Colleagues reaching across table to shake hands

Privacy Policy

Last Updated: November 3, 2025
Product: Callisto
Company: PowerTrain, Inc. (“PowerTrain”, “we”, “us”, or “our”)
Contact: info@powertrain.com | 8201 Corporate Drive, Suite 500, Hyattsville, MD 20785

This Privacy Policy explains the information we collect about you when you use Callisto, how we use and share that information, and the choices available to you. By using Callisto, you acknowledge this Policy.

Who we are

PowerTrain, Inc. provides the Callisto learning management platform. If you have questions about this Policy or our privacy practices, contact info@powertrain.com. We do not sell your personal information.

What data we collect and receive

The information we collect depends on how you interact with Callisto.

1) Information You Provide

Account data: Name, username, password (hashed), work email, role, department, and optional profile details.
Support and communications: Content of messages you send us (e.g., help desk emails, contact forms, survey responses).
Learning records: Enrollments, completions, scores, due dates, time‑on‑task, uploaded assignments, and feedback you submit within the platform.

2) Authentication and Security Data

Sign-in events: Timestamps, IP address used at authentication, and indicators of multifactor status where applicable.
Session data: Session identifiers and tokens necessary to keep you signed in and secure.

3) Device, Log, and Usage Data

Device/browser data: IP address, browser type and version, operating system and version, language, referring URL.
Usage logs: Pages or features accessed, error/diagnostic events, and approximate location inferred from IP for abuse prevention and troubleshooting.

We do not intentionally collect government identifiers, precise geolocation, or biometric templates through Callisto.

How we use personal data (purposes)

The Callisto platform collects personal information from users at the time of registration. This information includes, but is not limited to, the user’s email address, first name, last name, and organizational affiliation. Such information is provided directly by the user through the registration process. In addition, administrative customers have the ability to configure the Callisto to collect supplementary data elements as required for their organizational needs. All personal data collected is handled in accordance with applicable data protection standards and is used solely for the purposes of operating and managing the platform, and analytical metrics. We use personal data to:

Provide Callisto: Operate and administer accounts, deliver coursework, track progress, and generate reports authorized by your organization.
Maintain and secure: Prevent abuse, investigate outages, fix bugs, and protect the integrity and availability of Callisto.
Support you: Respond to requests, provide notifications about Callisto (e.g., maintenance, policy updates), and improve user assistance.
Improve Callisto: Analyze aggregated/anonymous usage trends and quality metrics to enhance features and performance.
Legal and compliance: Meet legal obligations, enforce agreements, and protect rights and safety.

Legal bases (EEA/UK): contract performance, legitimate interests (e.g., service security), consent where required (e.g., for non‑essential cookies), and legal obligation.

How we share personal data

PowerTrain processes personal data exclusively for generating analytical metrics aimed at enhancing the quality and performance of its services. The data is not used for any unrelated purposes. Access to such data is strictly limited to authorized personnel and trusted service providers who require it in order to perform their duties, and it is not disclosed to any other third parties. We share information only as described below:

Your organization: Authorized administrators and instructors may access learner records and reports according to role-based permissions configured in Callisto.
Service providers: Vendors that host, support, or help us operate Callisto (e.g., secure hosting, email delivery, monitoring) under contracts that limit their use of data to providing services to PowerTrain.
Legal and safety: When required by law or legal process, to protect users and Callisto, to enforce agreements, or in connection with a corporate transaction (with notice as required by law).

We do not sell personal information and do not share it for cross-context behavioral advertising.

Cookies, Do Not Track, and similar technologies

The Callisto platform employs cookies strictly for purposes of user authentication, session management, and identification. PowerTrain does not use cookies for tracking, advertising, or any other unrelated purpose. All cookies are configured with Secure and HttpOnly attributes and are transmitted exclusively over encrypted HTTPS connections, thereby ensuring the protection and confidentiality of user information.

Essential cookies are required for core functions such as sign‑in, security, and session continuity. These cannot be disabled.
Functional cookies remember preferences such as language and accessibility settings.
Analytics cookies help us understand product usage and performance. Where required by law, analytics cookies operate only with your consent.

