Privacy policy
WeSchool Srl

 

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

 

The Data Protection Officer of WeSchool is Studio E-Lex, with registered office in Rome, 00186, Via Dei Barbieri, 6, VAT no. 11514241006. For contacts: rpd@weschool.com.

 

(V14 – 10 July 2024)

1.1 Adult Learners: Learners who are at least 18 years.

 

1.2 Cookies: Cookies are text files (letters and/or numbers) that contain information that is stored on a User’s computer or mobile device each time the User visits a website through a browser or web app. Upon subsequent visits, the browser sends cookies to the website that generated them. Cookies are stored either for a limited period of time for a specific site (i.e. session cookies), or for a longer period of time regardless of browsing time (i.e. persistent cookies).

 

1.3 Data Controller: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the aims and means of the Processing of Personal Data.

 

1.4 Didactic Communications: communications relating to the availability of materials, initiatives or educational services on the Platform, without any commercial purpose, based on the Organization and on the educational cycle.

 

1.5 Direct Marketing: marketing activities carried out by WeSchool, in its interest, by e-mail, relating to the License, the Services offered by WeSchool as an Educator, services, products and initiatives similar to the License, the WeSchool’s Services and the Platform.

 

1.6 Educators: Users who use the License to provide their Services to Learners within Groups.

 

1.7 EEA: “European Economic Area” composed of the member countries of the European Union, Norway, Iceland and Liechtenstein.

 

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

 

1.9 General Terms and Conditions: general terms and conditions of the License executed between WeSchool and each User.

 

1.10 Groups: private groups of Learners created by the Educators within which the Educators provide the Services.

 

1.11 Young Learners: Learners under the age of 18 who use the License to receive the Services by virtue of specific authorization by a Parent.

 

1.12 Learners: Users who use the License to receive the Services offered by Educators within Groups.

 

1.13 License: license of the Platform granted by WeSchool to Users to use the technical and neutral services provided by WeSchool as better described in art. 4.1 of the General Terms and Conditions.

 

1.14 Organization: a School, a University, a company, a public authority, a non-profit organization, a freelancer or any other legal entity.

 

1.15 Organization Agreement: an agreement relating to the provision of the License executed between WeSchool and the Organization of reference of the Users.

 

1.16 Parent: parent and/or guardian who has parental responsibility for a Young Learner.

 

1.17 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.

 

1.18 Platform: an online platform aimed at promoting access to culture and education, which allows various forms of interaction between the Users to share their knowledge and skills within an interactive community, where everyone can be both creator and user of educational, training and professional services.

 

1.19 Privacy Policy: Policy on the Processing of Personal Data and Policy on the Cookies which constitute this document. This Privacy Policy does not concern any Processing of Personal Data conducted through any third-party sites, pages or online services of third parties, reachable by the User through links on the Platform. The Privacy Policy is available and easily accessible from WeSchool’s website (https://www.weschool.com/) or from each User’s profile page.

 

1.20 Profiling: analysis of Personal Data using automated systems, for evaluation and predictive purposes.

 

1.21 Processing: any operation or set of operations concerning Personal Data, such as, by way of example, their collection, organization, structuring, storage, modification, extraction, consultation, use, communication, interconnection, limitation, cancellation and destruction.

 

1.22 School: educational institution of any order or degree.

 

1.23 Services: educational, training and professional services provided by Educators in favor of Learners.

 

1.24 Service Agreement: agreement governing the sale of the Services offered by the Educators (including WeSchool when it plays the role of Educator), which is executed between, on the one hand, the Learner (or in the case of Young learners, the Parent) and, on the other hand, the Educator offering the Service (including WeSchool when it plays the role of Educator).

 

1.25 University: scientific-didactic and cultural institution, public or private, which represents the highest level of education.

