EMMA collects some Personal Data from its Users.
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Nome Cognome - Ragione Sociale
Owner contact email: email@example.com
Among the types of Personal Data that EMMA collects, by itself or through third parties, there are: email address; first name; last name; date of birth; country; Cookies; Usage Data; gender; password; profession; language.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using EMMA.
Unless specified otherwise, all Data requested by EMMA is mandatory and failure to provide this Data may make it impossible for EMMA to provide its services. In cases where EMMA specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through EMMA and confirm that they have the third party's consent to provide the Data to the Owner.
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of EMMA (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
The Owner may process Personal Data relating to Users if one of the following applies:
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Managing support and contact requests, Managing contacts and sending messages, Interaction with external social networks and platforms, Registration and authentication, Analytics and Hosting and backend infrastructure.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Personal Data is collected for the following purposes and using the following services:
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of EMMA, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.
1.Cookie name(s): __utma, __utmb, __utmc, __utmv, __utmz are for example the names of Cookies used by Google Analytics; emmaLang is the name of the Cookie used by Emma to identify user’ platform language in order to facilitate navigation.
2.Data stored: A random unique number or string of letters and numbers to identify your browser, the times and dates that you interacted with the site recently and the marketing materials or referring pages that led you to the site.
3. Expiry: Cookies expire 2 years after your last visit to the website. Others are deleted after 6 months, 30 minutes and the moment you close your browser.
Data collected in EMMA can be of two types:
1. Data provided by the user, ie through registration forms, questionnaire, mail contacts etc.
2. Data collected through the use of EMMA services, ie navigation, assignments, comment, and/or activity streams.
When you publish content or information using the Public setting, be aware that you are allowing everyone, to access and use that information, and to associate it with you (i.e., your name and profile picture).
Personal information - when a user registers in EMMA platform, the following data is being collected and stored: name, email address, country of residence, native language, profession and date of birth. After filling in a profile, the following information is stored: location, gender, educational history or qualifications. Personal information is collected and used with the following purposes:
1. to provide, maintain, protect and improve the quality of the Website and the MOOCs that EMMA offers; this includes conducting anonymised market research;
2. to provide you with personalised feedback;
3. to conduct evidence-based pedagogical improvements;
4. for purposes of scientific research, mainly in the areas of technology-enhanced learning;
5. to fulfil any contractual agreements between you and us (for example, when you register as a Learner in relation to the MOOC);
6. to send you information (by email) about products and services which we think may interest you, email notifications and updates about the Website or MOOCs you are enrolled;
7. to manage your account that you hold with us;
8. to allow you to make full use of EMMA features and services.
Personal information is stored in secured servers. EMMA has put in place technical and organisational security measures to prevent the loss or unauthorised access of users’ personal information (see Annexes).
Questionnaires - users of the EMMA platform are expected to fill three types of questionnaires: 1) the entry questionnaire to identify user expectations related to MOOCs and their previous experience of MOOCs; 2) the mini-survey with the aim of collect feedback related to certain MOOCs. Finally, 3) the exit questionnaire aiming at getting feedback about the EMMA experience as a whole. Surveys data are anonymized. The integration between descriptive data and opinions delivered may be used for users profiling. This does not mean that it is not possible to connect the data to a specific individual and to his/her identity.
Tracking - EMMA tracks most of your actions related to participation in our MOOCs, your performance in MOOCs and patterns of learning, for the aim of learning analytics. Learning analytics is designed for the EMMA platform to raise awareness of the learning and teaching process within MOOCs, and to provide feedback for MOOC designers and instructors.
Learning analytics in EMMA aims to establish a feedback loop for the MOOC instructors and facilitators and provide an overview of the course interactions in: a) an aggregated manner in the learning analytics dashboard within the EMMA platform and b) at a more detailed level as a retrospective analysis based on the facilitators’ requests in the context of specific MOOCs.
Data subjects in EMMA, whose data has been collected, are the MOOC participants; this includes the MOOC authors/facilitators who have designed and delivered their MOOCs on the EMMA platform, and learners who participate in EMMA MOOCs.
The following data is collected in EMMA platform for the purpose of learning analytics:
1. Access log to the servers
2. User visits in different pages (lessons, units, assignments);
3. User posts and comments in conversation tool;
4. User posts and comments in blog;
5. User submissions, results and comments in assignment functionality;
6. User submissions of peer-assessment;
7. Time spent on different activities.
Data pushed to the dashboard is mainly aggregated and does not contain personal information.
The MOOC facilitator dashboard enables teachers to visualise:
1. Overview - aggregated view of the frequency and time spent by the participants on different actions in different lessons and units;
2. Lessons - more detailed aggregated view under each lesson based on the frequency of user activity;
3. Enrollment - Enrolled and unenrolled users. First and last name of the users will be displayed in that view, also the username, which is linked as an e-mail address;
4. Activity stream - xAPI statements based overview of the 100 most recent activities in the specific MOOC context. Only users’ first name is displayed to demonstrate recent activities of the participants;
5. Social Network Analysis - Interactions between the MOOC participants are visualized with the first name.
The MOOC learner's dashboard enables learners to visualise:
1. Progress - data related to the specific learner is visualised, data related to other MOOC participants is aggregated;
2. Activity stream - xAPI statements based overview of the 100 most recent activities in the specific MOOC context. First name of user only is displayed;
3. Social Network Analysis - Interactions between the MOOC participants are visualised with first name of user only.
EMMA can collect, store and use information that you voluntarily disclose to us through your learning journey. If you contact us, we may also keep a record of that correspondence.
