Privacy policy - edCrumble

ILDE Privacy Policy

This Privacy Policy describes how Universitat Pompeu Fabra, through the Integrated Learning Design Environment web portal - https://ilde.upf.edu/ - (hereinafter "ILDE") collects, uses, stores, shares, and protects your information in connection with services offered by ILDE.

Personal data of users provided through using the ILDE website and services is processed in accordance with the following policy.

Before accessing or using our Service, please ensure that you have read and understood our collection, storage, use and disclosure of your personal information as described in this privacy policy.

Legal text	Friendly version
Responsibility and contact. The entity responsible for processing your data, as data controller, is the Universitat Pompeu Fabra (UPF). The personal data provided will be stored in UPF file 'Projectes de recerca, desenvolupament i innovació'. You may contact tide-info@upf.edu for all purposes in relation to the processing of your data. You may also contact the UPF's Data Protection Officer at dpo@upf.edu.	The UPF is responsible for the personal data collected on ILDE.
Data Collection. We collect personal data relating to you on creating your user account and/or via contact forms, and during the course of your use of the site, subscribing to our mailing list and communicating with us. In Annex 1 we detail the data we collect and the specific purposes of processing. The table also lists the legal basis which we rely on to process the personal information, the categories of any recipients of your personal data, and information as to how we determine applicable retention periods. We also automatically collect personal information about you indirectly - about how you access and use the Service and information about the device you use to access the Service – this is set out in Annex 2. Our cookie policy sets out how some of your personal data may be collected by cookies on our site, in particular Google Analytics.	We expressly collect the data in the web forms and usage data. You must not upload sensitive personal data.
Users may voluntarily add other data in their profile. Only the data marked with a star is obligatory. Users must provide and maintain true and accurate personal profile data. Users must NOT upload any sensitive data regarding racial origin, trade union membership, religion, ideology and sexual life, the user’s or third party’s health, or relative to the commission of criminal offences or proceedings and associated penalties or fines.	Do not upload any sensitive personal data to the site, and please keep your personal data updated
Purposes. The data is processed for the general purposes relating to the ILDE project indicated on the website and in our Terms of Use, and more specifically for the purposes set out in the tables in Annexes 1 and 2 below. In summary, for providing the ILDE platform services and for conducting research, development and innovation into learning designs in the context of the ILDE project, and for managing any results of this project. Thus, the data is processed for the purpose of providing and managing the ILDE services, communicating with ILDE users regarding activities of the site and of the TIDE group, managing user accounts, putting users in contact with each other, providing notices, newsletters and other electronic communications, and for any administrative and legal / judicial purposes. We also use your data for research.	Data is processed for R+D purposes, to manage your account and to contact you. Please see the tables in Annex for more details
Anonymisation. We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use this anonymised information for purposes that include testing our IT systems, research, data analysis, improving our Service and developing new features for our site. We may also share anonymised information with others for scientific (non-commercial) research purposes. We may also publish anonymised datasets with our research publications, in accordance with European Research guidelines and open access requirements.
Contacting you. From time to time we may contact you regarding the Site and your use of the Site and our research.
Disclosure. These data may be disclosed on a pseudonymous basis (i.e. only we keep data that identifies you, but not the party to whom the dataset is disclosed) to third parties solely for compatible research purposes in the same or closely related research field. For any further purposes, disclosure will only be made with your specific and express previous consent. By using the account to upload content to ILDE, or by using the ILDE service to send content, you hereby expressly agree that any personal data associated with that content may be viewed and shared with other ILDE users and third parties. Your personal data may also be disclosed in cases provided for by law.	Your name will not be associated with any data shared. Sharing will only occur for research related purposes on a pseudonymous basis.
Confidentiality. Technical and organizational measures have been adopted to preserve and protect users’ personal information from unauthorized use or access and from being altered, lost or misused, taking into account the technological state of art, the features of the information stored and the risks to which information is exposed. All personal information we collect will be stored on secure servers of UPF. All electronic transaction entered into via our Service will be protected by SSL encryption technology. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers	We apply security measures to keep your data confidential.
International Transfer. We do not transfer any personal data relating to your uses outside the EEA.
User rights. Your rights to access, correct, cancel, restrict or object to the processing of your personal data may be exercised by applying in writing, including a copy of your identity card or equivalent to: General Manager, Universitat Pompeu Fabra. Pl. de la Mercè, 12. 08002 - Barcelona. You may also email us with the same information at tide-info@upf.edu. You may also review and edit the personal information you have submitted to us by logging into your account on our Service. You also have the right to lodge a complaint to the data protection officer at dpo@upf.edu. You may also resort to the Agència Catalana de Protecció de Dades, as indicated at http://apdcat.gencat.cat/en/drets_i_obligacions/reclamar_i_denunciar/.	You may access and modify or delete your data by contacting us.
Links to third party sites. Our Service may, from time to time, contain links to and from third party websites, including, but not limited to, those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites may be collecting information from you when you are browsing and have their own privacy policies; we do not accept any responsibility or liability for their collection activities or policies. Please check the individual policies before you submit any information to those websites	We are not responsible for third party sites linked to ILDE
Children: Our Service is not directed at persons under 18 and we do not knowingly collect personal information from children. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us	Children should not register as users
Changes to this policy. We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the “last modified” date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page. We will notify registered users by email of any changes.	We may update this policy from time to time and we will notify you.
Consent. By registering as a user or sending a contact form, users expressly agree to this policy, including the sending of electronic communications related to the site and research group’s activities.	You agree to this processing of your data.

