End User License Agreement (EULA)

 

IMPORTANT, PLEASE READ CAREFULLY: THIS END USER LICENSE AGREEMENT “EULA” IS A LEGAL AGREEMENT BETWEEN YOU (AS AN INDIVIDUAL OR ENTITY, “YOU” THE “CUSTOMER”) AND Mobius Learning (“Mobius Learning”), FOR PRODUCTS AND SERVICES, WHICH MAY INCLUDE COMPUTER SOFTWARE AND ASSOCIATED DOCUMENTATION (“SOFTWARE”). BY INSTALLING OR OTHERWISE USING THE SOFTWARE OR RECEIVING THE SERVICES, YOU AGREE TO BE BOUND BY THE TERMS OF THIS EULA. IF YOU DO NOT AGREE WITH THE TERMS OF THIS EULA, DO NOT USE THE SOFTWARE OR SERVICES.

1.0 License Grant. This EULA grants you, the user, a non-exclusive, non-transferable license to use the Software, in object code for your internal business purposes (and not for managing third party data unless the product you have licensed expressly permits you to) under the terms and conditions stated herein. The Software is to be installed, used, and deployed in accordance with the specific license you purchased, a description of the license can be found at https://www.MobiusLearning.com/privacy-policy (“Licensing Policy”). This EULA and the Licensing Policy can be updated from time to time, in Mobius Learning’s sole discretion and will be made available at www.Mobius Learning.com

2.0 Permissible Use. You may use the Software for the number of licenses or capacity that you have purchased. You are permitted to make copies of the Software and documentation for your own use in accordance to EULA and Licensing Policy. Any copies or partial copies of Software and documentation that you make must incorporate all patent, copyright and trademark notices.

3.0 Prohibited Use. You may not (a) process third party data (as a service provider), provide commercial hosting services, sell, sublicense, rent or lease the Software to another party without purchasing the specific Mobius Learning license to do so, (b) decompile, disassemble, reverse engineer or modify in any manner, any of the Software (except to the extent such prohibition is expressly prohibited by law), (c) use the Software in violation of any applicable laws or regulations, or (d) make available the Software or your license file on any type of public sharing website or forums. The restrictions on using the Software to process the data of third parties, provide commercial hosting services, sublicense, rent or lease the Software does not apply to those participants of the Mobius Learning Cloud & Service Provider Program (“VCSP Program”), granted the rental license to use the Software under the terms of the VCSP Program. You agree that you may not disclose, transfer or otherwise make available the results of any performance or functionality tests of the Software, to any third party without the prior written consent of Mobius Learning.

4.0 Evaluation and “Not for Resale” Licenses. Software may be provided to you for beta, demonstration, test or evaluation purposes, or is labeled as “Not for Resale” (“NFR”). The license granted under an Evaluation, Beta or NFR license shall be for a term of thirty (30) days (the “Evaluation Period”) unless otherwise provided by Mobius Learning, limited specifically for evaluation or demonstration purposes only. You agree not to use the Software under an Evaluation License in a production environment or for production data processing purposes and your use of a Beta or Evaluation License Software is at your sole risk to backup data. There is no obligation to support, maintain or provide any assistance regarding any of these licenses. In no event will Mobius Learning be liable for any damages for any claim or cause for any direct, actual, indirect damages, loss of data, consequential, incidental or special indirect damages, even if Mobius Learning has been advised of the possibility of such damages.

5.0 Free Licenses and Community Licenses. Free and Community License products can be used in your own production environment in accordance with the terms and conditions of this Agreement. You may not use the Free and Community Licenses to provide services to third parties or to process third party data. These versions can be used without additional purchase and can be upgraded to paying versions of the products to unlock additional functionality and features. There is no obligation to support, maintain or provide any assistance regarding any of these licenses. In no event will Mobius Learning be liable for any damages for any claim or cause for any direct, actual, indirect damages, loss of data, consequential, incidental or special indirect damages, even if Mobius Learning has been advised of the possibility of such damages.

6.0 Maintenance and Support (“Maintenance”) for the Software is available in accordance with Licensing policy and Support Policy, which can be found at www.Mobius Learning.com/support.html. Maintenance, if it is included in the Software purchased, will commence upon the date your order is processed and the license file is generated. You will receive (a) support for your Software, and (b) any updates, enhancements or improvements that are included or defined in the Maintenance Policies. Software updates cannot be applied to the Software with an expired Maintenance.

