Contents
- Acceptance
- Who we are
- The Service
- Our role: controller or processor
- What personal data we collect
- How we use your data
- Our legal basis for processing
- Cookies and similar technologies
- How long we keep your data
- How we share your data
- Children
- International data transfers
- Security
- Your rights
- How to complain
- Changes to this policy
- Contact us
1. ACCEPTANCE
This Privacy Policy explains how Think Equal collects, uses, stores, shares and protects personal data through the Think Equal Learning Management System (the ‘LMS’). It applies to everyone who registers for or uses the LMS, wherever in the world you are accessing it from.
By creating an account, or by clicking ‘I Accept’ when prompted, you confirm that you have read and understood this policy, and that you agree to the collection and use of your personal data as described in it. If you do not agree, please do not create an account or otherwise use the LMS.
This policy sits alongside, and does not replace, Think Equal’s Child Data Protection & Privacy Policy and our main website Privacy Policy. It should be read together with our LMS Terms of Service, which governs your use of the platform itself and is incorporated by reference into what you agree to above.
2. WHO WE ARE
Think Equal is an international education charity. Depending on where you are engaging with us, the relevant Think Equal entity is one of the following:
- Think Equal, a 501(c)(3) charity incorporated in Delaware, USA, registered office at 900 Foulk Road, Suite 201, Wilmington, New Castle County, Delaware 19803.
- Think Equal, a company limited by guarantee and registered charity in England and Wales (charity no. 1174610, company no. 10166996), registered with the UK Information Commissioner’s Office under reference ZA320513.
- Think Equal, a registered charity in Scotland (no. SC054380).
3. THE SERVICE
The LMS is Think Equal’s online training platform. We use it to deliver teacher training courses, track your progress through those courses, let you upload evidence of completed activities, and issue certificates confirming completion.
Access to the LMS is normally arranged through your school, ministry of education, or another partner organisation working with Think Equal (the ‘Partner’). Depending on the programme, the Partner may set up your access and may also be the data controller for your information, see section 3 below.
4. OUR ROLE: CONTROLLER OR PROCESSOR
For most LMS activity, Think Equal is the data controller, meaning we decide why and how your personal data is used. Where we deliver training under a written agreement with a government or partner organisation that sets the purposes and means of processing, that partner may instead be the controller, and we process your data on their instructions as a processor. If you are not sure which applies to you, contact us using the details in section 16 and we will confirm.
5. WHAT PERSONAL DATA WE COLLECT
- Account and registration data: full name, email address, phone number, school or institution, country, district, city, username, and a securely hashed password.
- Training activity data: course enrolments, progress, survey, quiz and assessment results, certificates issued, and any messages or forum posts made within the platform.
- Uploaded evidence: documents and other files uploaded to demonstrate completion of a training activity. This does not include photographs or other images of children; the LMS is not used to collect or store any images of children.
- Technical and usage data: IP address, approximate location derived from IP, device and browser type, device or browser identifiers, log-in timestamps, pages visited, navigation activity, interactions with embedded content such as videos, and other technical information collected through cookies or similar technologies.
- Cookies and similar technologies, as described in section 7.
- Any correspondence you send us through the LMS or a related Think Equal email address, and information used to send you LMS-related emails, notifications or other communications.
Think Equal does not collect, request, or knowingly retain any photographs, images, or other personal data of children through the LMS. Evidence of training completion is limited to documents and materials that do not identify or depict children.
Think Equal does not directly store full payment card or banking details within the LMS. Where payment is required, payment information is processed by third-party payment providers such as Stripe or PayPal in accordance with their respective privacy practices.
6. HOW WE USE YOUR DATA
- Create and administer your LMS account.
- Deliver training content and track your progress.
- Verify and certify completion of training.
- Communicate with you about your account, courses, or relevant updates.
- Maintain the records our government and funding partners reasonably require to confirm that training was delivered under a specific programme.
- Improve the LMS and our training content.
- Comply with our legal, regulatory and reporting obligations.
- Investigate and respond to safeguarding concerns, complaints, or misuse of the platform.
7. OUR LEGAL BASIS FOR PROCESSING
Depending on the activity, we rely on: performance of a contract with you (for example, when you enrol on a course); your consent (for example, for optional communications, which you can withdraw at any time); our legitimate interest in keeping the LMS secure and improving it, balanced against your rights; a legal obligation we must comply with; and, for specific government partnership programmes, the public task carried out by the relevant education authority.
8. COOKIES AND SIMILAR TECHNOLOGIES
Last reviewed: September 2026
A cookie is a small text file placed on your device when you visit a website.
The LMS uses only cookies that are necessary for it to work. We do not use advertising, analytics or tracking cookies, and we do not use cookies to build a profile of you or to share your activity with third parties for their own purposes. Because these cookies are strictly necessary, we do not ask for your consent to set them.
Cookies set whenever you use the LMS
| Cookie | Set by | Duration | Purpose |
| MoodleSession | Think Equal | Until you log out or close your browser | Keeps you logged in and protects your account against security attacks |
| __cf_bm | Cloudflare | 30 minutes | Protects the platform against automated attacks |
| __cflb | Cloudflare | Until you close your browser | Routes your connection to the correct server |
Cookies set only if you begin a payment. If you enrol on a course that requires payment, our payment providers set cookies necessary to process the payment securely and prevent fraud. These are set by the provider, not by Think Equal, and are governed by that provider’s own privacy notice.
| Cookie | Set by | Duration | Purpose |
| __stripe_mid, __stripe_sid, m | Stripe | 30 minutes to 2 years | Secure payment processing and fraud prevention |
| l7_az, ts, ts_c | PayPal | Session to 2 years | Secure payment processing and fraud prevention |
| _px3, _pxvid, _pxde, pxcts | HUMAN Security (on behalf of our payment provider) | Session to 1 year | Bot and fraud detection during payment |
The LMS also stores technical information in your browser, such as interface translations and course navigation state, so pages load faster and in your chosen language. This does not identify you personally and is cleared when you clear your browser data.
