End User License Agreement

Last Updated: April 12, 2017

TERMS OF USE

BY USING THE TREADSTONE 71 CYBER INTEL TRAINING CENTER TRAINING PLATFORM, ATTENDING IN-PERSON TRAINING CLASSES AND SEMINARS, ACCESSING THE ONLINE CONFLUENCE PORTAL, OR THE ONLINE CYBER INTELLIGENCE LIFECYCLE PROTOTYPE, (THE “PLATFORM”), YOU ACCEPT THESE TERMS OF USE (“TERMS”). IF YOU DO NOT AGREE WITH THESE TERMS, YOU SHOULD IMMEDIATELY DISCONTINUE USE OF THE PLATFORM. CONTINUED USE OF THE PLATFORM SIGNIFIES YOUR CONTINUED ACCEPTANCE OF THESE TERMS AND ANY CHANGES TO THEM. THESE TERMS FORM A BINDING LEGAL CONTRACT BETWEEN TREADSTONE 71, LLC. ( “T71” or “WE”), AND YOU. PERSONS WHO RESIDE IN THE PEOPLE’S REPUBLIC OF CHINA, BURMA, CUBA, IRAN, LIBYA, MALAYSIA, NORTH KOREA, SUDAN, OR ANY OTHER COUNTRY THAT IS SUBJECT TO A U.S. GOVERNMENT EMBARGO, OR THAT HAS BEEN DESIGNATED BY THE U.S. GOVERNMENT AS A "TERRORIST SUPPORTING" COUNTRY, AND WHERE PROHIBITED OR OTHERWISE RESTRICTED BY LAW (“PROHIBITED COUNTRIES”) MAY NOT DOWNLOAD OR USE THE PLATFORM.

In addition to these Terms, the T71 privacy notice, found at https://www.cyberinteltrainingcenter.com/p/privacy (the “Privacy Policy”) will govern how personal information you submit on this Platform will be used, and together they form the agreement between you and T71 (the “Agreement”). THIS AGREEMENT CONTAINS DISCLAIMER AND OTHER PROVISIONS THAT LIMIT T71’S LIABILITY TO YOU.

Age Restriction

Only individuals eighteen (18) years of age or older may use the Platform.

END-USER LICENSE

Subject to these Terms, T71 grants you a personal, non-exclusive, non-transferable, non-sublicensable, limited and revocable license to use the Platform for personal use or for internal uses by your employer at the time you were granted access to the Platform only (“User License”). The User License is hereby incorporated into these Terms. Any use of the Platform in any other manner, including, without limitation, resale, reverse-engineering, disassembling, redistribution, transfer, modification or distribution of the Platform or text, pictures, video, data, hyperlinks, displays, and other content associated with the Platform is prohibited. You may not copy (except as expressly permitted by this Agreement), decompile, reverse-engineer, disassemble, attempt to derive the source code of, modify, or create derivative works of the Platform, any updates, or any part thereof (except as and only to the extent that any foregoing restriction is prohibited by applicable law or to the extent as may be permitted by licensing terms governing use of any open-sourced components included with the Platform). If you breach any of these restrictions, you may be subject to prosecution and damages. These Terms and User License also govern any updates to, or supplements or replacements for this Platform unless separate terms accompany such updates, supplements or replacements, in which case the separate terms will apply.

The User License is effective until terminated by you or T71, with or without written notice. Your rights under the User License will terminate automatically without notice from T71 if you fail to comply with any Terms or terms of the User License. Upon termination of the license, you shall cease all use of the Platform and destroy all copies, full or partial, of the Platform or Content.

ACCOUNTS

For certain aspects of the Platform, you may be asked to register an account. In the event you agree to register an account, you will select and/or receive a username and password upon providing registration information and successfully completing the registration process. This account is personal to you, and you will not share it or allow any other person to utilize your account. You may never use another’s account without permission. You are responsible for maintaining the confidentiality of your username and password and are fully responsible for all activities that occur under your username and password. You agree to immediately notify T71 in the event your registration information changes or you learn of or have reason to suspect any unauthorized use of your account or any other breach of security. You also agree that you will provide truthful and accurate information during the registration process. T71 may refuse to grant a particular username to you for any reason.

T71 reserves the right to deny or revoke access to this Platform, or any part thereof, or to otherwise terminate a user's access to its Platform, at any time in its sole discretion, with or without cause and without notice to you.

User Information

Various Platform features may use, maintain, or transmit personal information, including, without limitation, your name, password and email address, (collectively “User Information”).

By using the Platform, you consent to the transmission of User Information to T71, including its agents and third party partners, and consent to T71, including its agents and third party partners, receiving, collecting, storing, processing, transmitting, and using User Information for Platform functionality and for the purposes disclosed in our Privacy Policy. Our Privacy Policy is viewable within the Platform and at https://www.cyberinteltrainingcenter.com/p/privacy.

You further agree that T71, its service providers, and/or others involved in creating or providing the Platform, may collect and use technical data and related information—including, but not limited to, technical information about your device, system and Platform software, and peripherals—that is gathered periodically to facilitate the provision of software updates, product support, and other services to you (if any) related to the Platform.

Subscription Terms

Taxes are recalculated when you change the physical mailing address for your Treadstone 71Training Platform account provided that such change is received more than three business days in advance of the reoccurring subscription charge payment due date. Where changes of address are received less than three business days of the reoccurring subscription charge payment due date, the tax rate associated with the new mailing address will be reflected in the next billing cycle.

