Privacy Policy

1. Introduction & Data Controller

Fusion Results LLC dba Alpha Training & Consulting (“we,” “our,” or “us”) operates ASQ Exam Prep at asqexamprep.com (the “Service”). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website and use our services.

As the Data Controller (under GDPR) / Business (under CCPA/CPRA), we determine the purposes and means of processing your personal data. We are committed to protecting your privacy in compliance with all applicable data protection laws worldwide.

By using our Service, you acknowledge that you have read and understand this Privacy Policy. If you do not agree with our practices, please do not use the Service.

2. Information We Collect

2.1 Information You Provide Directly

• Account Registration: Name, email address, and password (stored as a bcrypt hash — we never store plaintext passwords)
• Profile Information: Optional bio, professional details, and study preferences
• Payment Information: Processed securely through Stripe. We receive only a tokenized reference, last four digits, card type, and billing address. We never receive or store your full card number, CVV, or complete card details.
• Communications: Content of emails, support requests, or feedback you send us
• User Content: Quiz responses, study notes, confidence ratings, and exam preparation data you submit through the platform

2.2 Information Collected Automatically

• Device Information: Browser type/version, operating system, device type, screen resolution
• Log Data: IP address, access times, pages viewed, referring URL, exit pages
• Usage Data: Quiz attempts, scores, study session duration, progress metrics, feature interactions, adaptive learning patterns
• Cookies & Similar Technologies: Session cookies, authentication tokens, and analytics identifiers (see Cookie Policy for details)

2.3 Information from Third Parties

• Payment Processor (Stripe): Transaction status, partial payment details, billing address
• Analytics (Google Analytics): Aggregated browsing patterns (configurable via cookie consent)

3. Legal Bases for Processing (GDPR Article 6)

If you are in the European Economic Area (EEA), United Kingdom (UK), or another jurisdiction that requires a legal basis for processing personal data, we rely on the following:

4. How We Use Your Information

• Service Delivery: Provide, operate, and maintain the platform including adaptive quizzes, mock exams, video content, and progress tracking
• Personalization: Customize your learning experience through spaced repetition, mastery tracking, and confidence-based adaptive algorithms
• Payment Processing: Process transactions, manage subscriptions, issue refunds, and maintain billing records
• Communications: Send transactional emails (account verification, password resets, purchase confirmations), respond to inquiries
• Security: Detect and prevent fraud, unauthorized access, and abuse
• Analytics & Improvement: Analyze usage patterns to improve content quality, user experience, and platform performance
• Legal Compliance: Fulfill legal obligations, resolve disputes, enforce agreements

We do NOT use your personal data for:

• Selling to third parties
• Targeted advertising or ad profiling
• Building marketing profiles for third parties

5. Data Sharing & Third Parties

We do not sell, rent, or trade your personal information. We share data only with the following categories of service providers, under appropriate safeguards:

We may also disclose information if required by law, court order, or governmental request, or to protect our rights, property, or safety.

6. Cookies & Tracking Technologies

We use cookies and similar technologies on our Service. For a detailed breakdown of specific cookies, their purposes, durations, and your choices, please see our Cookie Policy.

In summary, we use:

• Strictly Necessary Cookies: Authentication, session management, security (cannot be disabled)
• Analytics Cookies: Google Analytics (requires your consent where applicable)
• Functional Cookies: Theme preferences, study settings (requires your consent where applicable)

You can manage your cookie preferences at any time using our cookie consent banner or by visiting your browser settings.

7. Data Retention

When you request account deletion, we delete or anonymize your personal data within 30 days, except where retention is required by law.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

• Passwords hashed with bcrypt (industry-standard, one-way cryptographic hashing)
• All data transmitted via HTTPS/TLS encryption
• Database encryption at rest
• Regular security assessments and updates
• Access controls and principle of least privilege
• Secure cloud infrastructure with SOC 2 compliance

While we strive to protect your personal data, no system is 100% secure. We encourage you to use strong, unique passwords and keep your credentials confidential.

9. International Data Transfers

Our servers are located in the United States. If you access the Service from outside the US, your data will be transferred to, stored, and processed in the United States.

For transfers from the EEA/UK, we rely on:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Ensuring our service providers maintain adequate data protection safeguards
• Your explicit consent to the transfer where applicable

For transfers from other jurisdictions, we comply with the applicable legal requirements for cross-border data transfers.

10. Your Privacy Rights

Depending on your jurisdiction, you may have some or all of the following rights regarding your personal data:

• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure (“Right to Be Forgotten”): Request deletion of your personal data
• Right to Restriction: Request that we limit how we use your data
• Right to Data Portability: Receive your data in a structured, commonly used, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: Withdraw previously given consent at any time
• Right to Non-Discrimination: We will not discriminate against you for exercising your rights

To exercise any of these rights, please visit our Privacy Rights Request page or email us at [email protected].

We will respond to verified requests within the timeframe required by applicable law (typically 30–45 days).

11. US State Privacy Rights

11.1 California (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) grants you the following rights:

• Right to Know: What personal information we collect, use, disclose, and sell
• Right to Delete: Request deletion of personal information
• Right to Correct: Request correction of inaccurate personal information
• Right to Opt-Out of Sale/Sharing: We do not sell or share your personal information as defined by the CCPA/CPRA
• Right to Limit Use of Sensitive Personal Information: We only use sensitive PI for the purposes permitted under CCPA/CPRA
• Right to Non-Discrimination: We will not penalize you for exercising these rights

Categories of PI collected in the past 12 months: Identifiers (name, email), commercial information (purchase history), internet activity (usage data), education information (quiz results, study progress).

Sale of PI: We have not sold personal information in the preceding 12 months and do not intend to do so.

Authorized Agents: You may designate an authorized agent to submit requests on your behalf with proper verification.

