Legal

Privacy Policy

What personal data the platform processes, on what basis, who it is shared with, and what rights the people who train on it have.

Last updated 1 September 2026Version 1.0 — draft

7. How long we keep it

DataRetention
Account and profileWhile the account is active; deleted N days after deactivation
Progress and assessment resultsFor the term of the contract with the organisation, plus N years as proof of compliance
Certificates and verification recordsN years — a certificate is useless if it can no longer be verified
Audit and security logsN months
Technical and error logsN days
Billing and accountingThe applicable statutory period, 10 years

Once those periods end, data is deleted or irreversibly anonymised. Aggregate statistics that no longer identify anyone may be kept.

8. How we protect it

  • Encryption in transit (TLS) and at rest in the database and file storage.
  • Tenant isolation — an organisation reaches only its own data, enforced in the API and not just in the interface.
  • Role-based access control on least privilege, with stronger authentication on administrative accounts.
  • Audit logs of sensitive actions, recording who, when and the previous value.
  • Penetration testing and security review before each major release, following the OWASP Top 10.
  • Regular backups with tested restores, and monitoring with real-time alerting.

If a personal data breach occurs that poses a risk to individuals, we notify the responsible organisation without undue delay so that it can meet its own notification duties within the statutory deadlines.

9. Your rights

Under the GDPR and Cabo Verdean data protection law, you have the right to:

  • Know what data we hold about you and get a copy.
  • Correct inaccurate or incomplete data.
  • Ask for erasure, where there is no ground to keep it.
  • Ask us to restrict processing, or object to it where it rests on legitimate interest.
  • Receive your data in a structured, commonly used format and have it sent to another controller.
  • Withdraw consent at any time where processing relies on it, without affecting what was lawful before.
  • Lodge a complaint with a supervisory authority.

If your account belongs to an organisation, send your request to that organisation. If it reaches us directly, we pass it on and tell you we have. We respond within one month, extendable by two months in complex cases.

Supervisory authorities: in Cabo Verde, the Comissão Nacional de Protecção de Dados; in the European Union, the authority where you live or work.

10. Automated decisions

Multiple-choice assessments are marked automatically, but against an answer key written by people, and an administrator can review a result manually, with that change recorded. Course recommendations are based on training history and have no legal effect on you.

We make no solely automated decisions with legal effects on you. What your organisation decides on the basis of results — promotion, performance review — is its decision, not ours.

11. Children

The platform is built for professional and institutional settings and is not intended for anyone under 16. If an organisation uses it to train minors, it must ensure the proper legal basis, including the consent of the holder of parental responsibility where required.

12. Cookies

Our use of cookies and similar technologies is described in the Cookie Policy.

13. Changes to this policy

If we change this policy materially, we tell you by email and by notice in the platform before it takes effect. The date at the top always shows the last update, and we keep earlier versions available on request.

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