Yes, you can. When a manager who is based in the EU buys this training for another person or for several persons, those persons have to send me an email to explain that:
the invoice is paid (wait for the confirmation of your internal payment department or external paying agency).
you have bought the training for them. So, they should add your email and name.
they give me their permission to email them their access code.
In this way we act in line with the General Data Protection Regulation. By sending this email, I can give them quick access.