Privacy Policy

Version: 2.0
Effective Date: 14.07.2026

1. General Provisions

Welcome to the Brusnika.LMS ecosystem.

This Privacy Policy explains how Brusnika.LMS collects, uses, stores, transfers, and protects information when Users and Organizations access and use Brusnika.LMS Services.

This Privacy Policy applies to all Brusnika.LMS products and services, including:

  • the official Brusnika.LMS website;
  • Brusnika.LMS Cloud;
  • applications distributed through third-party marketplaces;
  • integrations with CRM, ERP, HRM, CMS and other platforms;
  • API services;
  • AI-powered features;
  • mobile applications;
  • other digital products and solutions provided under the Brusnika.LMS brand.

By using Brusnika.LMS Services, you acknowledge that you have read and understood this Privacy Policy.

This Privacy Policy should be read together with:

  • Brusnika.LMS Terms of Service;
  • Data Processing Addendum (DPA), where applicable;
  • other documents referenced in the relevant Brusnika.LMS Services.

2. Who Is Responsible for Data Processing

The entity responsible for providing Brusnika.LMS Services and organizing data processing is the legal entity that develops, maintains, and provides Brusnika.LMS Services (hereinafter referred to as the “Company”).

Information about the Company, including legal details and contact information, is published on the official Brusnika.LMS website.

The Company acts as the party determining the purposes and means of processing when it processes information for its own purposes, including:

  • providing and maintaining Brusnika.LMS Services;
  • managing user accounts;
  • ensuring security;
  • improving and developing Services;
  • complying with legal obligations.

When Organizations use Brusnika.LMS for employee training or internal development, the Company may process information of Organization users on behalf of such Organization to the extent necessary to provide the Services.

In such cases:

  • the Organization independently determines the purposes and legal basis for processing information of its employees and other users;
  • the Organization is responsible for ensuring that it has lawful grounds to provide such information to Brusnika.LMS;
  • the Company processes information according to the Organization’s settings and the terms governing the use of Brusnika.LMS Services.

The Company implements reasonable technical and organizational measures to protect information and ensure proper operation of Brusnika.LMS Services in accordance with applicable laws.

3. Information We Collect

Brusnika.LMS collects information necessary to provide, maintain, secure, and improve its Services.

The type of information collected depends on how the User or Organization interacts with Brusnika.LMS.

3.1. Account Information

When creating an Account or Workspace, Brusnika.LMS may collect:

  • name;
  • email address;
  • phone number, if provided;
  • company or organization name;
  • job title or role;
  • login credentials;
  • subscription information;
  • billing information;
  • other information provided during registration.

3.2. Organization Information

When an Organization uses Brusnika.LMS, the Company may process information related to such Organization, including:

  • organization name;
  • administrator information;
  • user lists;
  • roles and permissions;
  • subscription details;
  • configuration settings;
  • integration information.

3.3. User-Provided Content

Users and Organizations may create, upload, store, and process Content within Brusnika.LMS, including:

  • training materials;
  • courses;
  • lessons;
  • tests;
  • surveys;
  • documents;
  • videos;
  • audio materials;
  • knowledge bases;
  • reports;
  • competency models;
  • other educational or business-related materials.

Such Content remains the property of the User or Organization that created or uploaded it.

The Company processes User Content only as necessary to provide Brusnika.LMS Services.

3.4. Usage and Technical Information

When Users access Brusnika.LMS, the Company may automatically collect technical information, including:

  • IP address;
  • browser type and version;
  • operating system;
  • device information;
  • access timestamps;
  • usage activity;
  • error reports;
  • performance information;
  • security-related information.

Such information is used to maintain reliability, security, and performance of Brusnika.LMS Services.

3.5. Integration and Marketplace Data

When Brusnika.LMS is installed or accessed through third-party platforms, the Company may receive information required for integration and operation of the Service.

Such information may include:

  • account identifiers;
  • organization identifiers;
  • user profile information permitted by the platform;
  • authorization data required for integration;
  • technical information necessary for communication between systems.

The processing of such information may also be subject to the privacy policies and terms of the relevant third-party platforms.

3.6. Payment Information

When Users purchase paid Services, payment-related information may be processed.

Depending on the payment method and country of use, payments may be processed:

  • directly by the Company;
  • through marketplace operators;
  • through authorized partners;
  • through third-party payment providers.

The Company generally does not store complete payment card information. Such information may be processed directly by payment service providers according to their own privacy policies and security standards.

3.7. AI-Related Information

When Users use AI-powered features of Brusnika.LMS, the Company may process information necessary to provide such features, including:

  • prompts submitted by Users;
  • materials selected for processing;
  • generated results;
  • configuration parameters;
  • usage information.

