Privacy Policy

TrainAR Limited ("TrainAR", "we", "us", or "our") operates the TrainAR Core App which runs on AR smart glasses (the "App"), the TrainAR Dashboard web application, and the website https://trainar.ai (the "Website"). This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our services.

This policy applies to all users of the App and Website, including Trainers, Trainees, and any individual accessing the platform through their employer or training organisation. The functionality of the App is the same for both Trainers and Trainees, and the data we collect and process is treated equally regardless of your role.

By using the App or Website, you agree to the collection and use of information in accordance with this policy. If you do not agree, please do not use our services.

This policy has been drafted in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who We Are

TrainAR Limited is a company registered in England and Wales (Company Number 16034854). We provide an augmented reality (AR) training platform for the construction and trades industries, enabling organisations to deliver, record, and manage hands-on technical training for both Trainers and Trainees.

TrainAR acts as a data processor on behalf of your employer or training organisation (the data controller) for training-related data, and as a data controller for account registration and platform usage data.

For any questions about this policy or your data, please contact us at team@trainar.ai or write to us at TrainAR Limited, 22 Siskin Grove, Leighton Buzzard, LU7 4DQ, United Kingdom. Our website is https://trainar.ai.

2. Information We Collect

We collect information in several ways depending on how you interact with our services. The types of data collected are the same for both Trainers and Trainees.

Information you provide directly. When you create an account or use our services, you may provide your full name, email address, phone number, organisation name, job title or role, time zone, language preferences, location settings, and notification preferences. You may also provide training content such as notes, annotations, and voice recordings created during training sessions, as well as messages, feedback, and support requests you send to us.

Information collected automatically. When you use the App or Website, we automatically collect certain technical and usage information. This includes your device model, manufacturer, operating system type and version, unique device identifiers, screen resolution, and language settings. We also collect information about features you access, actions you take within the App, session start and end times, pages visited on the Website, and general interaction patterns. Additionally, we collect error reports, crash logs, performance diagnostics, system activity logs, your IP address, connection type, and general geographic location at city level.

Camera and microphone data. The App requires access to your device's camera and microphone for core training functionality. This applies equally to Trainers and Trainees. The camera is used for augmented reality training sessions, AI-powered fault diagnosis, and capturing training content through compatible AR smart glasses or your phone camera. The camera enables mixed reality overlays that guide users through practical tasks in real time. The microphone is used for voice guidance during training sessions, live audio connections between Trainers and Trainees, and voice note recording as part of structured training content. Camera and microphone data is only captured during active training sessions or when you explicitly initiate a live connection. We do not access your camera or microphone unless a training session is actively running. Once a session is explicitly started, access is maintained until the session is ended or paused by the user. We do not capture any audio or video data when the App is closed or when no session is active. You can revoke camera and microphone permissions at any time through your device settings, although this will limit the App's core functionality.

Session and training data. During the use of the App, the following training-related data may be collected for both Trainers and Trainees. This includes training session recordings comprising video, audio, timestamps, annotations, notes, and outcomes captured during AR training sessions, which serve as compliance evidence and contribute to the user's professional portfolio. We also collect competency records including task completion status, assessor sign-offs, progress towards qualifications, and performance metrics. AI diagnostic data submitted for AI-assisted training features may also be collected, including visual and contextual inputs used to provide real-time guidance and feedback. Additionally, device pairing data relating to the connection between your mobile device and compatible AR smart glasses or other peripherals used during training may be collected.

3. How We Use Your Information

We use the information we collect for the purposes set out below. Each purpose is linked to a legal basis under the UK GDPR. These purposes apply equally to data collected from Trainers and Trainees.

Performance of contract. We process your data as necessary to perform our contract with you or your organisation. This includes providing, maintaining, and operating the App and its features; delivering, recording, and playing back AR training sessions; providing AI-powered diagnostics, guidance, and fault identification; enabling live video and audio connections between Trainers and Trainees; tracking competency and qualification progress; and managing device authentication, pairing, and session management.

Legitimate interest. We process certain data where we have a legitimate business interest in doing so, provided that interest is not overridden by your rights and freedoms. This includes logging sessions for compliance tracking and portfolio evidence; analysing usage data to improve the App and user experience; providing customer support, technical assistance, and communications; monitoring for security threats, fraud prevention, and abuse detection; and notifying you of changes to our services or policies.

Legal obligation. We process data where necessary to comply with applicable laws, regulations, and legal processes.

We do not use your data for advertising, ad targeting, or behavioural profiling; selling, renting, or sharing your personal information with third parties for their own marketing purposes; automated decision-making that produces legal or similarly significant effects without human oversight; or profiling for purposes unrelated to training delivery and platform improvement.

4. Data Sharing

We do not sell, rent, or trade your personal information. We only share data where necessary to operate our services or where required by law.

Service providers. We may share data with third-party service providers solely for the purposes of operating our services. These providers offer cloud infrastructure and hosting, AI and machine learning processing, audio and video recording, real-time audio and video communications, database and authentication services, and analytics and performance monitoring. All third-party service providers are carefully vetted and are bound by data processing agreements that require them to handle your data in accordance with UK GDPR. They may only process your data on our instructions and for the specific purposes we define. A full list of our current subprocessors is available on request by contacting team@trainar.ai.