 

1.26 University ID: jointly (i) “eduPersonPrincipalName”, “mandatory field”, represents the unique identifier of the User, this field is necessary to use the login service with the University credentials; (ii) “eduPersonScopedAffiliaton”, “mandatory field”, represents the identification of the type of affiliation to the University, this field is necessary to use the login service with the University credentials; (iii) “email”, “mandatory field”, represents the User’s e-mail address, this field is necessary for the creation of the User’s profile on the Platform; (iv) “givenName”, “optional field”, represents the name of the User, this field is necessary for the creation of the User’s profile on the Platform; (v) “surname”, “optional field”, represents the surname of the User, this field is necessary for the creation of the User’s profile on the Platform.

 

1.27 Users: all individuals who use the Platform, such as Educators, Learners and Parents.

 

1.28 WeSchool: WeSchool S.r.l., with registered office in Via Guido Reni 42, 20133, Milan Tax Code/VAT 07236760968 and Milan Companies Register M-1946066.

a) Processing of Personal Data strictly connected and functional to the License:

 

i) in case of executing an Organization Agreement with a School or University: the Data Controller is the School or University of reference of each User, which carries out the Processing as referred to in paragraph 5 letters b) to f) below, according to its privacy policy (which WeSchool invites to analyze before using the License), and WeSchool operates as data processor, pursuant to art. 28 of the GDPR, on behalf of the School or University, from time to time Data Controller;

 

ii) in all cases other than point i): the Data Controller is WeSchool (as defined in point 1.28 of this Privacy Policy), which carries out the Processing referred to in paragraph 5 letters b) to f) below, according to this Privacy Policy;

 

b) Processing of Personal Data strictly connected and functional to the use of the Services:

 

i) in case of Services offered by WeSchool as Educator: the Data Controller is WeSchool (as defined in point 1.28 of this Privacy Policy), which carries out the Processing referred to in paragraph 5 letter g) below, according to this Privacy Policy;

 

ii) in the case of Services offered by Educators other than WeSchool: the Data Controller is the Educator who carries out the Processing referred to in paragraph 5 letter g) below, according to its privacy policy (which WeSchool invites you to analyze before using the Services), it being understood that WeSchool is third party not involved in such Processing; 

 

c) Processing of Personal Data not strictly connected and functional to the License and Services: the Data Controller is WeSchool (as defined in point 1.28 of this Privacy Policy), which carries out the Processing referred to in paragraph 5 letters a) and h) to l) below, according to this Privacy Policy. 

 

Any request by the User relating to the Processing carried out by WeSchool as Data Controller (including the exercise of the rights referred to in paragraphs 12 and 13 below) must be addressed to WeSchool by one of the following means: 

 

• by post to the registered office: WeSchool S.r.l., in Via Guido Reni 42, 20133, Milan;
• by e-mail to the following address support@weschool.com. 

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

For contacts: rpd@weschool.com.

WeSchool participates in the IDEM National Federation (IDEntity Management for federated access), for the creation of the federated Authentication and Authorization Infrastructure of the GARR network, and in the eduGAIN interfederation (which connects federations of national identities to each other to simplify access to contents, services and resources for the Research and Training community). The Personal Data of Users of the Universities participating in the IDEM National Federation will be protected according to the “Code of Conduct for Service Providers” approved by eduGain, which represents a standard for the protection of privacy in the university and research field.

WeSchool collects and uses Users’ Personal Data to achieve the following purposes:

 

a) Allow navigation on the Platform, essentially through the use of Cookies: the Processing of Personal Data is governed by the Cookies Policy set forth in points 14 and 15 below, which WeSchool recommends reading.

 

b) In case of registration request from Learners, verify their age for assessing the lack of legal power to register on the Platform and use the License, without prior and specific authorization of a Parent: the Processing of Personal Data is necessary to allow the Young Learner to access the Platform, and consequently, to register and use the License. 

 

c) Allow Users to register with a Group on the Platform and create a personal account: the Processing of Personal Data is necessary to allow Users to access to the Platform and, subsequently, use the License and any refusal prevents the User from using the License according to the provisions of the General Terms and Conditions. In particular, on the basis of specific access forms: (i) the registration on the Platform and the creation of a personal account for Young Learners are performed by a Parent, in the name and on behalf of the Young Learners; (ii) the registration of University Users takes place through the insertion by the Users of the University ID and the subsequent communication from the Universities to WeSchool of the Users’ Personal Data (e.g. name and surname). 

