Last updated version: May 10, 2019
IF YOU ACCESS OUR PLATFORM AS A MINOR STUDENT, OR AS A PARENT OF A MINOR STUDENT, FIRST READ THE FOLLOWING:
Collection Of Minor Students’ Personal Data
Progrentis is an educational platform. To perform our services, Progrentis requires academic institutions (on behalf of the parents or legal guardians of students under legal age) to provide consent for the collection of certain personal information of the minor student through Progrentis. In order to register to use Progrentis, students must use an access code provided to them by their authorized teacher.
Progrentis collects limited personal information from minor students, and only where that student’s academic institution has contracted with Progrentis to do so, and has provided such information to Progrentis. For this purposes, the academic institution, after consenting to this policy, enrolls the list of students into the platform directly, according to the grade or level of the group of students listed.
In particular, we collect and use the following “Personal Data” from minor students:
- Name, and surname;
- Email of the parent or legal guardian, if provided to the school by the parent or legal guardian;
- We use the name of the students to follow their learning path through the use of our platform. The platform has various activities with specific learning routes. As students complete those exercises, the system records their responses (answers) to provide an individualized student grade;
- We use this information that the student generates with the use of the system to perform our services and make our platform a comprehensible academic tool; and
- We also use this information generated for internal statistical, study and personalization purposes in the educational field.
We do not collect sensitive (special category) Personal Data of minor students enrolled to our program. We do not sell or commercialize any Personal Data.
Parents have the right to:
- Be informed of their child’s information and academic progress;
- Request the correction or update your child’s information;
- Refuse the site further contact with their child; and
- Have such information deleted by contacting the school administrator or us directly by email at: firstname.lastname@example.org.
FOR ALL USERS, READ THE FOLLOWING:
What Is This Policy About?
Who Is Responsible Of Your Data?
The party responsible of your Data is Progrentis.
Why Do We Collect Certain Personal Data?
We collect Personal Data for the following necessary purposes:
- We collect the Authorized User’s name to track his/her learning path through the use of our platform. The platform has various activities with specific learning routes. As users complete those exercises, the system records their responses (answers) to provide individualized grades. We use this information that the student generates with the use of the system to perform our services and make our platform a comprehensible academic tool. We also use this information generated for internal statistical, study and personalization purposes in the educational field.
- To administer our Websites;
- To respond to any communications, queries or requests for information or services from you, howsoever received;
- For internal research, studies and investigations, and internal statistics related to our academic purpose;
- To provide the function and utility of the device/application for the Authorized User;
- To monitor, maintain and improve our services; and
- To create new services.
We will not use Personal Data that you provide to us in a manner inconsistent with the purposes for which you provided it to us, as set above.
What Personal Data Do We Collect?
“Personal Data”: is directly related Personal Data that identifies an Authorized User as an individual or relates to an identifiable person. For the purposes of providing our Services, we collect from Authorized Users their name (name and surname), and their email address. As mentioned before, we track the Authorized User’s learning path through the use of our platform. This data that results from the active usage of our platform (for example, answers to learning activities coursed) serves the purpose of guiding the academic progress of the user.
“Sensitive Personal Data”: We do not collect or process sensitive (or special category) Personal Data from any of our Authorized Users. We ask that you do not send us, and you do not disclose, any Sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
“Other Information”: is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
- Hardware and software information including browser, device information, IP address and access times.
- Services usage data such as rates (indexes) of progress, grades and access times logs.
- Information collected through cookies, pixel tags and other technologies.
- Demographic information such as country, ZIP code, age, gender and other information provided by you.
- Institution contact information such as name, email, address, telephone, website, logo and coordinator‘s name, telephone and email, if provided to us.
- Aggregated information generated from the use of our platform by Authorized Users (for example, the answers provided by the user to the different learning activities of the platform) may be used for internal reports and analysis produced by Progrentis. These reports, that contain such aggregated information have been subjected to customary industry standards to minimize the likelihood of identification of any individual user, may be shared with Progrentis international network of offices as well as third parties. Any transfer of aggregated information will require a review process to ensure that all laws related to the transfer of such data, if applicable, are accounted for.
Where Is Your Data Stored?
