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en:privacy_policy [2018/06/14 14:59]
en:privacy_policy [2018/06/20 11:14] (current)
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 +==== Privacy Policy ====
-Effective starting: April 22018.+This Privacy Policy governs the manner in which GUnet collectsuses, maintains and discloses information collected from users (each, a “User”) of the mobile application Open eClass. (each, an "​Application"​).
-This Privacy Policy informs you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from visitors and registered users of efrontlearning.com (this "​Site"​). This Privacy Policy applies only to information that you provide to us through this Site and explains in plain language what we do with that information,​ how we share it, and how we handle the content you place. It also explains your rights and the choices available to you regarding our use of your personal information and how you can access and update this information. 
-Our Privacy Policy may be updated from time to time, and we will notify you of any material changes by posting the new Privacy Policy on the Site at Privacy policy and revising the “Effective starting” date at the top of this policy. Such updates are also expected the coming months due to the forthcoming GDPR EU regulation; You may find out more about eFront GDPR compliance on the website at eFront GDPR. We encourage you to review our Privacy Policy whenever you use this “Site” to stay informed about our information ​practices and the ways you can help protect your privacy. If you disagree with any changes to this Privacy Policy, you will need to stop using this “Site” and deactivate your account(s), as outlined below.+=== Personal identification ​information ​===
-This Privacy Policy applies to the information that we obtain through your use of "​Site"​ via a "​Device"​ or when you otherwise interact with eFront. A "​Device"​ is any computer used to access the “Site”, including without limitation a desktop, laptop, mobile phone, tablet, or other consumer electronic device. “Site” includes the eFront web site and e-learning service but does not include any other own or third party products or services for which a separate privacy policy is provided. These are third party products or services that you may choose to integrate with eFront services, such as third party Add-Ons/​Plugins in the Marketplace. You should always review the policies of third party products and services to make sure you are comfortable with the ways in which they collect and use your information. 
-By registering for or using eFront Services ​and accepting the Terms of Service you consent to the collection, transfer, processing, storage, disclosure ​and other uses described in this Privacy Policy.+Application may collect personal identification information from Users such as username, password ​and Open eClass installation URL. This kind of personal information remains only in mobile device memory ​and / or mobile device Operating System.
 +=== Non-personal identification information ===
-==== What information we collect? ====+We may collect ​non-personal identification information about Users whenever they use mobile application to interact with Open eClass installations. Non-personal identification information may include the browser name, the type of mobile device and technical information about Users means of connection to our Site, such as the Mobibe operating system and the Internet service providers utilized and other similar information.
-    Visitors and Users: In the course of using mobile application,​ you may provide us with personally identifiable information. This refers to information about you that can be used to contact or identify you, and information on your use of and activities at our Site that may be connected with you ("​Personal Information"​). Personal Information that we collect may include, but is not limited to, your name and email address. When you visit the Site, our servers automatically record information that your browser sends whenever you visit a website. This information may include, but is not limited to, your Internet Protocol address, browser type, the web page you were visiting before you came to our Site and information you search for on our Site. Like many websites, we may also use "​cookies"​ to collect information. A cookie is a small data file stored by your browser at your Device'​s hard disk for record-keeping purposes. We use "​session ID cookies"​ in order to support login and main service functionality. ​+=== Session ​data ===
-    In some cases another User may create an account on your behalf and may provide your information,​ including Personal Information (most commonly when your company requests that you use our service). We collect Information under the direction of our Customers and often have no direct relationship with the individuals whose personal ​data we process. If you are an employee of one of our Customers and would no longer like us to process your information,​ please contact your employer and us at the contact information below.+Our Application uses “session ​data” in order to run properly. If User deletes session data from his / hers mobile device ​our Application may not function properly.
-    Customers: In addition to the data we collect for all Users, we also collect data that are required for your contract with us, such as your company affiliation,​ invoicing data and also service usage data that prove that the service is used in accordance to your subscription terms, We may also acquire additional data through our Customers’ support requests to the extent this is required for us to resolve a technical issue or respond to a request or complaint. We also email to our Customers newsletters,​ announcements regarding our services, or marketing material. If you are a Customer and no longer wish to receive such emails you can remove yourself from the recipients list at any time by selecting the "​unsubscribe"​ link provided within the e-mail footer. If you are providing ​information ​(including Personal Information) about someone else, you must have the authority to act for them and to consent to the collection and use of their Personal Information.+=== Collection of non-personal ​information ​===
-    Content: We collect and store Content that you create, input, submit, post, upload, transmit, store or display in the process of using our “Site”Such Content includes any Personal ​Information ​or other sensitive information that you choose ​to include ("​incidentally-collected Personal Information"​). Although Epignosis owns the code, databases, and all rights to the service, Customers retain ownership, control and all rights to their records ​and data which are their property.+ GUnet may collect and use Users non-personal information to improve customer service. Information you provide helps us respond ​to your customer ​service ​requests ​and support needs more efficiently.