 

d) Provide the License in favor of Users, including the management of the administrative and accounting relationship deriving from the execution of the General Terms and Conditions and the sending of communications strictly related to the use of the License of a technical nature (e.g. notification of upload of a document or video on the Platform or advices on the use of the Platform and the availability of contents of a technical nature on the Platform) and / or of an administrative nature (e.g. updates to this Privacy Policy): the Processing of Personal Data is necessary to allow Users to access to the Platform and subsequently use the License and any refusal prevents the User from using the License according to the General Terms and Conditions.

 

e) Enable Users to make any payments provided on the Platform, upon identification of Users, for the Services offered for a fee by WeSchool or by other Educators: the Processing of Personal Data is necessary for the  provision or the use by the User of the Services offered for a fee on the Platform, and any refusal prevents the User from providing (in the case of Educators) or using (in the case of Learners) such Services according to the General Terms and Conditions. 

 

f) Verify and ascertain any illegal or fraudulent conduct on the Platform by Users, such as, for example, uploading and accessing illegal or fraudulent content (such as, for example, content of a violent, pornographic, obscene or discriminatory nature), or harmful to the rights (including the ones connected to image or intellectual property) and interests of third parties (including other Users), or in any case not suitable for supporting the training and education of the Learners: the Processing of Personal Data is necessary to protect the correct use of the Platform, in the interest of all Users, should an act or fact, negligent or willful by a User occur. 

 

g) Allow Learners to use the Services offered by WeSchool as Educator and manage the related administrative-accounting and after-sales relationship between Learners and WeSchool: the Processing of Personal Data is necessary for the use by the Learner of the Services offered by WeSchool as an Educator on the Platform and any refusal prevents the Learner from using these Services on the basis of the General Terms and Conditions and the Services Agreement between WeSchool and the Learner.

 

h) Carry out Direct Marketing by WeSchool, by sending information and advertising material, reporting and invitations to promotional initiatives: the Processing of Personal Data is optional and any refusal by the User prevents the latter from receiving Direct Marketing by WeSchool. 

 

i) Carry out the Profiling, following optional consent referred to in point 11 below,: the Processing of Personal Data is optional and any refusal by the User prevents the latter from taking advantage of Profiling on the preferences expressed by the same on the Platform to customize the License or the Services offered by WeSchool as an Educator (through, for example, the receipt of personalized Didactic Communications) and marketing activities both by WeSchool (referred to in the previous letter h) and third parties (referred to in the following letter j). 

 

j) Carry out marketing activities on behalf of third parties, following optional consent, relating to digital products and services useful to Users, such as courses, electronic devices for education and connectivity services, through statistical analysis and market research, sending information and advertising material (also through pop-up advertising on the Platform) and reporting and inviting promotional initiatives by such third parties: the Processing of Personal Data is optional and any refusal by the User prevents the latter from using marketing activities relating to third parties operating in sectors of interest to Users.

 

k) Perform statistical analysis, market research, improve the use of the License and the Services of WeSchool by Users. Where possible, to achieve this purpose WeSchool uses anonymous data (data that do not identify or make Users identifiable and which, therefore, do not constitute Personal Data): the Processing of Personal Data is optional and any refusal by the User prevents the latter from using the License and WeSchool’s Services more akin to User’s own preferences, without prejudice to the use of the License. 

l) Comply with legal obligations and enable WeSchool to ascertain, exercise and defend its rights in court or before any other competent authority: the Processing of Personal Data is necessary to protect the legal position, rights and interests of WeSchool with regards to the execution, interpretation and fulfilment of the General Terms and Conditions. In particular, if a User uploads content (such as texts, images and videos) on the Platform, WeSchool may retain the User’s Personal Data (including the Parent’s, in the case of a Young Learner), in order to protect itself in case of potential verification or assessments by the competent authorities or claims by third parties deriving from the upload of illegal content or otherwise harmful to the General Terms and Conditions.