External Services and Third Party Materials

The Platform may enable access to the third party services and websites outside of the Platform (collectively and individually, “External Services”). External Services include, but are not limited to LinkedIn, and other social media platforms. Use of the External Services may require you to accept additional terms. Certain External Services may display, include, or make available content, data, information, applications or materials from third parties (“Third Party Materials”) or provide links to certain third party web sites. By using the External Services, you acknowledge and agree that neither T71, nor its agents or those involved in creating or providing the Platform, is responsible for examining or evaluating the content, accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality, or any other aspect of such Third Party Materials or web sites. Neither T71, nor its agents or those involved in creating or providing the Platform, warrant or endorse, and do not assume and will not have any liability or responsibility to you or any other person for any External Services, Third Party Materials or web sites, or for any other materials, products, or services of third parties. Third Party Materials and links to other web sites are provided solely as a convenience to you. You agree to use the External Services at your sole risk and neither T71, nor its agents or those involved in creating or providing the Platform shall have any liability to you for content that may be found to be offensive, indecent, or objectionable. T71 reserves the right to change, suspend, remove, or disable access to any External Services at any time without notice. In no event will T71 be liable for the removal of or disabling of access to any such External Services. T71 may also impose limits on the use of or access to certain External Services, in any case and without notice or liability to you.

Prohibited Uses

Use of the Platform is limited to the contemplated functionality. The Platform shall not be used in any way that does any of the following:

Harasses, abuses, stalks, threatens, defames, or otherwise infringes or violates the rights of any other party (including, but not limited to, trademark, copyright, rights of publicity or other proprietary rights).

Is unlawful, fraudulent, or deceptive.

Uses technology or other means to access unauthorized content or non-public spaces, including, but not limited to, use of “bots,” “spiders,” or “crawlers.”

Attempts to (a) introduce viruses or any other harmful computer code, files or programs that interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment, (b) damage, disable, overburden, or impair the T71 servers or networks, or (c) gain unauthorized access to the T71 computer network(s) or user account(s).

Encourages conduct that would constitute a criminal offence, or that gives rise to civil liability.

Violates these Terms in any manner.

Fails to comply with applicable third party terms and conditions or other third-party policies (collectively “Acceptable Use”).

T71 reserves the right, in its sole discretion, to terminate any User License, remove Content, assist law enforcement in the prosecution of criminal liability, or assert a civil or criminal legal action with respect to Content or use of the Platform, that T71 reasonably believes is or might be in violation of these Terms or applicable law, but failure or delay in taking such actions does not constitute a waiver of T71’s rights to enforce these Terms.

You represent and warrant that (i) you are not located in a country that is subject to a U.S. Government embargo, or that has been designated by the U.S. Government as a “terrorist supporting” country, and (ii) you are not listed on any U.S. Government list of prohibited or restricted parties.

User-Generated Content

You may generate content, written or otherwise while using the Platform (“User-Generated Content”). You hereby (a) acknowledge and agree that you and you alone are responsible for your own User Generated Content, and (b) grant to T71 and its successors a worldwide, irrevocable, transferrable, sublicensable, fully-paid, royalty-free, non-exclusive license to reproduce, display, modify, delete from, add to, adapt, publish, prepare derivative works from, and otherwise use your User-Generated Content in any way, including, but not limited to, in advertising and product marketing campaigns; and that with respect to T71’s use of User-Generated Content, to the extent allowable under applicable law, you waive in favour of T71, all rights of “Droit Moral” or “Moral Rights of Authors” or any similar rights or principles of law that you may now or later have to the User-Generated Content.

Feedback and Submissions

If you submit comments, ideas, or feedback to us through the Platform or otherwise, you agree that we can use them without any restriction or compensation to you. We do not waive any rights to use similar or related ideas or feedback previously known to us, developed by T71, or obtained from sources other than you.

Indemnification

To the fullest extent allowable under applicable law, you agree to indemnify and hold harmless T71, including its agents, affiliated companies, employees, contractors, directors, and officers, and anyone involved in creating or providing the Platform, from all claims or causes of action, liabilities, damages, costs, fines, penalties, and expenses (including attorneys’ fees) occurring from or related to the use or misuse of the Platform, violation of these Terms, or violations of any rights of a third party, or any allegation thereof. T71 reserves the right to assume the exclusive defence and control of any matter otherwise subject to indemnification by you, in which event you will cooperate in asserting any available defences.

No Warranties

T71 IS PROVIDING THE PLATFORM AND CONTENT “AS IS” AND “AS AVAILABLE” WITHOUT ANY WARRANTIES OR REPRESENTATIONS, EXPRESSED OR IMPLIED. YOU USE THE PLATFORM AT YOUR OWN RISK. TO THE FULLEST EXTENT ALLOWABLE UNDER APPLICABLE LAW, T71 DISCLAIMS ALL WARRANTIES, WHETHER EXPRESS OR IMPLIED, INCLUDING ANY WARRANTIES THAT THE PLATFORM IS MERCHANTABLE, RELIABLE, ACCURATE, FIT FOR A PARTICULAR PURPOSE OR NEED, NON-INFRINGING OR FREE OF DEFECTS OR ABLE TO OPERATE ON AN UNINTERRUPTED BASIS, OR THAT THE USE OF THE PLATFORM BY THE USER IS IN COMPLIANCE WITH LAWS, OR THAT INFORMATION TRANSMITTED IN CONNECTION WITH THE PLATFORM WILL BE SUCCESSFULLY, ACCURATELY OR SECURELY TRANSMITTED.