All data collected through, or by using, devices within multiple countries are stored on servers located mainly within The United States of America or any other region used by Amazon Web Services (our cloud service provider), which complies with the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Framework.
By using the Services you consent to the transfer of information to countries outside of your country of residence. In this sense, we take appropriate steps to ensure that data remains within jurisdictions with adequate protections for Personal Data and ensure that recipients of Personal Data from us are bound to duties of confidentiality, where relevant or appropriate. Where this is not possible, we rely on data minimization, the selection of trusted companies with privacy policies and auditable processes, which we have reviewed and seek to ensure that there are adequate safeguards in place for protecting transferred data.
How Do We May Collect Your Personal Data?
We collect Personal Data from Authorized Users as follows:
- Through the Services: We collect Personal Data through the Services, e.g., when you, or the academic institution that enrolls students to our program, creates an account or populates your profile.
- Offline: We may collect Personal Data from you offline, such as when you contact customer service.
Please keep in mind that if you directly disclose personally identifiable information or sensitive Personal Data through our public message boards, this information may be collected and used by others.
How We Collect Other Information?
We may collect Other Information in a variety of ways, including:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
- Through your use of the App: When you download and use the App, we track and collect App usage data, such as the date and time the App on your device accesses our servers and what information has been downloaded to the App based on your device number.
- Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including Authorized Users that may receive emails from us), and compile statistics about usage of the Services and response rates.
- IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for the purposes of providing support for the internal operations of the Services, such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive your approximate, general, location from your IP address.
- From you: Information such as your communications preference may be collected from Authorized Users when they voluntarily provide it.
- By aggregating information: Aggregated Personal Data does not personally identify you or any other user of the Services.
How We May Use Personal Data?
We do not sell, rent or lease any Personal Data. We use Personal Data collected from Authorized Users:
- To operate the Services you have requested.
- To respond to your inquiries and fulfill your requests, such as to send you newsletters and status reports.
- To send administrative information to you, such as information regarding the Services and changes to our terms, conditions and policies.
- To inform you of other products or services available.
- To contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.
- To allow you to participate in contests.
- To personalize your experience on the Services by presenting customized content and advertising.
- For our internal business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information is not transferred to the third party.
How Personal Data May Be Disclosed?
- To the Authorized User, the parent or legal guardian of a minor student, or academic institution that enrolls students to our program, upon request.
- To our service providers, who provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.
- By you, on profile pages and other services to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public. We urge you to be very careful when deciding to disclose any information on other services.
- To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) and, in the remote case where having such data (name of a student user) would imply a risk for the Company or its affiliates, and it would be deemed necessary for it to be disclosed before an authority or be used as evidence in certain legal proceeding.
How We May Use And Disclose Other Information?
We may use and disclose Other Information for the purposes above stated, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Data. If we do, we will treat the combined information as Personal Data as long as it is combined.
How Do We Protect Personal Data?
We seek to use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. As you may know, unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. However, we work hard to ensure data is encrypted when in transit and storage, and access to this data will be strictly limited to a minimum number of individuals and subject to confidentiality commitments. As well, we employ security measures such as using firewalls to protect against intruders, building redundancies throughout our networks and testing for and protecting against network vulnerabilities. When Personal Data is transmitted to other websites, it is protected through the use of HTTPS encryption, such as the Secure Socket Layer (SSL) protocol. Access controls within the organization limit who may access information.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.
How Long Do We Keep Personal Data?
What Are Your Choices Regarding Marketing Related Communications?
You may opt-out from receiving status & marketing-related emails and notifications from us on a going-forward basis by clicking the unsubscribe link in any such email. In addition, in your user settings, you may opt-out of receiving notifications. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving status & marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out. You can always withdraw consent from this Policy. To do so, refer to our contact information.
How You Can Access, Change Or Suppress Your Personal Data?
If you are an Authorized User and you would like to review, correct, update, suppress or delete Personal Data that you have previously provided to us of yourself or others, notify us in accordance with the “Contact Us” section below.
In your request, please make clear what Personal Data you would like to have changed, whether you would like to have your Personal Data suppressed from our database. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your requests as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes. There may also be residual information that will remain within our databases and other records, which will not be removed.
How To Contact Us?