If, pursuant to point 2 above, WeSchool is the Data Controller of the Processing carried out for the purposes referred to in point 5 above, the following legal bases apply:

 

a) Allow navigation on the Platform, essentially through the use of Cookies: see the Cookies Policy.

 

b) Verify the possession of the age of the Learners, in order to allow Young Learners to register on the Platform and use the License, through prior and specific authorization of the Parent (if necessary by applicable law): legal obligation, on the part of WeSchool, to verify the age and consequent capacity to act of the Learners who intend to access the Platform. 

 

c) Allow Users to register with a Group on the Platform and create a personal account: execution of the General Terms and Conditions by the Educators, the Adult Learners and the Parent, in the name and on behalf of the same Parent and the Young Learner, and on the related pre-contractual measures proposed by WeSchool. 

 

d) Provide the License in favor of Users: acceptance of the General Terms and Conditions by the Educators, the Adult Learners and the Parent, in the name and on behalf of the same Parent and the Young Learner. 

 

e) Allow Users to make any payments, upon identification, provided on the Platform: acceptance of the General Terms and Conditions by the Educators, the Adult Learners and the Parent, in the name and on behalf of the same Parent and the Young Learner. 

 

f) Verify and ascertain any illegal or fraudulent conduct on the Platform by Users: acceptance of the General Terms and Conditions by Educators, Adult Learners and Parent, in the name and on behalf of the same Parent and the Young Learner, and related pre-contractual measures proposed by WeSchool and, if the involvement of third parties is necessary or appropriate, any legal obligation of WeSchool to collaborate with the competent authorities in carrying out verifications or investigations on illegal or fraudulent acts and facts carried out on the Platform.

 

g) Allow Users to use the Services that are offered by WeSchool as an Educator: acceptance of the General Terms and Conditions and of the Service Agreement relating to the Services of which WeSchool is an Educator by the Adult Learners and the Parent, in the name and on behalf of same Parent and of the Young Learner. 

 

h) Direct Marketing by WeSchool: WeSchool’s legitimate interest consisting of the benefit that WeSchool can obtain from sending commercial communications relating to the License (including advice on the use of the Platform and the availability of content on the Platform of a commercial nature), to the Services offered by WeSchool as an Educator or to services, products and initiatives similar to the License, Services and Platform, involving Users in WeSchool’s course of growth and development. WeSchool considers its legitimate interest as prevailing over the right to privacy of Users. The objection to this Processing can be exercised by the Educator, the Adult Learner or the Parent (on his/her own and in the name and on behalf of the Young Learner) at any time, and without any reason, following the instructions referred to in point 13 of this Privacy Policy.

 

i) Carry out the Profiling, following optional consent, referred to in point 11 below: freely-given, specific, informed and unambiguous consent of the Educator, the Adult Learner and/or the Parent (in the name and on behalf of the Young Learner), expressed by declaration or positive action (e.g. flag) on the Platform. The withdrawal of consent can be exercised by the Educator, the Adult Learner and/or the Parent at any time, following the instructions referred to in point 12 letter a) of this Privacy Policy.

 

j) Carry out marketing activities on behalf of third parties, following optional consent, relating to digital products and services useful to Learners: freely-given, specific, informed and unambiguous consent of the Educator, the Adult Learner and / or the Parent (in the name and on behalf of the Young Learner), expressed by declaration or positive action (e.g. flag) on the Platform. The withdrawal of consent can be exercised by the Educator, the Adult Learner or the Parent at any time, following the instructions referred to in point 12 letter a) of this Privacy Policy. 

 

k) Perform statistical analysis, market research, improve the use of the License and WeSchool’s Services by Users: legitimate interest of WeSchool consisting of the benefit that WeSchool can obtain in offering the License and Services that most fit the preferences expressed by its Users while browsing the Platform and using the License and the Services. WeSchool considers its legitimate interest as prevailing over the right to privacy of Users. The objection to this Processing (if not performed with anonymous data) can be exercised by the Educator, the Adult Learner or the Parent (in the name and on behalf of the Young Learner) at any time following the instructions referred to in point 12 letter f) of this Privacy Policy.