No Liability

TO THE FULLEST EXTENT ALLOWABLE UNDER PLATFORMLICABLE LAW, IN NO EVENT SHALL T71 OR ITS AGENTS, AFFILIATED COMPANIES, EMPLOYEES, CONTRACTORS, DIRECTORS, AND OFFICERS, AND ANYONE INVOLVED IN CREATING OR PROVIDING THIS PLATFORM OR CONTENT (A) BE LIABLE WITH RESPECT TO USE OF THE PLATFORM; AND/OR (B) BE LIABLE FOR ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL, PUNITIVE, EXEMPLARY OR OTHER DAMAGES, INCLUDING, WITHOUT LIMITATION, DAMAGES FOR LOSS OF GOODWILL, LOST PROFITS, LOSS, THEFT OR CORRUPTION OF USER INFORMATION, OR THE INABILITY TO USE THE PLATFORM. T71, ITS AGENTS AND ANYONE INVOLVED IN CREATING OR PROVIDING THIS PLATFORM OR CONTENT SHALL NOT BE LIABLE EVEN IF ANY OF THEM OR ANY AUTHORIZED REPRESENTATIVE OF THEM HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, INCLUDING, WITHOUT LIMITATION, DAMAGES OR INJURY CAUSED BY ERROR, OMISSION, INTERRUPTION, DEFECT, FAILURE OF PERFORMANCE, UNAUTHORIZED USE, DELAY IN OPERATION OR TRANSMISSION, LINE FAILURE, COMPUTER VIRUS, WORM, TROJAN HORSE OR OTHER HARM.

FOR USERS OF THE PLATFORM WHO RESIDE WITHIN THE EUROPEAN UNION, THE AFOREMENTIONED DOES NOT APPLY TO CLAIMS FOR DAMAGES BASED ON THE INJURY OF LIFE, BODY OR HEALTH OR CLAIMS BASED ON THE BREACH OF ESSENTIAL CONTRACTUAL OBLIGATIONS (CARDINAL DUTIES) AS WELL AS CLAIMS FOR OTHER DAMAGES BASED ON A WILLFUL OR GROSSLY NEGLIGENT BREACH OF DUTIES BY T71, ITS LEGAL REPRESENTATIVES OR AUXILIARY PERSONS. ESSENTIAL CONTRACTUAL OBLIGATIONS ARE THOSE THAT ARE NECESSARY FOR ACHIEVING THE OBJECTIVES OF THE CONTRACT. IF T71 BREACHES ESSENTIAL CONTRACTUAL OBLIGATIONS VIS-À-VIS USERS OF THE PLATFORM WHO RESIDE WITHIN THE EUROPEAN UNION, T71 WILL ONLY BE LIABLE FOR THE TYPICAL AND PREDICTABLE DAMAGE IF THE DAMAGE WAS CAUSED BY SLIGHT NEGLIGENCE. THIS DOES NOT APPLY TO DAMAGES THAT ARE BASED ON THE INJURY OF LIFE, BODY OR HEALTH. THE AFOREMENTIONED RESTRICTIONS ALSO APPLY IN FAVOR OF THE LEGAL REPRESENTATIVES AND AUXILIARY PERSONS OF T71 IF CLAIMS ARE DIRECTLY ASSERTED AGAINST THEM. THE PROVISIONS OF THE GERMAN PRODUCT LIABILITY ACT AND THE MANDATORY PROVISIONS OF THE PRODUCT LIABILITY ACTS OF OTHER EUROPEAN UNION MEMBER STATES REMAIN UNAFFECTED.

FOR USERS OF THE PLATFORM WHO RESIDE OUTSIDE OF THE EUROPEAN UNION, YOU AGREE THAT ALL CAUSES OF ACTION ARISING OUT OF OR CONNECTED WITH THIS PLATFORM, SHALL BE RESOLVED INDIVIDUALLY, WITHOUT RESORT TO ANY FORM OF CLASS ACTION AND THAT YOUR SOLE REMEDY IS TO CEASE USE OF THE PLATFORM.

FOR USERS OF THE PLATFORM WHO RESIDE OUTSIDE OF THE EUROPEAN UNION, in the event that applicable law does not allow the exclusion of certain warranties or the limitation or exclusion of liability for incidental, consequential or other damages, in no event, shall T71, its agents or anyone involved in creating or providing this Platform or Content be liable for damages, losses, and/or causes of action exceeding the amount, if any, paid by you for use of the Platform or $100, whichever is less.

Ownership of Content

All content, including text, images, video, lab environments and other content made available through the Platform is owned by T71 and/or third parties that have given permission for T71 to make such content or lab environments available through the Platform (“Platform Content”). Your use of the Platform, and your agreement to these Terms (and those of any other websites or services to which you gain access through the Platform), does not provide you with or transfer to you in any manner an interest in, or ownership right to, such Platform Content, which shall remain the property of T71 or other third party owner. For purposes of clarity, through your use of the Platform (and other sites to which you gain access hereby), you are provided with permission to use such Platform Content for the time period that you are a registered user of the Platform. This permission does not provide you with or transfer to you, an ownership or other interest in any Platform Content. No Platform Content may be reproduced, republished, uploaded, posted, transmitted, reproduced, distributed, copied, publicly displayed or otherwise used by you for any commercial purposes, except as provided in these Terms or as permitted by the owner thereof. Moreover, you may not distribute, reproduce, republish, display, modify, transmit, reuse, repost, link to, or use any materials of the Platform Content without the written permission of T71 or owner thereof. Modification of any materials displayed in the Platform Content without prior written permission from T71 or other third-party owners, is a violation of T71’s or other third party owner’s copyright and other proprietary rights.

Trademarks

The T71, Treadstone 71, and Treadstone 71, LLC name, logo and other marks, graphics and logos and designations of source used in connection with the Platform are trademarks of T71 (collectively “The T71 Marks”). Nothing contained in the Platform or other websites accessed hereby should be construed as granting you, by implication, or otherwise, permission to use any trademark displayed herein or therein, without the explicit written permission of its owner. The T71 Marks may not be copied, imitated or used, in whole or in part, without the prior written permission of T71.

