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Politecnico di Milano

Privacy Policy

This privacy policy refers to the Polimi Open Knowledge website (“POK”).

NOTICE: On May 25, 2018, POK adopted an amended privacy policy under the provisions of Article 13 of European Union GDPR - General Data protection Regulation (679/2016/EU).

Introduction

This page describes how the POK website is managed under the provisions of Article 13 and Article 14 of European Union GDPR - General Data protection Regulation (679/2016/EU) in relation to the processing of the personal data of its users.

This privacy policy provides information to those who interact with the POK service, which can be accessed electronically and pertains to the domain: pok.polimi.it. This privacy policy is issued solely in relation to the POK website.

Purpose of the personal data processing

Personal data is processed according to all purposes related to design and delivery of POK, that include:

  • purposes related to monitoring, analyzing and assessing the use of the service;
  • purposes related to teaching, learning, and research.

Data processing procedure

In relation to the stated purposes, the data processing is carried out with digital tools. In any case the protection is ensured by password.

Data Controller: Politecnico di Milano – Directorate General
Piazza Leonardo da Vinci 32 – 20133 Milan Italy
Phone +39 0223992243
PEC: pecateneo@cert.polimi.it

Data Protection Officer: privacy@polimi.it - phone: +39 0223999378

This privacy policy is organized as follows:

  1. Information that POK collects from you (including Personal Information)
  2. Cookies and tracking technologies on POK
  3. Third Party Cookies
  4. How your information is used
  5. How your information is shared
  6. How to manage your personal information
  7. Storage & security
  8. Privacy policy updates
  9. Contact information
  10. Glossary
  1. Information that POK collects from you (including personal information)

    POK directly collects information when you:

    • sign up for a POK user account and create a POK user profile;
    • enroll and participate in online courses;
    • request a certificate of accomplishment;
    • send email messages to POK (including messages to learner support);
    • participate in user surveys in anonymised form; and
    • participate in public forums, webinars, and other interactive experiences on the POK Site.

    POK also indirectly collects usage information about your visit to the POK Site, as explained in the section below titled Cookies and tracking technologies.

    POK requires your Personal Information only in limited circumstances when you:

    • sign up for a POK user account (name, username, email address), including single sign-on with Polimi credentials;
    • earn/request a certificate of accomplishment (the certificate will have your name on it).

    To the extent that POK associates the information that POK collects directly or indirectly with an individual (for example, you), the association is based on Personal Information in your account profile.

    You may voluntarily choose to share additional Personal Information on the POK Site, for example:

    • in your POK account profile (and you may display a limited or full profile to other POK Site users);
    • when participating in a course, forum, webinar, or other interactive experience on the POK Site (noting that in some cases, this information may be shared with a third party that provides tools and assistance for the POK courses).

    POK encourages you to use discretion before voluntarily sharing additional Personal Information on the POK Site. (If you later choose to delete your POK account, deletion of your Personal Information will be subject to the process and limits outlined below).

  2. Cookies and tracking technologies on the POK site

    POK uses Cookies and other common Tracking Technologies on the POK Site and in email communications to help POK better understand your use and needs of the POK Site, and how POK can improve. For example:

    • based on your cookie settings, POK tracks information indicating, among other things, which pages of the POK Site were visited, the order in which they were visited, when they were visited, and which hyperlinks and other user interface controls were used;
    • POK may log the IP address, operating system, and browser software (including mobile use and device type when you use POK native mobile apps) you used when accessing the POK Site, and POK may be able to determine from an IP address your Internet Service Provider and the geographic location of your point of connectivity;
    • Tracking is performed via Google Analytics based upon anonimyzation of IP addresses;
    • POK may track and collect information from emails that POK sends to you, for example whether you opened the email or clicked on any links from the email.

    POK uses Cookies and other Tracking Technologies for the following purposes:

    • when necessary for system administration, security, and integrity to ensure the POK Site works properly for you. Without these technologies, the POK Site may not function correctly;
    • to enable analytics, performance and functionality, to help POK gather information about how visitors use the POK Site and monitor POK Site performance, and to enhance your experience by recognizing and remembering whether you have visited the POK Site before and may have any personal preferences.