-    Other submissions:​ We collect other data that you submit to our “Site” or as you participate in any interactive features of the eFront Services, participate in a survey, contest, activity or event, request customer support, or otherwise communicate with us. +=== Sharing your personal information ===
-    How We Use, Process and Retain Personal Information+
-    Personal Information is or may be used for the following purposes: +We do not sell, trade, ​or rent Users personal or non personal identification information to others. We may share generic aggregated demographic information not linked ​to any personal identification information regarding visitors ​and users with our business partnerstrusted affiliates ​and advertisers for the purposes outlined above
-        ​to provide ​and improve ​our Siteservices, features ​and content, +
-        to administer your use of our Site, +
-        to enable you to enjoy and easily navigate ​the Site, +
-        to better understand your needs and interests,​ +
-        to fulfill requests you may make, +
-        to personalize your experience,​ +
-        to provide or offer software updates and product announcements,​ and +
-        to provide you with further information and offers from us or third parties that we believe you may find useful or interesting,​ including newsletters,​ marketing or promotional.+
-    We use information we obtain by technical means (such as the logging performed by our servers or through the use of cookies) for the above purposes and in order to monitor and analyze use of the Site and our services, for the Site's technical administration,​ to increase our Site's functionality and user-friendliness,​ to better tailor it to your needs, to generate and derive useful data and information concerning the interests, characteristics and website use behavior and to verify that visitors to the Site meet the criteria required to process their requests.+=== Changes ​to this privacy policy ===
-    We collect and process personal data in a transparent manner, ​to the extent necessary for specifiedexplicit and legitimate purposes, and do not process it further in manner incompatible with those purposes. We take care that the data we collect are accurate and, when necessary, updated. We take all reasonable steps to immediately delete or rectify personal data, if inaccurate. We process data in a way that guarantees their security, including their protection against unauthorized or unlawful processing ​and accidental loss, destruction or degradation,​ using appropriate technical or organizational measures. We are ready to prove at any moment ​how we adhere ​to the above principlesWe take the appropriate technical ​and organizational measures for the security, confidentiality,​ integrity ​and availability ​of the dataWe expressly declare that these measures ensure that, by definition, personal data are not made accessible without the intervention of the natural person to an indeterminate number of natural persons.+GUnet has the discretion ​to update this privacy policy at any time. When we dowe will post notification on the main page of our Siterevise the updated ​date at the bottom of this page and send you an email. We encourage Users to frequently check this page for any changes to stay informed about how we are helping ​to protect ​the personal information we collectYou acknowledge ​and agree that it is your responsibility to review this privacy policy periodically ​and become aware of modifications. 
 +Your acceptance of these terms
-    Each eFront instance data are retained for as long as the Customer'​s subscription ​to the service lastsUpon contract expiration ​the data will be deleted or returned to the Customer if the Customer instructs us to. Alternatively,​ the data will be stored offline for 12 months so that a service reconnection is as smooth as possible; in case subscription is not renewed after 12 months, the data are permanently deleted. +By using this Application,​ you signify your acceptance of this policy. If you do not agree to this policy, please do not use our ApplicationYour continued use of the Application following ​the posting of changes ​to this policy ​will be deemed your acceptance of those changes.
-    Information Sharing and Disclosure+
-    Users: We will display your Personal Information in your profile page and elsewhere on the Site according to the preferences you set in your account. Any information you choose to provide should reflect how much you want other eFront users to know about you. We recommend that you guard your anonymity and sensitive information,​ and we encourage you to think carefully about what information you disclose in your profile pages. You can review and revise your profile information at any time. You should be aware that the administrator,​ as well as specially designated support personnel in order to provide support for technical issues you may face, may be able to: access information in and about your account; access communications history, including file attachments,​ for your account; disclose, restrict, or access information that you have provided or that is made available to you when using your account, including your Content; and control how your account may be accessed or deleted. +=== Contacting us ===
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-    Third Parties: We do not sell your Personal Information or Content and will not share or disclose any of your Personal Information or Content with third parties except as described in this policy. We do not share Personal Information about you with third parties for their marketing purposes (including direct marketing purposes). +
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-    Service Providers, Business Partners and Others: For security, service operation and management purposes, eFront also uses third-party services for its managed eFront instances that provide the same level of protection as Epignosis. Third-party vendors and providers supply the necessary hardware, software, networking and storage to run the eFront LMS service instances; a detailed listing of them is included in the Terms of Service in the Data Processing Addendum (DPA). These third parties have access to your Personal Information only for purposes of performing these tasks on our behalf. +
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-    Compliance with Laws and Law Enforcement:​ eFront cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of eFront or a third party, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. +
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-    Children: Our services are not directed to children. We do not knowingly collect Personal Information from children. If we become aware that a child has provided us with Personal Information,​ we will take steps to delete such information. If you become aware that a child has provided us with Personal Information,​ please contact us at the contact information below. +