Depending on the selected AI feature, certain information may be transferred to external AI service providers.

Such processing is performed only to the extent necessary to provide the requested AI functionality and in accordance with this Privacy Policy.

4. How We Use Information

The Company uses collected information for the following purposes:

4.1. Providing and Maintaining Services

Information is used to:

  • create and manage Accounts;
  • provide access to Brusnika.LMS;
  • operate Workspaces;
  • process subscriptions;
  • provide requested functionality;
  • maintain integrations;
  • provide technical support.

4.2. Security and Fraud Prevention

Information may be used to:

  • protect Brusnika.LMS infrastructure;
  • detect suspicious activity;
  • prevent unauthorized access;
  • investigate security incidents;
  • enforce the Terms of Service.

4.3. Improving and Developing Services

The Company may use information to:

  • improve usability;
  • analyze performance;
  • fix errors;
  • develop new features;
  • improve reliability and security.

Where possible, such analysis is performed using aggregated or anonymized information.

4.4. Communication

The Company may use information to send:

  • service-related notifications;
  • security alerts;
  • technical updates;
  • information about changes to Services;
  • responses to support requests.

Marketing communications are sent only in accordance with applicable laws and available user preferences.

4.5. Legal Compliance

Information may be processed when necessary to:

  • comply with applicable laws;
  • respond to lawful requests from authorities;
  • protect legal rights;
  • resolve disputes;
  • enforce agreements.

5. Legal Bases for Processing

Depending on the jurisdiction, the Company processes Personal Data based on one or more of the following legal grounds:

5.1. Performance of a Contract

Processing may be necessary to:

  • provide Brusnika.LMS Services;
  • manage Accounts;
  • process subscriptions;
  • fulfill obligations under agreements with Users and Organizations.

5.2. Legitimate Interests

The Company may process information based on legitimate interests, including:

  • ensuring security of Services;
  • preventing misuse;
  • improving functionality;
  • maintaining technical reliability;
  • protecting legal rights.

5.3. Consent

Where required by applicable law, the Company may request consent before processing certain information.

Users may withdraw consent where permitted by law. Withdrawal of consent does not affect the lawfulness of processing performed before withdrawal.

5.4. Legal Obligations

The Company may process information when necessary to comply with applicable legal requirements.

6. Sharing of Information

The Company may share information only when necessary for providing, maintaining, securing, and improving Brusnika.LMS Services or when required by applicable law.

The Company does not sell Personal Data of Users.

6.1. Service Providers

The Company may share information with trusted third-party service providers that support the operation of Brusnika.LMS, including providers of:

  • cloud infrastructure;
  • data storage;
  • payment processing;
  • authentication services;
  • analytics tools;
  • customer support systems;
  • AI technologies;
  • security services.

Such providers may process information only for purposes related to providing services to the Company and in accordance with applicable agreements and security requirements.

6.2. AI Service Providers

Certain AI-powered features of Brusnika.LMS may require processing of information by external AI providers.

Depending on the selected AI functionality, information transferred to AI providers may include:

  • User prompts;
  • selected User Content;
  • educational materials;
  • structured data required to generate results.

The Company transfers only the information necessary to provide the requested AI functionality.

The processing of information by AI providers may also be subject to the privacy policies and terms of those providers.

6.3. Marketplace and Platform Providers

When Users access Brusnika.LMS through third-party marketplaces or platforms, information may be shared with the relevant platform to enable:

  • installation;
  • authentication;
  • integration;
  • operation of the Service.

Such platforms may independently process information according to their own privacy policies.

The Company does not control and is not responsible for the privacy practices of third-party platforms.

6.4. Business Transfers

Information may be transferred as part of:

  • a merger;
  • acquisition;
  • restructuring;
  • sale of assets;
  • transfer of business operations.

In such cases, the Company will take reasonable measures to ensure continued protection of information.

6.5. Legal Requirements

The Company may disclose information if reasonably necessary to:

  • comply with applicable laws;
  • respond to lawful requests from authorities;
  • protect the rights, property, or safety of the Company, Users, or third parties;
  • prevent fraud or security threats.

7. Processing of Organization Data

When an Organization uses Brusnika.LMS for employee training, onboarding, assessment, knowledge management, or other business purposes, the Organization may provide Personal Data of its employees, contractors, customers, partners, or other users.

In such cases:

  • the Organization determines the purposes and methods of processing;
  • the Organization is responsible for ensuring a lawful basis for processing and transferring such data;
  • the Company processes such data only to provide Brusnika.LMS Services according to the Organization’s instructions and configuration settings.

The Company does not control the internal policies of Organizations regarding their employees or users.

