Full policy

Privacy Policy for the Learning Management System (Moodle)

1. Data Controller

The data controller responsible for the processing of personal data within this learning management system (LMS) is:
in line consult
Brauerriege 2, 58339 Breckerfeld, Germany
reichberg@in-line-consult.de

If you have any questions regarding data protection or wish to exercise your rights under the GDPR, please contact us at:
reichberg@in-line-consult.de

2. Hosting

The LMS is hosted by Lima-City, a hosting provider located in Germany. All data processing takes place on servers within the European Union.

3. Purpose of Data Processing

Personal data is processed exclusively for the following purposes:

• Account creation and management,
• Provision and use of learning content,
• Communication between participants and course instructors (e.g., via forums),
• Fulfillment of contractual obligations with the customer (Asian Development Bank).

4. Legal Basis

The legal basis for the processing of personal data is:

• Art. 6(1)(b) GDPR (performance of a contract),
• Art. 6(1)(f) GDPR (legitimate interest in the secure, functional operation of the platform).

5. Types of Data Processed

The following types of personal data may be processed:

• Name, email address, username,
• Learning activities (e.g., progress, login data),
• IP address and technical usage data (e.g., browser type, access time),
• Forum posts and other user-generated content.

6. Data Transfers to Third Countries

Users may access the platform from non-EU countries (e.g., in Asia). However, data processing is exclusively carried out by the platform operator within the EU. No active transfer of personal data to third countries takes place.

7. Data Retention

Personal data is stored for as long as necessary to fulfill the contractual purposes. After the course ends or upon request, data will be deleted unless legal retention obligations apply.

8. Recipients of the Data

Data may be shared with:

• Lima-City as the hosting provider (under a data processing agreement in accordance with Art. 28 GDPR),
• Email providers for system-related communication (e.g., forum notifications),
• Tutors and course administrators, who have access to participant data (e.g., name, email, course progress) as part of their instructional duties.

No data is passed on to any other third parties.

9. Rights of Data Subjects

Users have the following rights under the GDPR:

• Right of access (Art. 15),
• Right to rectification (Art. 16),
• Right to erasure (Art. 17),
• Right to restriction of processing (Art. 18),
• Right to data portability (Art. 20),
• Right to object (Art. 21),
• Right to lodge a complaint with a supervisory authority.

10. Data Security

The platform employs technical and organizational measures to ensure the security of personal data. The connection is encrypted via SSL/TLS, and access is restricted to authorized users only.

11. Changes to This Policy

This privacy policy may be updated to reflect legal or technical changes. The current version is permanently available on the platform.

12. External Links

This platform may contain links to external websites operated by third parties (e.g. educational content, videos, documents).
We have no influence on the content or data protection practices of those websites.
When users click on an external link, they leave our platform and are subject to the privacy policies of the respective third-party provider. We recommend reviewing those policies before using their services.

13. Copyright and Usage Restrictions

All course materials provided within this platform, including but not limited to texts, graphics, documents, and videos, are protected by copyright.
The content is created and provided by a team of contracted authors and technical developers on behalf of the Asian Development Bank (ADB).

Use of the content is strictly limited to the purpose of course participation within this learning management system.
Unless explicitly permitted in writing by the authors or the ADB, users are not allowed to download, reproduce, distribute, or use course content for any purpose beyond the scope of this course.