Privacy policy [English version]

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1. Definitions

General Conditions, Service Agreement, Cookies, Personal Data, Learners, Adult Learners, Underage Learners, Teachers, GDPR, Parent, Groups, Non School Groups, School Groups, Information Society, Platform, Profiling, School, Services, Company, Treatment, Users, Weschool.

1. General Conditions: general conditions of the Services offered by WeSchool, signed by each User.
2. Service Contract: contract relating to the provision of the Services signed between WeSchool and the School or the reference Company of the Users, which provides for the appointment of WeSchool as the person responsible for the Processing of Personal Data relating to the Services pursuant to art. 28 of the GDPR by the School or the Company.
3. Cookies: cookies are text files (letters and / or numbers) that contain information packets that are stored on the User's computer or mobile device every time he visits a website through a browser or through a web app. At each subsequent visit, the browser sends cookies to the website that originated them. Cookies can be stored only for the time of use of a specific site (i.e. session cookies), or for a longer period of time independent of the session (i.e. persistent cookies).
4. Personal Data: any information relating to a natural person, identified or identifiable, directly or indirectly, by reference to the name, an identification number, location data, an online identifier or elements characteristic of his physical, physiological, genetic identity , psychic, economic, cultural or social.
5. Learners: learners who use the Services to participate in the educational or training courses of their teachers, within private groups.
6. Over 18 learners: Learners aged at least 18 years.
7. Underage Learners: Learners under the age of 18 who access the Services by virtue of specific Parent authorization.
8. Teachers: teachers who use the Services to carry out educational or training courses for their Learners, within private groups.
9. GDPR: EU Regulation 2016/679 of 27 April 2016.
10. Parent: parent and / or guardian exercising parental responsibility of a Minor Learner who intends to use the Services.
11. Groups: School groups and non-school groups created by teachers and marked by individual "class codes" within which to share teaching and training material with the students.
12. Non-School Groups: Groups marked by “class codes” which identify them as “non-school groups” on the Platform, if, by way of example: (i) the Teacher decides not to create a School Group; (ii) the Teacher is associated with a Company (regardless of the existence or otherwise of a Services Agreement with any associated Company); or (iii) the Learner attempts to register as a Teacher.
13. School Groups: Groups marked by "class codes" that identify them as "school groups" on the Platform, regardless of whether or not there is a Service Contract with any School associated with the Users participating in the Group.
14. Information: information on the processing of Personal Data and information on the Cookies that make up this document. This Notice does not concern any Processing of Personal Data conducted through any third party sites, pages or online services of third parties, accessible by the User via links on the Platform.
15. Platform: distance learning platform accessible through the app.weschool.com website and / or WeSchool app where the Services are provided.
16. Profiling: analysis with automated systems of personal aspects and navigation data, for evaluation and predictive purposes.
17. School: school of any order or grade in which the teachers work, for whatever reason, and which is attended by the Learners (ie the students / pupils of the School).
18. Services: services provided through the Platform, which allows various forms of interaction between Users. In particular, the Services consist in the possibility for the Teacher to create Groups, building and delivering interactive and engaging learning paths, as well as organizing and managing a virtual classroom for live lessons and a chat.
19. Company: company or other form of organization or association with or without profit that organizes and manages, through teachers appointed by the same, training courses for its employees or collaborators, in the role of Learners.
20. Treatment: any operation or set of operations concerning Personal Data, such as, by way of example, the collection, organization, structuring, storage, modification, extraction, consultation, use, communication , interconnection, limitation, cancellation and destruction.
21. Users: all users of the Platform, such as Teachers, Learners and Parents.
22. WeSchool: Oilproject S.r.l., with registered office in Via Guido Reni 42, 20133, Milan C.F./P.IVA 07236760968 and Milan Business Register M-1946066.

2.         Data Controller

1. Treatments strictly connected and functional to the Services: i) in the event of a lack of a Services Contract, WeSchool, or ii) in the event of a Services Contract, the School or the reference Company of the Users;
2. Treatments not strictly connected and functional to the Services: WeSchool.

a) Processing of Personal Data strictly connected and functional to the provision of the Services referred to in point 4 letters b), c), d) and e) of this Notice:

i) in the absence of a Services Agreement: the owner is WeSchool (as defined in point 1.22 of this Notice);

ii) in case of existence of a Services Contract: the owner is the School or the reference Company of each User, based on their privacy policy (which WeSchool invites you to analyze before using the Services), and WeSchool acts as a manager, pursuant to art. 28 of the GDPR, on behalf of the School or the Company, from time to time the owner.

b) Processing of Personal Data not strictly connected to the provision of the Services referred to in point 4 letters a), f), g), h) and i) of this Notice: the owner is WeSchool (as defined in point 1.22 of this Notice).