Users who access Brusnika.LMS through an Organization should contact that Organization regarding questions about:

  • why their data is processed;
  • what information is collected;
  • how long data is retained;
  • their employment-related rights.

8. Data Processing by AI Features

Brusnika.LMS may include AI-powered functionality designed to assist Users in creating, analyzing, improving, and managing educational materials and related information.

AI features may be used for:

  • generating course structures;
  • creating tests and assessments;
  • preparing competency models;
  • generating recommendations;
  • analyzing results;
  • translating materials;
  • improving educational content.

8.1. AI Processing Principles

AI-generated results may contain errors, inaccuracies, or incomplete information.

Users are responsible for reviewing AI-generated materials before using them in business, educational, or other processes.

8.2. Information Sent to AI Providers

To provide certain AI features, selected information may be transmitted to external AI providers.

Such information may include:

  • User instructions;
  • uploaded materials;
  • text or structured data submitted for processing.

The Company takes reasonable measures to limit transmitted information to what is necessary for the requested functionality.

8.3. User Responsibility

Users should avoid submitting confidential, sensitive, or restricted information to AI features unless they have appropriate rights and authorization to do so.

Organizations are responsible for determining whether their employees and users are permitted to use AI functionality with specific types of information.

9. User Content

Users and Organizations retain ownership rights to Content created, uploaded, or stored in Brusnika.LMS.

The Company does not acquire ownership rights to User Content.

9.1. Processing of User Content

The Company may process User Content only to the extent necessary to:

  • provide Brusnika.LMS functionality;
  • store and display materials;
  • enable access by authorized users;
  • perform backups;
  • maintain security;
  • provide technical support;
  • improve reliability of Services.

9.2. Organization Control Over Content

Organizations may control:

  • access permissions;
  • user roles;
  • visibility of materials;
  • available features;
  • management of Workspace data.

Users understand that Administrators appointed by an Organization may have access to information created within the Organization’s Workspace according to assigned permissions.

9.3. Responsibility for Content

Users and Organizations are responsible for:

  • having necessary rights to upload Content;
  • ensuring lawful use of Content;
  • protecting confidential information;
  • complying with applicable laws.

The Company is not responsible for the legality or accuracy of User Content uploaded by Users or Organizations.

10. International Data Transfers

Brusnika.LMS is used by Users and Organizations located in different countries.

Due to the international nature of the Services, information may be processed and transferred to countries other than the country where the User is located.

Such transfers may occur for purposes including:

  • hosting and maintaining Brusnika.LMS infrastructure;
  • using third-party technology providers;
  • providing AI-powered features;
  • providing technical support;
  • fulfilling contractual obligations.

The Company takes reasonable measures to protect information during international transfers, including appropriate contractual, technical, and organizational safeguards.

Where applicable laws impose specific requirements for international data transfers, the Company processes such transfers in accordance with those requirements.

11. Data Retention and Deletion

The Company retains information only for as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required by law or contractual obligations.

The retention period may depend on:

  • the type of information;
  • the way Brusnika.LMS is used;
  • Account status;
  • legal requirements;
  • terms applicable to the relevant Service.

11.1. Active Accounts

Information related to active Accounts is retained during the period of use of Brusnika.LMS and for a reasonable period after termination of use when necessary to:

  • fulfill contractual obligations;
  • maintain security;
  • resolve disputes;
  • comply with legal requirements.

11.2. Inactive Accounts and Workspaces

In accordance with the Brusnika.LMS Terms of Service, the Company may automatically delete inactive Accounts and Workspaces.

An Account or Workspace is considered inactive if no login by a User or Administrator has been recorded for 365 (three hundred sixty-five) consecutive calendar days.

This rule applies regardless of whether the Account was:

  • free of charge;
  • paid;
  • previously associated with an expired subscription.

After this period, the Company may delete:

  • the Account;
  • Workspace;
  • User Content;
  • courses;
  • training materials;
  • tests;
  • reports;
  • settings;
  • associated information.

The Company may, but is not obligated to, send a notification to the email address associated with the Account before deletion.

After deletion, restoration of the Account, Workspace, or associated information is not guaranteed and may be impossible.

Users and Organizations are responsible for preserving any information they consider important and creating their own backups where necessary.

11.3. Deletion After Termination of Use

After termination of use of Brusnika.LMS Services, the Company may delete relevant information in accordance with:

  • this Privacy Policy;
  • Brusnika.LMS Terms of Service;
  • applicable laws.

Certain information may be retained for additional periods where necessary for:

  • compliance with legal obligations;
  • protection of legal rights;
  • dispute resolution;
  • security purposes.

12. Data Security

The Company implements reasonable technical and organizational measures designed to protect information from:

  • unauthorized access;
  • loss;
  • alteration;
  • disclosure;
  • destruction.

