PRIVACY POLICY

Dear User,

The purpose of this Information Notice is to inform you about the methods and purposes of the processing of personal data concerning you, carried out in full compliance with current legislation on the protection of personal data.

I. DATA PROCESSED

1. Data Controller

Social Things SRL - via Battista de Rolandi 1, 20156 MILANO (MI)

Email address: privacy@socialthingum.com

2. Personal data subject to processing

By means of the Website, Social Things srl processes the following Personal Data:

  • User data. In order to use any features (for example, creating or simply enrolling in a course), you must create a user account. When you create or update your account, we process and store the information you provide voluntarily, such as your first and last name, email address and password.
  • Profile data.The provision of personal data provided in the "User profile" tab (telephone number, photo, gender and date of birth, city, education, employment, preferences, blog postings, course evaluations, assigning a unique identification number) is optional and, as such data may be visible to other users registered on the Site, please do not include sensitive data in that tab. Registering the User through the Facebook account involves linking the User's data to the Website and links the Facebook profile with the Site itself.The User profile data will be publicly visible and, therefore, can be seen by other users.
  • Data of unregistered users.The optional, explicit and voluntary sending of e-mails to the addresses indicated on the Site entails, by its very nature, the subsequent acquisition of the sender's address, necessary to respond to requests, as well as any other personal data included in the relevant forms or e-mails sent. We invite Users, in requests for services or questions, not to send names or other personal data of third parties that are not strictly necessary nor sensitive data and/or judicial.
  • Special categories of personal data and/or "sensitive data". As for art. 9 GDPR and 26 Privacy Code (for instance, personal data revealing racial or ethnic origin, political opinions, religious beliefs, state of health, etc.): these categories of data contained in the curricula or other documents uploaded to the web platform will be immediately deleted unless supported by specific and explicit consent to processing. The Curricula must therefore contain a subscription, pursuant to art. 9, EU Regulation 679/2016 and art. 26 of Legislative Decree 196/2003 that authorizes Whoteach to process personal data according to the purposes specified in the policy.
  • A child under the age of sixteen who has access to Whoteach without parental or guardian consent should not register as a User.

  • Shared Content. Whoteach web platform allows you to interact with other users or publicly share content, such as posting reviews on a course page, asking questions or providing answers, sending messages to users, or posting photos or other uploaded works. This shared content may be publicly visible, depending on where it was posted.
  • Course data. When you create or subscribe to a course, we collect certain data such as the course, the uploaded content and any tests, exchanges with other users, and, finally, essays, answers to questions and other materials submitted to meet the requirements of the course.
  • Communication and support. When you contact Whoteach for support or to report a problem or concern (whether or not you have created an account), we may collect and store contact information, messages and other data about you, such as your name, email address, operating system, IP address and any other information you provide or that we may collect through automated means (processed below). The data thus collected is used to respond to and review your request under this Privacy Policy.

The provision of personal data by the user is free and optional. However, if the User refuses to communicate it, it may be impossible for Social Things srl to provide the requested service.

3. Purpose of Processing Personal Data

The Personal Data provided by the User through the website will be processed by Social Things srl on behalf of Whoteach for the following purposes:

  • 1. Purposes related with the performance of the contract where the User is a party or the performance of pre-contractual measures taken at his request (eg: request for contact through the contact form);
  • 2. Purposes related to the website registration, which allow you to create a user profile including personal information such as name and surname, email address, age, city / location, educational qualifications, field of work, preferences, interventions in the blog evaluations of courses and authentication activities through registration of access (eg first access to the site and last access to the site).
  • 3. Purposes of research / statistical analysis on aggregated or anonymous data, therefore without the possibility of identifying the user, aimed at measuring the operation of the Site, measure traffic and evaluate usability and interest;
  • 4. Purposes related to the fulfilment of a legal obligation to which Social Things srl is subject;
  • 5. Purposes necessary to ascertain, exercise or defend a right in court or whenever the judicial authorities exercise their jurisdictional functions;
  • 6. To obtain further detailed information on the purposes of the processing and on the Personal Data specifically relevant for each purpose, the User may refer to the relevant sections of this document.

5. Legal basis of the processing

The Data Controller processes the User's personal data for the achievement of precise purposes and only in the presence of a specific legal basis provided for by the applicable law on privacy and protection of personal data. By using or consulting this site, visitors and users explicitly approve this privacy policy and consent to the processing of their personal data in relation to the methods and purposes described below, including any disclosure to third parties if necessary for the provision of a service. The provision of data and therefore consent to the collection and processing of data are optional, the user can deny consent, and may withdraw at any time the consent already given. However, denying consent may make it impossible to provide certain services and the experience of browsing the site would be compromised. The data of registered users are processed only after registration to the site, resulting in the issuance of access credentials.

