Data Processing - Axoryn Technology

Notice: This document describes AXORYN Technology's practices for the website axoryn.tech, the Virtual Classroom aula.axoryn.tech, and associated digital services. It has been drafted in accordance with international data-protection and digital-consumer principles (EU GDPR, Peru's Law 29733, and ISO/IEC 27701 good practices). It does not replace personalized legal advice; for specific cases, please contact contacto@axoryn.tech.

This document supplements the Privacy Policy and transparently describes the main personal-data processing activities carried out by AXORYN Technology (accountability principle).

1. Data controller

Legal name	Axoryn Technology LLC
Trade names	Axoryn Technology
Websites	axoryn.tech · aula.axoryn.tech
Privacy contact	contacto@axoryn.tech
Reference frameworks	EU GDPR · Peru's Law 29733 · ISO/IEC 27701 good practices

2. Processing activities (summary)

2.1. Management of contacts and sales leads

Purpose	Handling inquiries, GRC diagnostics, and requests for information about courses/simulators
Data	Name, email, mobile number, subject, message; company name if provided
Legal basis	Consent and/or pre-contractual measures
Retention	Until the request is resolved; a maximum of 3 years without an active relationship
Source	Web form / email

2.2. Student and instructor accounts (Virtual Classroom)

Purpose	Provision of the e-learning service, enrollments, progress tracking, certificates
Data	Identity, credentials, role, enrollments, progress, certificates
Legal basis	Performance of contract
Retention	For the duration of the relationship and applicable statutory periods thereafter

2.3. Simulator licenses and digital purchases

Purpose	Activating/extending licenses, monitoring validity, recording transactions
Data	Bound email (bound_email), license key, certification, dates, amount, payment reference
Legal basis	Performance of contract; legal obligation (invoicing) where applicable
Retention	Validity period + applicable tax/accounting periods

2.4. Exam evaluation and proctoring

Purpose	Exam integrity, scoring, reports to the student
Data	Answers, scores, timings, incidents (tab switching, camera off, multi-session)
Legal basis	Performance of contract; legitimate interest in preventing academic fraud
Note	Monitoring is event-based; it does not, by default, involve continuous video recording of the student

2.5. Site security and abuse prevention

Purpose	Rate limiting, reCAPTCHA, bot detection, access logs
Data	IP address, user agent, tokens, technical logs
Legal basis	Legitimate interest; security obligation

2.6. Service communications

Purpose	Welcome messages, password recovery, license notices, support
Legal basis	Performance of contract

3. Typical processors and sub-processors

Hosting / email provider (site infrastructure and SMTP)
Payment processor (when the payment gateway is active)
Google (reCAPTCHA; Tag Manager and, only with your consent, analytics and advertising tools on the public site; Gemini API used solely for internal generation of questions by administrators, not as a destination for end-student data in the ordinary flow)

Processors are subject to contractual obligations of confidentiality, security, and documented instructions.

4. Automated decisions and profiling

AXORYN does not make automated decisions with significant legal effects on individuals without human intervention. Exam scores are objective results of the questionnaire; the invalidation of an exam due to proctoring incidents is based on technical rules communicated to the user and can be reviewed through support.

5. Security measures (summary)

HTTPS/TLS, security headers (HSTS, CSP, nosniff, frame-ancestors)
CSRF protection, hardened sessions, rate limiting
Role-based access control (admin, instructor, student)
Sanitization of lesson HTML content
Backups and data minimization in public APIs

6. Exercising your rights

Send your request to contacto@axoryn.tech (subject line: "ARCO Rights / GDPR"). For details, see section 8 of the Privacy Policy.

Last updated: July 23, 2026 · Document controlled by AXORYN Technology

Information on Data Processing