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Privacy Notice

This Privacy Notice applies to the publicly accessible test Moodle site operated by Klippe Learning Kft. The site is used solely for technical testing purposes by selected users. It is not used for paid training services, official adult education activities, certification, billing, marketing, recruitment, customer relationship management, profiling, or automated decision-making.

Although the site is intended only for selected test users who register knowingly for testing purposes, it is publicly accessible. For this reason, Klippe Learning Kft. provides this minimal Privacy Notice to explain what personal data may be processed if a user registers or uses the test Moodle site.

1. Data Controller

Name of Data Controller: Klippe Learning Oktató és Szolgáltató Kft.
Registered office: 1123 Budapest, Győri út 20, 3rd floor, door 7, Hungary
Representative: Dr. Péter Tamás Balkányi
Contact email: hello@klippe.hu

Klippe Learning Kft. does not carry out activities that would require the appointment of a Data Protection Officer.

2. Purpose of Processing

Personal data is processed on the test Moodle site only for the following purposes:

• enabling selected test users to register and log in;
• operating the basic technical functions of the Moodle environment;
• testing Moodle functionality, course structure, interface settings, user flows, and related technical configurations;
• maintaining site security and preventing misuse.

3. Categories of Personal Data Processed

The following personal data may be processed when a user registers or uses the test Moodle site:

• name;
• email address;
• username;
• password in encrypted form;
• Moodle profile data voluntarily provided by the user;
• technical login and usage data generated by Moodle, including login time, activity logs, IP address, and browser or device-related technical information;
• test activity data created within Moodle, such as participation in test courses, test submissions, completion status, or other Moodle-generated activity records.

Users must not upload sensitive, confidential, or real learner data to the test Moodle site unless expressly requested for a specific testing purpose.

4. Legal Basis

The legal basis for processing is the legitimate interest of Klippe Learning Kft. under Article 6(1)(f) GDPR.

This legitimate interest is the operation, testing, maintenance, and security of the test Moodle environment. Processing is limited to the minimum data necessary for these purposes.

5. Retention

Personal data processed on the test Moodle site is retained only for as long as necessary for the testing purpose.

As a general rule, test user accounts and related Moodle activity data may be deleted when the relevant testing activity has ended, the test Moodle environment is reset, the user requests deletion, or the test site is discontinued, unless retention is necessary for legal, technical security, or dispute-resolution reasons.

6. Access, Processors, and Transfers

Personal data on the test Moodle site may be accessed only by authorised Klippe Learning Kft. personnel who need such access for the operation, configuration, testing, maintenance, or security of the Moodle environment.

No personal data from the test Moodle site is downloaded, exported, forwarded, sold, disclosed, or otherwise made available to third parties by Klippe Learning Kft., except where required by law or by a competent public authority.

For the purposes of this test Moodle site, Klippe Learning Kft. does not use additional external data processors for separate processing activities connected to test users’ Moodle data. If the technical hosting or infrastructure of the Moodle environment is provided by a contracted hosting or IT service provider, such provider may technically process data on behalf of Klippe Learning Kft. solely for hosting, maintenance, or infrastructure operation purposes. No independent use of the data is permitted.

No personal data from the test Moodle site is transferred outside the European Union by Klippe Learning Kft.

7. Special Categories of Data, Automated Decision-Making, and Profiling

Klippe Learning Kft. does not intentionally process special categories of personal data, carry out automated decision-making, or perform profiling on the test Moodle site.

8. Your Rights

You may request access to, correction of, deletion of, restriction of, or portability of your personal data. You may also object to processing based on the legitimate interest of Klippe Learning Kft.

To exercise these rights, or if you have any question about the processing of your personal data, contact Klippe Learning Kft. at hello@klippe.hu or by post at the registered office address above.

Klippe Learning Kft. will respond to such requests without undue delay and no later than within 30 days.

9. Complaints and Remedies

If you believe that your data protection rights have been infringed, you may lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information:

Name: Nemzeti Adatvédelmi és Információszabadság Hatóság
Website: naih.hu
Email: ugyfelszolgalat@naih.hu

You may also seek judicial remedy before the competent court.

10. Changes to this Privacy Notice

Klippe Learning Kft. may update this Privacy Notice from time to time. The current version will be made available on the test Moodle site or through another appropriate channel.