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Federica Web Learning

Privacy & Cookies Policy

Federica Web Learning, University Centre for Innovation, Experimentarion and Diffusion of Multimedia Learning at the University of Naples Federico II, collects information about its users as they use the platform, in order to improve its services. Collection and treatment of user data is in line with law 196/2003 on data protection, and subsequent integrations, as well as with European GDPR Ruling 678/2016

Any questions about how your data is collected, stored and used should be addressed to our office as indicated below. This Privacy Policy may be subject to change but Federica Web Learning will not limit user rights as defined in this Privacy Policy without prior consent.

By using this website, users accept the terms of this Privacy Policy and consent to the collection and use of information as indicated in it.

  1. OWNER AND DATA CONTROLLER

Federica Web Learning – University Centre for Innovation, Experimentation and Diffusion of Multimedia Learning

Administration office : Università degli Studi di Napoli Federico II, via Partenope 36 – 80121, Napoli (Italy)

Email: federicaweblearning@unina.it

  1. RESPONSIBLE FOR PERSONAL DATA (RDP)

Dott.ssa Claudia Russo

Università degli Studi di Napoli Federico II, via Partenope 36 – 80121, Napoli (Italy)

federicaweblearning@unina.it

  1. MODE AND PLACE OF PROCESSING DATA

3.1. Ways in which data are processed

The Owner takes appropriate security measures to prevent unauthorised access, use, misuse, disclosure, modification or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons, involved in the organisation of the activities and services offered (administration, communication, marketing, legal, system administration) or external parties (such as third-party technical service providers,  hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

3.2. Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

3.3. Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the Owner section above.

3.4. Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

3.5 The purposes of processing the data collected

The Data concerning the User is collected to allow the Owner to provide its Service, as well as the following: Managing contacts and sending messages (paragraph 3.6.1) Statistics (paragraph 6), Interaction with platforms that collect data and other third parties (paragraph 6) and interaction with external social networks and platforms (paragraph 6).

3.6 Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services

3.6.1 Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  • Account registration form on Federica.eu (SignUp) (Register)
    By completing the registration form (SignUp) with their own Data, the User consents to the use of this Data to respond to the request for information or for other purposes indicated on the form itself.

     

    • Personal Data collected: Name, Surname; Email; Date of birth; Browser, Device, Gender (optional; Nationality (optional); Education + qualifications (optional), Profession (optional), Sector (opztonal), How did you hear about Federica (optional)
    • Place of data processing: Iceland – Privacy Policy.

Note: Users can also register via the Social Login via the following services: FacebookGoogleLinkedIn. In this case, only the compulsory information (name, surname, email) will be recorded on the server.

  • Support form: report a problem on Federica.EU
    By completing the Report a problem form with their own Data, the User consents to the use of this Data to respond to the request for information or for other purposes indicated by the title of the form itself.

     

    • Personal Data collected: User ID, Name, Surname, Email, Browser, Device.
    • Place of data processing: Italy: – Privacy Policy. Privacy Shield participant.
  • MailChimp (The Rocket Science Group, LLC.)
    MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC.
  • By signing up to the mailing list or newsletter via the double opt-in,  the User’s email is automatically included in a contact list which enables Federica Web Learning Centre to send email messages with information, including commercial and promotional information, about their work. User emails are also automatically added to this contacts list when users register on the Federica.EU platform.
    • Personal Data collected for users who are not registered on the Federica.EU platform: name, surname, email, date of birth, Postcode.
    • Personal Data collected for users registered on Federica.EU: name, surname, email, user ID, class code, date of birth.
    • Place of processing: United States – Privacy Policy. Privacy Shield participant.
  • Zendesk Support & Guide (Zendesk Inc.)
    Zendesk Support & Guide is a support and contact request management service provided by Zendesk Inc.
    When users send an email to info@federica.eu or support@federica.eu, the user email address is automatically inserted in a contacts list which enables Federica Web Learning Centre to send email messages providing help and information about the services they offer.  User email address can also be added to this contact list when they register on the Federica.EU platform.

     

    • Personal Data collected: email, name and surname and any other data provided for registration on the Federica.EU platform.
    • Place of processing: United States – Privacy Policy. Privacy Shield participant.
  1. HOSTING AND BACKEND INFRASTRUCTURE

The federica.eu website is hosted on servers located in Iceland. Data concerning registration to the platform, platform language cookies, data related to MOOC enrollments and assignment results are all collected and stored on those servers. Since Iceland belongs to the European Economic Area (EEA), the EEA legislation on privacy and the protection of personal data has been implemented.

