In short
- We process only the data needed for your account, training, communication, invoicing and security.
- We do not sell personal data, do not show ads and do not use analytics or tracking tools, neither on the website, nor in the platform, nor in the mobile app. The app only sends reports about its own errors, without data that identifies you.
- NexiLMS Cloud data is hosted in Germany, in the European Union.
- If your organization created your account, it decides what data is processed for training, and we process that data on its behalf.
- You can download your data and delete your account directly in the settings or in the app. Details on the Account deletion page.
Who we are and how to contact us
NexiLMS is jointly administered by S.C. “Internet Consulting” S.R.L. (IDNO 1005600039866) and GRANDIOLE S.R.L. (IDNO 1023605001826), both with their registered office at str. Florilor 12/A, of. 15D, Chișinău, MD-2068, Republic of Moldova (“we”).
For the processing described here in which we act as controller, the two companies are joint controllers: they jointly determine the purposes and means of processing. We have agreed that Internet Consulting is the point of contact for data subjects and handles requests. You can exercise your rights against either of the two companies.
What this policy covers
- the nexilms.com website and its contact form;
- the NexiLMS Cloud platform, including organizations’ dedicated addresses;
- the NexiLMS mobile app for iOS and Android;
- support, demos, orders and invoicing.
NexiLMS installations on an organization’s own server are operated by that organization. Its own privacy policy applies to them; the section Installations on your own server explains what data we receive.
We comply with Law No. 195/2024 on personal data protection of the Republic of Moldova and, where applicable, the EU General Data Protection Regulation 2016/679 (GDPR).
Our role: controller or processor
We are the controller for the data of website visitors, people who write to us, customers and their representatives, accounts created directly on the platform, invoicing and the security of the services.
We are a processor for the data that a customer organization or course creator manages in its own space: its employees, learners, courses and their results. In this case the organization or creator is the controller. They decide who gets an account, which courses are assigned and which reports are produced, and we process the data only on their instructions, under the contract and, on request, a data processing agreement.
If your organization created your account, please contact it first with questions about training. If you write to us, we will forward your request to the organization and help it respond.
What data we process
| Category | Data | Source |
|---|---|---|
| Account and profile | first and last name, email, password (stored only as a cryptographic hash), country, language, role; optional: phone, profile photo, job title, department, branch, groups, mentor, employment dates; for creators, the public profile | you or your organization (including via import from Excel, iSpring or another LMS) |
| Sign-in | the identifier and email of your Google, Apple or organization SSO account, if you use one; two-step verification settings | Google, Apple or your organization’s identity provider |
| Training | enrolments and deadlines, progress, active time in lessons, test attempts and answers, SCORM data, practical assignments and feedback, certificates, attendance at events and webinars, points and leaderboards, internal documents read | generated when you use the platform |
| Communication | chat messages and files, lesson questions, comments, notifications | you and other users |
| Webinars | display name, join and leave times, duration of participation; for those who turn on their camera, microphone or screen sharing, the video, audio and screen transmitted in real time | generated during the webinar |
| Orders and invoicing | name or company name, address, IDNO or tax code, VAT number, email, orders, invoices and payments | the customer |
| Technical and security data | IP address and browser of active sessions; sign-in history (method, device type, browser, operating system); log of administrative actions; server logs | generated automatically |
| Consents | the version of the documents accepted, the date, your choices about marketing communications | you |
| Contact form | name, email, phone, organization, its type and size, selected interests, your message | you |
We do not ask for or intentionally process sensitive data such as health data, religious beliefs or biometric data. Please do not include such data in messages, answers or files.