You can delete or block cookies through your browser settings, but blocking the necessary cookies listed above will prevent you from logging in.
9. HOW LONG WE KEEP YOUR DATA
LMS account and training records are retained for 2 years after your last activity on the platform, after which your account is securely deleted or anonymised, unless a longer period is required by a specific programme, contract, or legal obligation. Where uploaded evidence forms part of a specific programme’s reporting, it is retained according to that programme’s terms, as set out in our internal Data Retention Schedule. This schedule is reviewed periodically by our Data Protection Officer and senior leadership.
10. HOW WE SHARE YOUR DATA
We share personal data, only to the extent necessary, with:
- Our LMS hosting provider, which processes data on our behalf and under contract.
- Implementing Partners and government education authorities who commission or co-deliver a specific training programme, limited to what is needed to confirm participation and completion.
- Service providers who support our IT systems and data storage.
- Regulators, courts, or other authorities, where we are required to do so by law.
We do not sell personal data, and we do not share it with third parties for their own independent marketing purposes. If Think Equal were ever to merge with, or transfer a programme to, another organisation, your data may transfer as part of that; we will tell you if this materially changes how your data is used.
11. CHILDREN
The LMS is designed for use by adults: teachers, trainers, and school staff. We do not knowingly collect personal data directly from children through the LMS, and the LMS is not used to collect or store any images of children. If we become aware that a child has registered or provided personal data directly, we will take steps to delete it.
Any processing of children’s personal data as part of our classroom programme, separate from the LMS, is governed by our Child Data Protection & Privacy Policy.
12. INTERNATIONAL DATA TRANSFERS
Our LMS is hosted in Madrid, Spain, within the European Union. The hosting environment was migrated from California, United States, to Madrid, Spain, during the weekend of 11–14 September 2026, and access to the LMS was restored on 14 September 2026.
Hosting the LMS within the European Union means that, in respect of users located in the European Economic Area (EEA), the storage of their personal data no longer constitutes an international transfer of personal data outside the EEA.
If you access the LMS from the United Kingdom, Mexico, or another jurisdiction that imposes its own requirements or restrictions in relation to international transfers of personal data, your personal data may still be transferred internationally in certain circumstances. This may occur, for example, where support personnel of our hosting provider, or any of its sub-processors, are located outside the country or jurisdiction from which you access the LMS.
Where we make such a transfer, we put in place a legally recognised safeguard, such as Standard Contractual Clauses approved by the European Commission, or another mechanism recognised as providing an equivalent level of protection, and, where required, we assess the risks associated with that transfer and apply additional safeguards where needed. For specific government partnership programmes, additional or different arrangements may apply under that programme’s own agreement.
13. SECURITY
We apply technical and organisational measures appropriate to the sensitivity of the data we hold, including encryption of data at rest and in transit, role-based access control, multi-factor authentication on internal systems, regular review of access rights, and contractual security requirements on our hosting and technology providers.
14. YOUR RIGHTS
You have the right to: ask what personal data we hold about you; ask us to correct inaccurate data; ask us to delete your data; ask us to restrict or object to certain processing; ask for a copy of your data in a portable format; and withdraw consent at any time, where consent is our basis for processing. To exercise any of these, contact us using the details in section 16.
If you are in the European Union or United Kingdom
You have the rights listed above under the GDPR (or UK GDPR). You also have the right to complain to us directly first, see section 14, before referring the matter to your national data protection authority, or, for UK matters, the Information Commissioner’s Office (ICO), quoting our registration reference ZA320513.
If you are in Mexico
Applicable data protection law gives you ARCO rights: you can request Access to the personal data we hold about you, Rectification of inaccurate data, Cancellation of your data (comparable to a right of erasure), and you can Oppose certain uses of your data. Consent to process a minor’s personal data must be given by a parent or legal guardian, and we apply the best interests of the child as a guiding principle when doing so. You can exercise these rights, or raise a complaint, using the details in section 16, or by contacting Mexico’s data protection authority, the SecretarÃa Anticorrupción y Buen Gobierno.
If you are in the United States
Our services are not directed to children under 13. This notice is not a notice under the California Consumer Privacy Act (CCPA); as a nonprofit organisation, Think Equal is not subject to the CCPA. We do comply with the California Online Privacy Protection Act (CalOPPA). We do not sell personal data and will not treat you differently for exercising any privacy right.
Wherever you are
You can always contact us to ask what data we hold about you, to correct it, or to ask us to delete it, and we will respond in line with the standard set out in this policy.
15. HOW TO COMPLAIN
If you believe we have not handled your personal data properly, please contact us first at digital@thinkequal.org so we can look into it and respond. If you are not satisfied with our response, you can escalate the matter to your national data protection authority, the ICO (UK), or Mexico’s SecretarÃa Anticorrupción y Buen Gobierno, as applicable to you.
16. CHANGES TO THIS POLICY
We may update this policy from time to time to reflect changes in our practices or in the law. Where changes are significant, we will take reasonable steps to notify LMS users before the changes take effect. The date at the top of this document shows when it was last prepared.
17. CONTACT US
If you have any questions about this policy, or want to exercise any of the rights described above, please contact us at digital@thinkequal.org, or write to us at Think Equal, 900 Foulk Road, Suite 201, Wilmington, New Castle County, Delaware 19803, USA.
Last updated: August 2026