    You have some options for managing Cookies and other Tracking Technologies. These include modifying your browser settings: You should be able to control how and whether your web browser accepts Cookies by adjusting its privacy and security settings. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new Cookies, how to receive notification of new Cookies, and how to disable existing Cookies. If you reject POK’s Cookies, many functions and conveniences of the POK Site may not work properly.

  3. Third party cookies

    This website uses Google Analytics, a web analytics service provided by Google Inc. of 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google”). Google Analytics uses 'cookies', which are text files placed on your computer, to help the web team analyse how Users use the site. The information generated by the cookie about your use of the website will generally be transmitted to and stored by Google on servers in the United States. In case of activation of a IP-anonymisation, Google will reduce your IP address within the member states of the European Union and other member States to the Treaty on the European Economic Area. Only in exceptional cases, the full IP-address will be transmitted to a server of Google in the United States and be reduced there. In assignment of the operator of this website Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.

    Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You may also deactivate Google Analytics by installing a so called browser-input-group-addon, which is provided by Google under the following address: http://tools.google.com/dlpage/gaoptout?hl=en.
    Please note that this website extended Google Analytics for the code “gat._anonymezlp();” to ensure an anonymised recording of IP-addresses (IP masking).

    More information on Google Inc. and Google Analytics can be found here: http://www.google.com/intl/en/policies/terms/.
    This website also use YouTube, another service by Google, to provide you video lectures and YouTube can collect additional cookies. Google’s privacy policy can be found here: http://www.google.com/intl/en/privacy/privacy-policy.html.

  4. How your information is used

    Your data is processed in accordance with Polimi policies; POK uses information, including Personal Information, to carry out the following purposes:

    • Create, administer, provide, and teach online courses.
    • Operate and improve the POK Site – This includes personalizing the POK Site, so your learning experience is tailored to your interests and needs.
    • Improve POK service – This includes enabling you to navigate the POK Site, to enroll and participate in courses on the POK Site, to learn effectively in such courses and programs, and to obtain certificates of accomplishment.
    • Develop and maintain the security and performance of the POK Site – This includes tracking POK Site outages and creating software solutions, detecting violations of the Honor Code and Terms of Service, and monitoring uses, misuses, and potential misuses of the POK Site.
    • Communicate with you – This includes answering your course and platform questions, notifying you of course and POK Site maintenance, updates, course offerings, news.
    • Support scientific research including, for example, in the areas of cognitive science and education – This includes collaborating to enable and conduct research about how learners access and master course materials online, with the goal of improving course outcomes; software can be used internally on this purpose.
    • Track POK Site usage against goals and mission – This includes performing analytics to evaluate access to and performance in courses and, in some specific cases, to report aggregate usage information (not Personal Information) to course partners and external audiences.

    POK may also seek your consent for additional uses of information, including Personal Information, and will use it only for the purpose described to you. All use of Personal Information is subject to applicable law.

  5. How your information is shared

    POK may share information, including Personal Information, only as needed to fulfill the relevant purpose(s), with the following third parties:

    • staff authorised to process personal data;
    • European Union;
    • subjects that provide outsourcing services or acting as technicians operating the POK equipment and service programs;
    • entities / authorities for issuing public key certificates.

    In addition to that, POK shares information with other learners in courses that you take and with other visitors to the POK Site, to create an interactive learning environment, support class participation, and share course information. This includes sharing comments, coursework, or other information or content that you submit to a portion of the POK Site designed for viewing by other class members or for public communication.

    POK may also seek your consent for additional disclosures of information, including Personal Information, and will share it only as described to you. In addition, POK may share with the public and with third parties, including but not limited to researchers and partners, information and Personal Information that is de-identified or aggregated in a manner that does not personally identifies you.

  6. How to manage your personal information

    Access and correct your personal information

    Much of your Personal Information is available in your POK account. Your name, email address, and other identifiable profile information is editable through the profile settings in your POK account. Your account dashboard lists all current and archived courses in which you have enrolled and includes links to any certificate of accomplishment you may have earned. The dashboard also contains copies of your answers and other participation and performance in courses.