7.0 Technical Information Collection. You agree that Mobius Learning may, for business purposes and improving the Software, collect, process and use technical information that is gathered as part of any product maintenance and support services provided to you, and any other technical information you provide to Mobius Learning, provided that such information does not identify You, a specific individual, or contain any personally identifiable information. By providing technical data and information to Mobius Learning, you consent to Mobius Learning’s storage and processing of such technical information for purposes of providing Software and support to you.

8.0 Technical Reporting and Logs. The Software has the capability to provide certain reports and survey information, including the generation and collection of geolocation data, regarding its use to Mobius Learning. This data collection is turned OFF by default and must be enabled by you. You always have the option to enable or disable at any time. Any information collected is deemed confidential and will only be used by Mobius Learning internally to enhance the quality of the Software.

9.0 Personal Information. In the event you provide personal information to Mobius Learning as part of your purchase and use of the Software, or for obtaining Maintenance, your personal information will be used, stored and processed in accordance with the Mobius Learning Privacy Policy, which can be found at https://www.MobiusLearning.com/privacy-policy. You can always update your preferences by visiting the Mobius Learning customer portal.

10.0 Capacity Limitations in Software. For certain Software, your use of the Software may be limited by the capacity purchased. In the event you exceed the purchased capacity, the Software may not process additional workloads beyond the maximum capacity until you purchase additional capacity.

11.0 Intellectual Property Rights. All right, title and interest to the intellectual property rights in and to the Software, and any copies that you are permitted to make, are owned by Mobius Learning and / or its licensors and is protected by Swiss, United States and other country patent, copyright, trade secret and other laws and international treaties. Such licensors, in addition to any other rights or remedies available to them, are third party beneficiaries of this EULA for their respective software. This Software is LICENSED, NOT SOLD. The purchase of the Software license (perpetual or subscription), is non-returnable and non-refundable. The Software is protected by patents, and certain trademarks and logos used in the software are protected by trademarks. A list of patents and trademarks can be found at https://www.Mobius Learning.com/Mobius Learning-patents-and-registered-trademarks.html.

12.0 Audit. During the term of this Agreement and for a period of one year thereafter, Mobius Learning may, during normal business hours and upon reasonable prior notice to End User, inspect the files, computer processors, equipment and facilities of End User to verify End User’s compliance with this EULA.

13.0 Open Source and Third Party Software. “Open Source” means various open source software components licensed under the terms of applicable open source license agreements included in the materials relating to such software. Open Source Software is composed of individual software components, each of which has its own copyright and its own applicable license conditions. A current list of Open Source Software and third party software components used by Mobius Learning can be found at http://www.MobiusLearning.com.

14.0 Mobius Learning Community Forums. Any information that you post on the Mobius Learning Community Forums is deemed non-confidential to you. Mobius Learning has no obligation to manage or protect any information (confidential or personal) that you disclose on the Mobius Learning Community Forums.

15.0 Limited Warranty and Limitation of Liability. Mobius Learning warrants that it has the right and authority to grant the License under this EULA. Mobius Learning will defend or, at its option, settle any action against End User based upon a claim that its use of the Software infringes any patent, copyright or other intellectual property right of a third party, and will indemnify End User against any amounts awarded against End User as a result of the claim, provided Mobius Learning is promptly notified of the assertion of the claim and has control of its defense or settlement. Mobius Learning warrants that the Software, in its unmodified form as initially delivered or made available to End User, will perform substantially in accordance with the Documentation for a warranty period of ninety (90) days from the date the Software is delivered to End User. This warranty does not apply to Licenses under sections 4.0 and 5.0. In the event the Software fails in a material respect to operate in accordance with the Documentation during the warranty period and Mobius Learning is unable to correct the defect, Mobius Learning’s sole and exclusive liability and End User’s sole and exclusive remedy shall be a refund of the License fee, if any, paid by End User for the Software. In the event a reported problem with the Software is End User’s fault, End User agrees to reimburse Mobius Learning for its correction efforts in accordance with its then standard rates. The foregoing limited warranty will not apply if failure of the Software is the result of damage or misuse caused by End User. EXCEPT FOR THE LIMITED WARRANTY SET FORTH ABOVE, THE SOFTWARE IS PROVIDED ‘AS IS”, WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION ANY IMPLIED WARRANTY THAT THE SOFTWARE IS FREE OF DEFECTS, MERCHANTABLE OR FIT FOR A PARTICULAR PURPOSE. NO ORAL OR WRITTEN INFORMATION OR ADVICE GIVEN BY Mobius Learning OR ANY THIRD PARTY, INCLUDING, WITHOUT LIMITATION, ANY Mobius Learning DISTRIBUTORS OR RESELLERS, SHALL CREATE ANY WARRANTY IN ADDITION TO, OR IN ANY WAY INCREASE THE SCOPE OF, THE LIMITED WARRANTY. In no event will Mobius Learning, its affiliates, resellers, or distributors or suppliers be liable for any indirect, special, incidental or consequential damages arising out of the use of or inability to use the Software, including, without limitation, damages for lost profits, loss of goodwill, work stoppage, computer failure or malfunction, or any and all other commercial damages or losses, even if advised of the possibility thereof.

