Privacy Policy

This notice is addressed to those who use the Services (provided through the bsmart.it Website or through applications) owned by bSmart Labs srl.

The notice explains how at bSmart Labs srl we use the Data of Users who are registered to our Services. It also allows Users to understand the purposes and methods of processing their personal Data by us in the event they provide it.

This notice may be modified. The latest update was on: 23/04/2020.

Data Controller and Data Protection Officer

bSmart Labs srl, Via Montorfano, 98 - 20831 Seregno (MB), tel. 0362 640018. For information about this Privacy Notice, write to us at privacy@bsmart.it.

We have appointed a Data Protection Officer (DPO) to verify the compliance of our personal data processing with Italian and European regulations. The Data Protection Officer is LiquidLaw Srl - UniSalento 2018-2022 spin-off company and can be contacted at: privacy@liquidlaw.it. They are also the point of contact for requesting and receiving information about the processing of your personal data and the contact for the Supervisory Authority.

What Data do we store?

We collect certain personal Data of Users, such as User ID and password, name, surname, and email address, information aggregated during browsing, and other personal Data voluntarily provided by the User during registration or when requesting the Services offered (e.g., photos, written works as part of educational activities, etc.). We may also collect your personal data when you contact us for assistance or use the social network plug-ins available on the Website.

Some Services may be accessible to Users without the need to provide their personal Data; however, most functionalities are only accessible to registered Users.

Personal Data provided by Users

We store in our databases the name and surname, email address, username, password, personal information, and other information that the User provides to us through the use of our Services.

Personal Data of Minors

The Services we provide are intended for Users of all ages. A Minor can register for one or more bSmart Labs srl Services as long as such registration is carried out by one of the Parents - or another individual exercising parental authority. The Parent - or another individual exercising parental authority - authorizes bSmart Labs srl to process the Minor's personal Data through explicit consent requested at registration, where expressly required (when the legal basis is different from the performance of contractual obligations for the Services provided), accepting the terms set out in this Notice (cf. par. "How do we use the Data we collect?"), on the Terms and Conditions page, and in compliance with Article 8 of the General Data Protection Regulation (EU/2016/679).

The Parent - or another individual exercising parental authority - has the right to view, request rectification, integration, or deletion of the Minor's personal Data for whom they registered for one or more bSmart Labs srl Services through communication with the Data Controller. Furthermore, if they become aware of the registration of a Minor for one or more bSmart Labs srl Services, over whom they exercise parental authority, without their express authorization (where required), they may notify the Data Controller, who will work to delete the Minor's account within a reasonable time.

Browsing Data

The IT systems and software procedures that make our Services work acquire, during their normal operation, certain Data that is transmitted implicitly when using Internet communication protocols.

Examples of this data category include IP addresses, domain names of computers used by Users who connect to the Sites and applications of bSmart Labs srl, the time zone of the request to the server, the method used in submitting the request to the server, and other parameters relating to the User's operating system and IT environment.

The aforementioned information is generally not collected to be associated with identified data subjects and may be used by bSmart Labs srl to derive anonymous statistical information about the use of our Services and to ensure their proper functioning.

The Data may also be used to ascertain responsibility in the event of hypothetical cybercrimes against our Sites, applications, or software.

How do we use the Data we collect?

We process Users' personal Data exclusively in the ways described in this notice and in compliance with the provisions of the General Data Protection Regulation (EU/2016/679).

To use some Services offered by bSmart Labs srl, the User may need to give consent for the use of their personal Data. In particular, the legislation provides that there must be a specific reason that allows the processing of the users' personal data on the platform, which consists of:

  • in some cases, the need to respond to your requests for registration or access to the Services provided by bSmart Labs srl or to respond to information requests about our products and services (these are contractual or pre-contractual purposes and consent is not required);
  • complying with certain legal and/or regulatory requirements (compliance with obligations provided by Law, a Regulation, or Community Legislation, and, in this case as well, consent is not required);
  • pursuing a legitimate interest of bSmart Labs srl or third parties (e.g., service users);
  • in limited circumstances, consent provided by the User (e.g., for marketing or co-marketing purposes or profiling by bSmart Labs srl);
  • with specific and different consent, for the transfer or sale of personal data to third parties (including commercial partners) in the following economic and merchandise sectors: Publishing, School, Education, Culture, Commerce, to carry out promotional activities, present offers, commercial communications, and subsequently send informational, advertising, and/or promotional material and/or opinion polls, market research, newsletters, and direct sales.

Therefore, we use your Data for the following purposes:

  • To operate, maintain, and improve our Sites, