List of active policies

Name Type User consent
Privacy Policy Privacy policy All users


Last updated 10 February 2020

This Privacy Notice tells you how we, FABLAB FACTORY BVBA, will collect and use your personal data to provide our service which allows users, of any kind, to create and access courses and activities, all optimized for collaborative learning. The Moodle software is free and open source, and may be hosted by FABLAB FACTORY BVBA. This notice will tell you how FABLAB FACTORY BVBA uses your data.

Full policy


FABLAB FACTORY BVBA is a software company which allows users, of any kind, to create and access courses and activities, all optimized for collaborative learning. The Moodle software is open source, and may be hosted by FABLAB FACTORY BVBA.


Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

All data subjects whose personal data is collected, in line with the requirements of the GDPR. Since FABLAB FACTORY BVBA is hosting a website on its own behalf, it is the Data Controller for all the data collected.


In order for FABLAB FACTORY BVBA to provide you a personal learning experience with access to specific courses and course activities we need to collect personal data for correspondence purposes and/or to allow us to provide you our service(s). We are committed to ensuring that the information we collect and use is appropriate for this purpose. FABLAB FACTORY BVBA is a company which values its users’ data protection and privacy rights and we have no interest in collecting data beyond what we need to make our service(s) work for you.

If you are going to be contacted by us for marketing purposes, we will not rely solely on this notice, but will always seek an additional confirmation from you that it’s ok to do that.

In general we collect personal data relating to you for specific purposes, with the nature of the data collected depending on your interaction with FABLAB FACTORY BVBA. We are committed to transparency in this and have provided a very detailed breakdown of these processes in Annex 1 of this Privacy Notice.

Our legal basis for the processing of personal data are:

    • Article 6.1(a), GDPR, Consent
    • Article 6.1(b), GDPR, Contract
    • Article 6.1(f), GDPR, Legitimate Interest

Any legitimate interests pursued by us, or third parties we use, are as follows:

    • recruitment and Induction of new Candidates
    • emergency Contacts for people who work with us, such as employees and contractors for health and safety purposes.
    • business Development

The special categories of personal data concerned are:

    • biometric Data in the form of facial images
    • health Data in respect of employees, contractors and other people who work with us
    • any special categories of special personal data which any user volunteers while using the Moodle systems (for example in a forum or submission)


We may pass your personal data on to third-party service providers contracted to FABLAB FACTORY BVBA in the course of dealing with you. We do this because there are some services, such as our video conferencing facility, which will not work unless we are able to make these transfers. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to deliver the service they provide on our and of course, your behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with FABLAB FACTORY BVBA’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, or if it is necessary to comply with an employment contract, or we are legally required to do so. If you would like an up-to-date register of all our third-party service providers, please contact and we will be happy to provide it.


FABLAB FACTORY BVBA will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. FABLAB FACTORY BVBA maintains a register of its data processes which includes a record of the data retention policy for each type of data collected and is committed to only ever trying to process the minimum amount of data needed. FABLAB FACTORY BVBA is required to retain certain information in accordance with the Law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.


FABLAB FACTORY BVBA at your request, can confirm what information we hold about you and how it is processed. If FABLAB FACTORY BVBA does hold personal data about you, you can request the following information:

    • identity and the contact details of the person or organisation that has determined how and why to process your data.
    • contact details of our data protection officer in the EU, where applicable.
    • the purpose of the processing as well as the legal basis for processing.
    • if the processing is based on the legitimate interests of FABLAB FACTORY BVBA or a third party, information about those interests.
    • the categories of personal data collected, stored and processed.
    • recipient(s) or categories of recipients that the data is/will be disclosed to.
    • if we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely.
    • the EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information. These will rely on measures approved by the EU Commission.
    • how long the data will be stored.
    • details of your rights to correct, erase, restrict or object to such processing.
    • information about your right to withdraw consent at any time.
    • how to lodge a complaint with the relevant supervisory authority.
    • whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
    • the source of personal data if it wasn’t collected directly from you.
    • any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.


FABLAB FACTORY BVBA accepts a request made through a Moodle account while the person making the request is logged in. In certain circumstances FABLAB FACTORY BVBA could ask for additional information and the following forms of ID when information on your personal data is requested:

    • A colour copy of a Passport, driving licence or National ID Card


By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Where consent is required for FABLAB FACTORY BVBA to process both standard and sensitive types of personal data, it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used. Agreement with this Privacy Notice and its accompanying terms and conditions (as applicable) (and any Data Processing Agreements, if they apply to you) will be considered to be explicit consent and we will keep a copy of the records of that consent for audit purposes.

You may withdraw consent at any time by:

  • Learn Make Share:

Please identify your role in relation to Moodle, and the data you wish to withdraw consent to be processed.


FABLAB FACTORY BVBA will processes different forms of personal data for as long as is necessary and proportionate for the purpose for which it has been supplied and will store the personal data for the shortest amount of time possible, taking into account legal and service requirements. For further details on the retention period for any particular type of data, please contact


At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • right of access – you have the right to request a copy of the information that we hold about you.
  • right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • right to object – you have the right to object to certain types of processing such as direct marketing.
  • right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • right to judicial review: in the event that FABLAB FACTORY BVBA refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in the section named “Complaints” below.