Any request from the User relating to the Processing performed by WeSchool as the owner (including the exercise of the rights referred to in points 10 and 11 below will be addressed to WeSchool by one of the following means:

• by post to the registered office: Oilproject S.r.l., Via Guido Reni 42, 20133, Milan;
• by e-mail to the following address support@weschool.com.

3.         Personal Data Protection Officer (DPO)

Legal Area S.r.l.

rpd@weschool.com

Area Legale S.r.l., with registered office in Rome, Via Crescenzio, n. 9.
For contacts: rpd@weschool.com.

4. Purpose and legal basis of the processing

1. navigation on the Platform: consent;
2. in case of non-school groups, check of age: legal obligation;
3. Registration to Groups on the Platform: signing of the General Conditions;
4. use of the Services: signing of the General Conditions;
5. checks or investigations on illegal or fraudulent uses of the Platform: signing of the General Conditions and, in case of involvement of authorities, legal obligation;
6. sending of commercial and promotional communications by WeSchool: legitimate interest;
7. Profiling: express consent;
8. sending commercial and promotional communications on behalf of third parties: express consent;
9. improvement of the Services and the Platform: legitimate interest.

WeSchool collects and uses the Personal Data of Users to achieve the following purposes:

1. Allow browsing on the Platform, essentially through the use of Cookies: the processing of personal data for the purposes referred to in letter a) is governed by the Cookies Policy which WeSchool recommends reading.
2. In the event of a request for registration to Non-School Groups, check that the Learners are of majority age, in order to allow Minors to register on the Platform and use the Services, with prior and specific authorization from the Parent: the Processing of Personal Data for the purpose referred to in letter b) is necessary to allow the Underage Learner to access the Non-Scholastic Groups available on the Platform, and consequently, to register and use the Services. Any indication of an age under 18 prevents the Minor Learner from accessing Non-Scholastic Groups without prior, specific and express authorization from the Parent. This processing is based on the legal obligation of WeSchool to verify the age and consequent ability to act of the Users who intend to access the Platform. In the case of a Minor Learner, the signing of the General Conditions and this Information is requested from the Parent, in the name and on behalf of the Minor Learner himself.
3. Allow Users to register with a Group on the Platform and create a personal account. In particular, with regard to Minor Learners, the registration on the Platform and the creation of a personal account is performed by the Parent, in the name and on behalf of the Minor Learner: the Processing of Personal Data for the purposes referred to in letter c) is necessary for access to the Platform and subsequent use by the User of the WeSchool Services and any refusal prevents the User from using the Services based on the provisions of the General Conditions. This Treatment is based on the signing of the General Conditions by the Teachers, the Adult Learners and the Parent, in the name and on their own behalf and the Minor Learner (in the case of Non-Scholastic Groups through the previous Treatment referred to in letter b), and on the related pre-contractual measures proposed by WeSchool.
4. Provide the Services to Users, including the management of the administrative and accounting relationship deriving from the signing of the General Conditions and the sending of communications strictly connected to the performance of the Technical Services (eg notification of upload of a document or video on the Platform or advice on the use of the Platform and on the availability of content on the Platform of a technical nature) and / or of an administrative nature (eg updates to this Information): the processing of personal data for the purposes referred to in letter d) is necessary for the access to the Platform and the use by the User of the WeSchool Services and any refusal prevents the User from using the Services according to the provisions of the General Conditions. This Treatment is based on the signing of the General Conditions by the Teachers, the Adult Learners and the Parent, in the name and on their own behalf and the Minor Learner, and on the related pre-contractual measures proposed by WeSchool.
5. Verify and ascertain any illegal or fraudulent conduct on the Platform by Users, such as, for example, uploading and accessing illegal or fraudulent content (such as, for example, content of a violent, pornographic, obscene or discriminatory nature), or harmful rights (including image or intellectual property rights) and the interests of third parties (including other Users), or in any case not suitable for supporting the training and education of Learners: the processing of personal data for the purposes referred to in letter e) is necessary to protect the correct use of the Platform, in the interest of all Users, should a negligent or willful act or deed occur by a User. This Treatment is based on the signing of the General Conditions by the Teachers, the Adult Learners and the Parent, in the name and on their own behalf and the Minor Learner, and on the related pre-contractual measures proposed by WeSchool and, if necessary or appropriate, the involvement of third-party authorities, on the possible legal obligation of WeSchool to collaborate with the competent authorities in carrying out checks or investigations on the illegal or fraudulent acts and facts carried out on the Platform.