The NexiLMS mobile app (iOS and Android)
The app uses the same account and the same data as the platform. In addition, it processes only what is needed for it to work on your phone or tablet:
| Access or data | When and why |
|---|---|
| Notifications | if you allow them: assigned courses, deadlines, events and webinars, messages, news from your organization; you can choose the types in your account settings. They are delivered through Apple Push Notification service and Google Firebase Cloud Messaging, using a device notification identifier, stored together with the platform (iOS or Android), the app version and whether notifications are allowed. The app icon shows the number of unread notifications. |
| Camera and microphone | only when you turn them on in a webinar or a live session, for example as a presenter. The system asks for your permission the first time. |
| Photos and files | only the files you choose: your profile photo, a practical assignment, a chat attachment. |
| Downloads | files you choose to download (for example certificates or course materials) are saved on the device or opened with the app you choose. |
| Device information | model, operating system version, app version and language, for compatibility, security and the list of active sessions. |
| Storage on the device | sign-in data (the platform’s session cookies), the list of organizations you have connected to and app preferences, kept in the app’s private storage, which other apps cannot access. Sign-in data is deleted when you sign out, everything else when you uninstall the app. |
| Choosing the organization | the organization code or platform address you enter in the first step is sent to our central server, which replies with the organization’s name, logo and address. If you first sign in with Apple or Google, the central server looks up the NexiLMS Cloud organizations where you have an account, so that it can connect you directly. |
| Invitation links | if you open an invitation link before you have the app, the app continues the invitation after installation, without you entering any codes. On Android, Google Play passes the invitation parameter to the app. On iPhone, the invitation page copies the link to the clipboard and the app reads it once, at first launch, with iOS’s permission; in addition, when the invitation is opened our server records the IP address, model and system version of the device, to match them at the app’s first launch. This data is deleted after at most 24 hours. |
| Error reports | if the app stops unexpectedly, it sends a report through Google Firebase Crashlytics: the device model and system, the app version, the time and place in the app’s code where the error occurred, the memory state and a random installation identifier. The report does not contain your name, email, account or page content and is not used for tracking or advertising. |
The app does not collect your location, contacts or advertising identifier, contains no ads and no third-party analytics or tracking tools, and does not track you across other apps or websites. The only diagnostic service is the error reporting described above. You can withdraw permissions at any time in the device settings; the related features will no longer be available, while the rest of the app keeps working.
If you have allowed your device to share diagnostic data with developers, Apple or Google may provide us with crash reports for the app, without identifying data.
The window in which you can rate the app is shown by the App Store or Google Play. Your rating and review go directly to Apple or Google and are published in the store under their rules.
The app connects to the organization’s NexiLMS installation chosen in the first step. If it runs on your organization’s server, the data goes directly there and the organization is its controller; only notifications pass through our server so that they can reach Apple and Google (see Installations on your own server).
Why we process data and on what legal basis
| Purpose | Legal basis |
|---|---|
| Creating and managing your account, sign-in, access to courses, tests, certificates, webinars and chat | performance of the contract; for accounts created by organizations, the organization’s instructions, based on its own legal basis (for example, the employment contract or a legal training obligation) |
| Notifications and emails about activity in your account: assignments, deadlines, results, password reset | performance of the contract |
| Public verification of certificates by their number | performance of the contract and the legitimate interest of the holder and of those verifying the certificate |
| Replying to messages sent through the form, by email or phone; offers and demos | steps prior to entering into a contract and our legitimate interest in answering requests |
| Marketing communications about news and offers | your consent, which you can withdraw at any time |
| Invoicing, accounting, e-Factura and responding to requests from authorities | legal obligation |
| Security: protecting accounts, preventing fraud and abuse, logs and backups | legitimate interest in protecting users and the services |
| Technical support, including support access to an account | performance of the contract and legitimate interest in solving reported problems |
| AI translation of courses, at the author’s request | performance of the contract, on the customer’s instructions |
| Keeping the platform working correctly and quickly, based on technical logs | legitimate interest in maintaining and improving the service |
| Finding the organization by its code, continuing invitations after the app is installed and delivering notifications in the app | performance of the contract and the steps you take to join your organization; for matching the invitation on iPhone, our legitimate interest in sparing you from entering codes |
| Keeping the mobile app stable, based on error reports | legitimate interest in fixing errors and keeping the app working |
Where the basis is legitimate interest, we have checked that it does not override your rights. You can object to this processing at any time (see Your rights).