Choice of Law, Arbitration and Jurisdiction for Disputes

Binding Arbitration for users who reside outside of the European Union: To the fullest extent allowable under applicable law, any controversy or claim arising out of your downloading, installation, use of or other interaction with the Platform shall be settled by binding arbitration in a location determined by the arbitrator as set forth herein (provided that such location is reasonably convenient for claimant), or at such other location as may be mutually agreed upon by the parties, in accordance with the procedural rules for commercial disputes set forth in the Comprehensive Arbitration Rules and Procedures of JAMS (“JAMS Rules and Procedures”) then prevailing, and judgment upon the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof. The arbitrator shall be selected pursuant to the JAMS Rules and Procedures. The arbitrator shall apply Illinois law consistent with the Federal Arbitration Act and applicable statutes of limitations and shall honor claims of privilege recognized at law. In the event that the claimant is able to demonstrate that the costs of arbitration will be prohibitive as compared to the costs of litigation, T71 will pay as much of the claimant’s filing and hearing fees in connection with the arbitration as the arbitrator deem necessary to prevent the arbitration from being cost-prohibitive. If any part of this arbitration provision is deemed to be invalid, unenforceable or illegal (other than that claims will not be arbitrated on a class or representative basis), or otherwise conflicts with the rules and procedures established by JAMS, then the balance of this arbitration provision shall remain in effect and shall be construed in accordance with its terms as if the invalid, unenforceable, illegal or conflicting provision were not contained herein. If, however, the portion that is deemed invalid, unenforceable or illegal is that claims will not be arbitrated on a class or representative basis, then the entirety of this arbitration provision shall be null and void, and neither claimant nor T71 shall be entitled to arbitrate their dispute. Upon filing a demand for arbitration, all parties to such arbitration shall have the right of discovery, which discovery shall be completed within sixty (60) days after the demand for arbitration is made, unless further extended by mutual agreement of the parties. THE ARBITRATION OF DISPUTES PURSUANT TO THIS PARAGRAPH SHALL BE IN YOUR INDIVIDUAL CAPACITY, AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING. THE ARBITRATOR MAY NOT CONSOLIDATE OR JOIN THE CLAIMS OF OTHER PERSONS OR PARTIES WHO MAY BE SIMILARLY SITUATED. DO NOT DOWNLOAD AND/OR USE THIS PLATFORM IF YOU DO NOT AGREE TO HAVE ANY CLAIM OR CONTROVERSY ARBITRATED IN ACCORDANCE WITH THESE OFFICIAL RULES.

FOR USERS OF THE PLATFORM WHO RESIDE OUTSIDE OF THE EUROPEAN UNION, BY DOWNLOADING, INSTALLING, USING, OR OTHERWISE INTERACTING WITH THE PLATFORM, YOU AGREE THAT TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW: (1) ANY AND ALL DISPUTES, CLAIMS AND CAUSES OF ACTION ARISING OUT OF OR CONNECTED WITH THE PLATFORM WILL BE RESOLVED INDIVIDUALLY THROUGH BINDING ARBITRATION AS SET FORTH ABOVE, WITHOUT RESORT TO ANY FORM OF CLASS ACTION; (2) ANY AND ALL CLAIMS, JUDGMENTS AND AWARDS WILL BE LIMITED TO ACTUAL THIRD PARTY, OUT-OF-POCKET COSTS INCURRED (IF ANY), BUT IN NO EVENT WILL ATTORNEYS' FEES BE AWARDED OR RECOVERABLE; (3) UNDER NO CIRCUMSTANCES WILL YOU BE PERMITTED TO OBTAIN ANY AWARD FOR, AND YOU HEREBY KNOWINGLY AND EXPRESSLY WAIVE ALL RIGHTS TO SEEK, PUNITIVE, INCIDENTAL, CONSEQUENTIAL OR SPECIAL DAMAGES, LOST PROFITS AND/OR ANY OTHER DAMAGES, OTHER THAN ACTUAL OUT OF POCKET EXPENSES), AND/OR ANY RIGHTS TO HAVE DAMAGES MULTIPLIED OR OTHERWISE INCREASED; AND (4) YOUR REMEDIES ARE LIMITED TO A CLAIM FOR MONEY DAMAGES (IF ANY) AND YOU IRREVOCABLY WAIVE ANY RIGHT TO SEEK INJUNCTIVE OR EQUITABLE RELIEF. SOME JURISDICTIONS DO NOT ALLOW THE LIMITATIONS OR EXCLUSION OF LIABILITY, SO THE ABOVE MAY NOT PLATFORMLY TO YOU.

T71 is neither willing nor obliged to participate in conciliation proceedings before a consumer mediation body within the European Union.

Governing Law & Jurisdiction: All disputes in connection with the Platform, shall be governed by, and construed in accordance with, the laws of the State of Florida, without giving effect to the conflict of laws rules thereof. Any matters or proceedings which are not subject to arbitration as set forth above and/or for entering any judgment on an arbitration award shall take place in the State of Florida in the state or federal courts in Florida and you consent to the exclusive jurisdiction of such courts. Laws in the country where the user of the Platform resides may give the user the right to file claims before the courts of that country and may provide that some laws of that country are also applicable to this Platform. However, if any provision of the Terms or the application of any such provision to any person or circumstance shall be declared to be invalid, unenforceable or void, such decision shall not have the effect of invalidating or voiding the remainder of the Terms, it being the intent and agreement of the parties that the Terms shall be deemed amended by modifying such provision to the extent necessary to render it valid, legal and enforceable while preserving its intent or, if such modification is not possible, by substituting, therefore, another provision that is valid, legal and enforceable so as to materially give effect to T71’s intent.