 

l) To comply with legal obligations and enable WeSchool to ascertain, exercise and defend its rights in court or before any other competent authority: i) legitimate interest of WeSchool consisting in the benefit that WeSchool can obtain in protecting its legal position, its rights and its interests, which WeSchool considers prevailing over the right to privacy of Users; and ii) where the involvement of third parties authorities is necessary or appropriate, WeSchool’s legal obligation to cooperate with the competent authorities in carrying out investigations relating to the execution, interpretation and fulfillment of the General Terms and Conditions.

WeSchool collects Personal Data in the following ways:

 

a) Personal Data entered on the Platform by Users: these are the Personal Data provided, by way of example and not exhaustively, to browse, register and access the Platforms and use the License.

 

b) Personal Data provided to WeSchool by third parties authorized by, or otherwise connected to, Users: these are Users’ Personal Data provided to WeSchool by other Users, for example, by Educators to create and manage their Groups, or by Schools, Universities (that, based on the University ID, communicate the Personal Data of their Users to WeSchool) or by other Users’ Organizations of reference, prior to the acceptance of the General Terms and Conditions by each User, or by the providers of the Schools’ electronic registers, throughout the period of validity of the General Terms and Conditions.

 

c) Personal Data expressly provided to WeSchool by Users in offline mode: these are the Personal Data provided, by way of example, to WeSchool’s customer service (in case of contact request) or collected during events and / or initiatives organized by WeSchool.

 

d) Personal Data automatically collected by the Platform: these Personal Data are automatically collected by the Platform, for example user agents or IP addresses of Users, including through Cookies (for more information, WeSchool recommends consulting the Cookies Policy below). 

Personal Data are processed by WeSchool and / or third parties, selected for reliability and competence, and to which they may be communicated as necessary or appropriate, provided that they are within Italy or the EEA. In particular, WeSchool informs Users that Personal Data may be processed by, and/or communicated to:

 

a) employees and/or collaborators of WeSchool;

 

b) other Users who participate in the same Group as the User to whom the Personal Data refers;

 

c) Users’ reference Organizations;

 

d) third party providers of services necessary to guarantee the functioning of the Platform (by way of example: company that deals with hosting services);

 

e) third party providers of services necessary to use the License and Services (e.g. services related to the Services);

 

f) payment service providers;

 

g) third parties that provide browsing data analysis concerning the Platform;

 

h) competent authorities to carry out verifications or investigations on illegal or fraudulent acts or facts committed on the Platform;

 

i) third parties, that provide automatic services for sending newsletters and / or any other type of commercial communication, marketing services, promotion;

 

j) third parties, subject to the optional consent of the User (in the case of a Young Learner, by the Parent), that provide Profiling;

 

k) third parties, subject to the optional consent of the User (in the case of Underage Learner, by the Parent), that send commercial and promotional communications concerning their products and services, also after Profiling, and / or that carry out statistical analysis or market research concerning Users.

To the extent possible, WeSchool avoids the transfer of Personal Data outside the EEA. However, limited to the services indicated below, some WeSchool service providers may transfer Personal Data to non-EEA Countries pursuant to article 44 and following of the GDPR, by virtue of adequate guarantees to ensure the protection of Personal Data as declared by the suppliers themselves, as follows: 

 

a) United Kingdom: by virtue of the United Kingdom’s adequacy decision issued by the European Union Commission on June 28, 2021.

 

i) [Limited to sending newsletters] Three Hearts Digital Ltd. (Email Octopus), with registered office at Keltan House, 115 Mare Street, London, E8 4RU, United Kingdom.

 

b) United States: by virtue of the EU-U.S. and Swiss-U.S. Data Privacy Frameworks adequacy decision issued by the European Union Commission on 10 July 2023.

