1.1 Introduction

This Privacy Policy constitutes the agreement between Babeș-Bolyai University (“UBB”) and you, as a user who accesses, subscribes to access, or otherwise establishes a connection (“User”) to https://promis.education(“Platform”). Our provision of the Platform and related eLearning and educational services are further referred to collectively as the “Services”.

This Platform may collect personal information from our users. By using these Services and agreeing to this Policy, you consent to collecting, storing, and processing your data as outlined in our Privacy Policy.

Our Services are intended for general audiences over the age of 16 years old. We do not knowingly collect information from children under the age of 16 years old.

The PROMIS platform does not intentionally collect information from users under the age of 16. If a parent or legal guardian notifies UBB of the existence of such personal data, UBB will take all necessary steps to delete the information.

If you believe that data from a person under the age of 16 has been collected through the UBB website, please contact us at the following e-mail address: dpo@ubbcluj.ro.

IF YOU ARE NOT AT LEAST 16 YEARS OLD, DO NOT USE THE SERVICES.

You must agree to abide by all the provisions of these Terms to remain an authorized user of the Platform and your use of the Platform constitutes your agreement to comply with these Terms. You are solely responsible for your use of the Platform and ensuring that your use complies fully with these Terms’ provisions. Your rights are personal and non-assignable. This means that you will be responsible for the acts of anyone accessing the Platform through you or using your name and password.

We reserve the right, in our sole discretion, to change any or all of the provisions of this Policy at any time. We will notify you of any material changes by posting them on the Platform or through other reasonable means of providing notice. Any changes to these Terms will be effective immediately upon notice to you unless we advise otherwise. Your use of the Platform after notice of changes to this agreement will be deemed your acceptance of the changes. We reserve the right, in our sole discretion, to change, limit, or discontinue any aspect, content, or feature of the Platform, as well as any aspect pertaining to the use of the Services.

IF YOU DO NOT AGREE TO THE PROVISIONS OF THESE TERMS, YOUR SOLE AND EXCLUSIVE REMEDY IS TO DISCONTINUE YOUR USE OF THE PLATFORM AND SERVICES, AS APPLICABLE.

1.2 Consent for processing personal data when using the Platform

The information below is provided to you to have a faithful image of our activity on the Platform regarding personal data processing. You will also find identification information, our goals, your rights and the concrete ways to achieve it. Data privacy is one of our primary concerns.

 

Users’ personal data is processed strictly for implementing, managing and monitoring the Erasmus+ Strategic Partnership project “Promoting social inclusion skills in a post-truth world: A gamified online platform and curriculum” (“PROMIS”) (no. 2019-1-RO01-KA203-063157). The protection of personal data under PROMIS has as its central and constant concern to ensure to the users their fundamental human rights and freedoms in the spirit of the Charter of Fundamental Rights of the European Union.

UBB is a personal data operator, as defined in Art. 4 (7) of the GDPR and performs operations or sets of operations through which it processes personal data.

Babeș-Bolyai University is a higher education institution in Romania located in Cluj-Napoca.

Address: 1 Mihail Kogălniceanu Street

400084, Cluj-Napoca, Romania

Tel: +40 264 405 300

Fax: +40 264 591 906

Mob: +40 744 423 188 (DPO UBB)

E-mail: dpo@ubbcluj.ro

With this Privacy Policy, we inform you about the processing of personal data in connection with the use of this Platform. If you are redirected to other websites via a link, the respective website operator’s privacy policy applies. We recommend that you inform yourself about the handling of personal data on the respective website. We know that your data’s protection is important to you and appreciate the trust placed in us. UBB strictly adheres to the applicable data protection law’s legal provisions when collecting, processing, and using your data.

This Privacy Policy tells you how we will collect and use your personal data to provide our service, which allows you to use our Platform, content and to be connected with other people for the process of collaborative learning.