EMMA may also collect data relating to your visits to the Website that can record your use of our Website and its MOOCs including, for example, details of how long you have used the Website and the MOOC.
EMMA may combine data that you have provided in your profile with other data collected from you while studying the MOOC and other users’ data to provide you with a better learner support.
No individual learning analytics will be knowingly made available to other people outside the Platform.
We may also collect your computer IP address.
This type of service has the purpose of hosting Data and files that enable EMMA to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of EMMA.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
EMMA cares for your privacy, and procedural and technological measures are in place to protect your Personal Information. Such procedures protect the confidentiality of the Personal Information or user traffic that EMMA creates, receives, stores and transmits.
EMMA has done all in its power to ensure that the Company providing the Hosting Services for EMMA has put in place all the requisite technical and organisational security measures to prevent unauthorised access to users’ personal information.
As far as security measures under the direct control of EMMA are concerned, we ensure:
1. Authenticated access control using a password or pin number - all administrator users accessing the system will be required to use passwords;
2. Firewall measures;
3. Security Socket Layer - SSL "Secure Sockets Layer" installed;
4. Regular back-ups of the system
EMMA protects all stored data from misuse and respects the rights of the data owners which are guaranteed by the European Union's (EU) Data Protection Directive 95/46/EC.
EMMA protects all personal data no matter where it is sent, processed or stored, even outside the EU, and therefore must comply with the EU standard contractual clauses.
EMMA may disclose your Personal Information only:
(a) if we are required to do so by law, regulation or other government authority or otherwise in cooperation with an investigation of a governmental authority;
(b) to enforce the Emma Terms and Conditions of Use;
The EMMA platform is hosted on servers located in Iceland. Data concerning registration to the platform, platform language cookies, data related to MOOC enrollments and assignment results are all collected and stored on those servers. Since Iceland belongs to the European Economic Area (EEA), the EEA legislation on privacy and the protection of personal data has been implemented. To find out more about how EMMA servers are protected, please check the annexes to this document.
However, some data - mainly concerning user monitoring (questionnaires, logs, tracking) may be stored in European Countries. In this case, data protection and security measures are covered by EU legislation (Data Protection Directive 95/46/EC).
You are asked for consent before any data is collected, in accordance with the European Union (EU) Data Protection Directive 95/46/EC.
Registration is not allowed without user consent to Privacy and Terms and Conditions policies.
The Website may, from time to time, contain links to the websites of third parties. If you follow a link to any of these websites, please bear in mind that these websites have their own privacy policies and that we do not accept responsibility or liability for any of these policies. Please check these policies before you submit any personal information to these websites.
Iceland Act no. 77/2000 on The Protection of Privacy as regards the Processing of Personal Data; Icelandic Rules no. 837/2006 on Electronic Surveillance. Icelandic Rules no. 698/2004 on The Obligation to Notify and Processing which requires a Permit; Icelandic Rules no. 299/2001 on security of personal data; Icelandic Regulation no. 322/2001 on Management of Personal Information by the Police.
The Secure Sockets Layer is a protocol that aims to allow the applications to transmit information in a secure and protected way. The applications that use the SSL certificates are able to manage sending and receiving of the protection keys, and encrypt and decrypt information transmitted using the same keys. In this way, all sensitive data that travels inside the platform maintains a heightened level of security. The same SSL certificate technology is used by EMMA partners when communication between different platforms is needed; this keeps the data transfer secure not only within the EMMA Platform but also when transferring data to and from the partner platforms.
This type of service allows interaction with social networks or other external platforms directly from the pages of EMMA.
The interaction and information obtained through EMMA are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on EMMA isn’t being connected back to the User’s profile.
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data processed: Cookies; Usage Data.
The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.
Personal Data processed: Cookies; Usage Data.
The YouTube button and social widgets are services allowing interaction with the YouTube social network provided by Google Ireland Limited.
Personal Data processed: Usage Data.
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Mailchimp is an email address management and message sending service provided by The Rocket Science Group LLC.
Personal Data processed: country; date of birth; email address; first name; last name.
This type of service allows EMMA to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
Zendesk is a support and contact request management service provided by Zendesk Inc.
By registering or authenticating, Users allow EMMA to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, EMMA will be able to access some Data, stored by these third-party services, for registration or identification purposes.
The User registers by filling out the registration form and providing the Personal Data directly to EMMA.
Personal Data processed: country; date of birth; email address; first name; gender; language; last name; password; profession.
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of EMMA or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
For operation and maintenance purposes, EMMA and any third-party services may collect files that record interaction with EMMA (System logs) use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
EMMA does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through EMMA (or third-party services employed in EMMA), which can include: the IP addresses or domain names of the computers utilized by the Users who use EMMA, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
The individual using EMMA who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of EMMA. The Data Controller, unless otherwise specified, is the Owner of EMMA.
The means by which the Personal Data of the User is collected and processed.
The service provided by EMMA as described in the relative terms (if available) and on this site/application.
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).