For support access, a platform administrator can enter a user’s account only to solve a problem. The access ends automatically after at most 30 minutes, is logged, and the account holder receives a notification.
Who we share data with
We do not sell or rent personal data. We share it only in the situations below.
Within your organization and the platform
- Your organization’s administrators and managers see training data within the limits of their role.
- Colleagues may see your name and photo in chat, in webinars and, if your organization uses them, in leaderboards.
- Anyone with a certificate number can check the holder’s name, the course and the issue date on the verification page.
- A course creator’s public profile is visible to everyone if the creator enables it.
Providers who help us (processors)
| Provider | What it does | Where |
|---|---|---|
| Hetzner Online GmbH | data centres where the servers and backups run | Germany (EU) |
| Anthropic PBC, OpenAI | AI translation, only at the author’s request and only for the course text | USA |
| Apple, Google | sign-in with your Apple or Google account, if you choose it; delivery of notifications in the mobile app; passing the invitation on installation from Google Play; the app’s error reports (Google Firebase Crashlytics) | USA and other countries |
Platform emails are sent from our own server, without an external email service. Our contracts ensure that providers protect data at least to the level described in this policy and use it only for the services they provide to us.
Other recipients
- Services chosen by your organization: the SSO identity provider, integrations configured via API or webhooks, external webinar platforms (Google Meet, Zoom, Microsoft Teams, Jitsi) and videos embedded in lessons.
- Banks, for payments, and the State Tax Service, through the e-Factura system.
- Public authorities, courts and lawyers, where the law requires it or to defend a legal claim.
- A possible successor in the event of a reorganization or sale of the business, with the same safeguards.
International transfers
NexiLMS Cloud data is hosted in the European Union. Our team accesses it from the Republic of Moldova for administration and support. For customers and users to whom the GDPR applies, this access and transfers to providers in the USA are based on the Standard Contractual Clauses approved by the European Commission or, where applicable, the provider’s certification under the EU-U.S. Data Privacy Framework. On request, we will send you a copy of the safeguards applied.
How long we keep data
| Data | How long we keep it |
|---|---|
| Account and profile | as long as the account is active. When the account is deleted, identifying data is deleted or anonymized immediately. |
| Accounts created by an organization | as long as the organization uses NexiLMS or until the organization deletes the account. When an employee leaves, the organization can deactivate the account and keep the training history for its records. |
| Training results | as long as the account exists. After the account is deleted, they remain only in the organization’s reports, without identifying data. |
| Issued certificates | kept for verification, including the name printed on the certificate. You can ask at any time for your certificates to be cancelled. |
| Chat messages | as long as the conversation exists. After the account is deleted, messages sent remain visible to the other participants as messages from a deleted user. |
| Active sessions (IP, browser) | until you sign out or at most 12 months from last use |
| Sign-in history | 13 months |
| Server logs | 14 days; slow-page log, 30 days |
| Log of administrative actions | as long as the organization uses NexiLMS, for security and to prove who changed what |
| Import files and items in “Deleted” | 30 days |
| Orders and invoices | 6 years, under the accounting laws of the Republic of Moldova |
| Proof of acceptance of terms and of consents | as long as the account is active and then as long as needed to prove them to an authority or court |
| Contact form messages | for the duration of the conversation and at most 3 years from the last message, unless we become partners |
| App notification identifier | until you sign out, uninstall the app or turn off notifications |
| Data used to continue an invitation on iPhone (IP address, device model and system) | at most 24 hours |
| App error reports | 90 days, then Google deletes them automatically |
| Notifications sent by installations on an organization’s own server | not stored on our server: handed over immediately to Apple or Google |
| Backups | replaced automatically; deleted data disappears from them within 30 days at most |
After a contract with an organization ends, the organization can export its data for 30 days. We then delete it from active systems within 30 days and from backups within a further 30 days, except for documents the law requires us to keep.
