Updated 02/09/2022 Applicable To The Following Mobile Application:
ARETE Geometry and ARETE Geography Pilot 2 of the ARETE project
Article 1 – DEFINITIONS:
a) APPLICABLE MOBILE APPLICATION (ARETE Geometry and ARETE
Geography Pilot 2 of the ARETE project): This Privacy Policy will refer to and be
applicable to the Mobile App listed above, which shall hereinafter be referred to as
“Mobile App.”
b) EFFECTIVE DATE: “Effective Date” means the date this Privacy Policy comes
into force and effect.
c) PARTIES: The parties to this privacy policy are the following data controller: UNW
(“Data Controller”) and you, as the user of this Mobile App. Hereinafter, the parties
will individually be referred to as “Party” and collectively as “Parties.”
d) DATA CONTROLLER: Data Controller is the Party responsible for the collection of
information described herein. Data Controller shall be referred to either by Data
Controller’s name or “Data Controller.”
e) OPERATOR: Operator is the publisher, owner, and operator of the Mobile App
and is the Party responsible for the collection of information described herein, along
with Data Controller. Operator shall be referred to either by Operator’s name or
“Operator.” If Operator or Operator’s property shall be referred to through first–person
pronouns, it shall be through the use of the following: us, we, our, ours, etc.
f) YOU: Should you agree to this Privacy Policy and continue your use of the Mobile
App, you will be referred to herein as either you, the user, or if any second–person
pronouns are required and applicable, such pronouns as ‘your”, “yours”, etc.
g) SERVICES: “Services” means any services that we make available for sale on the
Mobile App.
h) PERSONAL DATA: “Personal DATA” means personal data and information that
we obtain from you in connection with your use of the Mobile App that is capable of
identifying you in any manner.
Article 2 – GENERAL INFORMATION:
This privacy policy (hereinafter “Privacy Policy”) describes how we collect and use
the Personal Data that we receive about you, as well as your rights in relation to that
Personal Data, when you visit our Mobile App or use our Services.
This Privacy Policy does not cover any information that we may receive about you
through sources other than the use of our Mobile App. The Mobile App may link out
to other websites or mobile applications, but this Privacy Policy does not and will not
apply to any of those linked websites or applications.
We are committed to the protection of your privacy while you use our Mobile App.
By continuing to use our Mobile App, you acknowledge that you have had the
chance to review and consider this Privacy Policy, and you acknowledge that you
agree to it. This means that you also consent to the use of your information and the
method of disclosure as described in this Privacy Policy. If you do not understand the
Privacy Policy or do not agree to it, then you agree to immediately cease your use of
our Mobile App.
Article 3 –CONTACT AND DATA PROTECTION OFFICER:
Data controller: 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.
Data Protection Officer: ensures, in an independent manner, that an organization
applies the laws protecting individuals’ personal data. In particular, the DPO must:
• inform and advise the controller or processor, as well as their employees, of their
obligations under data protection law;
• monitor compliance of the organisation with all legislation in relation to data
protection, including in audits, awareness–raising activities as well as training of staff
involved in processing operations;
• provide advice where a DPIA has been carried out and monitor its performance;
• act as a contact point for requests from individuals regarding the processing of
their personal data and the exercise of their rights;
• cooperate with DPAs and act as a contact point for DPAs on issues relating to
processing;
Within the different Pilots of ARETE project, all partners involved are Data
Controllers in their own right. For the communication purposes with the stakeholders
involved, the Project Coordinator institution (UCD DPO) will act as an overarching
communicator with the ARETE Pilots’ Data Controllers and DPOs.
If any stakeholder would like to contact us in order to assert their rights at any point
during the project lifetime and within 5 years after the project termination (April
2023), please email us to: arete@ucd.ie
If you feel that your private data or your rights were infringed under the GDPR, you
may make an official complaint to the data protection authorities in your country:
https://edpb.europa.eu/about–edpb/about–edpb/members_en
Article 4 – LOCATION:
The location where the data processing activities take place is as follows:
The data is stored on the server https://learninglocker.vicomtech.org. The server
is using AWS infrastructure and is physically located in Frankfurt, Germany. All
the traffic sent to the server is encrypted and only the users with administrative
rights can access it. Once Pilot 2 is over, the data collected will be removed from
AWS and safely stored on a server on Vicomtech’s premises, located in San
Sebastian, Spain.
