FocoLMS SaaS Privacy Policy

Effective Date: 23rd March 2026

1. Introduction

FocoLMS, Inc. (collectively, “we,” “us,” “our,” or “Company”), respects the privacy of our customers and individuals who use our services. This SaaS Privacy Notice (“Notice”) describes how we collect, use, and share personal data we process on behalf of our Customers when you use our hosted learning management software applications and platform (“Services”).

It also describes your choices regarding the use, access, and correction of your Personal Information that we process in the course of fulfilling our obligations as a service provider according to the FocoLMS Terms of use (“Terms of use”) executed between FocoLMS and our customer (“Customer”). The Customer may be your employer, or if you are a student, contractor, or participant, they may be the entity that has authorized your access to the platform.

2. About FocoLMS and the Personal Information we Collect

FocoLMS is a learning technology company that provides software solutions for training, professional development, and educational administration. While using our Services, Customers and their authorized users input or transfer electronic data into the FocoLMS systems (“Customer Data”).

Customer Data may include an individual’s:

  • Name and email address
  • Unique user identifier(s) and login credentials
  • Phone number(s)
  • Company position, business unit, or academic department
  • Course progress, test scores, certifications, and training histories

3. Retention of Personal Information

FocoLMS will retain Personal Information we process on behalf of our Customers for as long as necessary to provide Services to our Customer, and as required to comply with our legal obligations, resolve disputes, and enforce our agreements.

4. Transfers of Personal Information

FocoLMS is responsible for the processing of Personal Information it receives from Customers and any onward transfers to third parties acting on our behalf in compliance with applicable law, including but not limited to:

4.1 Compliance with Argentinian Law and International Transfers

FocoLMS processes and transfers personal data in strict compliance with the Argentinian Personal Data Protection Act No. 25.326 (Ley de Protección de Datos Personales). When Customer Data originates from Argentina and is transferred or hosted outside of Argentine territory (such as to servers in the United States), FocoLMS ensures that the receiving country provides an adequate level of protection as determined by the Agencia de Acceso a la Información Pública (AAIP), or we utilize the official Standard Contractual Clauses (Cláusulas Contractuales Tipo) approved by AAIP Resolution (including regional standards aligned with the Ibero-American Data Protection Network) to legally safeguard cross-border data flows.

4.2 Legal Framework for Processing

For users subject to Argentine jurisdiction, FocoLMS processes your Personal Information based on:

  • Prior, informed, and express consent: Granted when registering on the platform or accepting these terms.
  • Contractual Necessity: To fulfill the contractual obligations established in the Services Agreement with our Customers (your employer or institution).
  • Legal Obligations: To comply with local tax laws (including Factura E configurations for service exportations), judicial orders, or compliance auditing.

5. How We Collect Personal Information

5.1 From Customers

FocoLMS processes Customer Data under the direction of our Customers and has no direct control or ownership of the Personal Information it receives. If you are an authorized user of one of our Customers (such as an employee or student) and no longer wish to be contacted by them, please contact the Customer organization you interact with directly. Customers are responsible for complying with regulations or laws requiring notice, disclosure, and/or consent prior to transferring data to FocoLMS.

5.2 From You

FocoLMS may collect Personal Information directly from you when you:

  • Register to use the Services or access a learning portal
  • Launch a course, take an assessment, or download educational content
  • Contact the FocoLMS Support team

5.3 Passive Collection

As is true of most web applications, we gather certain information automatically. This information may include Internet Protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, features viewed within the platform (e.g., HTML pages, course modules, graphics), operating system, date/time stamps, usage volume, and change history to analyze trends and administer the platform.

6. Access, Changes, and Removal Requests

FocoLMS acknowledges that you have the right to access your personal information. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate Personal Information should:

  1. First direct their query to the FocoLMS Customer (your employer or institution, who acts as the data controller).
  2. Second, email the request directly to info@focolms.com.

We will process your request within a reasonable timeframe, provided we are not otherwise prevented from doing so on legal grounds. If an adjustment impact is unreasonable to the privacy of others or legally restricted, we will notify you of the reasons why.

7. Customer Obligations Around Personal Information

If a Customer or individual user (“Information Provider”) provides FocoLMS with Personal Information about someone else, the Information Provider must ensure they are authorized to disclose that information. They must ensure that FocoLMS may legally collect, use, and disclose such information for the purposes described in this Notice without taking further administrative steps. It is the Information Provider’s responsibility to ensure that the Personal Information provided to us is accurate, complete, and up to date.

8. Purposes for Processing Personal Information

8.1 To Provide the Services

The use of Personal Information collected through our platform is limited to the purpose of providing the Services defined in the Service Agreement. FocoLMS uses your information to:

  • Verify your identity when you log in
  • Track course completion, grades, and compliance certifications
  • Prevent or address service or technical problems and respond to support issues
  • Produce de-identified, aggregated industry learning trends or platform performance benchmarks

Note on De-identified Data: When aggregate learning data is processed for product improvement, we leverage anonymization techniques that hash, filter, or scrub the data so it cannot identify you as an individual or pinpoint your specific organization.

8.2 To Secure the Services

We use information about you and your platform activity to verify accounts, monitor compliance with service policies, and protect against potential security incidents, fraud, or malicious software activity.

8.3 To Protect Legitimate Interests and Legal Rights

Where required by law or to protect our legal rights, interests, and the interests of our Customers, we use information about you in connection with legal claims, compliance, regulatory audits, and disclosures related to the acquisition, merger, or sale of a business.

We process your information only when:

  • We need it to operate the platform and provide customer support.
  • It satisfies a legitimate interest (such as research and development into better educational tools) that is not overridden by your data protection interests.
  • You give us explicit consent for a specific purpose.
  • We must comply with a legal obligation.

9. Third-Party Disclosures

Your Personal Information may be shared with authorized Affiliates and sub-contractors (“Personnel”) such as cloud computing infrastructure providers (e.g., hosting servers) necessary to host the platform. These entities are restricted from using your data for any independent marketing or operations.

FocoLMS will not otherwise disclose your Personal Information to a third party without your express consent, except as required by law to comply with court orders, subpoenas, or lawful requests by public authorities (including national security or law enforcement requirements).

10. Cookies and Tracking Technologies

FocoLMS and its analytics partners use cookies or similar technologies to process transactions, manage user sessions, and analyze platform trends.

  • Essential Cookies: Used strictly for authentication, securing your login session, and maintaining course state.
  • Analytics (e.g., Google Analytics): Used to evaluate the usage of our platform and identify performance bottlenecks. In our core SaaS applications, data sent to analytics providers is completely anonymized.
  • Opt-Out: You can control or refuse cookies through your web browser's settings. Disabling cookies may cause some interactive learning features or automated tracking within FocoLMS to malfunction. Our systems do not currently recognize browser "Do Not Track" (DNT) signals.

12. Privacy Complaints and Contact Information

FocoLMS commits to resolving complaints about our collection or use of your Personal Information. For questions regarding this Notice, please contact our Privacy Officer at:

Our Privacy Officer will endeavor to provide an initial response to your query or complaint within 15 Business Days.

13. Changes to This Policy

We may update this SaaS Privacy Notice from time to time to reflect changes to our information security and privacy practices. We encourage users to periodically review this page for the latest updates.