Severability

If any of these Terms shall be deemed invalid, void, or for any reason unenforceable, those terms shall be deemed severable and shall not affect the validity and enforceability of any remaining terms. Failure of T71 to exercise or enforce any right or provision of this Agreement shall not constitute a waiver of such right or provision in that or any other instance.

Modification of these Terms

We will notify you of changes to these Terms by posting the amended terms in this Platform, at least thirty (30) days before the effective date of the changes. If you have provided us with your email address or with consent to contact you via text message or other means, we will also notify you of material changes to these Terms via those means at least thirty (30) days before the effective date of the changes to the address/number you most recently provided to us. We encourage you to keep the contact information you provide to us current and to promptly notify us of any changes, so that you may receive any notices we send to you regarding material changes to these Terms. If you do not agree to any changes, you should stop using the Platform, and if you are a registered user, you may cancel your account with us within the thirty (30) day period by contacting us at This email address is being protected from spambots. You need JavaScript enabled to view it. and you will not be bound by the new terms. Otherwise, the new terms will take effect after thirty (30) days.

Contact Us

If you have any questions, complaints or claims regarding the Platform or our privacy practices, you can email us at This email address is being protected from spambots. You need JavaScript enabled to view it..

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General Data Protection Regulation

What is GDPR?

The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union.

Who is involved with GDPR?

There are three main parties to the GDPR when collecting information on Treadstone 71.

First would be the individual providing their personal identifying information. Hereafter referred to as 'Data Subject'.

Second is Treadstone 71, aka the Consulting Company.

As Treadstone 71 collects student data for the use of setting up classes to manage registration for our training, we are determining what data is collected, how it is used, how long it is retained, and what access to the data the registrant is allowed.

Does GDPR really affect me?

Treadstone 71 does not provide legal advice as to whether or not the data you control on Treadstone 71 falls under the purview of GDPR (ie, "in-scope").
Treadstone 71 does provide the following information to assist you in determining for yourself if your data collection/retention is in-scope of GDPR and if so, how you meet what is required of you by GDPR.

First, GDPR does not use wording concerning 'citizen' or 'resident' when referencing a Data Subject. Depending on the situation, GDPR can apply to *any* person as a Data Subject.
Three significant points to consider if GDPR applies for a given Data Subject are the following:

  1. establishment of the Data Controller inside the EU
  2. establishment of the Data Processor inside the EU
  3. establishment of the Data Subject inside the EU, and as marketed too, was known as being in the EU by the Data Controller

Treadstone 71 is entirely US based. Thus (b) alone does not result in GDPR in-scope data yet the collection of data used for training is stored by a third party for registration purposes.

We use a US based Data Controller to collect and process data, while marketing their event to individuals in the US (or anywhere outside the EU), would find their data to not be GDPR in-scope.

The right to be informed.

The Data Subject must have readily transparent access to information describing how their personal data is used, stored and retained.
Treadstone 71 provides a written Privacy Policy.

The right of access

The Data Subject has the right to receive all personal data held by you concerning the Data Subject within 30 days of request.

The right to rectification

The Data Subject has the right to have their personal data updated. Treadstone 71 provides the tools through training registration partners PlanetReg and Teachable to allow for update of Data Subject data.
Either the Data Subject updates their own data via the 'edit' button on online confirmation headers.

Or you, the Data Collector, can update the Data Subject data via Registrant Review/Update Registration Information.

The right to be forgotten

The Data Subject has the right to have their personal data deleted.

Both registrant and event level 'data delete' functions are currently being developed to make this process simpler.

In the meantime, Treadstone 71 allows for full update of all Standard and Custom Questions where personally identifying information might be stored.

These fields can be updated to reflect no data, thus affecting a 'delete' of Data Subject data.

The right to restrict processing

The Data Subject has the right to have their personal data no longer be processed.

As the only Data Subject personal data processing occurring on Treadstone 71 post registration is for email purposes, this primarily would involve no emails being sent via the automated Treadstone 71 systems and also your own contact of them via email/mail/phone.

Treadstone 71 is targeting the partner services for an 'opt-out of processing' option.

Currently, updating the Data Subject email address to prevent contact via email would suffice.

The right to data portability

The Data Subject has the right to access their data in a format readily usable for other purposes.

Currently, you can download all data, including the Data Subject personal data, on a registrant via CSV file and provide that to them.

Contact us at This email address is being protected from spambots. You need JavaScript enabled to view it. you would like assistance with this.

To simplify this for you, Treadstone 71 is developing a 'download' button that will allow the registrant to do so themselves from the confirmation page.

The right to object
The Data Subject has the right to have you stop processing on their data for the purpose of direct marketing. Treadstone Treadstone 71 is targeting the partner services for an 'opt-out of processing' option.

Other Considerations

Aside from these defined 'rights' there are some additional aspects to GDPR that affect the data you collect on Treadstone 71.
Concerning the consent to process data by the Data Subject, GDPR Article 6 (1) provides the following six legal grounds for processing:

  1. the data subject has given consent to the processing of their personal data for one or more specific purposes;
  2. processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
  3. processing is necessary for compliance with a legal obligation to which the controller is subject;
  4. processing is necessary in order to protect the vital interests of the data subject;
  5. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  6. processing is necessary for the purposes of the legitimate interests pursued by a controller, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. This shall not apply to processing carried out by public authorities in the performance of their tasks.

The vast majority of Data Subject personal information input on Treadstone 71 would be covered by (a), as the Data Subject registers for an event, providing their personal data as part of the registration process for the purpose of event registration. This consent does not cover other marketing related contact, more on that below.