In accordance with the provisions of Art. 6 (1) and Art. 7 of EU Regulation 2016/679 (GDPR) express my consent for my personal data identified according to the table below to be processed by Babeș-Bolyai University of Cluj-Napoca (Romania), University of Bologna (Italy), University of Bordeaux (France), Cardinal Stefan Wyszyński University of Warsaw (Poland), Kaunas University of Technology (Lithuania), Utrecht University (Netherlands) SC eLearning & Software SRL Arad (Romania) within the Erasmus+ Strategic Partnership project “Promoting social inclusion skills in a post-truth world: A gamified online platform and curriculum” (PROMIS) (no. 2019-1-RO01-KA203-063157).

The project contract (no. 2019-1-RO01-KA203-063157) is concluded between UBB as project coordinator and the National Agency for Community Programs in the Field of Vocational Education and Training. UBB has as partners the University of Bologna (Italy), the University of Bordeaux (France), Cardinal Stefan Wyszyński University of Warsaw (Poland), Kaunas University of Technology (Lithuania), Utrecht University (Netherlands) SC eLearning & Software SRL Arad (Romania).

1.3 What is personal data

 

Under the EU’s General Data Protection Regulation (GDPR), personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

If you have an account at Platform, we will process your personal data manually entered by you or with which you agreed in advance, such as:

• Name;
• E-mail address, IP address;
• Enrollment in a University and Study specialization;
• E-mail address;
• Data on how you use the Platform, Activity on the Platform, Activities in the courses, Grades, Certificates, Badges and Points obtained in the eLearning courses provided by Promis Project, Feedback provided;
• Other information regarding the access and actions carried out on the Platform, as well as any other categories of data you provide directly in the context of user account creation in the context of discussion forums, placement of feedback, comments or requests through the Platform or in any other way resulting from the use of the Platform.

Some data is registered just based on your visit. When you visit our Platform, the browser on your device automatically sends information to the server on our Platform. This information is temporarily stored in a so-called log file. The following information is collected and stored until it is automatically deleted: IP address of the requesting computer; date and time of access; name and URL of the accessed file; website from which access is made (“referrer URL”); if applicable, the search engine you used; the browser used; and, if applicable, the operating system of your computer as well as the name of your access provider.

1.4 Personal data we request and reasons

Personal data are provided individually by each participant directly on the PROMIS’s platform, https://promis.education.

UBB owns the Platform as the coordinator of Erasmus+ Strategic Partnership project “Promoting social inclusion skills in a post-truth world: A gamified online platform and curriculum” (PROMIS) (no. 2019-1-RO01-KA203-063157). The Platform is Administered from the technical point of view by eLearning & Software SRL (Romania).

Depending on the purpose of the processing, we inform you about the types of personal data processed, the purpose of the processing, and the legal basis for processing, storing, and transmitting personal data.

Personal Data	Purpose of processing	Processing means	Legal basis
Name, Surname	- account creation - identification in the platform	Sign-Up form	Consent (Art. 6 (1) (a) of the GDPR)
E-mail Address	- validation of the account registration to the platform - notifications regarding Trainers’ feedback and points obtained - communication with Trainers and other peers - password recovery	Sign-Up form	Consent (Art. 6 (1) (a) of the GDPR)
Username and Password	- private connection to the platform - course enrollment and identification	Sign-Up form	Consent (Art. 6 (1) (a) of the GDPR)
IP	- identification – temporary storage	Automated collection	Consent (Art. 6 (1) (a) of the GDPR) Cookies Policy
University, Subject of study program	- enrollment to training programs - assessment of activities within the Platform	Profile editing	Consent (Art. 6 (1) (a) of the GDPR)

 

Personal data - which have been or will be requested - will be provided by you and will be processed within a period of time provided for in European and national legislation, in accordance with the GDPR and other legal bases that require this, respecting the principles of ensuring their security and respecting your rights. In this case, European law provides for a retention period of 8 years from the project’s start date, 4^th of November 2019.

The personal data collected within PROMIS are processed by UBB together with SC eLearning & Software SRL Arad (Romania), the administrator of the MOODLE platform https://promis.education as an associated operator.