- +
-    Business Transfers: We may share or transfer your Information (including your Personal Information) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You will be notified on any change in ownership or uses of your Personal Information,​ as well as any choices you may have regarding your Personal Information. +
-    Your Rights +
- +
-    Epignosis respects your rights as a data subject. When Epignosis processes personal data on behalf of and as instructed by its Customers, our Customers are responsible towards the data subjects and you should contact the respective Customer to which the content of your service belongs for exercising your rights. In this case, Epignosis does not respond directly to your requests for the exercise of your rights that come to our knowledge, but we inform the Customer without delay and provide all reasonable and reasonable assistance to satisfy your requests in accordance with instructions of the Customer. The service has all the necessary features to enable our Customers to exercise the rights of the data subjects on their behalf. For example, the service provides the ability to obtain and manage consent, and to implement strict and secure password policies as well as to exercise the right to be forgotten. +
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-    A synopsis of your rights as a data subject is provided below. You may also refer to the eFront GDPR page for detailed step-by-step instructions on how you can exercise these rights by means of invoking eFront service features. +
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-    Transparency,​ information and answers to requests: Epignosis adheres to the principle of transparency in processing. For any question regarding this policy you may contact us at the email provided at the end of this Policy. We will respond without delay and in any case within one month upon receipt of the request. +
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-    Access: You have the right to receive from Epignosis confirmation on whether your personal data are processed and in case this happens all required information thereof (processing means, goal, records etc.). +
- +
-    Rectification:​ You have the right to require the rectification of inaccurate data relating to you without undue delay, as well as to fill in incomplete data if necessary for processing. +
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-    Erasure: You have the right to ask for the erasure of personal data concerning you without undue delay. Epignosis by means of its designated personnel will erase the data where one of the following grounds applies: a) the personal data are no longer necessary in relation to the purposes of processing; or b) the person requesting the erasure withdraws consent on which the processing is based and there is no other legal ground for the processing; or c) the data subject objects to the processing and there are no overriding legitimate grounds for the processing or the data subject objects to processing for direct marketing; or d) the personal data have to be erased for compliance with a legal obligation. Epignosis will not proceed to the erasure of the personal data if the data must be maintained for compliance with a legal obligation or in cases where the processing is required for the establishment,​ exercise or defence of legal claims. If you receive marketing emails, you can remove yourself from the recipients list by selecting the "​unsubscribe"​ link within the e-mail. +
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-    Restriction of processing: You have the right to request restriction of processing if the accuracy of personal data is disputed, for that period of time that allows Epignosis to verify the accuracy of personal data, or based on any other legitimate reason specified in applicable Data Protection Laws. +
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-    Data Portability:​ You have the right to receive your personal data in a structured, commonly used and machine-readable format as well as the right to request the direct transmission of personal data by Epignosis to another, if this is technically feasible. +
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-    Right to Object: You may oppose the processing of personal data which takes place without your consent. In this case, Epignosis no longer submits the personal data unless it demonstrates imperative and legitimate reasons for the processing that outweigh the interests, rights and freedoms of you as a data subject or for the foundation, exercise or support of legal claims. If you receive promotional emails, you can remove yourself from the recipients list by selecting the "​unsubscribe"​ link within the e-mail content. You may also oppose processing at any time by contacting us at the email provided at the end of this Policy. +
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-    Complaint to Supervisory Authority: You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes Data Privacy Laws. +
-    Security +
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-    eFront is very concerned with safeguarding your information. We employ reasonable measures designed to protect your information from unauthorized access. +
-    Data Ownership +
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-    Although Epignosis owns the code, databases, and all rights to the eFront service, Customers retain ownership, control and all rights to their records and data which are their property. +
-    Data Transfers from EU to the United States +
- +
-    Epignosis LLC participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. We are committed to subjecting all Personal Information received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield website Privacy Shield website. A list of Privacy Shield participants is maintained by the Department of Commerce. While this Site, including the demo sites that you may set up to try out the service are hosted in the US, eFront instances can be and are already deployed in the US, the EU or elsewhere as instructed by our customers, using cloud infrastructure providers with global presence. You can choose the location of your eFront instance from multiple options across the US, Asia, Australia and the European Union, including France, Germany, Ireland and the UK and you can configure your eFront instance not to perform any international data transfers. +
-    Cooperation With Supervisory Authority +
- +
-    Epignosis cooperates with the competent supervisory authorities,​ while Epignosis LLC is represented within the Union by the English company Epignosis UK Ltd. +
-    ​Contacting ​Us +
- +
-    If you have any questions about this Privacy Policy, please contact ​us at: privacy at efrontlearning dot com.+
 +If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at eclass@gunet.gr
 +This document was last updated on June 19, 2018