1. Scope

This Privacy Policy governs how AndeCore Learning collects, uses, stores, and protects personal data in connection with the use of Manifest LMS. Manifest LMS is the delivery platform through which AndeCore Learning provides educational content, and all data practices described herein are conducted in support of that purpose.

This Policy applies to all individuals who access or use the platform, including students, auditors, facilitators, administrators, and organizational users. It is intended to provide clarity regarding what data is collected, why it is collected, how it is used, and what rights users may have in relation to that data.

This Policy should be read in conjunction with the Analytics & Data Use Disclosure, which provides additional detail regarding system-level tracking and engagement data.

2. Legal Basis for Processing

AndeCore Learning processes personal data on several lawful bases, depending on the nature of the interaction with the platform.

Data may be processed on the basis of user consent, such as when a user creates an account, enrolls in a course, or agrees to receive communications. Data may also be processed as necessary to fulfill contractual obligations, including providing access to purchased courses, maintaining user accounts, and delivering platform functionality.

In addition, certain data processing activities are carried out under legitimate interest, including maintaining system performance, improving user experience, ensuring platform security, and supporting educational delivery. Where required, data may also be processed to comply with legal obligations.

No processing is conducted beyond what is reasonably necessary for these purposes.

3. Personal Data Collected

AndeCore Learning collects personal data that is necessary to operate the platform and deliver its services.

This may include identifying information such as a user’s name and email address, along with account-related data such as login credentials, role assignments, and organizational affiliations. The platform also collects learning-related data, including course enrollment, progress, completion status, and interactions with lessons and activities.

Transaction-related data may also be collected in connection with purchases, though payment information is processed through third-party providers and not stored directly by AndeCore Learning.

4. Use of Data

Personal data is used to provide, maintain, and improve the functionality of Manifest LMS.

This includes enabling user access to the platform, delivering course content, tracking progress and completion, and supporting communication between the platform and its users. Data is also used to process transactions, generate reports for authorized roles, and improve system performance and usability.

Data is not used for purposes unrelated to the educational and operational objectives of the platform. In particular, AndeCore Learning does not use personal data for advertising-based profiling or unrelated behavioral analysis.

5. Data Storage and Transfers

Personal data may be stored on servers located in jurisdictions appropriate to the operation of the platform and may be processed by third-party service providers acting on behalf of AndeCore Learning.

Where data is transferred across jurisdictions, reasonable safeguards are implemented to ensure that such transfers comply with applicable legal standards and protect user data from unauthorized access or misuse.

AndeCore Learning takes reasonable steps to ensure that all service providers handling data operate under appropriate confidentiality and data protection obligations.

6. User Rights

Depending on applicable law, users may have certain rights in relation to their personal data.

These rights may include the ability to access personal data held about them, request correction of inaccurate information, request deletion of data, restrict certain types of processing, or request a copy of their data in a portable format.

Requests to exercise these rights may be submitted through designated contact channels. All requests are subject to identity verification and applicable legal limitations.

7. Data Retention

Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected, including providing platform services, maintaining account functionality, complying with legal obligations, and supporting legitimate operational needs.

Retention periods may vary depending on the type of data and the context in which it was collected. Where data is no longer required, it may be deleted, anonymized, or archived in accordance with internal policies.

8. Third-Party Services

Manifest LMS relies on third-party services to support its functionality, including but not limited to payment processing, hosting, and communication systems.

These third-party providers operate under their own terms and privacy policies. While AndeCore Learning selects providers with appropriate standards, it does not control their independent data practices beyond the scope of contractual agreements.

Users are encouraged to review the policies of third-party services where relevant.

9. Changes to This Policy

This Privacy Policy may be updated from time to time to reflect changes in platform functionality, legal requirements, or operational practices.

Where changes are material, users may be notified in accordance with platform policies. Continued use of Manifest LMS after updates take effect constitutes acceptance of the revised Policy.