Privacy Policy

Effective Date: April 1, 2026
Company: trainwell Recruiting LLC
Contact Email: [email protected]

SECTION 1 – INTRODUCTION AND SCOPE

trainwell Recruiting LLC ("trainwell," "we," "us," or "our") operates as a recruitment process outsourcing (RPO) and talent sourcing firm. We do not act as your employer. Instead, we evaluate candidates on behalf of our clients, which consist of insurance agency offices, to present qualified candidates for potential employment with those third-party organizations. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you submit an application through our Jotform application form or otherwise engage with our recruitment services.

By submitting your application, you acknowledge that you have read, understood, and agree to be bound by all terms of this Privacy Policy. IMPORTANT: trainwell is not your prospective employer. Any employment relationship, if offered, will be with one of our client insurance agencies, not with trainwell Recruiting LLC.

SECTION 2 – INFORMATION WE COLLECT

We collect the following categories of personal information from candidates. Personal Identifiers include full name, email address, phone number, physical address, and professional social media profiles such as LinkedIn URL. Professional Information includes resume/CV, cover letter, work history, educational background, skills, certifications, licenses, references, portfolio samples, and sourcing samples. Application Responses include answers to application questions, including outreach message samples, sourcing strategies, availability, and work authorization status. Sensitive Data, if voluntarily provided, includes race/ethnicity, gender, disability status, and veteran status only where collected for diversity reporting with client consent. Technical Information includes IP address, browser type, device information, and referral URLs collected automatically via Jotform's systems. Communications include any information you provide when contacting us directly via email or phone. We do not collect payment information, as no payment is required at any stage of the application process.

We use the National Insurance Producer Registry NIPR Producer Database and state insurance department systems to verify the active status, lines of authority, expiration date, and disciplinary history of applicant insurance licenses. This verification is conducted to confirm eligibility for placement with client insurance agencies and to comply with insurance industry regulatory requirements. You expressly authorize this verification by checking the designated checkbox on your application.

SECTION 3 – HOW WE USE YOUR INFORMATION

We use your personal information for the following business purposes. We use it for Candidate Evaluation to assess your qualifications, skills, and fit for positions with our client insurance agencies. We use it for Client Submission to present your candidacy to our client insurance agencies for their hiring consideration. We use it for Verification to verify the accuracy of information provided and confirm work history, references, and credentials. We use it for Communication to inform you of your application status, interview opportunities, and potential placements. We use it for Record Keeping to maintain internal records for compliance with legal and regulatory obligations. We use it for Process Improvement to enhance our sourcing and recruitment processes. We use it for Legal Protection to protect our legal rights, prevent fraud, and defend against legal claims.

SECTION 4 – DISCLOSURE OF YOUR INFORMATION

We do not sell, rent, or trade your personal information to any third parties for monetary or other valuable consideration. We may share your information in the following circumstances.

4.1 – Disclosure to Client Insurance Agencies. The primary purpose of collecting your information is to present you as a candidate to our client insurance agencies. When we determine that you may be a suitable candidate for a role with one of our clients, we will share your personal information (including resume, contact details, and work history) with that client for their independent hiring evaluation. You acknowledge and agree that once disclosed to a client insurance agency, that client becomes an independent data controller responsible for its own processing of your information. trainwell does not control, and is not responsible for, the hiring decisions, data practices, or privacy policies of our client agencies. You should review the privacy policy of any client agency that contacts you regarding employment. Verification results including license status and any regulatory actions may also be shared with client agencies as part of your candidate evaluation.

4.2 – Service Providers (Data Processors). We use third-party service providers to process and store your information. These providers act as data processors on our behalf and are contractually obligated to maintain the confidentiality and security of your information. We use Jotform for application form hosting, data collection, and secure form submissions, with data storage located in the United States on US-based servers. We use Airtable and HighLevel for candidate database management, tracking, and workflow organization, with data storage located in the United States on US-based servers. We use Email Services for communication with candidates regarding application status. All service providers are contractually prohibited from using your information for any purpose other than providing services to trainwell.

4.3 – Legal Compliance and Enforcement. We may disclose your information if required to do so by law, regulation, legal process, or governmental request (including in response to a court order or subpoena). We may also disclose information to enforce our policies, protect our rights, privacy, safety, or property, or those of others, and to defend against legal claims.

4.4 – Business Transfers. In the event of a merger, acquisition, reorganization, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. You will be notified via email or a prominent notice on our website of any change in ownership or use of your information.

SECTION 5 – DATA SECURITY

We implement appropriate technical and organizational security measures designed to protect your information from unauthorized access, disclosure, alteration, or destruction. Encryption: All data transmitted through Jotform is protected by 256-bit SSL/TLS encryption. Access Controls: Access to candidate data in Jotform, Airtable, and HighLevel is restricted to authorized trainwell personnel on a need-to-know basis. Multi-Factor Authentication: MFA is enabled for all accounts with access to candidate data. Service Provider Security: Jotform maintains PCI DSS Level 1, SOC 2 Type II, and HIPAA-compliant infrastructure; Airtable maintains SOC 2 Type II and ISO 27001 certification; HighLevel maintains SOC 2 Type II certification. No method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information using industry-standard safeguards, we cannot guarantee absolute security. In the event of a data breach that affects your information, we will notify you and relevant authorities as required by applicable law.

SECTION 6 – DATA STORAGE LOCATION AND INTERNATIONAL TRANSFERS

All candidate data collected by trainwell Recruiting LLC is stored exclusively on servers located within the United States. We do not transfer, store, or process your personal information outside the United States. In compliance with the Protecting Americans' Data from Foreign Adversaries Act (PADFAA) , we explicitly prohibit the transfer of candidate data to, or storage of candidate data in, China, Russia, Iran, North Korea, or any entity controlled by these countries. If you are accessing our application from outside the United States, you acknowledge and agree that your information will be transferred to and processed in the United States, which may have data protection laws that differ from those in your jurisdiction.