How we protect data
- All connections to the website, platform and app are encrypted (HTTPS/TLS).
- Passwords are stored only as cryptographic hashes. Access keys, two-step verification secrets and cookies are encrypted.
- You can enable two-step verification and view and end active sessions in your account settings.
- In most logs, the IP address is stored in pseudonymized form.
- Each organization sees only its own data, and access is limited by role.
- The servers are in ISO/IEC 27001-certified data centres, and data is regularly copied to separate storage.
- Uploaded files can be scanned for viruses, and SCORM packages run on a separate domain.
- Our team’s access is limited to the people who need it for administration and support.
If a personal data breach occurs that poses a risk to you, we notify the supervisory authority within 72 hours, and customer organizations and affected people without undue delay.
Your rights
You have the right:
- of access: to find out what data we process and receive a copy of it;
- to rectification: to correct inaccurate data, including directly in your profile;
- to erasure: to ask for your data to be deleted or delete your account yourself;
- to restriction: to ask for processing to be limited while we check a dispute;
- to data portability: to receive your data in a structured format; in Account settings → My data and account deletion you can download it at any time as a JSON file;
- to object: to processing based on legitimate interest and, at any time, to marketing;
- to withdraw consent, without affecting the lawfulness of earlier processing;
- not to be subject to a decision based solely on automated processing that produces legal effects concerning you;
- to lodge a complaint with a supervisory authority (see Contact and complaints).
Write to us at info@webconsulting.md. We respond free of charge within 30 days. For complex requests this period may be extended by two further months, in which case we will let you know. We may ask for additional information to confirm that the request comes from the data subject.
Deleting your account and data
You can delete your account at any time, without contacting us:
- on the web: Account settings → My data and account deletion → Delete account;
- in the mobile app: from the same account menu, Account settings → My data and account deletion → Delete account.
If you no longer have access to your account or have uninstalled the app, write to us at info@webconsulting.md. The full steps, what is deleted and what is kept are described on the Account deletion page.
Children
NexiLMS is intended for people aged 16 and over. We do not knowingly create accounts for younger children. If an organization trains people under 16, it obtains the consent of their parents or legal guardians. If you learn that a child has created an account without consent, write to us and we will delete it.
Automated decisions and artificial intelligence
The platform automatically grades tests with predefined answers, calculates progress and can automatically group users by criteria set by the organization. These calculations support training, but we do not make decisions with legal effects on you based on them. If your organization uses the results for personnel decisions, it is responsible for them and you can ask it for a review by a person.
Artificial intelligence is used only to translate course text, at the author’s request. We do not send learners’ data to AI providers and do not use it to evaluate you.
Installations on your own server
When NexiLMS runs on an organization’s server, the organization is the controller and the data stays on its infrastructure. The installation periodically sends us only technical data for updates: the address and version of the installation, the installation mode and the total number of users, groups and courses, without any data about users. We access the installation only at the organization’s request, for support.
If the organization’s employees use the NexiLMS mobile app, the organization’s installation sends notifications through our central server, which hands them over immediately to Apple or Google. For each notification we receive the device notification identifier and the notification’s title, text and link, without storing them; for this data we act as the organization’s processor. The central server also knows the installation’s name, logo and address, so that the app can find the organization by its code.
Changes to this policy
We update this policy when our services, providers or the law change. The version and effective date are shown at the top of the page. We will notify you of important changes by email or in the platform before they take effect.
The Romanian text is the reference version. The English, Russian and German translations are provided for convenience.
Contact and complaints
For any question about your data, write to us at info@webconsulting.md. We will try to resolve any concern together with you.
You also have the right to lodge a complaint with the supervisory authority:
If you live or work in the European Union, you can also contact the data protection authority of your country.