 

ii. [Limited to sending push-notifications for the App and the Google Workplace integration service described here] Google Inc., with registered office at 1600 Amphitheatre Parkway Mountain View, CA 94043, United States; 

 

iii. [Limited to Payment Services and Anti-Fraud Controls Only] Stripe Inc., with registered office at Corporation Trust Center, 1209 Orange Street, Wilmington, New Castle, DE 19801, USA;

 

iv. [Limited to the error targeting of both frontend and backend Platform] Sentry Inc., with registered office at 45 Fremont Street, 8th Floor, San Francisco, CA 94105;

 

v.  [Limited to the customer care’s service] Zendesk Inc., San Francisco Bay Area, California;

 

vi. [Limited to Mobile app push notifications] OneSignal Inc., with registered office in 2194 Esperanca Avenue Santa Clara, CA 95054;

 

vii. [Limited to campaign tracking scripts on the Platform] Meta Platforms Inc., with registered office at Facebook 1 Hacker Way Menlo Park, CA 94025 .

 

b) Standard data protection clauses:

 

viii. [Subject to push-notifications for the App] Apple Inc., with registered office at 1 Apple Park Way Cupertino, California, United States.

 

Additional information regarding these appropriate safeguards can be obtained from WeSchool.

With specific reference to the transfer of data to Google Inc. for the integration with Google Workplace referred to in point (b)(ii) above, WeSchool specifies that the integration takes place in an automated manner via Google Workspace APIs and that Google Workspace APIs are not used to develop, improve or train generalised/non-personalised artificial intelligence (AI) and/or machine learning (ML) models.

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 User’s exercise of their right to withdraw their consent as per point 10 a) below or their right to object as per point 10 f) below, WeSchool will keep Personal Data as follows:

 

a) Cookies: for the purposes as per point 4 a), see the Cookie Policy as per point 12 below;

 

b) Personal Data to verify whether Users are 18 or older for Non-School Groups: for the purposes under point 4 letter b), if a Parent does not grant authorisation within 3 (three) weeks from the Young Learner’s registration request, the Young Learner’s Personal Data will be erased by WeSchool. If the Parent provides authorisation within the above term, letter c) below will apply;

 

c) Personal Data for the use of the Services: for the purposes under point 4 letters c), d) and e): (i) if WeSchool is the data controller as per point 2 letters a.i) and b), for the duration of the General Terms and Conditions and for the following 6 months, without prejudice to letter f) below; or (ii) if the School or the Company is the data controller as per point 2 a.ii), for the period of time that the School or the Company communicate to WeSchool as indicated in the related privacy policy, without prejudice to letter f) below;

 

d) Personal Data for commercial communications of WeSchool or third parties: for the purposes as per point 4 letters f) and h), for a period of 12 months (in case Profiling is associated with marketing activities, if consent to Profiling was previously given); or 24 months (in case no Profiling is associated with marketing activities, lacking previous consent to Profiling) following the User’s last interaction with WeSchool, suitable to demonstrate an interest in receiving communications concerning WeSchool (as per point 4 letter f) and/or third parties (as per point 4 letter h), including the collection of consent, the opening of newsletters, or participating in initiatives promoted by WeSchool or by third parties;

 

e) Personal Data for Profiling and for the improvement of the Services: for the purposes as per point 4 letters g) and i) (the latter 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;

 

f) in any case, WeSchool is authorised to keep, in whole or in part, Personal Data for a maximum of 10 years from when they are collected or for a longer period of any legal proceedings, limited to the information necessary to comply with legal obligations and allow WeSchool to ascertain, exercise and defend its rights in court or before any other competent authority. If a User uploads content (e.g. texts, images and videos) to the Platform, WeSchool may keep the User’s Personal Data (including that of the Parent, in the event of a Young Learner) for the term envisaged under this letter f), in order to protect itself in the event of investigations by the competent authorities or claims by third parties deriving from the uploading of unlawful content or content that is in breach of the General Terms and Conditions.

