Privacy Policy

1. Scope

This Privacy Policy explains how Aptlogica Technologies Private Limited, operating Sereni LRS, collects, uses, shares, and protects personal data when you visit https://www.serenilrs.com, communicate with us, create or administer an account, or use the Service.

This Policy does not replace a customer organisation’s privacy notice. When an organisation submits xAPI statements or other Customer Data to Sereni LRS, that organisation generally determines why and how the data is processed and acts as the controller/data fiduciary. We process that data on its instructions as a processor/data processor or service provider. Learners and other end users should first direct requests about Customer Data to the organisation that provided or manages their learning experience.

2. Who is responsible for your data

For website, sales, account, billing, and direct support data, the responsible entity is:

Aptlogica Technologies Private Limited

Registered address: S.No. 692/A/2A, Saluja Chambers, 2nd and 3rd Floor, above McDonald's Restaurant, Pune-Satara Road, opposite the LIC 95L building, Bibwewadi, Pune, Maharashtra 411037

Privacy contact / Grievance Officer: [email protected]

Data Protection Officer, if appointed: [email protected]

3. Personal data we collect

Depending on how you interact with us, we may collect:

• Account and contact data: name, business email, phone number, organisation, role, username, authentication identifiers, and preferences.
• Customer Data and learning records: xAPI statements and related actor, verb, object, context, result, timestamp, authority, attachment, and identifier fields; LMS or content-system identifiers; learner or employee identifiers; activity records; and reports. The exact content is controlled by Customer.
• Technical and usage data: IP address, device and browser information, operating system, log events, API requests, endpoint identifiers, timestamps, diagnostic information, feature usage, and security events.
• Transaction data: for Paid Plans, subscription, quotation, order-form, invoice, tax, billing-contact, payment-status, and transaction-reference information. Payment-card details, if online card payments are enabled, are processed by the applicable payment provider rather than stored by us. Free Plan users are not charged a recurring subscription fee under the current plan.
• Communications: support requests, emails, call or meeting details, survey responses, and feedback.
• Website data: pages viewed, referring pages, approximate location derived from IP address, cookie identifiers, and marketing interactions, subject to your choices and applicable law.
• Information from third parties:authorised integrations, identity providers, resellers, referral sources, public business sources, and service providers.

Please do not submit unnecessary sensitive personal data. Customers control the fields placed in xAPI statements and should use pseudonymous identifiers where appropriate.

4. How we use personal data

We use personal data to:

• provide, authenticate, administer, and support the Service;
• receive, store, query, export, validate, and report Customer Data as instructed by Customer;
• manage accounts, subscriptions, billing, and transactions;
• secure the Service, prevent abuse, investigate incidents, and maintain logs and backups;
• monitor performance, troubleshoot errors, and improve features and usability;
• communicate about service notices, support, product updates, and relevant offerings;
• understand website use and measure campaigns, where permitted;
• comply with law, enforce agreements, and establish or defend legal claims; and
• carry out other purposes disclosed when data is collected.

We do not sell Customer Data. We do not use Customer Data to train general-purpose artificial intelligence models unless Customer expressly agrees in writing.

5. Legal bases

Where applicable law requires a legal basis, we rely on one or more of the following: performance of a contract; legitimate interests such as operating, securing, improving, and marketing the Service; compliance with legal obligations; consent; and protection of vital or legal interests. Where we process Customer Data for Customer, Customer determines the appropriate legal basis.

You may withdraw consent at any time, without affecting processing already performed. You may object to processing based on legitimate interests, subject to applicable exceptions.

6. How we share personal data

We may share personal data with:

• Customer and its authorised users:administrators may access and manage account and learning data within their organisation.
• Service providers/subprocessors:providers of cloud hosting, databases, content delivery, authentication, monitoring, communications, customer support, analytics, payment processing, security, and professional services, subject to contractual safeguards.
• Integrations chosen by Customer: when Customer enables an LMS, content platform, identity provider, reporting tool, or other integration.
• Affiliates and corporate transaction parties: as needed for internal operations or a merger, financing, reorganisation, acquisition, or sale, subject to confidentiality and applicable law.
• Authorities and other parties: where reasonably necessary to comply with law, protect rights and safety, investigate fraud or security issues, or establish or defend legal claims.

