Privacy Policy
Last updated: December 12, 2025
1 Introduction
This Privacy Policy explains how eLearning23 (“we”, “our”, “us”) collects, uses, stores, and protects personal information when individuals interact with our website, products, Moodle plugins, and related services.
We provide LMS extensions, exam proctoring tools, student-teacher scheduling tools, and other educational technology products. Some of our tools operate inside an institution’s Moodle environment and process student assessment data.
We are committed to transparency and protecting the privacy of all users — including administrators, educators, and students.
2 Information We Collect
We collect information in two ways:
A. Information You Provide Directly
This includes:
- Name and contact information
- Account credentials
- Payment and billing information
- Communication preferences
- Technical support messages
- Business or institutional information when purchasing licenses
B. Information Collected Through Our Products and Moodle Plugins
Certain eLearning23 plugins process additional data to provide their functionality. The specific data depends on the plugin used.
1. Proctoring Pro (Online Exam Proctoring Plugin
When enabled by an institution, Proctoring Pro may collect:
- Periodic webcam images for presence verification
- Identity verification images (face matching via AWS Rekognition or BS Face Matching API)
- Exam-related activity logs (e.g., window focus changes, input activity)
- Timestamped events during assessments
- Technical device information (browser, OS, IP, session metadata)
Important:
All proctoring data is stored within the institution’s Moodle environment unless the institution configures otherwise. We do not use proctoring images or logs to train AI models.
2. Attendance by Face Plugin
This plugin may process:
- Face images submitted for attendance
- Cross-reference verification results
- Attendance timestamps
3. Alap Scheduler (Meeting Booking Plugin)
This plugin may process:
- Student and teacher names
- Availability schedules
- Booking information
- Meeting metadata (e.g., time, course, notes)
4. Interactive PDF Plugin
This plugin may process:
- Question responses within PDF activities
- Interaction data for activity progress
5. Coversheet Plugin
This plugin may process:
- Assignment metadata
- Student identifiers required to generate coversheets
6. Interview Plugin
This plugin may process:
- Interview scheduling information
- Responses recorded within the plugin
- Assessment notes
3How We Use Your Information
We use the information we collect to:
- Provide and maintain our products and services
- Enable core functionality of Moodle plugins
- Process transactions and send confirmations
- Provide identity verification when requested by institutions
- Respond to support requests and technical inquiries
- Improve our products and develop new features
- Comply with legal obligations
For plugins operating inside an institution’s LMS, we only process student data as required to deliver the functionality requested by the institution.
4 Information Storage & Processing Roles
A. Data Stored in Institutional Moodle Environments
Most plugin-generated data — including proctoring images, attendance records, interview data, activity logs, and assignment metadata — is stored directly within the institution’s Moodle server.
We do not store or transfer student assessment data to our own servers unless explicitly requested by the institution for troubleshooting.
B. Our Role Under GDPR
When an institution uses our Moodle plugins:
- The institution is the Data Controller
- eLearning23 is the Data Processor
We process data only according to the institution’s instructions and strictly for the purpose of providing the service.
5 Information Sharing
We do not sell or trade personal information.
We may share data in the following cases:
- With service providers who support operations (e.g., AWS Rekognition for identity matching, secure hosting partners)
- To comply with legal obligations, court orders, or regulatory requirements
- To protect rights, safety, or security
- As part of a business transfer, such as a merger or acquisition
All third-party providers are contractually obligated to protect user data and use it only for the intended purpose.
6 Biometric Data & AWS Rekognition
Some products (like Proctoring Pro or Attendance by Face) use facial recognition technologies only for identity verification or attendance validation.
- Facial images may be temporarily processed by AWS Rekognition
- AWS does not store these images beyond the processing request
- Facial data is not used for AI training
- eLearning23 does not store biometric templates or identifiers unless the client institution configures custom storage
Institutions are responsible for obtaining student consent where legally required.
7 Data Security
We implement technical and organizational measures, including:
- Encryption in transit (TLS)
- Secure API communication
- Access controls and authentication
- Isolation of customer environments
- Regular security audits
For Moodle plugins, additional protections are inherited from the institution’s LMS infrastructure.
8Data Retention
- Website account and billing information is retained as long as needed to provide services or comply with legal obligations
- Moodle plugin data (including proctoring images, attendance logs, activity logs, interview data, and scheduling information) is retained according to the institution’s settings and policies, not by eLearning23
When an institution deletes plugin data, it is removed from their LMS environment.
9 Your Rights
Depending on your region, you may have rights to:
- Access your personal data
- Request corrections or deletion
- Object to processing
- Request data portability
For student data stored in an institution’s Moodle environment, requests must be made through the institution, as they control the data.
10 Analytics & Advertising
We use tools such as Google Tag, Google Analytics, and Meta (Facebook) Pixel to understand website usage and improve our marketing. These tools may use cookies to collect non-sensitive information about how you interact with our site. We may use this data to show you relevant ads (retargeting) on Google, Facebook, and other platforms.
You can manage or disable these cookies through your browser settings or the ad preference settings provided by advertisement platforms.
11 Cookies and Tracking
Our website uses cookies and similar technologies to:
- Improve browsing experience
- Maintain login sessions
- Analyze website performance
You may disable cookies in your browser settings, but some features may not work properly.
12Third-Party Services
Our services may link to external websites or integrate with third-party platforms. This Privacy Policy does not apply to those services, and we are not responsible for their privacy practices.
13 Changes to This Policy
We may update this Privacy Policy from time to time. Any material changes will be posted on this page with an updated effective date.
14 Contact Us
If you have questions about this policy or our data practices, please contact:
- [email protected]
- www.elearning23.com