6. Carry out direct marketing activities by WeSchool relating to the Services, services, products and initiatives similar to the Services and the Platform, through statistical analysis and market research, sending information and advertising material, reporting and invitations to promotional initiatives: the Processing of Personal Data for the purposes referred to in letter f) is optional and any refusal by the User prevents the latter from taking advantage of WeSchool's direct marketing activities relating to the Services and similar services, products and initiatives to the Services and the Platform. This Processing is based on WeSchool's legitimate interest consisting of the benefit that WeSchool can obtain from sending commercial communications relating to the Services (including advice on the use of the Platform and the availability of content on the Platform of a commercial nature) or services, products and initiatives similar to the Services and the Platform, involving Users in the growth and development path of WeSchool, which the latter considers to prevail over the Users' right to privacy. Opposition to this Treatment can be exercised by the Teacher, the Adult Learner or the Parent (in his / her own name as well as in the name and on behalf of the Under-18 Learner) at any time, and without any reason, following the instructions in point 10 lett. f) of this Information.
7. Subject to optional consent, carry out the Profiling, referred to in point 9 below: the Processing of Personal Data for the purpose referred to in letter g) is optional and any refusal by the User prevents the latter from taking advantage of activities Profiling on the information and preferences expressed by the same on the Platform to customize the Services (by, for example, receiving personalized advice on the use of the Platform and on the availability of content on the Platform that are useful or of potential interest to Users) and the activities of marketing both by WeSchool (referred to in the previous letter f) and by third parties (referred to in the following letter h). This Treatment is based on the free, specific, informed and unambiguous consent of the Teacher, of the Adult Learner and / or of the Parent (in his / her own as well as in the name and on behalf of the Minor Learner), expressed through a declaration or positive action (eg flag) on ​​the Platform. The withdrawal of consent can be exercised by the Teacher, the Adult Learner or the Parent at any time, following the indications referred to in point 10 lett. a) of this Information.
8. Subject to optional consent, carry out marketing activities on behalf of third parties relating to digital products and services useful to Learners, such as, by way of example, courses, electronic devices for school and connectivity services, through statistical analysis and market research, '' sending information and advertising material (including through forms of pop-up advertising on the Platform) and the notification and invitation to promotional initiatives of such third parties: the processing of personal data for the purposes referred to in letter h) is optional and any refusal by the User prevents the latter from taking advantage of marketing activities relating to third parties operating in sectors of interest to the Learners. This Treatment is based on the free, specific, informed and unambiguous consent of the Teacher, of the Adult Learner and / or of the Parent (in his / her own as well as in the name and on behalf of the Minor Learner), expressed through a declaration or positive action (eg flag) on ​​the Platform. . The withdrawal of consent can be exercised by the Teacher, the Adult Learner or the Parent at any time, following the indications referred to in point 10 lett. a) of this Information.
9. Perform statistical analysis, market research, improve the presentation of the Services and the use of the Platform by Users. Where possible, to achieve this purpose WeSchool uses anonymous data (data that does not identify or make Users identifiable and therefore do not constitute Personal Data): the processing of personal data referred to in letter i) is optional and any refusal by the User prevents the latter from using Services more similar to their preferences, without any prejudice to the reception of the Services. This Processing is based on WeSchool's legitimate interest consisting of the benefit that WeSchool can obtain from the offer of Services more similar to the preferences expressed by its Users while browsing the Platform and using the Services that we believe to prevail over the right to confidentiality of the Users. The opposition to this Treatment (if not performed with anonymous data) can be exercised by the Teacher, the Adult Learner or the Parent (in his / her own as well as in the name and on behalf of the Minor Learner) at any time following the indications referred to in point 10 lett. f) of this Information.