Iceland Act no. 77/2000 on The Protection of Privacy as regards the Processing of Personal Data

  • Iceland Act no. 837/2006 on Electronic Surveillance;
  • Iceland Act no. 698/2004 on the Obligation to Notify and Processing which requires a Permit;
  • Iceland Act no. 299/2001 on security of personal data;
  • Iceland Act no. 322/2001 on the Management of Personal Information by the Police.

Some data, however, – mainly regarding user monitoring (questionnaires, registers, tracking) may be stored in European countries. In this case, data protection and security measures are covered by EU legislation (Directive on data protection 95/46 / CE).

You are asked for consent before any data is collected, in accordance with the European Union (EU) Data Protection Directive 95/46/EC

Registration is not allowed without user consent to Privacy and Terms and Conditions policies.

The federica.eu website may, from time to time, contain links to the websites of third parties. If you follow a link to any of these websites, please bear in mind that these websites have their own privacy policies and that we do not accept responsibility or liability for any of these policies. Please check these policies before you submit any personal information to these websites.

Secure Sockets Layer is a protocol that aims to allow the applications to transmit information in a secure and protected way. The applications that use the SSL certificates are able to manage sending and receiving of the protection keys, and encrypt and decrypt information transmitted using the same keys. In this way, all sensitive data that travels inside the platform maintains a heightened level of security. The same SSL certificate technology is used by federica.eu partners when communication between different platforms is needed; this keeps the data transfer secure not only within the federica.eu Platform but also when transferring data to and from the partner platforms.

  1. STATISTICS – ANALYTICS

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior to improve the services offered.

  • Federica Analytics (Federica Web Learning)
    Federica Analytics is the tracking system owned by Federica.EU and used to monitor user sessions. The system tracks a series of actions carried out on the platform including: number of accesses, session duration, access to resources (lessons, videos, images, audio-slides, quizzes and clicks on further study links)

     

    • Personal Data collected: Cookies and Usage Data.
    • Place of Processing: Italy – Privacy Policy. Privacy Shield participant.
  • Google Analytics (Google Inc.)
    Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Personal Data collected to contextualize and personalize the ads of its own advertising network.

     

    • Personal Data collected: Cookie e Usage Data.
    • Place of Processing: United States – Privacy Policy– Opt Out. Privacy Shield participant.
  • Vimeo Stats (Vimeo, LLC)
    Vimeo Stats is the video analytics platform for Vimeo LLC and allows for monitoring user activity on the platform videos, like number of views, viewing time, interaction with the player (play, pause, go forwards or go back).

     

    • Personal Data collected: Cookies and Usage Data.
    • Place of Processing: United States – Privacy Policy.
  1. INTERACTION WITH DATA COLLECTION PLATFORMS AND OTHER THIRD PARTIES
    This type of service allows users to interact with platforms that collect data or offer other services directly from the pages of federica.eu with the purpose of saving and reusing data.

This type of service might still collect traffic data from the pages where the service is installed,   even when Users do not use the service.

Video Vimeo (Vimeo, LLC)
Vimeo is a video content viewing service provided by Vimeo, LLC that allows Federica.EU to integrate video content on its pages.

  • Personal Data collected: Cookies and Usage Data.
  • Place of Processing: United States – Privacy Policy.

YouTube (Google, Inc.)
YouTube is a video content viewing service managed by Google, Inc. which allows  Federica.EU to integrate video content on its pages.

  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: United States – Privacy Policy.
  1. INTERACTION WITH EXTERNAL PLATFORMS AND SOCIAL NETWORKS

This type of service allows interaction with social networks or other external platforms directly from the pages of the Federica.EU platform.

The interaction and information obtained through Federica.EU are always subject to the User’s privacy settings for each social network.

This type of service might still collect traffic data for the pages where the service of interaction with the social network is installed, even when Users do not use it.

Facebook Like button and social widgets (Facebook, Inc.)
Facebook “Like” button and social widgets are services allowing interaction with the Facebook social network, provided by Facebook, Inc.

  • Personal Data collected: Cookies and Data Usage.
  • Place of Processing: United States – Privacy Policy. Privacy Shield participant.