 

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

Profiling is carried out by WeSchool as follows:

 

a) context: Profiling can be associated both with WeSchool’s offering the Services on the Platform (by means of, for example, personalised Didactic Communication) and with the performance of marketing activities relating to WeSchool and/or third parties, as better described in point 4 above. Therefore, if the User accesses the Platform exclusively to use the Services and objects to WeSchool marketing (point 4 lett. f) or has not consented to third-party marketing (point 4 lett. h), the Profiling will only be carried out in connection with the Services, for improving for example the content of the Didactic Communication;

 

b) object: information concerning Users, e.g. age, education, location of the School of reference (where available), the type of Services used (e.g. educational courses);

 

c) legal basis: consent expressed, for example, by Teachers, Adult Learners, and Parents (on behalf of the Young Learners) flagging a box on the Platform;

 

d) rationale of Processing: (i) analysis and evaluation of the information collected regarding the Users as per letter b) on a statistical basis through the processing and comparison of all User Personal Data on the Platform; and (ii) classification of Users within homogeneous categories of Users to analyse or make predictions regarding their possible preferences;

 

e) purpose: to customise the Services and marketing activities based on User possible preferences and, therefore, improve Users’ degree of satisfaction with the Services provided on the Platform and in receiving WeSchool and/or third-party commercial and promotional communications. Profiling is therefore aimed at making predictions regarding the preferences and the future choices of the Users, based on the didactic content of the Platform;

 

f) effects for Users: use of the Services on the Platform or receipt of commercial communications that are in line with the interests and preferences expressed by Users in browsing the Platform and using the Services. In no way does WeSchool Profiling: i) constitute an automated decision-making process whereby legal or similarly significant effects derive for Users; ii) affect the behaviour and training or purchasing choices of Users; iii) have a prolonged and permanent impact for Users, considering that Personal Data collected by WeSchool can be independently updated at any time by Users; or iv) discriminate against Users.

In accordance with the GDPR, Users, in particular a Parent in the Parent’s and the Young Learner’s name and on their behalf, have the right, for the period as per point 8 of this Privacy Policy, to:

 

a) with reference to Processing as per point 4 g) and h), withdraw consent at any time without prejudice to the lawfulness of prior Processing, by sending an email to WeSchool or by opting out of WeSchool commercial communications (Article 7 of the GDPR);

 

b) 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 User (Article 15 of the GDPR);

 

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

 

d) request, for specific reasons (e.g. 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);

 

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

 

f) with reference to the Processing under point 4 f) and i) (in the latter case, 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);

 

g) 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);

 

h) 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);

 

i) lodge a complaint with the supervisory authority of the EU country where the User resides, works or where the User 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, Users 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.

Users, in particular Parents on their own behalf and on behalf of Young Learners, have the right to object to the Processing of their Personal Data as per point 4 letter f), 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 Users exercise this right, WeSchool will stop using the User’s Personal Data for purposes of marketing the Services or services, products or initiatives similar to the Services and the Platform and will not carry out Profiling associated with its direct marketing activities.

Users can enable the Cookies described in point 14 above as indicated on the banner published on the Platform. In any case, disabling technical Cookies described in point 14 is not possible, because it would prevent Users from correcting browsing the Platform and/or limit its usability.

This being said, Users can modify Cookie settings on the Platform as described in the settings section of the User’s browser:

 

• Google-Chrome: https://support.google.com/chrome/answer/95647?hl=en-EN&hlrm=fr&hlrm=en

 

• Mozilla-Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop

 

• Internet Explorer: https://support.microsoft.com/en-us/help/278835/how-to-delete-cookie-files-in-internet-explorer

 

• Microsoft Edge: https://support.microsoft.com/it-it/help/4027947/microsoft-edge-delete-cookies

 

• Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac https://support.apple.com/it-it/guide/safari/sfri11471/mac

 

Finally, not only can Users use their browser settings to enable or disable individual marketing Cookies, www.youronlinechoices.com shows a list of the main providers that work with website managers to collect and use information useful for the use of behavioural advertising. Users can deactivate or activate all companies (including WeSchool) or adjust their preferences for each company. Users can use the tool at page www.youronlinechoices.com/it/le-tue-scelte to check all behavioural advertising preferences when browsing the Internet.