Financial Incentives: We do not offer financial incentives related to personal information.

Shine the Light (Cal. Civ. Code § 1798.83): California residents may request information about data shared with third parties for direct marketing. We do not share data for third-party direct marketing.

11.2 Virginia (VCDPA)

Virginia residents have rights under the Virginia Consumer Data Protection Act:

• Right to access, correct, delete, and obtain a portable copy of personal data
• Right to opt out of targeted advertising, sale of personal data, and profiling
• Right to appeal our response to your request

11.3 Colorado (CPA)

Colorado residents have rights under the Colorado Privacy Act including access, correction, deletion, data portability, and opt-out of targeted advertising, sale, and profiling. We honor universal opt-out signals (e.g., Global Privacy Control).

11.4 Connecticut (CTDPA)

Connecticut residents have similar rights including access, correction, deletion, portability, and opt-out of targeted advertising and sale. We respond to requests within 45 days.

11.5 Other US States

We also comply with privacy laws in Utah (UCPA), Iowa (ICDPA), Indiana (INCDPA), Tennessee (TIPA), Montana (MCDPA), Oregon (OCPA), Texas (TDPSA), Delaware (DPDPA), New Hampshire (SB 255), New Jersey (SB 332), Nebraska (NDPA), Maryland (MODPA), Minnesota (MCDPA), and Kentucky (KCDPA). If you are a resident of any of these states, you generally have rights to access, correct, and delete your personal data, as well as opt out of the sale of personal data and targeted advertising. Contact us to exercise these rights.

12. European Economic Area (GDPR)

If you are located in the EEA, you are protected under the General Data Protection Regulation (EU) 2016/679. In addition to the rights listed in Section 10:

• Right to Lodge a Complaint: You have the right to lodge a complaint with your local Data Protection Authority (DPA). A list of DPAs is available at edpb.europa.eu.
• Data Minimization: We collect only data that is adequate, relevant, and limited to what is necessary
• Purpose Limitation: Data collected for specified purposes is not processed in a manner incompatible with those purposes
• Storage Limitation: Data is kept in a form permitting identification only for as long as necessary

Legal Bases: See Section 3 for details on our legal bases under GDPR Article 6.

Transfers: See Section 9 regarding Standard Contractual Clauses for international transfers.

13. United Kingdom (UK GDPR)

If you are located in the United Kingdom, you are protected under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. You have the same rights as EEA residents (Section 12).

Supervisory Authority: You may lodge complaints with the Information Commissioner's Office (ICO) at ico.org.uk.

International Transfers: We use UK-approved International Data Transfer Agreements (IDTAs) or UK Addenda to EU SCCs for transfers outside the UK.

14. Brazil (LGPD)

If you are located in Brazil, the Lei Geral de Proteção de Dados (LGPD) grants you the following rights:

• Confirmation of processing and access to data
• Correction of incomplete, inaccurate, or outdated data
• Anonymization, blocking, or deletion of unnecessary or non-compliant data
• Data portability to another service provider
• Deletion of data processed with consent
• Information about sharing with public and private entities
• Information about the possibility of denying consent and its consequences
• Revocation of consent

Supervisory Authority: Autoridade Nacional de Proteção de Dados (ANPD) at gov.br/anpd.

15. Canada (PIPEDA)

If you are a Canadian resident, the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws provide you with rights to:

• Access your personal information held by us
• Challenge the accuracy and completeness of your information and have it amended
• Withdraw consent (subject to legal or contractual restrictions)
• File a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca

We obtain meaningful consent before collecting, using, or disclosing your personal information, and we limit collection to what is necessary for the identified purposes.

16. South Africa (POPIA)

If you are a South African resident, the Protection of Personal Information Act (POPIA) provides you with rights including:

• Access to your personal information
• Correction or deletion of personal information
• Objection to processing
• Right to lodge a complaint with the Information Regulator at inforegulator.org.za

17. Australia (Privacy Act)

If you are an Australian resident, you have rights under the Privacy Act 1988 and the Australian Privacy Principles (APPs):

• Access to your personal information
• Correction of personal information
• Complaint to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au

18. Children's Privacy

Our Service is not directed to individuals under 16 years of age (or 13 in jurisdictions where that threshold applies under COPPA). We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal data from a child, we will promptly delete it. If you believe a child has provided us with personal information, please contact us at [email protected].

19. Do Not Track Signals

We honor Global Privacy Control (GPC) signals and treat them as valid opt-out requests under applicable laws (CCPA/CPRA, CPA, CTDPA). When we detect a GPC signal, we will not load analytics cookies or share data with analytics providers for that session.

For browser-level “Do Not Track” (DNT) signals, there is currently no universally accepted standard, but we respect these signals by limiting tracking to essential cookies only.

20. Automated Decision-Making

Our platform uses automated processing to personalize your learning experience:

• Adaptive Quiz Algorithms: Automatically select questions based on your performance history and mastery levels to optimize learning
• Spaced Repetition: Automatically schedule review of topics based on confidence ratings and time intervals
• AI-Generated Explanations: Generate educational explanations using AI models (no personal data is used in prompts)

These automated processes are used solely to enhance your educational experience. They do not produce legal or similarly significant effects. Under GDPR Article 22, you have the right to request human intervention, express your point of view, and contest decisions made solely by automated processing.

21. Data Protection Officer

For data protection inquiries, you may contact our designated privacy contact:

Privacy Contact
Fusion Results LLC dba Alpha Training & Consulting
Email: [email protected]

22. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes:

• We will update the “Last updated” date at the top of this page
• We will notify registered users via email for material changes
• Where required by law, we will obtain your consent before applying changes

We encourage you to review this Privacy Policy periodically.

23. Contact Us

For any privacy-related questions, concerns, or requests: