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Organisation Privacy Policy

 

PRIVACY POLICY ORGANISATION AS PER ARTICLES 13 AND 14 OF REGULATION (EU) 2016/679 (GDPR) 

(V1 – 05 October 2022)

1. Definitions

Contract, GDPR, Data Subjects License, Organisation, Personal Data, Platform, Privacy Policy, Processing, Website, WeSchool.

1.1 Contract: the contract for the License that is executed between the Organisation and WeSchool that regulates the parties’ obligations.

 

1.2 GDPR: Regulation (EU) 2016/679 of 27 April 2016.

 

1.3 Data Subjects: all individuals who execute and perform the Contract in the name and on behalf of the Organisation, whose Personal data are processed by WeSchool.

 

1.4 License: a software as a service license of the Platform to be used by the users belonging and/or connected to the same Organisation. 

 

1.5 Organisation: can alternatively be a school, university, company, public authority or organisation, non-profit organisation, self-employed or any other legal entity.

 

1.6 Personal Data: any information that directly or indirectly concerns an identified or identifiable natural person such as the person’s name, identification number, location data, online identifiers, or factors of the person’s physical, physiological, genetic, psychic, economic, cultural or social identity. 

 

1.7 Platform: online platform aimed at promoting access to culture and education, which allows various forms of interaction between users for sharing their knowledge and skills within an interactive community, in which everyone can be both creator and user of educational, training and professional services.

 

1.8 Privacy Policy: the information contained in this document concerning the processing of Personal Data. This Privacy Policy does not concern the Processing of Personal Data through third-party sites, pages or online services of third parties that are accessible to Users through links on the Platform. The Privacy Policy is available and easily accessible from WeSchool website (https://www.weschool.com/en/pricing).

 

1.9 Processing: any operation or set of operations concerning Personal Data, including, by way of example, the collection, organisation, structuring, storage, modification, extraction, consultation, use, circulation, interconnection, limitation, erasure and destruction of the Personal Data.

 

1.10Website: this website

 

1.11 WeSchool: WeSchool S.r.l., with registered office at Via Guido Reni 42, 20133, Milan; tax code/VAT no. 07236760968; Milan Companies Register no. M-1946066.

2. Data controller

WeSchool - support@weschool.com

WeSchool is the data controller of the Processing indicated in point 4 below. Any requests by the Data Subjects concerning the Processing shall be addressed to WeSchool:

  • via mail sent to WeSchool’s registered office: WeSchool S.r.l., Via Guido Reni 42, 20133, Milan;
  • via e-mail: support@weschool.com.

 

3. Data Protection Officer (DPO)

Studio E-Lex - rpd@weschool.com

Studio E-Lex, with registered office in Rome, 00186, Via Dei Barbieri, 6, VAT no. 11514241006

For contacts: rpd@weschool.com.

4. Purposes and nature of Processing

a) Website registration and execution of the Contract: necessary;
b) payment of the License and identification: necessary;
c) accounting and administrative management of the commercial relationship: necessary;
d) investigations into unlawful or fraudulent use of the Platform: necessary;
e) direct marketing by e-mail: optional;
f) improvement of License and of the Platform: optional;
g) compliance with legal obligation and protection of WeSchool’s rights: necessary

WeSchool collects and uses Data Subjects’ Personal Data for the following purposes:

 

a) Allow Data Subjects to register on the Website and execute the Contract in the name and on behalf of the Organisation. The Processing of Personal Data is necessary for the Organisation to execute the Contract for purchasing the License and, subsequently, to use the Platform, and any refusal will prevent the Data Subject from being able to create an account and purchase the License in the name and on behalf of the Organisation as per the Contract. 

 

b) Allow Data Subject to carry on the payment of the Licence, upon preliminary identification, in the name and on behalf of the Organisation. The Processing of Personal Data is necessary for the purchase of the License by the Organisation, and any refusal to do so prevents the Organisation from using the License as per the Contract.

 

c) Manage the administrative and accounting relationship arising from the Contract and the sending of notices that are strictly connected to the License and are either of a technical nature (e.g. notifications of a technical nature of uploads of documents or videos on the Platform or advice on use of the Platform and on the availability of content on the Platform of a technical nature) and/or of an administrative nature (e.g. updates of the price of the License or amendments or termination of the Contract). The Processing of Personal Data is necessary for Organisation to use the License, and any refusal will prevent the Organisation from using the Platform as per the Contract and WeSchool from fulfilling the Contract. 

 

d) Conduct investigations concerning unlawful or fraudulent use of the Website by Data Subjects, including the uploading of incorrect or fraudulent information regarding the Organisation (e.g. number of users of the Organisation using the Platform, type of Organisation) or incorrect or fraudulent payment of the License (e.g. using of a means of payment without funds or not connected to the Organisation). The Processing of Personal Data is necessary to safeguard the proper purchase of the License by the Organisation and the subsequent use of the Platform in the interest of all the users of the Platform (including the Organisation’s users), should wilful or negligent events or actions by a Data Subject take place.

 

e) Carry out direct marketing activities concerning the License, the Platform, and services, products and initiatives similar to the Platform, through statistical analysis and market research, sending by e-mail information and advertising material, reports and invitations to promotional initiatives. The Processing of Personal Data is optional, and any refusal by the Data Subject will prevent the Data Subject from taking advantage of direct marketing activities by WeSchool relating to the License, the Platform, and products and initiatives similar to the Platform, but it will not affect Organisation’s use of the License and of the Platform. 

 

f) Perform statistical analysis, market research, improve the License and the Platform. Where possible, to achieve this purpose, WeSchool will use anonymous data (data that does not identify or make Data Subjects identifiable and therefore does not constitute Personal Data). The Processing of Personal Data is optional and any refusal by the Data Subject will prevent the Organisation from using the License or the Platform that most fit its preferences, but it will not affect Organisation’s use of the License and of the Platform.

 

g) Comply with legal obligations and allow WeSchool to ascertain, exercise and defend its rights in court or before any other competent authority. The Processing of Personal Data is necessary to safeguard the legal position, rights and interests of WeSchool regarding the execution, interpretation and performance of the Contract.

6. Personal Data modalities of collection

a) Personal Data provided by Data Subjects on the Website;
b) Personal Data provided by third parties authorised by, or connected to, the Organisation;
c) Personal Data provided “offline” by Data Subjects.

WeSchool collects Personal Data in the follow modalities:

 

a) Personal Data provided on the Website by the Data Subjects: these Personal Data are provided, for example, to browse the Website and register for the purchase of the License offered by WeSchool.

 

b) Personal Data provided to WeSchool by third parties authorised by the Organisation or in any case connected to the Organisation.

 

c) Personal Data expressly provided to WeSchool by Data Subjects ‘offline’ (‘in person’): these Personal Data are provided, for example, to WeSchool’s customers service (if requests are made) or collected at WeSchool events and/or initiatives.

7. Categories of recipients of Personal Data

Employees and/or staff, providers of services for the Website, providers of IT services, e-signature service and payment services, customer services, competent authorities.

Personal Data are processed by WeSchool and/or by third parties, selected based on their reliability and expertise, to which the Personal Data could be provided as necessary or appropriate, as long as they operate within Italy or the European Economic Area (which the European Union is part of). Data Subjects’ Personal Data could be processed by, and/or provided to:

 

a) employees and/or staff of WeSchool;

 

b) third-party providers of services necessary for the proper functioning of the Website (e.g. companies that offer web hosting services);

 

c) third-party providers of electronic signature service;

 

d) third-party providers of services necessary to purchase the License (e.g. payment processors and services related to the payment);

 

e) subscription management services and customer relationship management;

 

f) competent authorities, including courts and public officers.

8. Transfer of Personal Data outside of the EEA (including the EU)

Yes, but only for backup storage and remote access for internal organisation.

As far as possible, WeSchool avoids any transfer of Personal Data outside the EEA, opting for providers of services having operation and servers located inside the EEA. However, limited to backup storage and internal organization purposes, some providers may transfer Personal Data collected by WeSchool according to point 4 of this Privacy Policy, in the following countries outside SEE:

 

a) U.S.A.: waiting for the a new “Trans-Atlantic Data Privacy Agreement”, that was announced by the European Commission and the President of the United States on March 25th, 2022, the transfer of Personal Data between UE and U.S.A. is based on the safeguards currently available pursuant to Article 44 of the GDPR and proposed by the following service providers (such as standard data protection clauses or binding corporate rules) and on additional measures designed to protect the Personal Data adopted by the same service providers following recommendation of the competent authorities:

i) CHARGEBEE INC., with registered office at 340 South Lemon Avenue Suite 1537 Los Angeles, CA 91789 United States

ii) NetSuite INC., with registered office at 2300 Oracle Way Austin, Texas 78741 United States;

iii) HubSpot INC., with registered office at 25 First Street, Cambridge, MA 02141, United States;

iv) Stripes INC., with registered office at Corporation Trust Center, 1209 Orange Street, Wilmington, New Castle, DE 19801, United States;

v) Zoho Corporation, with registered office at 4141 Hacienda Drive, Pleasanton, CA 94588, United States.

