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Data Processing Agreement (DPA)
This Data Processing Agreement (DPA) governs the processing of students' personal data by the platform provider on behalf of the Client (the data controller), in accordance with Art. 28 of Regulation (EU) 2016/679 (GDPR).
Parties
Controller (Client) — the entity purchasing a TherLMS platform licence, which processes the personal data of its students. Processor (Provider) — Maciej Nowak, 1 Clockhouse Mews, School Rd, Wrington, BS40 5NA Bristol, United Kingdom, e-mail: kontakt@therlms.pl.
1. Subject matter and nature of processing
The Processor processes personal data on behalf of the Controller solely to provide e-learning platform services (hosting of accounts, courses, learning progress, certificates, communication). The processing includes: identification data (first name, last name, e-mail address, username), training activity data (progress, quiz results, certificates), technical data (logs, IP addresses) and data necessary for payment processing (passed to the payment operator).
2. Duration of processing
Processing lasts for the duration of the licence agreement and, after its termination, until the data is deleted or returned in accordance with section 8, unless the law requires longer retention.
3. Controller's instructions and confidentiality
The Processor processes data solely on the documented instructions of the Controller, unless processing is required by EU or Member State law. Persons authorised to process the data have committed themselves to confidentiality.
4. Security measures (Art. 32 GDPR)
The Processor implements appropriate technical and organisational measures to ensure the security of the data, including: transmission encryption (SSL/TLS), access control, regular backups, security monitoring and incident response procedures.
5. Sub-processors
The Processor may use sub-processors (including the hosting provider, the payment operator Stripe, e-mail providers), informing the Controller thereof. The use of sub-processors is based on a contract imposing obligations consistent with this DPA. The current list of sub-processors is available upon the Controller's request.
6. Data subject rights
The Processor assists the Controller in fulfilling data subjects' rights (access, rectification, erasure, restriction, portability, objection), including by providing the relevant platform features and cooperating in the handling of requests.
7. Personal data breaches
The Processor notifies the Controller of a personal data breach without undue delay after becoming aware of it and assists the Controller in complying with the obligation to notify the supervisory authority and the data subjects.
8. Return and deletion of data
After the provision of services ends, the Processor deletes or returns to the Controller all personal data and deletes copies thereof, unless the law requires their retention. The Controller has the right to audit/verify the processing in justified cases.
Last updated: August 24, 2026