Article 5 – MODIFICATIONS AND REVISIONS:
We reserve the right to modify, revise, or otherwise amend this Privacy Policy at any
time and in any manner. If we do so, however, we will notify you and obtain your
consent to the change in processing. Unless we specifically obtain your consent, any
changes to the Privacy Policy will only impact the information collected on or after
the date of the change. It is also your responsibility to periodically check this page for
any such modification, revision or amendment.
Article 6 – THE PERSONAL DATA WE RECEIVE FROM YOU:
Depending on how you use our Mobile App, you will be subject to different types of
Personal Data collected and different manners of collection:
a) Unregistered users: If you are a passive user of the Mobile App and do not
register for any purchases or other service, you may still be subject to certain
passive data collection (“Passive Data Collection”). Such Passive Data
Collection may include through cookies, as described below, IP address
information, and certain browser data, such as history and/or session
information.
b) All users: The Passive Data Collection that applies to Unregistered users
shall also apply to all other users and/or visitors of our Mobile App.
However, we only share your Personal Data with a trusted related entity if that
entity agrees to our privacy standards as set out in this Privacy Policy and to
treat your Personal Data in the same manner that we do.
Article 7 – THE PERSONAL DATA WE RECEIVE AUTOMATICALLY:
ARETE applications do not collect any personal sensitive data via mobile
applications.
Cookies: We may collect information from you through automatic tracking systems
(such as information about your browsing preferences) as well as through
information that you volunteer to us (such as information that you provide during a
registration process or at other times while using the Mobile App, as described
above).
For example, we use cookies to make your browsing experience easier and more
intuitive: cookies are small strings of text used to store some information that may
concern the user, his or her preferences or the device they are using to access the
internet (such as a computer, tablet, or mobile phone). Cookies are mainly used to
adapt the operation of the site to your expectations, offering a more personalized
browsing experience and memorizing the choices you made previously.
A cookie consists of a reduced set of data transferred to your browser from a web
server and it can only be read by the server that made the transfer. This is not
executable code and does not transmit viruses.
Cookies do not record or store any Personal Data. If you want, you can prevent the
use of cookies, but then you may not be able to use our Mobile App as we intend. To
proceed without changing the options related to cookies, simply continue to use our
Mobile App.
Technical cookies: Technical cookies, which can also sometimes be called
HTML cookies, are used for navigation and to facilitate your access to and use
of the site. They are necessary for the transmission of communications on the
network or to supply services requested by you. The use of technical cookies
allows the safe and efficient use of the site.
You can manage or request the general deactivation or cancelation of cookies
through your browser. If you do this though, please be advised this action might
slow down or prevent access to some parts of the site.
Cookies may also be retransmitted by an analytics or statistics provider to collect
aggregated information on the number of users and how they visit the Mobile
App. These are also considered technical cookies when they operate as
described.
Temporary session cookies are deleted automatically at the end of the browsing
session – these are mostly used to identify you and ensure that you don’t have to
log in each time – whereas permanent cookies remain active longer than just one
particular session.
Third–party cookies: We may also utilize third–party cookies, which are cookies
sent by a third–party to your computer. Permanent cookies are often third–party
cookies. The majority of third–party cookies consist of tracking cookies used to
identify online behavior, understand interests and then customize advertising for
users.
Third–party analytical cookies may also be installed. They are sent from the
domains of the aforementioned third parties external to the site. Third–party
analytical cookies are used to detect information on user behavior on our Mobile
App. This place anonymously, in order to monitor the performance and improve
the usability of the site. Third–party profiling cookies are used to create profiles
relating to users, in order to propose advertising in line with the choices
expressed by the users themselves.
Profiling cookies: We may also use profiling cookies, which are those that
create profiles related to the user and are used in order to send advertising to
the user’s browser.
When these types of cookies are used, we will receive your explicit consent.
Support in configuring your browser: You can manage cookies through the
settings of your browser on your device. However, deleting cookies from your
browser may remove the preferences you have set for this Mobile App.