Do Not Track: Some browsers send “Do Not Track” signals. Callisto may not respond to these signals. You can control cookies through your browser settings. Blocking or deleting cookies may affect Service functionality.

Security

We employ administrative, technical, and physical safeguards intended to protect personal data, including encryption in transit, encryption at rest, role-based access controls, logging/monitoring, and security training for personnel. No method of transmission or storage is completely secure; we cannot guarantee absolute security. If a security incident occurs that affects personal data, we will notify affected customers and/or individuals as required by law.

Data retention

We retain data for as long as your account is active or as needed to provide Callisto, comply with our legal obligations, resolve disputes, enforce agreements, and protect our legal rights. Your organization’s administrators may set retention or deletion schedules for certain records. Upon termination of a customer tenant, we delete or return customer data within the period specified in the applicable agreement, subject to standard backup cycles.

Your rights and choices

Depending on your location, you may have rights to access, correct, delete, restrict, or object to certain processing, as well as to data portability. You may also have rights to opt out of certain data sharing.

If your account is managed by an organization, please direct requests to your administrator. We will support your organization in responding.
If you interact with PowerTrain directly (e.g., on our website), contact info@powertrain.com to exercise your rights. We may need to verify your identity.
We will not discriminate against you for exercising your privacy rights.

California (CCPA/CPRA): California residents may request access to categories/specific pieces of personal information we collect, request deletion or correction, and opt out of certain sharing, subject to verification and exceptions provided by law.

Accountability

PowerTrain has implemented policies and procedures to ensure compliance with data protection laws and regulations, including regular audits and employee training. PowerTrain also conducts due diligence on its vendors and partners to ensure that they comply with applicable data protection laws and regulations.

An employer – as the controller of an employee’s personal data – administers the use of the applicable PowerTrain products and services. As such, the employer’s privacy policies govern the product and/or service usage.

PowerTrain is the controller of, and responsible for, the contact information we collect in connection with our marketing initiatives and employment opportunities that often originate with our website located at: PowerTrain, Inc. PowerTrain is the processor of, and responsible for, processing personal data in connection with the performance of its contractual duties and the provisions of the services and products provided to the customer organization.

The table below summarizes PowerTrain’s role according to the relationships it has with the data subject.

Data Subject(s)	Controller	Processor	What governs the handling and use of the Personal Data of the Data Subject(s) as between Controller and Processor?
Licensed end-user	Customer organization	PowerTrain, Inc.	Master Services/License Agreement together with a Data Protection Addendum, as applicable.
Marketing contacts (e.g., whitepaper registrants, webinar attendees) and job applicants	PowerTrain, Inc.	Our various service providers	PowerTrain’s Privacy Policy
Individual learner, organization’s employee	Customer Organization (e.g. Azure Marketplace)	PowerTrain, Inc.	PowerTrain’s Privacy Policy and Employer’s privacy policy or analogous document disclosing for what purpose (e.g., corporate training).

Children’s privacy

Callisto is intended for organizational use and is not directed to children under 13 (or other age as defined by local law). If you believe we have collected personal information from a child without appropriate consent, contact us so we can take appropriate action.

International data transfers

Where applicable, we may transfer personal data across borders to operate Callisto. When we do so, we rely on appropriate safeguards recognized by law (e.g., standard contractual clauses) and implement measures to protect the data during transfer and storage.

Third-party websites

Callisto may contain links to external websites. This Policy does not apply to those sites, and we are not responsible for their privacy practices or content. We encourage you to review the privacy policies of any external sites you visit.

Changes to this policy

We may update this Policy from time to time. If we make material changes, we will update the “Last Updated” date and provide additional notice where required (for example, within Callisto or by email to administrators). The updated Policy takes effect when posted unless a later date is stated.

Complaints

If you have any concerns or complaints about our data processing activities, we urge you to first try to resolve your issue directly with us by contacting our Data Protection Officer via dpo@powertrain.com. We try to respond to all verified requests within one month of receiving them. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.