In the Treadstone 71 privacy policy a statement is included to which the Data Subject agrees that the data offered is processed for the specific purpose of the registration process.
As the needs and uses of data varies widely between events, you may determine it necessary to add some specific language in the Registration Information/Details sections of Setup/2.Layout concerning the data you are collecting.

(f) brings forth the instance when the Data Subject is a child (Child Data Subject).

Specific requirements across districts can vary when dealing with Child Data Subject data, of which the GDPR is only a part.

We suggest you collect personally identifying information of a child only when absolutely necessary.

If it is necessary to do so, at minimum, couple the collection of this data with a parental/guardian consent via a required Custom Question (Setup/3.Questions) or utilize the Waiver feature in this manner (Setup/3.Questions).

Consent for marketing

Processing Data Subject data for the purpose of marketing requires explicit consent if GDPR in-scope.

GDPR requires consent to receive marketing to be ‘freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.’

Thus an 'opt-in' checkbox that is not required to be checked and not pre-checked must be offered if you plan on using the Data Subject personal data in non-event-required marketing.
A Custom Question (Setup/3.Questions) can readily meet this requirement if worded correctly.

Note, the emails sent to registrants per the built-in partner registrant contact system (confirmation, reminder, follow- up survey) fall under Article 6(1)(a), as a specific purpose for the registration process for an event.
Treadstone 71 operates a secure data collection and storage system for what little data we collect. All data is collected on TLS secured pages on a secure dedicated server physically residing in the USA and is stored on a secure server physically residing in the USA.

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GDPR Notice - Agreement

What is GDPR?

The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union.

Who is involved with GDPR?

There are three main parties to the GDPR when collecting information on Treadstone 71.

  • First would be the individual providing their personal identifying information. Hereafter referred to as 'DataSubject'.
  • Second is Treadstone 71, aka the Consulting Company.

As Treadstone 71 collects student data for the use of setting up classes to manage registration for our training, we are determining what data is collected, how it is used, how long it is retained, and what access to the data the registrant is allowed.

Does GDPR really affect me?

Treadstone 71 does not provide legal advice as to whether or not the data you control on Treadstone 71 falls under the purview of GDPR (ie, "in-scope").

Treadstone 71 does provide the following information to assist you in determining for yourself if your data collection/retention is in-scope of GDPR and if so, how you meet what is required of you by GDPR.

First, GDPR does not use wording concerning 'citizen' or 'resident' when referencing a Data Subject. Depending on the situation, GDPR can apply to *any* person as a Data Subject.

Three significant points to consider if GDPR applies for a given Data Subject are the following:

  • (a) establishment of the Data Controller inside theEU
  • (b) establishment of the Data Processor inside theEU
  • (c) establishment of the Data Subject inside the EU, and as marketed too, was known as being in the EU by the Data Controller

Treadstone 71 is entirely US based. Thus (b) alone does not result in GDPR in-scopedata yet the collection of data used for training is stored by a third party for registration purposes.

We use a US based Data Controller to collect and process data, while marketing their event to individuals in the US (or anywhere outside the EU), would find their data to not be GDPR in-scope.

The right to be informed.

The Data Subject must have readily transparent access to information describing how their personal data is used, stored and retained.

Treadstone 71 provides a written Privacy Policy.

The right of access

The Data Subject has the right to receive all personal data held by you concerning the Data Subject within 30 days of request.

The right to rectification

The Data Subject has the right to have their personal data updated. Treadstone 71 provides the tools through training registration partners PlanetReg and Teachable to allow for update of Data Subject data.

Either the Data Subject updates their own data via the 'edit' button on online confirmation headers.

Or you, the Data Collector, can update the Data Subject data via Registrant Review/Update Registration Information.

The right to be forgotten

The Data Subject has the right to have their personal data deleted.

Both registrant and event level 'data delete' functions are currently being developed to make this process simpler.

In the meantime, Treadstone 71 allows for full update of all Standard and Custom Questions where personally identifying information might be stored.

These fields can be updated to reflect no data, thus affecting a 'delete' of Data Subject data.

 

The right to restrict processing

The Data Subject has the right to have their personal data no longer be processed.

As the only Data Subject personal data processing occurring on Treadstone 71 post registration is for email purposes, this primarily would involve no emails being sent via the automated Treadstone 71 systems and also your own contact of them via email/mail/phone.

Treadstone 71 is targeting the partner services for an 'opt-out of processing' option.

Currently, updating the Data Subject email address to prevent contact via email would suffice.

The right to data portability

The Data Subject has the right to access their data in a format readily usable for other purposes.

Currently, you can download all data, including the Data Subject personal data, on a registrant via CSV file and provide that to them.

Contact us at This email address is being protected from spambots. You need JavaScript enabled to view it. you would like assistance with this.

To simplify this for you, Treadstone 71 is developing a 'download' button that will allow the registrant to do so themselves from the confirmation page.

The right to object

The Data Subject has the right to have you stop processing on their data for the purpose of direct marketing. Treadstone Treadstone 71 is targeting the partner services for an 'opt-out of processing' option.

Other Considerations

Aside from these defined 'rights' there are some additional aspects to GDPR that affect the data you collect on Treadstone 71.

Concerning the consent to process data by the Data Subject, GDPR Article 6 (1) provides the following six legal grounds for processing:

  • the data subject has given consent to the processing of their personal data for one or more specificpurposes;
  • processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into acontract;
  • processing is necessary for compliance with a legal obligation to which the controller issubject;
  • processing is necessary in order to protect the vital interests of the datasubject;
  • processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in thecontroller;
  • processing is necessary for the purposes of the legitimate interests pursued by a controller, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. This shall not apply to processing carried out by public authorities in the performance of theirtasks.