SECTION 7 – DATA RETENTION

We retain your personal information for the following periods. For Active Candidates, we retain information for the duration of your active consideration for roles with our clients. For Inactive Candidates, we retain information for up to two (2) years from the date of your last application or communication, to consider you for future opportunities. For Placed Candidates, we retain information for up to seven (7) years from the date of placement, as necessary to comply with legal obligations, defend against claims, and maintain placement records. Deletion Requests: If you wish to have your information deleted before the retention period expires, you may contact us at [email protected]. Upon receipt of a verified deletion request, we will delete your information from our Airtable and Jotform systems within thirty (30) days, subject to exceptions permitted by law (such as legal hold or pending claims). Note: We cannot delete information that has already been shared with a client insurance agency. If you wish to have your information deleted from a client's systems, you must contact that client directly.

SECTION 8 – YOUR RIGHTS

Depending on your state of residence (California, Colorado, Connecticut, Utah, Virginia, etc.), you may have the following rights regarding your personal information. You have the Right to Know, which is the right to request disclosure of the categories and specific pieces of personal information we have collected about you, the sources of that information, our purposes for collection, and the categories of third parties with whom we have shared it. You have the Right to Deletion, which is the right to request deletion of your personal information, subject to legal exceptions. You have the Right to Correction, which is the right to request correction of inaccurate personal information. You have the Right to Opt-Out, which is the right to opt-out of the sale or sharing of your personal information (trainwell does not sell or share personal information). You have the Right to Non-Discrimination, meaning you will not receive discriminatory treatment for exercising your privacy rights. You have the Right to Appeal, meaning if we deny your request, you have the right to appeal that decision. To exercise any of these rights, please contact us at [email protected]. We will respond to all verified requests within thirty (30) days, or as otherwise required by applicable law. We may need to verify your identity before processing your request.

SECTION 9 – CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with additional rights. You have the Right to Limit Use of Sensitive Personal Information, meaning you may request that we limit our use of sensitive personal information (such as race, ethnicity, or health information) to only that which is necessary to perform the services you expect. You have the Right to Correct Inaccurate Information, meaning you have the right to request correction of inaccurate personal information. Regarding No Sale of Personal Information, trainwell does not sell personal information, nor do we share it for cross-context behavioral advertising. Regarding Retention Disclosure, we retain candidate information as described in Section 7 above. California residents may exercise their rights by contacting us at [email protected]. For requests submitted by an authorized agent, we will require written proof of authorization.

SECTION 10 – CONSENT AND LEGAL BASES FOR PROCESSING

10.1 – Consent. By submitting your application, you expressly consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy, to the transfer of your application and personal information to our client insurance agencies for their independent hiring consideration, and to the storage of your information on Jotform, HighLevel, and Airtable servers located in the United States.

10.2 – Withdrawal of Consent. You may withdraw your consent at any time by contacting us at [email protected]. Upon withdrawal of consent, we will cease processing your information and delete it from our systems, subject to legal exceptions. However, we cannot retract information already disclosed to client agencies.

10.3 – EEA/UK Applicants (Additional Basis). If you are located in the European Economic Area (EEA) or the United Kingdom, our processing is based on Legitimate Interests (evaluating candidates and facilitating recruitment on behalf of our clients), Contractual Necessity (processing necessary to take steps at your request prior to entering into an engagement, if applicable), and Legal Compliance (compliance with applicable laws).

SECTION 11 – THIRD-PARTY LINKS AND SOCIAL MEDIA

Our application may include links to third-party websites (such as LinkedIn profiles you provide, or client websites). We are not responsible for the privacy practices or content of these external sites. Any information you provide to third-party websites is governed by their own privacy policies, not this Privacy Policy. We encourage you to review the privacy policies of any third-party websites you visit.

SECTION 12 – REPRESENTATIONS REGARDING REFERENCES

By providing contact information for references or previously sourced candidates, you represent and warrant that you have obtained all necessary consents to share this information with trainwell, that the information provided is accurate and complete to the best of your knowledge, and that you understand reference information will be used solely for evaluating your candidacy and will not be used for any purpose unrelated to our recruitment services.

SECTION 13 – CHILDREN'S PRIVACY

Our recruitment services are not intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If you become aware that a minor has provided us with personal information, please contact us immediately at [email protected].

SECTION 14 – DISCLAIMER OF EMPLOYMENT RELATIONSHIP

trainwell Recruiting LLC is not your employer. Any employment relationship, if offered, will be with one of our client insurance agencies. trainwell does not make hiring decisions, set compensation, or control the terms of employment with any client agency. We act solely as a sourcing and evaluation intermediary. Nothing in this Privacy Policy or in our recruitment process creates an employment contract, joint employer relationship, or agency relationship between trainwell and any candidate.

SECTION 15 – CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or client needs. Changes and clarifications will take effect immediately upon posting. If we make material changes, we will notify you by updating the "Effective Date" at the top of this policy and, where feasible, by email notification. Your continued engagement with us after any changes constitutes acceptance of the revised Privacy Policy.

SECTION 16 – CONTACT INFORMATION

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at [email protected]. Our company is trainwell Recruiting LLC. For data subject requests (access, deletion, correction, etc.), please use the subject line: "Privacy Request – [Your Name]"

By submitting your application through this form, you acknowledge that you have read, understood, and agree to be bound by all terms of this Privacy Policy. You acknowledge that trainwell Recruiting LLC is not your employer and that your information will be shared with client insurance agencies for hiring consideration.