Data Annex 1 – Personal data we collect

*Category of personal information*	*How we use it*	*Legal basis for the processing*	*Categories of recipients* As required in accordance with how we use it, we will share your personal information with the following	*Retention period*
*Contact and profile information.* Personal information, such as your name, phone number, address, e-mail address, and other information (including images)	We use this information to: operate, maintain and provide to you the features and functionality of the Service; maintain the safety of the service; communicate with you including sending service-related communications; and deal with enquiries and complaints made by or about you relating to the Service	The processing is necessary for: the performance of a contract and to take steps prior to entering into a contract; and our legitimate interests, namely administering the Service, and communicating with users	*Other users of the Service.* Other users of the Service that you interact with or that we share information with, such as your dog, your dog sitting needs or your availability as a dog sitter. *The public*. When you post user content on the Service which is publicly available,	For no longer than necessary for the purposes set out and in accordance with our legal obligations and legitimate business interests.
*Activity* Your actions in the platform, and user-generated content	Understanding how users use the platform and what type of content they generate	Your express consent and performance of the Terms of Use contract	Share data for research purposes for all registered users as pseudonymised data (rather than anonymized under Spanish law)
*Preferences. Preferences set for notifications, marketing communications and how our Service is displayed*
*All personal information set out above.*	We will use all the personal information we collect to: operate, maintain and provide to you the features and functionality of the Service, communicate with you, to monitor and improve our Service and business, to help us develop new products and services. to detect and prevent fraud and defend ourselves from any legal claims; comply with any applicable legal obligations	The processing is necessary for: our legitimate interest, namely to administer and improve the Service; and .compliance with legal obligations.

Annex 2 – Personal data we collect automatically

Category of personal information

How we use it

Legal basis for the processing

Categories of recipients

As required in accordance with how we use it, we will share your personal information with the following

Retention period

Information about how you access and use the Service. For example, the website from which you came and the website to which you are going when you leave our Service, how frequently you access the Service, the time you access our Service and how long you use it for, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service.

We use this information to:

present our Service to you on your device;

monitor and improve our Service, and to help us develop new products and services.

The processing is necessary for our legitimate interests, namely: to tailor our Service to the user and to improve our Service generally; to monitor and resolve issues; to communicate with users; to contact users; and for the detection and prevention of illegal activities.

Select third parties. Third parties, so that they can provide you with information and marketing messages about products or services that may interest you.

For no longer than necessary for the purposes set out and in accordance with our legal obligations and legitimate business interests.

Information about your device.

We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to our Service. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to our Service through the device, your Internet service provider or mobile network, your IP address

We use information about how you use and connect to our Service to present our Service to you on your device and to determine products and services that may be of interest to you for marketing purposes

Idem

Law enforcement, regulators and other parties for legal reasons. Third parties as required by law or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of DogBuddy, our users or others

Idem