(2 November 2017)
This document contains information about the processing of personal data provided pursuant to Article 13 of Italian Legislative Decree no. 196/2003 and subsequent amendments, for the Services offered by Oilproject Srl (“OP”) through the web portal at the address http://www.weschool.com and through any related mobile application, both directly and indirectly (“WeSchool”).
This document is provided in favor of the Users that supplied data to OP in order to use the Services provided on WeSchool, and is not applicable to third-party websites and/or external mobile applications that may be accessible via links contained in WeSchool, for which OP is not in any way liable.
1. General information and methods of data processing
The Data Controller is Oilproject Srl, VAT number 07236760968, having its registered offices in Via Guido Reni, 42, 20133 – Milan (ITALY), email: [email protected]
The data collected will be processed by the Data Controller in the following manner(s); collected data:
- shall be transmitted, with the express consent of data subjects, to subsidiaries and associated companies, which are part of the same corporate group;
- shall be disclosed to public and/or private entities, for the performance of obligations prescribed by applicable law;
- shall be transferred abroad, within the limits provided by Articles 43 and 44 of Italian Legislative Decree no.196/2003;
- shall be communicated to individuals, companies and/or professional firms providing their assistance, advice or collaboration to OP in accounting, administrative, legal, tax and financial matters;
- shall be transmitted to external collaborators and to all parties to whom the disclosure is necessary to properly fulfill the obligations assumed by OP to supply its Services to the Users;
- shall be disclosed to third parties appointed by OP as “Data Processors” and/or charged with the processing of personal data in the manners and for the purposes set out in this statement;
- shall be used by OP to enforce and/or defend a legal right/action/claim.
The processing of personal data is carried out through the operations and/or the complex of operations described at Art. 4 par.1 lett. a) of Legislative Decree no. 196/2003: collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, removal and destruction of data.
Data and documents collected shall be organized by OP in databases and/or electronic files and/or in paper format.
Current Data Processors designated by OP are:
- AMAZON WEB SERVICES Inc, having its registered offices in 1200 12th Avenue South Suite 1200 Seattle, WA 98144-2734, United States
2. Types of personal data processed
a) Data provided by Users
Most of the data processed for the use of WeSchool is supplied by Users during the registration process.
To join the Community and use the Services of WeSchool, Users must create a complete Profile, providing OP with the following personal data:
- Date of birth;
- Valid e-mail address;
The inclusion of these data is required in order to finalize the registration and to access the Services provided by WeSchool.
In the case of a child under the age of 13, an Account can be created by a teacher if authorized to do so by the child’s parents/legal wardens in accordance with these Terms & Conditions. The child’s Account, with limited functionalities, will not be linked to an email address and its password will be automatically generated.
The User guarantees the accuracy and truth of the information provided and commits to ensure their periodic update on his/her own responsibility. Inaccurate/false data shall be deleted by OP, without any prior notice to the supplier.
Failure to provide the above data at the time of registration, or provision of inaccurate, incomplete and/or false information may result in the inability to access the Services provided through WeSchool. The data processing operations described herein cover only personal data which are strictly relevant, according to the legal obligations, duties and purposes set out in the following Articles of this policy.
A data subject, therefore, should not provide to OP any other data regarding his/her health status, racial and ethnic origin, religious beliefs, political opinions, sex life (so-called “sensitive data”), as well as legal data.
It is understood that the name, surname, date of birth, gender, and the photo provided by a registered User shall be made public and visible to other Users of the Community.
Additional personal data might also be requested when processing payment for the Services provided through WeSchool. It is understood that such personal data shall be processed by third parties (such as banks, payment intermediaries and/or similar entities), according to their separate privacy policies, and shall therefore not be directly treated and/or be available to OP.
The credit card number and all payment information that may be given to OP to complete a purchase will never be revealed to other Users of the community, and will only be used by OP and/or persons appointed by OP to process payments and/or refunds.
b) Data collected automatically while using the Portal
i) NAVIGATION DATA
The computer systems and software procedures used to operate WeSchool acquire, during their normal operation, some data, whose transmission is implicit in the Internet communication protocols. Such information is not collected to be specifically associated with certain data subjects, but by their very nature they could, through processing and association with data provided by third parties, be used to identify one or more Users.
This category of data may include IP addresses or domain names of the terminals on which Users are accessing WeSchool, the addresses in URI (Uniform Resource Identifier) of requested resources, the request time, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the reply given by the server (“successful”, “error”, etc.) and other parameters regarding the operating system and computer environment of the User’s terminal.
This data is processed only to obtain statistical information on the use of WeSchool and the Services provided therein, to provide new and/or updated Services, and to verify and ensure the correct operation of WeSchool; all data processed to obtain statistical information shall be deleted immediately after processing, except where their use is necessary to provide certain Services on WeSchool, and/or in case of crimes committed by damaging WeSchool and/or where their use is required by the competent Authorities, to the purposes of law enforcement and prosecution of offenses.