5.       Methods of collecting Personal Data

1. Personal Data entered on the Platform by Users;
2. Personal Data communicated by authorized third parties or in any case connected to Users;
3. Personal Data expressly communicated to WeSchool by Users;
4. Personal Data collected automatically by the Platform (through Cookies).

WeSchool collects Personal Data in the following ways:

1. Personal Data entered into the Platform by Users: these are the Personal Data provided, by way of example and not limited to, to navigate, register and access the Services offered by WeSchool;
2. Personal Data communicated to WeSchool by third parties authorized by, or in any case connected to, Users: these are the Personal Data of Users that are communicated to WeSchool by other Users, such as for example by Teachers for the creation and management of their own groups of Learners , or by the Schools or by the reference Companies of the Users, before the signing of the General Conditions by each User, or by the suppliers of the electronic registers of the Schools, during the period of validity of the General Conditions;
3. Personal Data expressly communicated to WeSchool by Users in offline mode: Personal Data provided, by way of example, to WeSchool customer service (in the event of a contact request) or collected on the occasion of events and / or initiatives organized by WeSchool;
4. Personal Data collected automatically by the Platform: these are Personal Data collected automatically by the Platform, such as user agents or IP addresses of Users, also through Cookies (for more information, WeSchool recommends reading the Cookies Policy below) .

6.       Any categories of recipients of the Personal Data

Employees, collaborators, other Users, School or User reference company, third party IT service providers, competent authorities, technical and commercial third parties.

Personal Data are processed by WeSchool and / or by third parties, selected for reliability and competence, and to which they can be communicated as necessary or appropriate, provided that within Italy or the European Economic Area (of which part of the European Union). In particular, WeSchool informs Users that Personal Data may be processed by, and / or communicated to:

1. WeSchool employees and / or collaborators;
2. other Users who participate in the same private group as the User to whom the Personal Data refer;
3. Schools or Companies of reference of the Users;
4. third party service providers necessary to guarantee the functioning of the Platform (by way of example: company that deals with hosting services);
5. third party providers of services necessary for the use of the Services (e.g. services connected to the Services);
6. third parties that provide navigation data analysis services of the Platform;
7. competent authorities to carry out checks or investigations on illegal or fraudulent acts or facts committed on the Platform;
8. subject to the optional consent of the User (in the case of a Minor Learner, by the Parent), third parties who provide automatic services for sending newsletters and / or any other type of commercial communication, marketing services, promotion, analysis of habits and choices consumer, Profiling;
9. subject to the optional consent of the User (in the case of a Minor Learner, by the Parent), third parties who send commercial and promotional communications relating to their products and services, including by profiling, and / or who carry out statistical analyzes or market research on Users.

7.       Transfer of Personal Data outside the EEA (including the EU)

Yes.

The Personal Data collected by WeSchool for the purposes referred to in point 4 of this Notice, are transmitted by WeSchool, pursuant to arts. 44 and ss. of the GDPR, by virtue of adequate guarantees to ensure the protection of Personal Data, to:

1. Google Inc., with registered office at 1600 Amphitheater Parkway Mountain View, CA 94043, United States, by virtue of the company's adherence to the agreement between the United States and the European Union called "Privacy Shield";
2. Apple Inc., with registered office at 1 Apple Park Way Cupertino, California, United States, by virtue of the company's adherence to the agreement between the United States and the European Union called "Privacy Shield";
3. Pusher Ltd., with registered office at 160 Old Street, London, EC1V 9BW, United Kingdom, by virtue of the United Kingdom's withdrawal agreement from the European Union;
4. OneSignal, Inc., having its registered office at 2850 S Delaware St Suite 201 San Mateo, CA 94403 USA, by virtue of [●];
5. Three Hearts Digital Ltd. (Email Octopus), with registered office in Keltan House, 115 Mare Street, London, E8 4RU, United Kingdom, by virtue of the United Kingdom's withdrawal agreement from the European Union;

More information regarding such adequate guarantees can be obtained from WeSchool.

8.       Retention period of Personal Data (or criteria for determination)

1. Cookies: see information relating to Cookies;
2. Personal Data for verifying the age of majority for Non-School Groups: 3 weeks from the registration request;
3. Personal Data for the use of the Services: duration of the General Conditions and for a period of 26 months after the termination of the General Conditions;
4. Personal Data for commercial purposes: for a period of 12 months from the last User interaction;
5. Personal Data for Profiling and Improving the Services: for a period of 12 months from collection;
6. Personal Data for legal obligations or judicial protection: 10 years from collection.

