1. Introduction

EUN Partnership aisbl (hereafter called European Schoolnet or EUN) is developing and managing the European Schoolnet Academy portal, which is subject to the privacy policy set out below.

EUN takes the protection of your privacy seriously. Our intention is to provide a secure and safe environment for all users. The following statement outlines the policies by which the European Schoolnet Academy portal collects, manages and uses the personal data provided to us by users, and how users of the portal may exercise their rights.

The General Data Protection Regulation (Regulation 2016/679), GDPR for short, governs this privacy statement; as such, the legal justification for collecting personal data is consent, which you provide when you register on European Schoolnet Academy.

The privacy statement details your rights in respect to the data we collect, for example, your right to contact us to get confirmation of the data we hold on you, the right to have your data rectified or to have it deleted. The privacy statement also tells you where you can get further information on our privacy policy and the official organisations to which you can complain in the event that you feel that your data rights have been infringed (see Section 9 of this policy).

2. What personal data do we collect?

To best serve our users, the European Schoolnet Academy portal requires users to submit personally identifiable data. Personally identifiable data refers to information which can be used to identify you.

The following personally identifiable data is required as a part of the registration process:
First name, Last name, Email address, and Country or Region of residence

In addition, information such as a user's IP address, Internet service provider (ISP), web browser, operating system, approximate times of use, referring site, specific user interactions with the systems functionality and any similar data exchanged between a user's computer and the servers of the European Schoolnet Academy portal will be collected. These will not be linked to specific user accounts except as indicated below.

Finally, aggregated statistics will be collected regularly, including, but not limited to, the number of users during a specific period, the preferred courses chosen by users, and account usage.

Personal data from participation in online courses

The European Schoolnet Academy offers users the opportunity to participate in an online course on or through the portal.

If you participate in an online course, we may collect certain student-generated content from you, such as assignments you submit, peer-graded assignments and peer-grading student feedback. We also collect course data, such as student responses to quizzes, forum entries and surveys on the platform.

Personal data from forums and other online communication tools

The European Schoolnet Academy may offer public forums or other communication tools (such as Padlet, Tricider, Infogram or ZeeMaps) as part of its online courses. These tools can be on the portal or they can be embedded or linked to from the portal. On the forums you can share comments, thoughts, photos, videos and other resources. In order to participate in a communication tool, you may be required to register with us and/or a partner site and provide personally identifiable information such as your name and email address. The use of external, third-party tools is optional as part of the online courses. These tools are managed by third-party websites applying their own privacy policies. By registering to them the participants accept that their personal data will be processed by these third parties (as controllers). We advise you to consult the respective Privacy Policies of these third-party websites for more detailed information.

Please keep in mind that information you post or make available in forums and other discussion tools will be publicly visible on the European Schoolnet Academy portal and in some rare cases, even outside of the portal. Accordingly, you should be careful when posting any personal or sensitive information and ensure you have the relevant permissions to share any resources.

Personal data from surveys

We may receive personally identifiable data when you provide information in response to a survey operated by us through SurveyMonkey or another third-party tool. If that is the case, surveys/questionnaires will include their own privacy statements, which will describe the type of personal data we will collect in the survey (for example, name, surname, email address, photographs, etc.), the purpose of the processing, who will have access to the data, and the period of time for which the data will be kept. However, this processing may additionally be subject to SurveyMonkey or the chosen tool's own terms and conditions (for SurveyMonkey, you can read more on their privacy policy here).

Personal data from third-party sites

We may receive personally identifiable data when you access or log in to a third-party site that displays information on our site, e.g. Twitter or Tricider. This may include the text and/or images available from the third-party site. We may also receive personally identifiable data from a third-party site if you log in using the authorisation mechanism of the third-party site, e.g. Google or Facebook.

Partner sites providing online course-related tools and services such as online quizzes, peer-marking mechanisms or social media functionality to the European Schoolnet Academy users may also collect personally identifiable data regarding the individual's use of that partner site while engaged with such online course-related activities. The partner sites may share that data with the European Schoolnet Academy for the purpose of improving European Schoolnet Academy's services, the partner site's services, and the individual's education experience. This data includes information such as the amount of time spent on the partner site and pages viewed.

3. How do we use the data we collect?

Personal information and contributions provided by the user or collected during usage of the European Schoolnet Academy platform will be used to:

• Allow users to contribute to the European Schoolnet Academy online courses through ratings, comments, bookmarks, tagging, completing quizzes and uploading their own resources.
• Track attendance on training courses, progress and completion of modules by individual users.
• Share personally identifiable information and performance in a given online course with the instructors or moderators who teach the course or are part of running the course.
• Liaise with external organisations offering official accreditation to confirm the course completion of those participants who have requested for such official accreditation.
• Enable and improve the user experience within this and similar projects via access control, tracking usage frequency, search behaviours, preferences and settings.
• Inform the user about learning resources and activities he or she might be interested in within this or other EUN projects and about any developments and updates related to the European Schoolnet Academy initiative.
• Allow and facilitate monitoring and research activities within and across EUN projects and activities.
• Collect, categorise and summarise of user contributions in the forums and other discussion tools, in order to present the course outcomes.

4. Who can access this data?

Access to personal data

Access to the full user data is strictly limited to designated EUN staff and course moderators/instructors.