Some of the personal data collected are accessible to teachers from the University of Bologna (Italy), the University of Bordeaux (France), Cardinal Stefan Wyszyński University in Warsaw (Poland), Kaunas University of Technology (Lithuania), Utrecht University (Netherlands).

The transfer of personal data is based on the contract concluded between Babeș-Bolyai University of Cluj-Napoca and the stated partners.

 

In accordance with Regulation (EU) 2018/1725 on the protection of individuals with regard to the processing of personal data by EU institutions, bodies, offices and agencies and on the free movement of such data, part of personal data is transferred to:

Head of Unit B4

Directorate B - Youth, Education and Erasmus +

General Directorate of Education, Youth, Sports and Culture

The European Commission

B-1049 Brussels

Belgium

and,

The National Agency for Community Programs in the Field of Vocational Education and Training

Splaiul Independenței no. 313, UPB Central Library, building A,

060042 Bucharest

Romania

UBB has taken steps to ensure full security in the process of transferring personal data in accordance with the GDPR. PROMIS partners have established technical and organizational measures to ensure the security of personal data. The servers on which personal data is stored are located in the EU.

We inform you that in accordance with Art. 7 of the GDPR, you can withdraw at any time your consent to the processing of your personal data for the purposes previously set out in the space for your Personal Profile.

This consent may not be used by UBB and partners for purposes other than those explicitly stated in the document, including their transmission to third parties.  

1.5 What data protection rights do I have?

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights in accordance with the GDPR:

-       the right to be informed (Art. 13 and 14 of the GDPR) - about the type, purpose, and legal grounds of the processing;

-       the right to access data (Art. 15 of the GDPR) - the person has the right to obtain confirmation from the controller if he processes personal data concerning him;

-       the right to rectification (Art. 16 of the GDPR) - of personal data without undue delay;

-       the right to delete data, “the right to be forgotten” (Article 17 of the GDPR) - to obtain from the controller the deletion of personal data concerning you, without undue delay, and the controller has an obligation to delete the data staff without undue delay;

-       the right to restriction of processing (Art. 18 of the GDPR) - when you consider that personal data are inaccurate, or you consider that the processing is illegal, or the operator no longer needs this data;

-       the right to be notified of the rectification or deletion of personal data or the restriction of processing (Art. 19 of the GDPR);

-       the right to data portability (Art. 20 of the GDPR) - you have the right to receive personal data concerning you and which you have provided to the controller in a structured format, commonly used and which can be read automatically to could transmit to another operator;

-       the right to object (Art. 21 of the GDPR) - you may object to the processing of personal data concerning you, including Article 6 (1) (e) or (f) or Article 6 (1), including creating profiles based on those provisions;

-       the right not to be subject to a decision based exclusively on automatic processing, including the creation of profiles (Art. 22), which produces legal effects concerning you or similarly affects you to a significant extent;

-       the right to submit a complaint to the National Authority for the Supervision of Personal Data Processing in Romania (Art. 15) - anspdcp@dataprotection.ro or  https://www.dataprotection.ro/?page=Plangeri_pagina_principala. Previously, the complaint will be submitted to UBB (dpo@ubbcluj.ro).

For additional information related to the privacy policy regarding the protection of personal data of UBB or if you have questions or concerns regarding the processing of your personal data, you can contact the Head of Personal Data Protection (DPO) of Babeș-Bolyai University ( https://www.ubbcluj.ro/ro/politici/) at Tel: +40 264 405 300 int 6028, Mobile: +40 744 423 188, Fax: +40 264 591 906, E-mail: dpo@ubbcluj.rob, correspondence: Babeș-Bolyai University - Cluj-Napoca, Mihail Kogălniceanu street, no. 1, 400084, Cluj-Napoca, Romania.

This privacy policy is supplemented by:

- Cookies policy

- Consent to the processing of personal data

- Guide to the processing of personal data during the PROMIS