For further information and support, you can also visit the specific help page of
the web browser you are using:
– Internet Explorer: http://windows.microsoft.com/en–us/windows–vista/block–
or–allow–cookies
– Firefox: https://support.mozilla.org/en–us/kb/enable–and–disable–cookies–
website–preferences
– Safari: http://www.apple.com/legal/privacy/
– Chrome: https://support.google.com/accounts/answer/61416?hl=en
– Opera: http://www.opera.com/help/tutorials/security/cookies/
– Google Play: https://policies.google.com/privacy?hl=en–US
– iTunes: https://www.apple.com/ie/legal/privacy/en–ww/
Log Data: Like all websites and mobile applications, this Mobile App also makes
use of log files that store automatic information collected during user visits. The
different types of log data could be as follows:
– internet protocol (IP) address;
– type of browser and device parameters used to connect to the Mobile App;
– name of the Internet Service Provider (ISP);
– date and time of visit;
– web page of origin of the user (referral) and exit;
– possibly the number of clicks.
The aforementioned information is processed in an automated form and collected in
an exclusively aggregated manner in order to verify the correct functioning of the
site, and for security reasons. This information will be processed according to the
legitimate interests of the Data Controller.
For security purposes (spam filters, firewalls, virus detection), the automatically
recorded data may also possibly include Personal Data such as IP address, which
could be used, in accordance with applicable laws, in order to block attempts at
damage to the Mobile App or damage to other users, or in the case of harmful
activities or crime. Such data are never used for the identification or profiling of the
user, but only for the protection of the Mobile App and our users. Such information
will be treated according to the legitimate interests of the Data Controller.
Article 8 – THIRD PARTIES:
We may utilize third–party service providers (“Third–Party Service Providers”), from
time to time or all the time, to help us with our Mobile App, and to help serve you.
We may use Third–Party Service Providers to assist with information storage
(see Article 4 for detailed information).
We may provide some of your Personal Data to Third–Party Service Providers in
order to help us track usage data, such as referral websites, dates and times of
page requests, etc. We use this information to understand patterns of usage of,
and to improve, the Mobile App.
We may use Third–Party Service Providers to host the Mobile App. In this
instance, the Third–Party Service Provider will have access to your Personal
Data.
We only share your Personal Data with a Third–Party Service Provider if that
provider agrees to our privacy standards as set out in this Privacy Policy.
ARETE Pilot 2 mobile applications use EasyAR SDK. The details of privacy
policy for EasyAR SDK can be found on their website
(https://www.easyar.com/view/protocol.html).
Your Personal Data will not be sold or otherwise transferred to other third parties
without your approval.
Notwithstanding the other provisions of this Privacy Policy, we may provide your
Personal Data to a third party or to third parties in order to protect the rights,
property or safety, of us, our customers or third parties, or as otherwise required
by law.
We will not knowingly share your Personal Data with any third parties other than
in accordance with this Privacy Policy.
If your Personal Data might be provided to a third party in a manner that is other
than as explained in this Privacy Policy, you will be notified. You will also have
the opportunity to request that we not share that information.
In general, you may request that we do not share your Personal Data with third
parties. Please contact us via email, if so. Please be advised that you may lose
access to certain services that we rely on third–party providers for.
Article 9 – HOW PERSONAL DATA IS STORED:
We use secure physical and digital systems to store your Personal Data when
appropriate. We ensure that your Personal Data is protected against unauthorized
access, disclosure, or destruction.
Please note, however, that no system involving the transmission of information via
the internet, or the electronic storage of data, is completely secure. However, we
take the protection and storage of your Personal Data very seriously. We take all
reasonable steps to protect your Personal Data.
Personal Data is stored throughout your relationship with us. We delete your
Personal Data upon request for cancelation of your account or other general request
for the deletion of data.
In the event of a breach of your Personal Data, you will be notified in a reasonable
time frame, but in no event later than two weeks, and we will follow all applicable
laws regarding such breach.
Article 10 – PURPOSES OF PROCESSING OF PERSONAL DATA:
We primarily use your Personal Data to help us provide a better experience for you
on our Mobile App and to provide you the services and/or information you may have
requested, such as use of our Mobile App.