    POK does not track or index every time or every place on the POK Site when or where a learner may volunteer Personal Information, so POK will not be able to help you locate or manage all such instances.

    POK encourages you to use discretion before volunteering Personal Information on the POK Site.

    Note that usernames cannot ever be changed. This is a POK system restriction. Because usernames identify you in courses and elsewhere on the POK Site, POK encourages you to use discretion in choosing your username.

    Restrict or object to the processing of Personal Information

    You may object to, or request that POK stops, its use of your Personal Information by contacting privacy@polimi.it. Please note that if you choose to restrict POK’s ability to process Personal Information, and the processing is otherwise required to provide you with the service offered on the POK Site, you may not be able to establish a POK user account or enroll for a course, and POK may not be able to provide you with this service.

    Delete account and Personal Information

    To request deletion of your POK account and Personal Information, you should send a request to privacy@polimi.it. Because deletion on the POK system is a permanent action and cannot be reversed, POK may ask you to complete a process that aims to confirm your authority to manage the POK account affected by your request.

    With respect to your POK account, POK will permanently:

    • deactivate your POK account,
    • remove the active profile,
    • retire your username, and
    • remove you from POK email lists.

    With respect to your Personal Information, POK will permanently delete your POK account profile Personal Information from the POK Site. By erasing the Personal Information in your POK account profile, the remaining information about your activity on the POK Site will no longer be associated with you, except as noted below. These changes will be applied to data stores that are used for operation of the POK Site.

    Exceptions:

    • Deletion will not apply to historical activity logs or archives unless and until these logs and data naturally “age-off” the POK system.
    • POK will archive course data (in a manner and to the extent permitted under applicable law) to enhance the service offered. These archives may be used to produce encrypted research data packages.
    • POK will retain and use Personal Information as necessary to comply with its legal obligations, enforce its agreements, and as otherwise permitted by applicable law.

    Data retention

    POK will retain your Personal Information for as long as your account is active or as needed to provide you with services. If you enroll in a course, your Personal Information will be retained for as long as needed to provide you with services.

  7. Storage & security

    POK stores information, including Personal Information, on its own servers located at Polimi. POK controls its own copy of information collected through the POK Site and has an information security program designed to protect information in its possession or control. This is done through a variety of privacy and security policies, processes, and procedures. POK uses administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the information that it collects, receives, stores, or transmits. Nonetheless, no method of transmission over the Internet, or method of electronic storage, is 100% secure; and therefore, POK cannot guarantee its absolute security. While POK works hard to ensure the integrity and security of its network and systems, POK cannot guarantee that its security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining information.

    If POK learns of a security breach involving its copy of your Personal Information, POK may attempt to notify you electronically so that you may take appropriate protective steps. By using the POK Site or providing Personal Information to POK, you agree that POK can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the POK Site. If a security systems breach occurs, POK may post a notice on the POK homepage (www.pok.polimi.it) or elsewhere on the POK Site and may send an email to you at the email address associated with your POK account.

  8. Privacy Policy updates

    This privacy policy will be reviewed and updated from time to time. When changes are made, the privacy policy will be labeled as "Revised (date)," indicating that you should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. By accessing the POK Site after any changes have been made, you accept the modified privacy policy and any changes contained therein. In case you miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this privacy policy.

  9. Contact information

    If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the Personal Information that POK maintains about you, please contact the Data Protection Officer at privacy@polimi.it or phone +39 0223999378.

    If you consider the answer provided to be unsatisfactory, you may lodge, free of charge, a complaint with the Italian Authority for Data Protection - Garante per la protezione dei dati personali (www.garanteprivacy.it)

  10. Glossary

    • Cookies are unique identifiers usually in the form of small data files placed on your device that send certain information about your activity on the POK Site or in an email communication back to POK or the authorized third party that served the cookie. POK or third parties may also use Flash cookies.
    • Personal information is information that specifically identifies you or that, when combined with other information, could be used to identify you.
    • Tracking technologies are web beacons, clear gifs, pixels, and similar technologies that are also unique identifiers used to track your online activity but are not stored on your device.
    • Certificate of accomplishment is a virtual certificate that shows that you have successfully completed your POK course.

Effective date: May 25, 2018

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