Such measures may include:

  • access control for Company personnel;
  • secure communication protocols;
  • permission management;
  • security monitoring;
  • backups;
  • software updates;
  • other standard information security practices.

However, no digital service can guarantee absolute security of information transmission or storage.

Users are also responsible for:

  • protecting their Accounts;
  • using strong passwords;
  • keeping authentication credentials confidential;
  • notifying the Company of suspicious activity.

13. Cookies and Similar Technologies

Brusnika.LMS may use cookies and similar technologies to ensure proper operation of Services and improve user experience.

Cookies may be used for the following purposes:

13.1. Essential Cookies

These technologies are required for:

  • authentication;
  • maintaining user sessions;
  • security;
  • proper operation of interfaces.

Disabling essential cookies may prevent certain features of Brusnika.LMS from functioning properly.

13.2. Analytics Cookies

The Company may use analytics technologies to:

  • understand how Services are used;
  • identify errors;
  • improve interfaces;
  • monitor performance.

13.3. Preference Cookies

Cookies may be used to store User preferences, including:

  • interface language;
  • display settings;
  • user preferences.

Users may control cookie settings through their browser or device settings.

Restricting cookies may affect availability of certain Brusnika.LMS features.

14. User Rights

Depending on applicable laws, Users may have the right to:

  • receive information about processing of their Personal Data;
  • access their Personal Data;
  • correct inaccurate information;
  • request deletion of Personal Data;
  • restrict processing;
  • object to certain processing activities;
  • receive a copy of their Personal Data in a portable format;
  • withdraw consent where processing is based on consent.

To exercise these rights, Users may contact the Company using the contact information provided on the official Brusnika.LMS website.

The Company may request additional information to verify the identity of the requester and protect Personal Data from unauthorized access.

Where Personal Data is processed by Brusnika.LMS on behalf of an Organization, Users may need to contact the relevant Organization first, as the Organization may determine the purposes and methods of such processing.

15. Use of Brusnika.LMS Through Marketplace Platforms

Brusnika.LMS may be provided through third-party application marketplaces and platforms, including CRM, ERP, HRM, CMS, and other information systems.

When using Marketplace versions of Brusnika.LMS, certain aspects of information processing may differ depending on the relevant platform.

15.1. Third-Party Platforms

When Brusnika.LMS is installed or used through a Marketplace platform, certain information may be processed using the infrastructure and authentication mechanisms of the relevant platform.

Such information may include:

  • platform account identifiers;
  • user profile information;
  • organization information;
  • technical information required for integration;
  • information authorized by the User during installation.

Processing of information by third-party platforms is governed by their own privacy policies and terms.

15.2. Authentication Through Third-Party Services

In certain cases, access to Brusnika.LMS may be provided through an account created on a third-party platform.

The Company does not receive passwords from such platforms and is not responsible for the security of third-party accounts.

Users are responsible for complying with the rules and security requirements of the relevant third-party services.

15.3. Removal of Marketplace Applications

Removing Brusnika.LMS from a third-party platform may result in loss of access to certain features, information, or settings connected with such integration.

Retention and deletion of information after removal of an application are governed by:

  • this Privacy Policy;
  • Brusnika.LMS Terms of Service;
  • the settings and functionality of the relevant Service.

16. Children’s Data

Brusnika.LMS Services are primarily intended for use by organizations and adult users for professional training, employee development, knowledge management, and related purposes.

The Company does not intentionally collect Personal Data of children without an appropriate legal basis.

If a User believes that information relating to a child has been provided to Brusnika.LMS without proper authorization or legal basis, the User may contact the Company using the contact information provided on the official Brusnika.LMS website.

The Company will take reasonable measures to review such requests and delete relevant information where legally required.

17. Changes to This Privacy Policy

The Company may update this Privacy Policy from time to time to reflect changes in:

  • Brusnika.LMS Services;
  • technologies used;
  • legal requirements;
  • data processing practices.

The updated version becomes effective upon publication unless another effective date is specified in the updated version.

If changes materially affect the rights of Users of paid Services or significantly change how Personal Data is processed, the Company may provide additional notice through available communication channels.

Users are encouraged to periodically review the current version of this Privacy Policy.

18. Contact Information

For questions regarding this Privacy Policy, processing of Personal Data, exercise of User rights, or use of Brusnika.LMS Services, Users may contact the Company using the contact information provided on the official Brusnika.LMS website.

Requests may include:

  • questions regarding data processing;
  • requests for access, correction, or deletion of information;
  • notifications of potential privacy issues;
  • other matters related to data protection.

The Company may request additional information necessary to verify the identity of the requester and properly process the request.