Information that does not identify you personally, but that may assist in providing us
broad overviews of our customer base, will be used for market research or marketing
efforts. Such information may include, but is not limited to, interests based on your
cookies.
Personal Data that may be considering identifying may be used for the following:
a) Improving your personal user experience
b) ARETE anonymous research data collection
Article 11 – DISCLOSURE OF PERSONAL DATA:
Although our policy is to maintain the privacy of your Personal Data as described
herein, we may disclose your Personal Data if we believe that it is reasonable to do
so in certain cases, in our sole and exclusive discretion. Such cases may include,
but are not limited to:
a) To satisfy any local, state, or EU laws or regulations
b) To respond to requests, such discovery, criminal, civil, or administrative
process, subpoenas, court orders, or writs from law enforcement or other
governmental or legal bodies
c) To bring legal action against a user who has violated the law or violated the
terms of use of our Mobile App
d) As may be necessary for the operation of our Mobile App
e) To generally cooperate with any lawful investigation about our users
f) If we suspect any fraudulent activity on our Mobile App or if we have noticed
any activity which may violate our terms or other applicable rules
Article 12 – CHILD ACCESS:
We may collect information from children, as well as allow and encourage children to
visit our Mobile App.
The information we collect from children is as follows:
â—Ź number of clicks within app
â—Ź time spent in the app
We do not allow children to make their Personal Data publicly available and do not
collect personal or sensitive data (eg., device location) for the research purposes of
these mobile applications
Information collected from children in accordance with this clause is collected to help
us enhance all user experiences and to improve our Mobile App.
It is also collected for the specific purpose of the following:
Data collection characteristics
During the intervention, the CLB apps will collect anonymous user data on time
spent in the apps and numbers of clicks.
Handling of Data
The technical data will be collected anonymously in the CLB apps, transferred via
xAPI to Learning Locker and shared with UNW. After transfer, it will be stored by
UNW securely for 6 years post project.
Analysis (Jul 2022–Apr 2023)
• Descriptive statistics
• Identification of references between cumulated app data and post–testing / retention
results
We do not require children to disclose any further information than is reasonably
necessary to interact with our Mobile App.
Parents or guardians of minor children may review the Personal Data of their child
and have it deleted at their request. They may also agree to collection and use of
information, without consenting to disclosure to any other party. They may also
refuse to permit any further collection or use of such information by sending us an
email at arete@ucd.ie.
Otherwise, information collected from children in accordance with this clause is
collected, used and if applicable, disclosed, in accordance with the general
provisions of this Privacy Policy.
Article 13 – MODIFYING, DELETING, AND ACCESSING YOUR INFORMATION:
If you wish to modify or delete any information we may have about you, or you wish
to simply access any information we have about you, you may reach out to us at the
following email address: arete@ucd.ie.
Article 14 – ACCEPTANCE OF RISK:
By continuing to our Mobile App in any manner, use the Product, you manifest your
continuing asset to this Privacy Policy. You further acknowledge, agree and accept
that no transmission of information or data via the internet is not always completely
secure, no matter what steps are taken. You acknowledge, agree and accept that we
do not guarantee or warrant the security of any information that you provide to us,
and that you transmit such information at your own risk.
Article 15 – YOUR RIGHTS:
You have many rights in relation to your Personal Data. Specifically, your rights are
as follows:
– the right to be informed about the processing of your Personal Dat
– the right to have access to your Personal Data
– the right to update and/or correct your Personal Data
– the right to portability of your Personal Data
– the right to oppose or limit the processing of your Personal Data
– the right to request that we stop processing and delete your Personal Data
– the right to block any Personal Data processing in violation of any applicable
law
– the right to launch a complaint with the Federal Trade Commission (FTC) in the
United States or applicable data protection authority in another jurisdiction
Such rights can all be exercised by contacting us at the relevant contact information
listed in this Privacy Policy.
Article 16 – CONTACT INFORMATION:
If you have any questions about this Privacy Policy or the way we collect information
from you, or if you would like to launch a complaint about anything related to this
Privacy Policy, please use the following email address: arete@ucd.ie