Personal Data are kept by WeSchool for the period of time strictly necessary to achieve the purposes for which they were collected, as indicated in point 4 above. In particular, subject to the exercise of the right to revoke the consent referred to in the following point 10 lett. a) or the right to object as per point 10 below lett. f), WeSchool retains Personal Data for the following terms:

1. Cookies: for the purposes referred to in point 4 letter a), the letter of the Cookies Information referred to in point 12 below is recommended;
2. Personal Data for verifying the age of majority in case of access to Non-School Groups: for the purposes referred to in point 4 letter b), in case of refusal to authorize the Parent within 3 (three) weeks from the request for registration of the Learner Minor, the Personal Data of the Minor Learner is deleted by WeSchool. In case of authorization by the Parent within this period, the provisions of letter c) below apply;
3. Personal Data for the use of the Services: for the purposes referred to in point 4 letters c), d) and e), for the duration of the General Conditions and for the following 26 months, without prejudice to the provisions of the following letter f);
4. Personal Data for WeSchool or third party commercial communications: for the purposes referred to in point 4 letters f) and h), for a period of 12 months (in case of Profiling associated with marketing activities) or 24 months (in lack of Profiling associated with marketing activities), subsequent to the last interaction with WeSchool by the User (as regards the Underage Learner by the Parent), suitable for demonstrating an interest in receiving communications relating to WeSchool and / or third parties (as described in point 4 letter h), such as for example the collection of consent, the opening of newsletters or participation in initiatives promoted by WeSchool or by third parties;
5. Personal Data for Profiling and for the improvement of Services: for the purposes referred to in letters g) and i) (the latter only in the case of use of Personal Data and not anonymous data) for a period of 12 months following collection of Personal Data from WeSchool;
6. in any case, WeSchool is authorized to keep, in whole or in part, the Personal Data for the maximum period of 10 years from the collection or for the longer term of any legal proceeding, limited to the information necessary to fulfill legal obligations and allow WeSchool itself to ascertain, exercise and defend its right in court or before any other competent authority. In particular, should a User upload content (such as texts, images and videos) to the WeSchool platform, WeSchool may keep the User's Personal Data (including the Parent, in the case of a Minor Learner) for the term provided for in this letter. e), in order to protect oneself in the event of potential checks or investigations by the competent authorities or claims by third parties deriving from the uploading of illegal content or in any case harmful to the General Conditions.

Once these terms have elapsed, WeSchool will automatically delete the Personal Data collected, or transform them into an irreversible anonymous form.

9.       Profiling

Automated processing of Users' Personal Data, aimed at revealing the interests and preferences of Users expressed on the Platform, for evaluation and / or predictive purposes.

The Profiling operated by WeSchool has the following characteristics:

1. context: Profiling can be associated both with the provision of the Services on the Platform by WeSchool and with the performance of marketing activities relating to WeSchool and / or third parties, as better described in point 4. Therefore, if the User access the Platform exclusively to use the Services and have opposed the marketing activities of WeSchool (point 4 letter f) or have not joined the marketing activities of third parties (point 4 letter h), Profiling will only be carried out in connection to the provision of the Services;
2. subject: information on Users relating, for example, to age, to the school cycle to which they belong, to the location of the reference School (where available), to the type of content used within the Services (eg educational courses), suitable for disclosing tastes, preferences, lifestyle or consumption habits;
3. legal basis: consent expressed by means of a positive action (flag) on ​​the Platform by Teachers, Adult Learners and Parents, in the name and on their own behalf and / or under 18 Learners;
4. logic of processing: (i) analysis and evaluation of the information collected on minors referred to in letter b) on a statistical basis through the processing and comparison of the personal data of all users of the platform; and (ii) classification of Users within homogeneous categories of Users, to analyze or make predictions about their possible interests;
5. purpose: to make both the Services and the marketing activities more "personalized" on the possible interests and preferences of the Users and, therefore, to improve the degree of "satisfaction" of the Users both in the use of the Services provided on the Platform and in the receipt of commercial communications and WeSchool and / or third party promotions. Profiling is therefore aimed at defining the profile or personality of Users, or at analyzing consumption habits or choices, or at making predictions on future choices, or at monitoring the use of electronic communication services;
6. effects for Users: use of Services on the Platform or receipt of commercial communications, in line with the interests and preferences expressed by Users in browsing the Platform and using the Services. In no way, WeSchool Profiling: i) constitutes an automated decision-making process from which legal or similarly significant effects derive for Users; ii) affects the behavior and training or purchasing choices of Users; iii) has a prolonged and permanent impact for Users, considering that the Personal Data collected by WeSchool can be independently updated at any time by the Users; as well as iv) does not discriminate against Users.