Your employer or training organisation. Where you access the App through your employer or training organisation, whether as a Trainer or Trainee, we may share training session outcomes and completion records, competency assessments, sign-offs and qualification progress, attendance and participation records, and aggregated usage statistics with them as part of the service. Your employer or training organisation acts as the data controller for this training-related data. Please refer to their own privacy policy for information on how they handle your data.

Legal requirements. We may disclose your data where required to do so by law, regulation, legal process, or enforceable governmental request. We may also disclose data to protect the rights, property, or safety of TrainAR, our users, or the public.

5. International Data Transfers

Your data is primarily stored and processed within jurisdictions that provide adequate data protection under UK GDPR.

Where data is transferred to service providers located outside the United Kingdom or European Economic Area, we ensure appropriate safeguards are in place. These include Standard Contractual Clauses approved by the UK Information Commissioner's Office, UK International Data Transfer Agreements where applicable, and adequacy decisions recognised by the UK Government. We will not transfer your data to any country or organisation that does not provide an adequate level of data protection without implementing appropriate supplementary measures.

6. Data Storage and Security

We take the security of your personal data seriously and implement a comprehensive set of technical and organisational measures to protect it.

All data is encrypted in transit and at rest using industry-standard encryption methods. We implement strict access controls to ensure that only authorised personnel can access personal data, and only to the extent necessary for their role. Organisation data is logically isolated to prevent any cross-tenant access, ensuring that data belonging to one organisation is never accessible to another.

Our infrastructure is hosted in secure, professionally managed data centres with appropriate physical and environmental controls. We continuously monitor our systems for vulnerabilities, unauthorised access attempts, and security incidents. All team members with access to personal data receive regular training on data protection and security best practices. We maintain documented incident response procedures to ensure rapid detection, containment, and remediation of any security events.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. This applies equally to data from Trainers and Trainees.

Account information is retained for the duration of your active account, plus 12 months after account closure, to allow for account recovery and to resolve any outstanding matters. Training session recordings are retained in accordance with your organisation's retention policy and applicable industry compliance requirements. Competency and qualification records are retained as required by industry regulations and your organisation's policies, which is typically between 3 and 7 years. Usage and analytics data is retained for up to 24 months from collection in anonymised or aggregated form. Log and diagnostic data is retained for up to 12 months from collection. Communications and support requests are retained for up to 24 months from resolution.

When data is no longer required, it is securely deleted or anonymised so that it can no longer be associated with you.

8. Your Rights

Under the UK GDPR and the Data Protection Act 2018, you have rights in relation to your personal data. These rights apply equally to Trainers and Trainees.

You may request access to the personal data we hold about you, along with information about how it is being processed. You may also request that we correct any inaccurate or incomplete personal data, or that we delete your personal data where there is no compelling reason for us to continue processing it.

To exercise any of these rights, contact us at team@trainar.ai. We will respond to your request within 30 days. In some cases, we may need to verify your identity before processing your request. If your request is complex or we receive a large number of requests, we may extend the response period by a further 60 days, in which case we will notify you.

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at https://ico.org.uk or by telephone on 0303 123 1113.

9. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner's Office within 72 hours of becoming aware of the breach, where required by law. We will notify affected individuals without undue delay where the breach is likely to result in a high risk to their rights and freedoms. All breaches are documented, including the facts surrounding the breach, its effects, and the remedial actions taken.

10. Children's Privacy

The App is not directed at children under the age of 18. We do not knowingly collect personal data from anyone under 18 years of age. The minimum age for using the App is 18, reflecting the professional nature of the construction and trades training delivered through the platform.

If we become aware that we have inadvertently collected data from a person under 18, we will take steps to delete it promptly. If you believe a child has provided us with personal data, please contact us at team@trainar.ai.

11. Cookies and Tracking

The Website (trainar.ai) may use cookies and similar technologies for essential site functionality such as session management and security features, and for analytics purposes using anonymised usage data to help us understand how visitors interact with the Website and to improve its performance. No personally identifiable information is collected through analytics cookies. We do not use cookies for advertising, remarketing, or cross-site tracking. You can manage your cookie preferences through your browser settings. Disabling non-essential cookies will not affect the core functionality of the Website.

The App does not use cookies. Usage analytics within the App are collected via SDK-based tools and are processed in accordance with this policy. Analytics data is not shared with advertising networks or any third parties for marketing purposes.

12. Third-Party Links

The App and Website may contain links to third-party websites, services, or resources that are not operated by TrainAR. We are not responsible for the content, privacy practices, or security of those third-party sites. We encourage you to review the privacy policies of any third-party sites you visit. The inclusion of a link does not imply endorsement by TrainAR.

13. Ads Declaration

The TrainAR App does not contain advertisements. We do not integrate any ad networks, ad SDKs, ad-serving technologies, or any form of in-app advertising. Your data is never used for advertising purposes.

14. Changes to This Policy

We may update this Privacy Policy from time to time 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 and notify you via email or in-app notification where the changes are significant. Where required by law, we will seek your consent to material changes before they take effect.

We encourage you to review this policy periodically. Your continued use of the App or Website after changes are posted constitutes acceptance of the updated policy.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or our data practices, please contact us by email at team@trainar.ai, through our website at https://trainar.ai, or by post at TrainAR Limited, 22 Siskin Grove, Leighton Buzzard, LU7 4DQ, United Kingdom.

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at https://ico.org.uk or by telephone on 0303 123 1113.