The purpose of this Privacy Policy is to describe how Turnaround Training Technologies, Inc. (“Turnaround Training”, “us”, “we”, or “our”) collects, uses and shares information about you through our U.S. online interfaces (e.g., websites and mobile applications) owned and controlled by us, including www.oscarearias.com (referred to herein as the “Website”). Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to contact us at [email protected] Your use of the Website serves as your acceptance of this Privacy Policy and consent to Turnaround Training’s collection and use of the information you provide as set forth in the Privacy Policy. Your use of our Website is also governed by our Terms of Use.

Please note that this Privacy Policy applies only to the Website, and not to other Websites operated by other companies or organizations to which we may link. When you link to any other Websites from the Website, this policy no longer applies and Turnaround Training has no control of the activities of those Websites. Also this Privacy Policy does not apply to any information that Turnaround Training may collect from you in any manner other than online. Turnaround Training may revise this Privacy Policy at any time. You should, therefore, review it periodically. If you do not want to submit personal information when requested, you will not be able to access certain areas on the Website. However, you do not need to provide personal information to Turnaround Training in order to use the Website.

Collection of Information

Turnaround Training generally only collects personally identifiable information from you when you voluntarily submit it to us when you: purchase our products or services or send us questions or comments via e-mail or Website form. This information may include personal information such as your name, e-mail address, telephone number, and home address. Also, we may request certain demographic information such as your age and gender. Customers purchasing goods and services through our online store must provide a valid credit card number and expiration date, in addition to name, mailing address, phone number and e-mail address. We never collect more information than what is reasonably necessary to fulfill your requests and our legitimate business objectives. We will take appropriate steps to ensure the security and integrity of any information you provide to us. If you are under the age of 13, your parent or guardian’s consent is required before you can provide any personal information to us.

How Turnaround Training Uses Information

Turnaround Training collects the personal information you provide on the Website. We may use the personal information you submit to the Website to send you advertising or promotional materials. We also use your personal information for our internal marketing and demographic studies, so we can constantly improve the products and services we provide you and can better meet your needs. The demographic information (such as age and gender) you provide us is collected by Turnaround Training and may be disclosed in aggregate to third parties. This aggregate demographic information cannot be used to personally identify you or your computer.

How Turnaround Training Shares Personal Information

From time to time, Turnaround Training may use and share Website user’s personal information with entities who use it solely to provide support for the internal operations of the Web site (for example, online product fulfillment, e-mail services, or technical support). These entities will not use your personal information for any other purpose, and have agreed to maintain the confidentiality, security, and integrity of the personal information they obtain from us.

We may disclose personal information in the good faith belief that we are required to do so by law, including but not limited to disclosure to law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or us to legal liability.

Generally, Turnaround Training only uses personal information collected from and about its users for the purpose for which it is submitted, unless we disclose other uses at the time we collect the information. If we disclose such other uses, you will have the opportunity to instruct us not to use your data in other ways. We may also sometimes share personally identifiable information with our affiliates or business partners who might like to send you information about their products or services. If you do not want your information used in this manner, you may “opt-out” in the manner described below under the paragraph titled, “Opt-Out”. Notwithstanding the foregoing, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, Turnaround Training’s customer information may be transferred to Turnaround Training’s successor or assign, if permitted by and done in accordance with applicable law.

Information Sharing with Non-Affiliated Third Parties

Because Turnaround Training values all customer relationships, it will not disclose customers’ nonpublic personal information to nonaffiliated third parties, except as described in this policy or as otherwise permitted by law. If you feel you have been contacted in error by a party other than Turnaround Training, please contact Website Support at [email protected]

Cookies and IP Addresses

Turnaround Training may use “cookies” on the Website. Cookies are pieces of information that we place on your computer to help us accurately understand how many consumers are visiting a particular site, how often they visit that site, and what content they are most interested in. For example, a cookie will allow us to remember certain things based on your Internet Protocol or “IP” address (an IP address is the string of numbers that identifies each sender or receiver of information that is sent across the Internet), such as the time and duration of your visits, how you navigated through our content and where you exited a particular site. This lets us know how many people are coming to individual sites, how frequently, and how they are using the sites, allowing us to make updates to content and improve navigation as appropriate. We cannot tell who you are or where you are. Turnaround Training will never use cookies to retrieve information from your computer that Turnaround Training did not originally send in a cookie.

Linking/Co-Branding

To provide relevant information not found on the Website and to provide a greater variety of online opportunities, Turnaround Training may provide links from the Website to third party web sites. We encourage our Website visitors to read third party sites’ privacy policies before submitting personal information. Turnaround Training is not responsible for any information these websites may obtain from you and we do not review or oversee their privacy policies or procedures.

Opt-Out

If you do not want Turnaround Training to send you e-mail or regular mail about our products and/or services, you can opt-out at the time we collect the information. If you are receiving e-mails

or regular mail and at a later date you choose to opt-out and have your name removed from Turnaround Training’s e-mailing list, you can do so by using the link included with an Turnaround Training e-mail or by sending an e-mail to [email protected] Turnaround Training will occasionally send email announcing changes or enhancements to our site or services. If you do not wish to receive these announcements, please notify us at [email protected] that you wish to opt-out of all announcements.

California Privacy Rights

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To obtain this information, please send an e-mail message to: [email protected] with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

International Privacy Practices

Turnaround Training’s Websites are primarily operated and managed on servers located and operated within the United States. In order to provide our products and services to you, we may send and store your personal information (also commonly referred to as personal data) outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your personal information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal information. We are committed to protecting the privacy and confidentiality of personal information when it is transferred. If you reside or are located within the European Economic Area and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the European Economic Area to the extent feasible under applicable law. By using and accessing our products and services, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

Contacting Turnaround Training

If you have any questions about this Privacy Policy, please contact us by e-mail at [email protected]