Learning360Learning and the GDPR: agreement, role and data location.
360Learning is a learning tool. Most customers use it as a processor, it explains how to get its data processing agreement, and the data location depends on your account. Below: what to check and how to declare it.
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In short
- Category
- Learning
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Obtained through the vendor
What does 360Learning do with personal data?
Host online courses, communities or training and manage learners. That is how Privacyboard describes a typical use of 360Learning, as a starting point you can edit.
The data usually involved: names, email addresses, payment details, progress, completion data, community posts
Is 360Learning a processor or a controller?
Most customers use 360Learning as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for learning tools and it is what Privacyboard suggests.
As a processor, it needs a written agreement with you under Article 28, and you should know which subprocessors it uses. Confirm the role against your own agreement, because the way you use a tool can change it.
Where does 360Learning store personal data?
360Learning does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable.
How to find yours: Check your account settings, the address you log in to, or the provider’s data processing terms. Support can tell you if you cannot find it.
Even when the main location is in the EU, ask whether subprocessors or support access involve a transfer outside the EEA, and record it if so.
Which legal basis usually applies to 360Learning?
For the usual use of 360Learning, companies most often rely on performance of a contract (GDPR Article 6(1)). Giving access to a course or community the person signed up for is the contract.
Marketing to learners and analytics beyond course progress need their own basis.
This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Does 360Learning have a data processing agreement?
Checked on 12 November 2026. Vendors change their pages, so check the date.
360Learning does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy.
What we noted when we opened the page: 360Learning help article on GDPR compliance: 360Learning processes platform data on the customer's behalf (described as data sub-processor) under a DPA based on the European Commission's standard model, with a DPO appointed and ISO 27001 certification. No entity, hosting location or contact address on the page.
A page that exists does not mean you are covered. Whether the agreement applies to you depends on your plan and on what you accepted, so record the decision yourself in your vendor list.
Open the 360Learning reference pageHow to declare 360Learning
- 1
In your privacy policy
Name 360Learning as a recipient, say what it is used for (host online courses, communities or training and manage learners) and mention any transfer outside the EEA. Articles 13 and 14 ask you to tell people who receives their data.
- 2
In your vendor list
Add 360Learning with its purpose, the data involved, its role, its region and a link to the agreement. Privacyboard prefills all of this, you confirm or correct it.
- 3
In your processing register
Link 360Learning to the activities that use it, so each record shows its recipients. Article 30 asks the register to list the categories of recipients.
What to check before relying on 360Learning
- Check what learners can see about each other in communities and forums.
- Set what happens to accounts and progress when access ends.
- Check the role of the payment provider built into the platform.
- Record the region and any transfer outside the EEA.
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Questions, answered.
Is 360Learning GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how 360Learning is configured and used, on the agreement you have with it and on your own practices. What can be checked is documented here: it explains how to get a data processing agreement, the usual role and the data location. Read the agreement itself before relying on it.
Does 360Learning have a DPA?
360Learning does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy. The reference page is https://support.360learning.com/hc/en-us/articles/360020875591-360Learning-Compliance-with-GDPR.
Is 360Learning a data processor?
Usually, yes. Most customers use 360Learning as a processor that acts on their instructions. Check your own agreement and how you use the tool, because the role can differ.
Which legal basis applies when I use 360Learning?
For the usual use of 360Learning, companies most often rely on performance of a contract (GDPR Article 6(1)). Giving access to a course or community the person signed up for is the contract. Marketing to learners and analytics beyond course progress need their own basis.
Where does 360Learning store data?
360Learning does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable. How to find yours: Check your account settings, the address you log in to, or the provider’s data processing terms. Support can tell you if you cannot find it.
Do I need to mention 360Learning in my privacy policy?
Yes, if 360Learning handles personal data for you. The GDPR asks you to tell people who receives their data (Articles 13 and 14). Name the vendor or its category, say what it is used for and mention any transfer outside the EEA.
How do I add 360Learning to my vendor list?
In Privacyboard, pick 360Learning from the catalog. The purpose, the data, the suggested role and a link to its agreement are prefilled, and you confirm each one. Creating a workspace is free.
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Privacyboard is not affiliated with 360Learning. Names and logos belong to their owners and are used only to identify the tool. This page summarises public documents as checked on 1 November 2026; it is guidance, not legal advice, and it does not certify any vendor.