WeSchool stores the following cookies on Your computer:
|SchoolOilpLogin||Technical||Token to manage login on WeSchool|
|SchoolOilpRefresh||Technical||Token to refresh login on Weschool|
|SchoolOilpLastUsedGroup||Technical||Provides information on the latest group where a User was active|
|SchoolOilpLanguage||Technical||Stores language preferences|
|SchoolOilpJoinGroup||Technical||Used to specify which Group access invite a User is accepting (after account registration)|
|_weschool_client_timezone||Technical||Stores timezone preferences of the User|
|pnctest||Technical||Generic testing cookie|
|weschool-underage-violation||Technical||Helps to prevent the registration of users under 13 y.o.|
|weschool-app-mobile||Technical||Applies certain settings when WeSchool is used from a mobile application|
WeSchool also uses the following third-party cookies (see provided links for more information and instructions for opt-out and/or removal):
Google / Google Drive / Google Analytics / Youtube:
Microsoft / Windows Live:
You can also configure Your internet browser to prevent storage of any type of cookie. Please refer to the instructions provided by the manufacturer of Your browser, for more details on the matter.
c) Information provided by visitors of the Portal
Visiting WeSchool without logging in as a registered User does not involve processing of personal data of any kind. WeSchool, however, might store temporary cookies to properly display and cache its web pages; temporary cookies are automatically removed at the end of the relevant internet browser session of the visitor.
3. Purposes of the data processing:
The data collected according to the provisions set forth at Article 2 shall be processed by OP with ordinary and/or computerized and electronic means, so as to ensure the proper operation of WeSchool, in accordance with its Terms and Conditions and the license for Contents published on WeSchool.
OP reserves, in addition, the right to aggregate and process collected data anonymously, for statistical purposes on the usage of WeSchool, in order to always deliver services that meet the needs of its Users.
In particular, the data provided by Users in the manner referred to in Article 2, letter a) of this document, will be processed by OP by electronic and computerized means for the following purposes:
- to provide authentication of registered Users for the use of all Services offered through WeSchool;
- to create a database of registered Users for administrative, accounting and operational contract purposes, related to the Services offered through WeSchool;
- to provide communications relating to the performance of the contractual relationship with OP (including the management of mailing lists and newsletters);
- to provide information specifically requested by judicial authorities and/or other public authorities;
- To display relevant links to other websites or resources, including advertising messages, based on the User’s demographics, behaviour and platform activity.
- where expressly authorized by the registered Users, to provide promotional and/or commercial contact on services provided by OP;
- where expressly authorized by the registered Users, to provide promotional and/or commercial contact on services provided by selected third parties;
Data provided by Users as described at Article 2, letter b), will only be aggregated and processed anonymously, for statistic purposes on the usage of WeSchool, in order to always provide services and/or commercial offers according to the needs of the Users.
Data provided by Users as described at Article 2, letter c), will be processed by OP for the sole purpose of providing the Services of WeSchool, and shall not be made available to unregistered visitors and/or to third parties, except where such a disclosure is provided by law and/or regulation.
Data shall be processed and handled respecting the principles of correctness, lawfulness and transparency, with methods and ways to ensure maximum security standards and confidentiality.
OP will not disclose or transfer data to third parties, unless registered Users have expressly agreed to the processing for complementary, promotional and/or commercial purposes, as described above.
The processing of data as above summarized will have the necessary duration required by the purposes for which data were collected, in accordance with civil, criminal, and tax law.
In the event of deletion and/or suspension of a User Account, all relevant data will be stored in the manner and for the term prescribed by law.
All information and data collected from OP will be stored and maintained in safe facilities by automated tools, whose access is restricted to authorized staff only. The application by which the services are offered to OP and the security measures of the servers through which it operates are regularly tested to avoid data breaches and to ensure that all information collected are safe from unauthorized access.
OP complies with all security measures required by applicable law, to ensure and guarantee the confidentiality of personal data provided by Users, and to minimize, in the possible extent, any dangers posed by unauthorized access, removal, loss or damages to such data.
6. Exercise of Rights, Information and Contacts:
Here below follows the current text of Article 7 of the Italian Legislative Decree no. 196/2003, entitled “Right to access personal data and other rights”:
- A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.
- A data subject shall have the right to be informed
- of the source of the personal data;
- of the purposes and methods of the processing;
- of the logic applied to the processing, if the latter is carried out with the help of electronic means;
- of the identification data concerning data controller, data processors and the representative designated as per Section 1;
- of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.
- A data subject shall have the right to obtain
- updating, rectification or, where interested therein, integration of the data;
- erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
- certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
- A data subject shall have the right to object, in whole or in part,
- on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
- to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
All submissions and requests made by data subjects in accordance with the applicable Italian privacy legislation should be addressed to:
Via Guido Reni, 42
20133 – Milan (ITALY)
email: [email protected]