7. International data transfers

We and our service providers may process personal data in countries other than where it was collected. Where required, we use recognised transfer mechanisms and safeguards, such as contractual clauses, data processing agreements, adequacy decisions, and supplementary security measures.

8. Data retention and deletion

We retain personal data only for as long as reasonably necessary for the purposes described above, including contractual, security, accounting, tax, dispute, and legal requirements.

Customer Data is retained for the subscription term and deleted or returned according to Customer’s plan, configuration, contract, and documented instructions. Following termination, active Customer Data will generally be deleted after 30 days, and residual encrypted backups will expire through normal backup rotation within 30 days, unless law requires longer retention.

Account, billing, security, and transaction records may be kept for legally required periods. We may retain de-identified or aggregated information that cannot reasonably identify an individual.

9. Security

We use reasonable technical and organisational measures designed to protect personal data, which may include encryption in transit and at rest, access controls, logging, monitoring, backups, vulnerability management, and personnel confidentiality requirements.

No method of storage or transmission is completely secure. Customers should protect credentials and API keys, limit administrator access, use secure integrations, and avoid placing unnecessary personal data in xAPI fields.

To report a suspected security issue, contact [email protected]. Do not include sensitive data in the initial report.

10. Cookies and similar technologies

We may use:

• Strictly necessary cookies for authentication, security, session management, and essential features;
• Preference cookies to remember settings;
• Analytics cookies to understand performance and use; and
• Marketing cookies to measure campaigns or deliver relevant communications.

Non-essential cookies will be used only where permitted and, where required, after consent. Where a cookie-preference tool is available on the website, you can use it to manage non-essential cookies; you may also use your browser settings. Disabling necessary cookies may prevent parts of the Service from working.

11. Your privacy rights

Depending on your location and relationship with us, you may have rights to request access, correction, completion, deletion, restriction, objection, portability, withdrawal of consent, information about processing, and review of certain automated decisions. You may also have the right to lodge a complaint or grievance with a regulator.

To exercise a right regarding data controlled directly by us, contact [email protected]. We may verify your identity and authority before responding. Authorised agents may submit requests where permitted by law.

If your data was submitted by an employer, school, training provider, or other Sereni LRS customer, contact that organisation first. We will assist our customer as required by contract and law.

We will not discriminate against you for exercising applicable privacy rights.

12. Children’s privacy

The website and direct account registration are not directed to children, and we do not knowingly create direct accounts for children. Customers such as schools or training providers may use the Service to process learner data only where authorised by contract and law, with required notices, consents, and safeguards.

If you believe a child’s data was collected without appropriate authorisation, contact the responsible customer organisation first. You may also contact us at [email protected].

13. Automated decision-making

Sereni LRS may provide reports, dashboards, scores, or analytics based on Customer Data. Unless expressly stated, the Service does not make decisions that produce legal or similarly significant effects about individuals. Customers are responsible for human review and for ensuring that their use of reports and analytics is fair, accurate, transparent, and lawful.

14. Third-party links and services

Our website and Service may link to or integrate with third-party sites and services. Their privacy practices are governed by their own notices, and we are not responsible for services we do not control.

15. Changes to this Policy

We may update this Policy to reflect changes in the Service, law, or our practices. We will post the updated version, revise the “Last updated” date, and provide additional notice where required. Material changes will apply prospectively unless law permits otherwise.

16. Contact and grievances

For privacy questions, requests, or complaints:

Aptlogica Technologies Private Limited

Privacy / Grievance Officer: [email protected]

Address: S.No. 692/A/2A, Saluja Chambers, 2nd and 3rd Floor, above McDonald's Restaurant, Pune-Satara Road, opposite the LIC 95L building, Bibwewadi, Pune, Maharashtra 411037

Website: https://www.serenilrs.com

We will acknowledge and address grievances within the period required by applicable law.