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Privacy Notice for Wibe Academy service
Last updated 11 May 2018
This privacy notice provides information on the processing of your personal data as required under the European General Data Protection Regulation and applicable national data protection legislation. The privacy notice is intented to serve information needs of the data subject (natural person using Wibe Academy learning platform), organisation that uses the service for delivery of its training programmes (later ”Content Provider”) and supervisory authority.
When you use Wibe Academy service your personal data will be collected in Wibe Academy Ltd’s customer register (Wibe Academy Ltd is the controller) and each Content Provider’s training register (Content Provider is the controller).
2. Name of the data file and the controller
Data file: Wibe Academy’s customer register
Controller: Wibe Academy Ltd, Business ID 2618131-3
Contact person: Petri Koskinen, CEO
Mail address: Wibe Academy Ltd, Huopalahdenkatu 24, FI-00350 Helsinki, Finland
3. Personal data and processing purposes
When you register as a user Wibe Academy will record your personal data in Wibe Academy’s customer register.
Wibe Academy will process your personal data as described in this privacy notice. Legal basis of the processing is a contract between you and Wibe Academy and contract between Wibe Academy and the Content Provider who is providing to you training and other content.
Your personal data may contain all or part of the following information:
- email address and password
- profile picture that you have provided us
- phone number
- date of birth
- language selection
If you login in the service using your Facebook account, your Facebook token and ID will be recorded.
In addition, Wibe Academy may collect following technical or online behavior information that can be connected to you (meaning that such information is also regarded as personal data):
- location data collected from your wireless network, GPS data, WiFi or LAN connection; and
Wibe Academy is processing your personal data for the following purposes:
- providing the Service to you;
- managing our service relationships with you or the Content Provider that has targeted some Content to you
- maintaining, managing and developing the Service and its components
- monitoring use of the Service and users’ compliance with the Terms of Services
- collecting statistics and making analysis on the use of the Service; and
- collecting information on the use of the specific Content by its targeted recipients and reporting that to the respective Content Provider.
4. Personal data in Content Provider’s training register
When you access and use training material and other content provided to you by a Content Provider, Content Provider will collect in its own training register all or part of the following information:
- email address
- profile picture
- information of content targeted to you
- information on the Content Provider’s trainings that you have started and completed as well as information on other content you have accessed, time and location of access and device that was used
Content Provider may use a survey tool for collecting additional personal data that Content Provider will need in connection with its provision of trainings and other content to you.
Content Provider is the controller of its own training register. If you have any questions concerning processing of your personal data in a training register, please contact directly to the Content Provider that has provided you some content through the service.
5. Transfer of Personal Data
Wibe Academy may transfer your personal data (including data on the content targeted to you, training materials that you have started and completed and other content that you have accessed, time, place and device used when the content was accessed) to the Content Provider that has in the service targeted such content to you.
Wibe Academy may anonymize personal data so that it can no longer be connected to you. Wibe Academy may disclose such anonymized data to third parties.
Wibe Academy may disclose your personal data to authorities if that is mandatory under the applicable laws and regulations. Wibe Academy may use subcontractors and may transfer your personal data to its service providers and subcontractors to the extent that is necessary in order to provide the service.
Wibe Academy does not regularly transfer personal data outside the European Economic Area (”EEA”). However, if the Content Provider that provided Content to you is located outside the EEA, Wibe Academy may disclose to the Content Provider your name, email address and all details of your use of the content provided by this Content Provider.
6. Your rights
You have the right to know what personal data Wibe Academy have about you in its customer register and have of copy of such personal data. You have a right to have Wibe Academy to correct any incorrect data and delete such personal data for which there is no longer any lawful basis of processing. If you delete by yourself of demand that Wibe Academy deletes all personal data concerning you, you cannot use the service any more. European General Data Protection Regulation gives you in certain situations right to request restrictions on the processing of your personal data or object processing of your personal data and request for transfer of your personal data in electronic machine readable form. If you consider that your personal data is processed lawfully you have right to make a complaint to the supervisory authority.
If you have any questions concerning processing of your personal data, or if you want to know what personal data Wibe Acedemy has in its customer register or otherwise use your rights, please contact Wibe Academy by email at firstname.lastname@example.org.
You can also review, change, update or delete profile information that you have provided directly in the Wibe Academy service.
7. Retention of personal data
Wibe Academy stores your personnal data in the customer register as long as it is neccessary for the fulfilment of purposes for which personnal data was originally collected.
All personal data is stored in electronic format in Wibe Academy’s own or its subcontractor’s data centers located within the EEA. Wibe Academy has taken all appropriate technical and organisational measures to protect personal data against unauthorized or unlawful processing and prevent unintentional loss, change, destruction or damage to personal data. Access to the customer register is allowed only for authorized and identified employees and contractors who need access to the information for the performance of their work tasks.