limited to Treadstone 71, and each record is linked to the one before it so that later changes can be detected. No method of storage or transmission is completely secure, and we will notify you and the relevant authority of a personal data breach where the law requires.
09Changes to This Notice
We will post any change here with a new effective date. If a change materially affects how we use your data, we will also tell you by email.
10Contact
Treadstone 71, LLC. Privacy and GDPR Notice. Effective October 30, 2026.
© 2002 to 2026 Treadstone 71, LLC. All rights reserved.