10.     Rights of the User

Withdrawal of consent, access to Personal Data, rectification or integration of Personal Data, cancellation of Personal Data, limitation of Processing, opposition to Processing, portability of Personal Data, data breach, complaint to the competent authorities

Pursuant to and for the purposes of the GDPR, for the period referred to in point 8 of this Notice, each User, in particular the Parent in their own right as well as in the name and on behalf of the Underage Learner, has the right to:

1. with reference to the treatments referred to in point 4 letters g) and h), revoke the consent at any time without prejudice to the lawfulness of the previously performed treatment, by sending an e-mail to WeSchool or by exercising the opt-out in commercial communications of WeSchool (see art.7 of the GDPR);
2. ask WeSchool for access to Personal Data and information relating to the related Processing and any copy in electronic format, unless otherwise specifically requested by the User (see Article 15 of the GDPR);
3. request the correction and / or integration of Personal Data, without undue delay (see Article 16 of the GDPR);
4. for specific reasons (for example, unlawful processing, withdrawal of consent, non-existence of the purpose of the processing), request the deletion of Personal Data, without undue delay (see Article 17 of the GDPR);
5. when specific hypotheses occur (for example, inaccuracy of Personal Data, illegality of processing, exercise of a right in court), request the limitation of processing (Article 18 of the GDPR);
6. with reference to the processing referred to in point 4 letters f) and i) (in the latter case, if anonymous data were not used), oppose the processing of personal data at any time, by sending an e-mail to WeSchool (see art.21 of the GDPR);
7. in case of automated processing, receive the Personal Data in a readable format, for the purpose of communicating it to a third party, or, where technically feasible, request the transmission of Personal Data by WeSchool directly to this third party (so-called right to portability of Personal Data - see art.20 of the GDPR);
8. be informed by WeSchool without undue delay of any violations or unauthorized access by third parties to their systems containing Personal Data (so-called data breach - see Article 34 of the GDPR);
9. propose a complaint to the supervisory authority of the EU country in which he resides, works or in which he believes the violation of his rights has occurred (see Article 77 of the GDPR);

For more information on the terms and conditions for exercising the rights recognized to the User, the latter can consult the text of the EU GDPR published at the following link http://eur-lex.europa.eu/legal-content / IT / TXT / PDF /? Uri = CELEX: 32016R0679 & from = IT, or contact WeSchool in the manner provided for in point 2 of this Notice.

11.     Objection to WeSchool's Direct Marketing Processing

Right to object to receiving commercial and promotional communications relating to WeSchool.

WeSchool points out that each User, in particular the Parent on their own as well as in the name and on behalf of the Underage Learner, has the right to object to the Processing of Personal Data referred to in point 4 letter f), at any time and without any reason, by sending a e-mail to support@weschool.com or by exercising the opt out present in the commercial and promotional communications received by WeSchool. In case of exercise of this right, WeSchool will stop the use of the User's Personal Data for the purposes of direct marketing of the Services or services, products or initiatives similar to the Services and the Platform and will not carry out any Profiling associated with its activity of direct marketing.

12.     Type of Cookies

1. Technical cookies, necessary and functional for navigation on the Platform
2. Third party analytical cookies
3. Profiling cookies

Cookies necessary for navigation:

1. Purpose: Cookies are essential to ensure the proper operation of the Platform, as they allow the User to navigate within it and use its basic functions. In no case do these cookies collect information that can be used for commercial purposes. These necessary cookies are used, among other things, to: (i) store the data provided by the User during a browsing session in the browser; (ii) keep the User's preferences and credentials active while browsing the Platform; (iii) view the contents in the chosen language at each access, recognizing from which country the User is connecting (and remembering this setting in future accesses). For the correct functioning of the Platform, the acceptance of the Cookies necessary for navigation is required, as their non-acceptance could prevent, or strongly compromise, the possibilities of navigation on the Platform.
2. Collected data: data relating to navigation.
3. Duration: session cookie.