16.0 General. This Agreement sets forth Mobius Learning’s entire obligation and End User’s exclusive rights with respect to the Software and, except to the extent otherwise specifically provided in a purchase order or other written communication or advertising signed or jointly issued by both parties with respect to the Software, supersedes any conflicting terms of any purchase order and any other communication or advertising with respect to the Software. No failure of either party to exercise or enforce any of its rights under this EULA will act as a waiver of those rights. If any provision of this EULA is found illegal or unenforceable, it will be enforced to the maximum extent permissible, and the legality and enforceability of the other provisions of this EULA will not be affected. This EULA will be governed by the laws of Switzerland, without regard to its choice of law principles. You agree that exclusive jurisdiction for any claim or dispute arising out of or in connection with this EULA resides in the Courts of Switzerland in the Canton of Zug. This Agreement and the underlying licenses may not be assigned without completely removing the software installation from the assignor, notifying and providing Mobius Learning with the assignee contact information (for support purposes), and is subject to the assignee agreeing to and complying with the terms and conditions of this Agreement and the Licensing Policy.

Student Privacy Notice

This is the Privacy Notice for Moodle Pty Ltd (or “we”), the company at the heart of the Moodle™ community. The Moodle™ software is free and open source, and may be hosted by us, but also by anyone who wishes to manage an installation. This tells you how we will collect and use your personal data to provide our services which allow educators to create a private space online, filled with tools that easily create courses and various activities, all optimised for collaborative learning. 

We have the wellbeing of the community and the users of Moodle™ services at the heart of everything we do. 

Importantly, this Privacy Notice outlines how we manage your personal data. If the website you are using is not hosted by us, then the hosting IT administrator of your website will have separate Privacy Law obligations to you. In such circumstances you will need to check directly with your hosting IT administrator as to how your personal data is being managed by them. 

We hope this Privacy Notice outlines how we manage any of your personal data in its control in a clear and straightforward way. 

 

Who are we? The Data Controller and Data Protection Officer

  • The Data Controller for data processed under this Notice is:
    Moodle Pty Ltd. (ABN 55 116 513 363)
    First Floor, 20 Kings Park Road
    West Perth WA 6005 (Australia)
    Submit your enquiry here
  • Our independent Data Protection Officer is:
    Data Compliance Europe Ltd.
    Lower Bridge Street
    Dublin 8 (Ireland)
    email: dpo@moodle.com

What is covered by this Privacy Notice?

Your privacy protection is central to us. This is why we have adopted the EU’s General Data Protection Regulation 2016/679 (“GDPR”) as our global standard. It is the most advanced and protective Privacy Law globally. 

Under GDPR personal data is defined as: “any information relating to an identified or identifiable natural person (‘Data Subject”) and a Data Controller determines the purpose and means of processing personal data., whereas a Data Processor is responsible for processing data on behalf of the Data Controller.

This Privacy Notice relates to everyone whose personal data is processed by us.

Because the Moodle™ software is open source, anyone can install it on their own equipment or device. So, please note that:

  • where Moodle Pty hosts a website on its own behalf it is the Data Controller for all the personal data collected. Where Moodle Pty Ltd hosts someone else’s installation of the Moodle Platform (as with MoodleCloud) it is the Data Processor for the website administrator of that particular installation.
  • where Moodle Pty Ltd does not host an installation of the software platform, it is neither the Data Controller nor the Data Processor and those duties fall on the people or organisation(s) who have installed and host those installations.

Why does the Moodle Mobile application not need to collect and store any personal data?

Simply, we do not need your personal data to provide you with our Moodle Mobile application.

If we provide you with separate additional services through external installations hosted or not by us, we will always seek confirmation from you that it’s ok to do that.

Additional services provided by us are completely separate from the Moodle Mobile application and in case it is needed we will submit for your consent the relevant Privacy Notice and explain how personal data related to you for specific purposes are collected and what is the nature of the data collected depending on your interaction with us. We are committed to transparency in this and we will provide a very detailed breakdown of these processes in the applicable Privacy Notice submitted.