The vast majority of Data Subject personal information input on Treadstone 71 would be covered by (a), as the Data Subject registers for an event, providing their personal data as part of the registration process for the purpose of event registration. This consent does not cover other marketing related contact, more on that below.

In the Treadstone 71 privacy policy a statement is included to which the Data Subject agrees that the data offered is processed for the specific purpose of the registration process.

As the needs and uses of data varies widely between events, you may determine it necessary to add some specific language in the Registration Information/Details sections of Setup/2.Layout concerning the data you are collecting.

(f) brings forth the instance when the Data Subject is a child (Child Data Subject).

Specific requirements across districts can vary when dealing with Child Data Subject data, of which the GDPR is only a part.

We suggest you collect personally identifying information of a child only when absolutely necessary.

If it is necessary to do so, at minimum, couple the collection of this data with a parental/guardian consent via a required Custom Question (Setup/3.Questions) or utilize the Waiver feature in this manner (Setup/3.Questions).

Consent for marketing

Processing Data Subject data for the purpose of marketing requires explicit consent if GDPR in-scope.

GDPR requires consent to receive marketing to be ‘freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.’

Thus an 'opt-in' checkbox that is not required to be checked and not pre-checked must be offered if you plan on using the Data Subject personal data in non-event-required marketing.

A Custom Question (Setup/3.Questions) can readily meet this requirement if worded correctly.

Note, the emails sent to registrants per the built-in partner registrant contact system (confirmation, reminder, follow- up survey) fall under Article 6(1)(a), as a specific purpose for the registration process for an event.

Treadstone 71 operates a secure data collection and storage system for what little data we collect. All data is collected on TLS secured pages on a secure dedicated server physically residing in the USA and is stored on a secure server physically residing in the USA.

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About TreadStone71

About TreadStone 71

Treadstone 71 is a woman and  veteran owned small business  exclusively focused on cyber and threat intelligence consulting, services, and training. We are a  pure play intelligence shop.

Since 2002, Treadstone 71 delivers intelligence training, strategic, operational, and tactical intelligence consulting, and research. We provide a seamless extension of your organization efficiently and effectively moving your organization to cyber intelligence program maturity. Our training, established in 2009, follows intelligence community standards as applied to the ever-changing threat environment delivering forecasts and estimates as intelligence intends. From baseline research to adversary targeted advisories and dossiers, Treadstone 71 products align with your intelligence requirements. We do not follow the create once and deliver many model. We contextually tie our products to your needs. Intelligence is our only business.

  • We use intuition, structured techniques, and years of experience.
  • We supply intelligence based on clearly defined requirements.
  • We do not assign five people to do a job only one with experience.
  • We do not bid base bones only to change order you to overspending.
  • We do not promise what we cannot deliver. We have walked in your shoes. We understand your pressures.

For highly defined cyber intelligence services that are expertly delivered, Treadstone 71 is the gold standard. Contact us at info@treadstone71 com.

Treadstone 71 Press Releases - In the News

Students and organizations taught (non-inclusively):

AIB, American Express, Capital One, NATO, Belgian Military Intelligence, Commonwealth Bank, Bank of America, ING, NCSC NL, American Electric Power, Nationwide, Battelle, Standard Chartered, Columbus Collaboratory, Anomali, Defense Security Services, PNY, Dell Secureworks, HPE Security, EclecticIQ, Darkmatter (AE), General Electric, General Motors, PNC, Sony, Goldman Sachs, NASA, DoD, East West Bank, Naval Air Warfare Center, VISA, USBank, Wyndham Capital, Egyptian Government, DNB Norway, Euroclear, Malaysian Cyberjaya, People's United Bank, Baupost Group, Bank of North Carolina, Cardinal Health, Huntington, L Brands, OhioHealth, Fidelity Investments, Citi, Citigroup, T. Rowe Price, Wells Fargo, Thrift Savings Plan, Discover, Equifax, Blackknight Financial Services, Schwab, GM, FRB, Intercontinental Exchange (ICE), Citizens Financial Group, Cleveland Clinic, Scottrade, MetLife, NY Life, Essent, Synchrony Financial, TD Ameritrade, First Citizens Bank, M&T Bank, Western & Southern, American National Bank of TX, National Reconnaissance Office, OCBC Bank Singapore, Spentera, FBI, W.R. Berkley, People’s United Bank, Stellar Solutions, Lockheed Martin, Harvard Pilgrim, Symantec, State of Florida, Deloitte, Ernst and Young, Mitsubishi UFG Trust and Banking Corporation, Target, Tri Counties Bank, Mass Mutual, Tower Research, Latham and Watkins LLP, Geller & Company, KeyBank, Northern Trust, Fannie Mae, BB&T, Blue Cross Blue Shield Michigan, Farm Credit Services of America, Aviation ISAC, Regions Financial Corporation, Intercontinental Exchange (The ICE), Vista Equity Partners, JP Morgan Chase, Archer Daniels Midland, Nacha, Barclays, Options Clearing Corporation (OCC), Expo2020, Abu Dhabi Smart Solution's and Services Authority, Merck & Co., Inc Nomura International, ING, Finance CERT Norway, iPipeline, BBVA, PenFED, Santander, Bank of America, Equifax, BNY Mellon, UBS Group, OCC, Verizon, Vantiv, Raymond James, Bridgewater Associates, Bank of America Merrill Lynch, BBVA, Promontory Interfinancial Network, Bank of Canada, Credit Suisse, HSBC, Church of Jesus Christ of Latter Day Saints, Ocean First Bank, International Exchange, Vista Equity Partners, Aetna, QBE Insurance Group, ACI Universal Payments, Betaalvereniging Nederland, Dutch Police, Motorola Solutions, Intel Corporation, Salesforce, Singapore Ministry of Defence, Australia and New Zealand Banking Group Limited (ANZ), National Australia Bank Limited, non-inclusively (as well as several other firms by proxy as they hire qualified intelligence professionals trained by Treadstone 71).