Some data submitted by users will be displayed in the restricted area of the platform, meaning that it is visible only to other participants of the courses you are taking part in. You can choose for the “profile visibility” to be either full profile or limited profile. The following data is then visible:

• Full profile: Username, image (if added), joining date, country, language, description, social media accounts (Facebook, Twitter, LinkedIn), course certificates and accomplishments (course badges).
• Limited profile: Username and image (if added),

Any comment or input voluntarily made by a course participant using the provided interaction tools is visible for the users of the same course.

The transfer of specific data to other third parties can be permitted under the specific authorisation of the Data Controller; such authorisation will only be granted by the Data Controller to third parties with a legitimate interest in this information, taking into account the context and scope of the European Schoolnet Academy portal and/or the European Schoolnet Academy initiative (e.g., educational organisations, governmental bodies, research centres, universities, partners in the European Schoolnet Academy initiative). Personal data will only be transferred in accordance with applicable regulations. Data will be anonymised always before it is transferred to third parties for research purposes. EUN will not divulge your personal data for direct marketing purposes to third parties. EUN will have access to provided account information and can modify and/or delete information as needed to maintain the integrity of the user database or to ensure the proper operation of the European Schoolnet Academy platform.

Personal data from forums and other online communication tools

To facilitate your use of the forums and communication tools, we may use personally identifiable data collected during your use of these tools. In addition, we may publish this information via the portal or third-party extensions in order to present and summarise outcomes of a course.

We also reserve the right to reuse and reference posts in forums and communication tools containing personally identifiable data in ongoing and future versions of the courses we offer, and to enhance future course offerings. We may archive these posts and/or use them for future communications with course participants. We may also use or publish posts submitted on the forums without using personally identifiable data. Any contributions shared by the users, unless specified otherwise, will be licensed in the same way as all other course materials using a Creative Commons Attribution Share-Alike License. This means any user contributions can be reused and adapted, even for commercial purposes, as long as the original source is credited and the material is published using the same license. For example, lesson plans or learning diaries prepared by users and submitted as part of the courses would fall under this license, unless specified otherwise by the user.

Personal data for research

We may use and share general course data (including quiz or assignment submissions, grades, and forum discussions), information about your activity on our portal, and demographic data from surveys operated by us with our partners, so that our partners may use the data for research related to online education. Any data shared with our partners will be fully anonymised.

Length of data storage

Personal data provided by the users of the portal or collected during their usage of the portal will not be stored by EUN in a form allowing the identification of the users for longer than three years after the last use of the European Schoolnet Academy platform by the user or, in the case of multiple registrations, three years after the last use by the user of any site maintained by EUN, whichever is the later. In addition, registered users may contact the EUN as indicated below to terminate their accounts, which will result in the deletion of the personal data that they have provided during registration. EUN is not in charge of any data submitted on third-party tools which may apply different retention period for personal data.

5. Google Analytics

Google Analytics is a web analytics tool that uses cookies to track visitor interactions, helping website owners understand how visitors engage with their website. Google Analytics customers can view a variety of reports about how visitors interact with their website so that they can improve it. Google Analytics collects information without identifying you directly. It reports website trends to its users, such as ourselves, without identifying individual visitors. Specifically, and depending on whether Google has access to this information, users can get information on the visitors' age group, gender, interests, language preference, location, browser, device and operating system. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page.

6. Cookies

To make this site work properly, we sometimes place small data files called cookies on your device. Most big websites do this, too.

What are cookies?

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don't have to keep re-entering them whenever you come back to the site or browse from one page to another.

How do we use cookies?

On our site, we only use a very limited number of cookies, namely user preferences. These cookies help to improve a user's experience of a website by providing a more personalised service, without having to ask you again every time; more specifically, our Open edX Portal stores a limited number of user preferences, such as language and session id.

The platform applies the following cookies:

• _gat_gta_UA: Google Analytics tracking cookie
• _ga: Google Analytics tracking cookie
• _gid: Google Analytics tracking cookie
• csrftoken: a client-side token used to sign in the client browser to the platform
• edx-user-info: set when the user has logged in. Has information like username, version, enrolment status, urls, etc.
• edxloggedin: a “is logged in” status tracker
• openedx-language-preference: language of the user (UI)
• sessionid: edx generated session ID (can persist across browser sessions)
• welcome-message-timer: if the welcome message needs to be displayed
• welcome-message-viewed: if the welcome message has been viewed by the user
• Other specific cookies for specific actions (e.g. instructor dashboard)

How to control cookies?

You can control and/or delete cookies as you wish – for details, see aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.

7. Site security

The European Schoolnet Academy portal has implemented and continues to maintain appropriate technical and management measures to keep your personal information secure and safe from loss, damage, corruption, or deletion.

8. Changes within this privacy policy

Any and all changes to this privacy policy will be posted here and will take effect upon their publication. Users will be informed by email in case of any major changes in the privacy policy. If you have questions or concerns about this privacy policy, at any time, please contact privacy@eun.org

9. Contacting European Schoolnet

For any questions related to the European Schoolnet Academy platform’s privacy policy, you can contact us:

You can also contact us in order to exercise your right to data portability, access, rectify and, as the case may be, erase, any personal data relating to you, or restrict the processing of your personal data, in compliance with applicable laws. Please note that we may ask you to provide proof of identity (such as a copy of your ID card or passport) before we can comply with your request. Whenever we process your personal data based on your consent, you also have the right to withdraw your consent at any time.

10. Making an official complaint

If you feel that we have infringed your data protection rights, you may make an official complaint to the Data Protection Authority in the country where you reside or the Belgian Data Protection Authority at the following address:

Belgian Data Protection Authority
Rue de la Presse 35
B-1000 Bruxelles