Why do we need to collect and store personal data?

In order for us to provide you with MoodleCloud and other Moodle-hosted websites we need to collect your personal data for correspondence purposes and/or to allow us to provide you our service(s). We ensure that the information we collect and use is appropriate for this purpose. We are a company which values its users’ data protection and privacy rights and we have no interest in collecting any 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 Privacy Notice, but will always seek additional confirmation from you that it’s ok to do that.

We always process your personal data for specific purposes, with the nature of the data collected depending on your interaction with us. We are committed to transparency in this. 

Our legal bases for the processing of personal data are:

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

If you would like more details please refer to Annex 1.

We only rely on ‘legitimate interests’ as the legal basis for processing by us, or third parties we use, for these purposes;

  • 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
  • providing login systems to users via their existing social media accounts

The special categories of personal data we process 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)

Do we share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to Moodle Pty Ltd 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 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 our procedures.

We enter into Data Processing Agreements with our third-party service providers to ensure their commitment to these principles. 

If we need 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 a 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 us and we will be happy to provide it.

How does Moodle Pty Ltd use my personal data?

We 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. We maintain a register of personal data processes which include a record of the data retention policy for each type of data collected and we commit to only process the minimum amount of data needed. We are 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.

Can I find out the personal data that the organisation holds about me?

We at your request, can confirm what information we hold about you and how it is processed. If we 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 our legitimate interests 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 European Union 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.

How can I access my personal data rights?

We accept a request made through your personal Moodle account while you are logged in. In certain circumstances we 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

Agreement to these terms of service provides explicit consent for data processing

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 us 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:

  • In MoodleCloud, “Moodle Apps Plans portal” and other Moodle hosted websites: By contacting us
  • In self – hosted Moodle installations’: By contacting the Data Protection Officer for your Data Controller

To help us to respond as quickly as possible to your request, please identify your role in relation to us (if you are a contractor, employee, Moodle partner, end-user, site administrator etc.), and the processing for which you wish to withdraw consent.

Retention period and your GDPR rights

We will process different forms of personal data for as long as it is necessary and proportionate for the purpose for which it has been supplied and we 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 us.

Your rights as a Data Subject

At any point while we are in possession of your personal data or we process those, 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 Moodle Pty Ltd 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.

Where we are your Data Controller, you may make a request directly to the Data Protection Officer using the email address dpo@moodle.com

Where we are a Data Processor, and act on behalf of a data controller (such as MoodleCloud) any requests received by us will be passed on to the Data Controller.

Where we are not involved with your personal data, such as where the Moodle™ software has been self-hosted, you should address your requests to the Data Controllers of those websites since we have no access to your personal data.

Retention period

Moodle Pty Ltd 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 us

Your rights as Data Subject

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 Moodle Pty Ltd 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.

Where Moodle Pty Ltd are your Data Controller, you may make a request directly to the Data Protection Officer using the email address dpo@moodle.com

Where Moodle Pty Ltd are a Data Processor, and act on behalf of a data controller (such as MoodleCloud) any requests received by Moodle Pty Ltd will be passed on to the Data Controller.

Where Moodle Pty Ltd are not involved with your data, such as where the Moodle platform has been self-hosted, you should address your requests to the data controllers of those sites. Moodle Pty Ltd will have no access to your data.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by us (or third parties as described above), or how your complaint has been handled, you have the right to lodge a complaint directly with a Supervisory Authority and also with our Data Protection Officer, Data Compliance Europe Ltd.

If you wish to make a complaint about how your personal data has been processed in MoodleCloud, or by a self-hosted installation of the Moodle™ software you should contact your Moodle Site Administrator or the Data Controller for your Moodle installation. (For example, if your university or school hosts its own Moodle site, it will be the Data Controller).

The details of contacts for complaints where we are the Data Controller:

 

 

Supervisory Authority contact details

Data Protection Officer (DPO) / GDPR Owner contact details

Contact Name:

Data Protection Commissioner

Data Compliance Europe,

Address line 1:

Canal House

Lower Bridge Street

Address line 2:

Portarlington

Dublin 8

Address line 3:

Co Laois

  

Address line 4:

R32 AP23

  

Email:

info@dataprotection.ie

dpo@moodle.com

Telephone:

+353 57 8684800

+353 1 6351580

The contact details in case where Moodle Pty Ltd is not the Data Controller, should be made available directly by your Data Controller in your Moodle installation.

 

Last updated: November 2020

What personal data we collect and why we collect it

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.