 

b) India: the transfer of Personal Data between UE and India is based on the safeguards currently available pursuant to Article 44 of the GDPR and proposed by the following service provider (such as standard data protection clauses or binding corporate rules) and on additional measures designed to protect the Personal Data adopted by the same service provider following recommendation of the competent authorities:

i) Zoho Technologies Private LTD, with registered office at Estancia IT Park, Plot no. 140, 151, GST Road, Vallancheri, Chengalpattu District, 603202, India.

 

For any further information, the Data Subject may contact WeSchool.

9. Period of storage of the Personal Data (or criteria for determining such period)

a) Personal Data for the execution of the Contract: duration of the Contract and the following 6 months;
b) Personal Data for the payment: 5 years;
c) Personal data for direct marketing: for 24 months after the collection by WeSchool;
d) Personal Data for the improvement of the License: for 12 months after the collection by WeSchool;
e) Personal Data for legal obligations or judicial protection: 10 years from collection.

WeSchool will keep Personal Data for the period of time strictly necessary to achieve the purposes for which the Personal Data were collected, as per point 4 above. Without prejudice to Data Subject’s exercise of their right, WeSchool will keep Personal Data as follows:

 

a) Personal Data for the execution and performance of the Contract: for the purposes under point 4 letters a), b) and c): for the duration of the Contract and for the following 6 months, without prejudice to letter c) below;

 

b) Personal Data for the payment: for the purpose under point 4 letter b), for 5 years after the purchase of the License;

 

c) Personal data for direct marketing activities: for the purpose under point 4 letter e) for a period of 24 months after the collection of Personal Data by WeSchool;

 

d) Personal Data for the improvement of the License and the Platform: for the purpose under point 4 letter d) (only in cases of use of Personal Data and not anonymous data) for a period of 12 months after the collection of Personal Data by WeSchool;

 

e) Personal Data for comply with legal obligations and allow WeSchool to ascertain, exercise and defend its rights: for the purpose under point 4 letter e), for a maximum of 10 years from when the Personal Data are collected or for a longer period of any legal proceedings.

 

Once these terms expired, WeSchool will automatically erase the Personal Data collected or transform it into an irreversibly anonymous form.

10. Data Subject Rights

Access to Personal Data, rectification or completion of Personal Data, erasure of Personal Data, limitation of Processing, objection to Processing, portability of Personal Data, data breaches, complaints to the competent authorities

In accordance with the GDPR, Data Subjects, have the right, for the period as per point 9 of this Privacy Policy, to:

 

a) ask WeSchool for access to the Personal Data and information regarding the Processing, as well as request an electronic copy, unless otherwise specifically requested by the Data Subject (Article 15 of the GDPR);

 

b) request the rectification of the Personal Data and/or have it completed without undue delay (Article 16 of the GDPR);

 

c) request, for specific reasons (i.e. unlawful processing, withdrawal of consent, non-existence of the purpose for processing), the erasure of the Personal Data without undue delay (Article 17 of the GDPR);

 

d) in certain circumstances (i.e. inaccurate Personal Data, unlawful processing, exercise of a right before court) request that the Processing be restricted (Article 18 of the GDPR);

 

e) with reference to the Processing under point 4 d) (if anonymous data were not used), object to the Processing of the Personal Data at any time by sending an email to WeSchool (Article 21 of the GDPR);

 

f) in cases of automated processing, receive the Personal Data in a readable format, for the purpose of communicating them to a third party, or, where technically feasible, request that WeSchool send the Personal Data directly to the third party (right to Personal Data portability – Article 20 of the GDPR);

 

g) be informed by WeSchool without undue delay of any breaches or unauthorised access by third parties to WeSchool’s systems that contain the Personal Data (data breaches – Article 34 of the GDPR);

 

h) lodge a complaint with the supervisory authority of the EU country where the Data Subject resides, works or where the Data Subject believes that his or her rights have been breached (Article 77 of the GDPR).

 

For additional information on the terms and conditions for exercising their rights, Data Subjects can consult the GDPR at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L:2016:119:TOC, or contact WeSchool as per point 2 of this Privacy Policy. 

11. Objection to Processing concerning WeSchool direct marketing

Right to object to receiving commercial and promotional communications relating to WeSchool.

Data Subjects have the right to object to the Processing of their Personal Data as per point 4 letter e), at any time and for any reason, by sending an email to support@weschool.com or by opting out of receiving commercial and promotional communications from WeSchool. If Data Subjects exercise this right, WeSchool will stop using the Data Subjects’ Personal Data for purposes of direct marketing concerning the License, the Platform or services, products or initiatives similar to the Platform.