This policy explains what information FestMan Learning collects, why we collect it, who we share it with, how long we keep it, and the choices you have. It applies to the FestMan Learning website and to everything you do once you are signed in.
Where FestMan Learning decides why and how your information is used, it is responsible for that use and is your first point of contact.
Where an organisation such as an employer or a training provider enrolled you, that organisation decides what you are enrolled on, who supervises you and how long you keep your place. It is responsible for its own use of your records, and depending on how it uses the platform it may be responsible for them alongside us or in its own right. If you were enrolled by an organisation, read its privacy notice as well as this one.
Information you give us
You give us information directly when you create an account or use the platform:
- Account details such as your name, email address and password.
- Profile details you choose to add, such as a photo, a job title, a location or a short biography.
- Anything you write into the platform, including answers, project work, uploaded files, comments and messages to instructors.
- Details you provide when you contact support, apply for a programme, or confirm a payment.
You do not have to fill in optional profile fields, and you can edit or clear them at any time from your account settings. Some fields are required to create an account or to take payment, and the platform will tell you which.
Information we collect as you learn
The platform records your progress so it can show you where you are, and so your instructors can support you. This includes:
- Which courses, learning paths, virtual experiences, assignments and certifications you have started or finished.
- Attempts, answers, scores, points, badges and completion dates.
- Assignment submissions and the files attached to them, together with any grade or feedback an instructor records.
- Attendance where a programme runs live sessions.
- Certificates and credentials issued to you.
Instructors and administrators for your organisation can see this activity for the learners they are responsible for. Other learners cannot, apart from a leaderboard position where your organisation has enabled one.
Information collected automatically
When you visit the platform we receive some technical information, such as your IP address, browser type, device type, the pages you open and the time you opened them. We use this to keep the service running, to keep accounts secure and to diagnose faults.
We also use error monitoring, which records the technical details of a crash or failure so we can fix it. We take reasonable steps to strip authentication tokens and similar secrets from those reports before they are sent.
Payments
Where the platform charges for access, payments are handled by a third-party payment provider. Your card details are entered on the provider's systems and are never stored by us. We keep a record of the plan you bought, the amount, the date and the reference the provider returns, so we can give you the access you paid for and answer billing questions.
Where your organisation pays on your behalf, or where you upload proof of a bank transfer for an administrator to approve, we keep that record for the same reasons.
How we use your information
We use the information described above to:
- Create and secure your account and sign you in.
- Give you access to the courses and programmes you are entitled to.
- Record your progress, mark your work and issue certificates.
- Let your instructors and administrators support you and report on their cohorts.
- Send you service messages such as confirmations, reminders, grade notifications and password resets.
- Take payment and manage subscriptions.
- Keep the platform reliable, investigate faults, prevent abuse and enforce our terms.
We do not sell your personal information, we do not share it for cross-context behavioural advertising, and we do not use your learning activity to build advertising profiles.
Our legal grounds for using your information
Where data protection law requires us to name a legal ground, these are the ones we rely on:
- Performance of a contract, for running your account, giving you the access you or your organisation paid for, marking your work and issuing your certificates.
- Legitimate interests, for keeping the platform secure and reliable, preventing abuse and diagnosing faults. We weigh those interests against your rights and use the least intrusive option that works.
- Consent, for promotional messages. You can withdraw it at any time, and withdrawing it does not affect what we did before you withdrew it.
- Legal obligation, for keeping financial records and for responding to lawful requests.
AI features
Parts of the platform use third-party AI models, for example to help an instructor draft course material, or to answer a learner's question about the lesson in front of them.
When you use one of these features, the text needed to answer you is sent to the model provider. For the lesson assistant that is the content of the lesson and the question you asked, and what you ask it is never used to grade you.
We configure our paid AI API services so submitted content is not used for model improvement. Providers may retain prompts and responses temporarily for security, abuse monitoring and legal compliance. We do not save lesson-assistant conversations to your platform account after the session ends.
We never send model providers your password, your payment details, or the personal details of other learners.
Messages we send you
There are two kinds of message, and they work differently:
- Service messages are part of your account: confirmations, password resets, enrolment and cohort notices, deadline and session reminders, grades, receipts and subscription notices. You cannot opt out of these while your account is open, because they are how the platform tells you what is happening to your own learning.
- Promotional messages tell you about new programmes and offers. Every one of them carries an unsubscribe link, and unsubscribing stops them without affecting your account or your service messages.
You can also ask us to stop sending promotional messages at support@festman.io.
Personalisation and automated decisions
We use your progress to personalise what the platform shows you, such as which course to suggest next and which reminder is worth sending. Instructors may also see a flag where a learner appears to be falling behind, so that a person can decide whether to reach out.
We do not make decisions that produce a legal or similarly significant effect on you by automated means alone. Grades awarded by an instructor are decided by that instructor, and an automatically scored assessment can be reviewed by one on request.
Where information is held
Our hosting, storage, email and AI providers operate internationally, so your information may be stored or processed in a country other than your own, including countries whose data protection law differs from yours.
Where information leaves a region that restricts transfers, we rely on the protections recognised for that purpose, such as standard contractual clauses in our agreements with those providers, or a finding that the destination country offers adequate protection.
How long we keep information
We keep information only as long as there is a reason to:
- Account and learning records, for as long as your account is active, because they are the record of what you have completed and what you have been awarded.
- Payment and invoice records, for the period tax and accounting law requires, which is commonly up to seven years.
- Technical logs and error reports, for a short period while they are useful for diagnosing and preventing faults.
- Lesson assistant conversations, only for the length of your session.
If your account is closed, we delete or anonymise your personal details. Certificates that have already been issued and made publicly verifiable may remain verifiable, since their purpose is to prove that an award was made. Where a claim or legal obligation requires it, we keep what is needed for as long as that lasts.
Your choices and your rights
Depending on where you live, you may have the right to:
- Ask for a copy of the information we hold about you.
- Have inaccurate information corrected.
- Have information deleted where there is no longer a reason to keep it.
- Receive the information you gave us in a portable form, or have it sent to another provider where that is technically possible.
- Object to, or ask us to restrict, uses that rely on our legitimate interests.
- Withdraw a consent you gave, including for promotional messages.
You can edit most of your details yourself from your account settings. To make any other request, write to support@festman.io.
We will respond within the time the applicable law allows, and we may need to confirm your identity first. If you are not satisfied with our answer, you may complain to the data protection authority in your country.
Security
We protect information with encryption in transit and access controls that limit each account to the records it is entitled to.
No system is completely secure. Please use a strong and unique password, and tell us at once if you believe someone else has used your account. If a breach affects your information and the law requires it, we will notify you and the relevant authority without undue delay.
Children
The platform is built for adult and professional learners. It is not directed at children under 13, and accounts must not be created for them. Organisations must not enrol them either. We do not knowingly collect information from a child under 13, and if we learn that we have, we delete it and close the account.
Where an organisation enrols learners who are above 13 but below the age of majority in their country, that organisation must obtain the consent its local law requires before doing so.
Changes to this policy
We may update this policy as the platform changes. The date at the top shows when it was last revised. If a change materially affects how we use your information, we will tell you through the platform or by email before it takes effect.
Contact us
To ask a question about this policy, exercise a right, or raise a concern, write to support@festman.io.