Leadership

Jeff Bardin is the Chief Intelligence Officer for Treadstone 71 with clients on 4 continents. In 2007, Jeff received the RSA Conference award for Excellence in the Field of Security Practices. His team also won the 2007 SC Magazine Award – Best Security Team. Jeff sits or has sat on the Board of Boston Infragard, Content Raven, Journal of Law and Cyber Warfare, and Wisegate and was a founding member of the Cloud Security Alliance. Jeff served in the USAF as a cryptologic linguist and in the US Army / US Army National Guard as an armor officer, armored scout platoon leader.

Mr. Bardin has extensive experience in cyber intelligence lifecycle services, program builds, targeted research and support, cyber counterintelligence services and analysis, deception planning, and cyber operations. He teaches Cyber Intelligence and Counterintelligence (Anonymity, Cyber Personas, Collection management, Clandestine Cyber HUMINT, Socio-Cultural Aspects of Intelligence, Critical Thinking, Cognitive Bias, Methods and Types of Analysis, Mitre ATT&CK, Structured Analytic Techniques, Analytic Writing, Briefings, and Dissemination), open source intelligence, strategic intelligence, operational/tactical/technical intelligence, and methods in media manipulation identification.

He has BA in Special Studies - Middle East Studies & Language from Trinity College and an MS in Information Assurance from Norwich University. Jeff also attended the Middlebury College Language School for additional language training. Mr. Bardin also spent two+ years studying Russian history, literature, political systems, and language. He lived and worked in the Mediterranean area, Europe, Australia, Singapore, Malaysia, the Persian Gulf Region, and the Kingdom of Saudi Arabia. Jeff was an adjunct instructor of master’s programs in cyber intelligence, counterintelligence, cybercrime and cyberterrorism at Utica College. Mr. Bardin has also appeared on CNN, CBS News Live, FoxNews, BBCRadio, i24News, BBN, and several other news outlets and has contributed bylines to Business Insider non-inclusively.

We started teaching these courses in 2009 and have continued to update and hone them while maintaining true to the intelligence community standards. We have since built cyber threat intelligence programs for Fortune 500 firms and government organizations on four continents while providing targeted research against adversaries and nation-states.

Treadstone 71:

We founded the company in 2002 and started creating cyber personas and infiltrating al-Qaeda sites collecting information and sharing it with various US-based organizations in 2004. In 2009-10, we started teaching Cyber Intelligence, Cyber CounterIntelligence and Cyber Crime courses at the master’s level at Utica College where we established the intelligence program. After three years of teaching at the academic level, we switched to the commercial space honing the courses to CIA/DIA style tradecraft as aligned to the cyber environment using the skills acquired in 2004. Since that time, we have continued to update the courses using real-world case studies as part of the training.

We have kept the company purposely small and now offer the training courses (www.treadstone71.com/cyber-intelligence-trainingand www.cyberinteltrainingcenter.com) as well as Cyber Threat Intelligence maturity assessments, strategic and program planning, active research, collection, and reporting.  We also perform Threat Intel Platform assessments, selection, and rollout activities for clients. We have clients in the US, EU, Australia, and Asia with active proposals in the Middle East. My personal background is as an Arabic Linguist (USAF / NSA), Russian Linguist, and CISO financial services, government contracts, insurance, and cybersecurity vendors. We have also acted as a critical resource for government CISOs in the past authoring their agency strategic plans, program plans and responding to Congressional inquiries on their behalf.

Jeff has spoken at RSA, NATO CyCon (Estonia), the US Naval Academy, the Air Force Institute of Technology, the Johns Hopkins Research Labs, Hacker Halted, Malaysian Cyberjaya, Secureworld Expo, Hacktivity (Budapest), IS2 Prague, London (RSA), ISSA, Security Camp (Cairo), and several other conferences and organizations.

Mr. Bardin has authored books and contributed chapters to several other books most recently Current and Emerging Trends in Cyber Operations from George Washington University. Recently edited and provided content for Understanding Computers: Today and Tomorrow by Deborah Morley, Charles S Parker - 11th edition (March 2006 release). Reviewer for Building an Information Security Risk Management Program from the Ground Up (Evan Wheeler), Author Chapter 33 Computer Information Security Handbook 5th Edition - SAN Security. Author Chapter on Satellite Security - Computer Information Security Handbook 6th Edition. Author - The Illusion of Due Diligence - Notes from the CISO Underground (April 2010 release).

Treadstone 71 is a pure play intelligence company focusing on targeted research of adversaries building in-depth dossiers recording methods, tactics, techniques, procedures, known associates, memberships and psychological profiles. We author Current, Research/Foundational, Advisories, STEMPLES Plus, and Estimative Intelligence reports. We create profiles of high value targets including ‘know your customer’ profiles delivering assessments and gaps in protections with recommendations and opportunities.

We are known for building Strategic Intelligence Programs from vision, mission, guiding principles, goals, objectives, 36-month plans, policies, procedures, process flows, SOPs, KPIs, CSFs, training and awareness programs for intelligence. We also help establish internal intelligence community programs from technical and tactical to operational and strategic including physical, competitive, business, and cyber.

Read more: About TreadStone71

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Contact Treadstone 71 Today for all your Cyber Intelligence needs.

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