Functional navigation cookies:

1. Purpose: these are cookies that allow you to make the use of the Platform more usable. These cookies are able to store User data for logging in to the Platform, avoiding that the same data must be re-entered at each browsing session. These cookies are designed to facilitate and speed up the use of the Platform, but are not, however, essential to be able to browse it.
2. Collected data: data relating to navigation and preferences expressed during navigation.
3. Duration: Session and permanent cookies.

Google Analytics cookies 

1. Purpose: These are cookies provided by Google Inc. to monitor, in an anonymous and aggregate form, the statistical analysis of User traffic on the Platform to adapt the Platform to the results emerging from this analysis, in accordance with the interests shown by the Users themselves.
2. Collected data: data relating to the computer and the User's visit to the Platform and which, in no case, allow WeSchool to independently trace the Users' Personal Data: (i) the domain from which the Internet is accessed; (ii) the web address from which the User connected to the Platform, if available; (iii) the date and time of the connection with the Platform, how long it lasted and which pages were visited; (iv) the Internet protocol address (IP) of the User; (v) the computer operating system and the browser used by the User; (vi) the aggregate demographic detail of the Users who access the Platform.
3. Duration: Session cookies.

For more information on Google analytics, the User can consult the following web page: https://tools.google.com/dlpage/gaoptout.

WeSchool profiling cookies:

1. Purpose: WeSchool uses profiling cookies with the aim of improving the commercial experience of Users, by offering content modeled on personal tastes and habits, as well as sending advertising communications relating only to products that are most relevant to the interests of the User.
2. Data collected: data relating to the computer and the User's visit to the Platform, for the creation of a "navigation profile" of the User, based on the searches carried out by the latter and on the most consulted sections of the Platform.
3. Duration: session and permanent cookies.

Third party advertising cookies:

1. Purpose: Third-party advertising cookies are cookies provided by other websites to which WeSchool, through links or banners present within the Platform, refers, as they are third-party sites that have been found to be similar to the User's interests, to the for the purpose of sending information and commercial offers based on interests associated with the User's online activities. These Cookies do not personally identify Users.
2. Collected data: data and information on the User's guidelines and / or online preferences such as, for example, the searches carried out, the frequency of page loading or activity on other third party sites.
3. Duration: Session and permanent cookies.

For more information on third-party advertising cookies, the User can consult the following web page: https://www.manzoniadvertising.com/it/pages/Cookie_Concessionaria

13.     Acceptance and waiver of cookies

Consent, banners, access to browser control panels, Your Online Choices service

The User may give his consent to the use of the Cookies described in section 12 above using the methods indicated on the banner published on the Platform

The manifestation of consent can be modified at any time by the User according to the indications contained in this Information, which is accessible via the link in the banner and on each page of the Platform (footer). To this end, the User can also contact WeSchool at any time to obtain information about the concrete ways in which he can exercise his consent / selective refusal or delete cookies.

However, WeSchool specifies that disabling the technical cookies indicated in the previous section 12 could prevent correct navigation on the Platform and / or limit its usability. Consequently, in order to better use the WeSchool Services accessible through the Platform, the User is strongly discouraged from proceeding with the deactivation of these technical cookies.

Having said this, with reference to all the Cookies of the Platform, the User can change the settings relating to them, in the manner provided for in the control panels of the browser used, such as by way of example:

• Google-Chrome: https://support.google.com/chrome/answer/95647?hl=it-IT&hlrm=fr&hlrm=en
• Mozilla-Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
• Internet Explorer: https://support.microsoft.com/it-it/help/278835/how-to-delete-cookie-files-in-internet-explorer
• Microsoft Edge: https://support.microsoft.com/it-it/help/4027947/microsoft-edge-delete-cookies
• Safari: https://support.apple.com/it-it/guide/safari/sfri11471/mac

Furthermore, with specific reference to profiling and advertising cookies, in addition to being able to use the tools provided by the browser to activate or deactivate individual cookies, WeSchool informs the User that the website www.youronlinechoices.com shows the list of the main providers that they work with website managers to collect and use information useful for the use of behavioral advertising. The User can deactivate or activate all companies (including WeSchool) or, alternatively, adjust their preferences individually for each company. To do so, the User can use the tool on the page www.youronlinechoices.com/it/le-tue-scelte to check any preference on behavioral advertising provided when browsing the Internet.