You may make a request directly to the Data Protection Officer using the email address


Purpose of processing

Categories of personal data

The source of the personal data

Individual’s Profile on Moodle Partner site

Contact details

Data subject and data subject employer

Individual’s data on Moodle Partner website

User and activity data

Data subject, Controller

Partner Marketing Support

Partner details, Location, Date, Times

Data subject

Partner Marketing Support

Client details, Partner details

Data subject, data subject employer, Partner organisation

Partnership support conference calls

Name, Voice Recording, Video/Photograph of user

Moodle HQ – Moodle Partner Site Data

Partner Organisation Profile on Moodle Partner site

User details, Partner Organisation details

Partner Organisation provides info and manages it

Partnership team commercial discussion about Partners and sectors

HQ Organisation details, Partner Organisation details, names, emails, addresses

Controller(s) – Moodle Pty Employees (Moodle HQ) and for contractors -themselves or company

Partnership team business development discussion

Partner Organisation details

Controller(s) – Moodle Pty Employees (Moodle HQ) and for contractors -themselves or company.

Moodle HQ team communication

Contact details and any other as comes up in emails


Moodle HQ team communications

Contact details


Moodle Client Customer financial data from Partners

Client details, Partner details


Lead / Customer Information

Contact Details

Data Subject

Writing and storage of agreements/contracts/documentation with partners, and potential partners

Contact Details

Moodle Partner / Applicant

General Business Documentation of meetings including attendees

Partner Organisation details, Partner details, Partner Employees


General Business Documentation

Partner Organisation details, Partner details


Central code repository

Contact details (name, surname, email, photo), activity and contribution

Data subject

Community education and feedback

Contact details (name, surname, email, photo), activity and contribution

Data subject

Mirror of central code repository

Contact details (name, surname, email, photo), activity and contribution

Data subject

Public Moodle Code Repository

Contact details (name, surname, email, photo), activity and contribution

Data subject

Private Moodle Code Repository

Contact details (name, surname, email, photo), activity and contribution

Data subject

Developer code repository

Contact details (name, surname, email, photo), activity and contribution

Data subject

Sharing of rapid prototypes, research artefacts, usability testing feedback

Contact details, activity, contribution


Conduct user studies, interviews, and surveys

Contact details, activity, contribution


Conduct user surveys, MOBILE – Support for Airnotifier sites

Contact details, form entries

Data subject

Scheduler for usability testing & user interviews

Contact details (name, surname, email, photo), activity and contribution

Data subject

Host the usability tests and user interview recordings

Contact details, biometric data including pictures video and voice recording

Data subject

Community engagement & recruitment for user studies

Names, Addresses, emails, phone numbers, Health Records, Contact details, biometric, IP Address, document contents, email contents, usage records

Data subject

Sending e newsletters

Name, email, phone number, country of subscribers

Data subject

Sending e newsletters

Email address of subscribers

Data subject

Attendees’ registration and payment for Moodle Moots organized by Moodle directly

Email address, name, telephone, payment details, country of origin, occupation, dietary requirements

Data subject

Presentations’ admission process run by Marketing department for Moodle Moots organized by Moodle directly

Email address, name, country, workplace, personal presentation, summary of applicable presentations

Data subject

Sending notifications to Moodle Moots attendees that have voluntary downloaded the Moodle Moot application for the conference

Name, surname, email address


Pass to partnership team MOOC participants personal data interested in further training or other Moodle services

Name, email, phone number, country of subscriber

Data subject

MOOC participants information provide service to the users

Name, email address

Data subject

Provide Moodle education certification service to the user

Name, email address, users contributions, IP addresses, on a voluntary basis: geo localization, photo

Data subject and Partner

Recruitment of candidates

Name, Address, phone number, email, social media profile links, Photograph, educational and work history, interests

Data subject

Reference’s check of candidates to be recruited for recruitment

Contact details, role and any relevant info of referee’s candidate

Data subject

On-boarding of employees and contractors

Contact details, emergency contact details, drivers licence, passport, ID documents, banking details, tax details, superannuation details, gender, qualifications, biometric data, date of birth

Data subject

Health and Safety

Name, phone number, email, relationship with Employee

Data subject

Health Records for Employees/contractors

Health Records

Data subject

Performance’s measure

Performance information, contact details


Letter of Offer

Name, address, phone number, email and remuneration details of contractors

Data subject

Management coaching to strength management capability

Performance information, performance opinions, contact details

Data subject

Manage the organizational structure of the company

Pictures, name and surname

Data subject

Paying wages to employees

Contact details (name, surname and email), Bank details, Tax details, sick leave, Annual Leave, salary, pension


Collecting fees payable by direct clients

Contact details (name, surname and email)


Collecting fees payable by partners

Contact details (name of partner, email, name and surname of partner representative)


Receiving event registration fee

Contact details (name, surname, email of the participant, phone number, business name and address


Paying supplier invoices

Supplier details (name, surname, email, bank details)


Log storing and searching for analysing and troubleshooting LMS site and signup/provisioning

Location, IP address

LMS site admins and LMS site users

Storing of historical logs – moodle, web server, statistics

Website name, location, IP address

LMS site admins and LMS site users

Facilitating the signup and control of the LMS account

Name, email, location, telephone number

LMS site admins

Primary provider for text messaging. Logs for text message sending

Phone numbers

LMS site admins

Email processing (Moodle and signup)


LMS site admins and LMS site users

Text messaging service

Phone numbers

LMS site admins

Backup text messaging service

Phone numbers

LMS site admins

Sending emails to site admins regarding their LMS service

Name, email, financial data

LMS site admins

Operational reporting on cloud servers and moodle sites

Location, IP address, moodle activity data

LMS site admins

Manage recurring subscriptions and payments

Name, email, country

LMS site admins

Billing and subscription management

Name, surname, billing country, website name

LMS site admins

Conversion of assignments in various formats into PDF file to enable the teacher to grade and annotate the document

Any data submitted in the document submitted

LMS site users

Web conferencing feature for LMS

Contact details, voice, audio, video, biometrics, IP address, location data

LMS site users

Webhooks from payment processor triggered on subscription change


LMS site admins

Customer data storage

Any data submitted in the file

LMS site admins and users