6. Data retention period

The data are processed and stored for the time required for the purposes for which they were collected. Therefore:

  • Personal data processing for purposes related to the execution of a contract between the Data Controller and the User will be retained until the execution of such contract is completed.
  • Personal data processing for purposes related to the legitimate interest of the Data Controller will be retained for the time necessary and supported by the same. For more information on the criteria for determining the period of retention of personal data in question, you can contact us at the address provided.
  • When processing is based on the User's consent, the Data Controller shall process the personal data until such time as the User's consent is revoked.

The Data Controllor may be required to retain personal data for a longer period in accordance with a legal obligation or by order of an authority. In any case, at the end of the retention period, the personal data will be deleted. Data used for site security purposes (blocking of attempts to damage the site itself) are stored for 30 days. Data for analytics purposes (statistics) are stored for 24 months.

8. Interaction with social networks and external platforms

QThis type of service allows you to interact with social networks, or other external platforms, directly from the pages of https://www.whoteach.eu/lms/. The interactions and information acquired by Social Things srl are in any case subject to the privacy settings of the User for each social network. This type of service may still collect traffic data for the pages where the service is installed, even when the Users do not use it. It is recommended to disconnect from the respective services to ensure that the data processed on https://www.whoteach.eu/lms/ are not linked to the User's profile. .

Facebook widget button (Facebook, Inc.)

Facebook widget button is a service of interaction with the social network Facebook, provided by Facebook, Inc.

Personal Data processed: Cookies; Usage Data.

Place of processing: USA – Privacy Policy.

This type of service allows you to view and interact with content hosted on external platforms directly from the pages of https://www.whoteach.eu/lms/

If such a service is installed, it is possible that, even if Users do not use the service, it collects traffic data relating to the pages on which it is installed.

9. Viewing content from external platforms

YouTube Video Widget Button (Google Inc.)

YouTube is a video content viewing service managed by Google Inc. that allows Social Things srl to integrate such content into its pages.

Personal Data Collected: Cookies; Usage Data.

Place of treatment: USA - Privacy Policy.

Statistics

The services contained in this section allow the Data Controller to monitor and analyse traffic data and are used to keep track of the User's behaviour.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of https://www.whoteach.eu/lms/, compiling reports and sharing them with other services developed by Google. Google may use your Personal Data to contextualize and customize ads in its advertising network. Personal Data Collected: Cookies; Usage Data.

Place of processing: USA– Privacy PolicyOpt Out

II. USER RIGHTS

The User, as an interested party, is guaranteed by the Data Controller the exercise of the rights that are recognized under the legislation on the personal data protection.

In particular, the User has the right to:

  • Withdraw their consent at any time, when the processing of their personal data is based on consent;
  • Oppose the processing of their data;
  • Access the information regarding the processing of their data, and to receive a copy of the data processed.
  • Verify the personal data processed and request its rectification;
  • to obtain the limitation of the processing, when certain conditions are met;
  • obtain the cancellation or removal of their personal data, when certain conditions are met;
  • receive their data or have them transferred to another holder, in structured format, commonly used and readable by automatic device and, where technically feasible, without obstacles. This provision is applicable when the Data is processed by automated means and the processing is based on the User's consent, on a contract to which the User is a party or on contractual measures connected to it;
  • lodge a complaint with the competent data protection supervisory authority

In order to exercise the User's rights, Users may address a request to the contact details of the Data Controller indicated in this document. Requests are filed free of charge and processed by the Holder as soon as possible, in any case within one month.

More information about the treatment

System log and maintenance

For needs related to operation and maintenance, https://www.whoteach.eu/lms/ and any third party services used by it may collect system logs, ie files that record interactions and may also contain Personal Data, such as the User IP address.

Response to "Do Not Track" requests

https://www.whoteach.eu/lms/ does not support "Do Not Track" requests. To find out if any third party services you use support them, please refer to their privacy policies.

Privacy Policy Changes

The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on https://www.whoteach.eu/lms/ and, where technically and legally feasible, by sending a notification to Users through one of the contact details held by the Data Controller. Please consult this page regularly, referring to the date of the last change indicated at the bottom.

III. AMENDMENTS

This Privacy Policy came into force on 25 May 2018. Social Things srl reserves the right to modify or simply update the content, in part or in full, including due to changes in the Applicable Law. Social Things srl will inform the user of such changes as soon as they are introduced and will be binding as soon as they are published on the Site. Social Things srl therefore invites the user to regularly visit this section to learn about the most recent and updated version of the Privacy Policy so that you are always updated on the data collected and the use that Social Things srl carries out.