Twitter Tweet button and social widgets (Twitter, Inc.)
The Twitter Tweet button and social widgets are services allowing for interaction with the Twitter social network provided by Twitter, Inc.

  • Personal Data collected: Cookies and Data Usage.
  • Place of Processing: United States – Privacy Policy. Privacy Shield participant.

Linkedin button and social widgets sociali (LinkedIn Corporation)
The LinkedIn button and social widgets are services allowing for interaction with the Linkedin  social network, provided by LinkedIn Corporation.

  • Personal Data collected: Cookies and Usage Data.
  • Place of Processing: United States – Privacy Policy.

YouTube button and social widgets (Google Inc.)
The YouTube button and social widgets are services that allow for interaction with the YouTube social network, provided by Google Inc.

    • Personal Data collected: Usage Data.
    • Place of processing: United States Uniti – Privacy Policy. Privacy Shield participant
  1. THE RIGHTS OF USERS

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller.Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

8.1 Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Si Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

8.2 How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

  1. ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING

9.1 Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of the Federica.EU platform or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

9.2 Specific Information

Upon request from the user, in addition to the information contained in this privacy policy, Federica.EU may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data.

9.3 System logs and maintenance

For operation and maintenance purposes, the Federica.EU platform, and any third-party services it uses, may collect files that record interactions with Federica.EU (System logs) and that may contain other Personal Data (such as the IP Address) for this purpose.

9.4 Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

9.5 Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and, if possible, on Federica.EU and/or – as far as technically and legally feasible – by sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

MORE INFO ABOUT COOKIES USED ON FEDERICA.EU

10.1 What is a Cookie?

Cookies are small text files containing small amounts of information which are downloaded to your device (computer, tablet or smartphone) when you visit a website. The text files memorise information which the site recognises when the same device visits a site for a second time. Fundamentally, cookies are useful because they allow a site to identify a user’s device.

Cookies are used in various ways: they make navigation between different pages on the platform more efficient, they memorize preferences and in general improve the user experience. In some cases, cookies allow us to show promotions that might interest our users. Some of these cookies are essential to correct functioning of the platform, others, on the other hand, are useful because they offer a secure way of memorizing user name or language settings. The advantage of having cookies instakked on your device is that you don’t need to re-provide information you have already given when you go back to a website you already visited.

Some cookies are automatically disabled at the end of a session (from when a user opens their browser to when they switch off their browser) others are saved on the user’s device for a longer period (usually these cookies are used to memorise user preferences and choices when they visit the platform, or to profile commercial offers).

10.2 What cookies do we use?

The cookies we use enable us to recognise users and their data when they come back to the Federica.EU platform, so they do not have to provide the same information each time they visit. They also enable us to analyse user traffic and behaviour when they visit Federica.EU to improve the user experience.

Here are some of the types of cookies used on our Platform:

10.2.1 Technical cookies

These cookies are essential to enabling navigation on the platform and making full use of its features, like accessing all the different areas of the platform, for example. Without these cookies, certain services may not be accessible. It is not necessary to get user consent for technical cookies, because these cookies are indispensible to the provision of the services the user requires.

10.2.2 Cookie Analytics

We use cookies for statistical analysis, to improve the Platform Website and to make the user experience easier, as well as to monitor its functioning.

These cookies also enable us to retrieve more detailed technical information, like the last page viewed, which parts of the platform users visit, and how much time elapses between one click and another. This information can be associated with details about the user, like IP address, domain or browser, but the analysis is anonymous and cannot be linked to the identity of a specific user.

10.2.3 Third party Cookies

Some third party cookies are installed on the site and are activated when you click “ACCEPT” on the cookies notification, or choose “ACCEPT” on the cookies banner or select an element in the page under the banner.

Third-party cookies are covered in the section Details on processing of Personal Data.

10.2.4 Disabling Cookies via your Browser

Most browsers (Internet Explorer, Firefox, Chrome, ecc.) are set to accept cookies. However you should be able to cancel or disable them following the instructions at the following links :

Chrome

https://support.google.com/chrome/answer/95647?hl=it

Firefox

https://support.mozilla.org/it/kb/Eliminare%20i%20cookie

Internet Explorer

https://windows.microsoft.com/it-it/internet-explorer/delete-manage-cookies#ie=ie-10

Opera

https://www.opera.com/help/tutorials/security/privacy/

Safari

https://support.apple.com/it-it/guide/safari/sfri11471/mac

 

Last updated: 27 February 2020

 

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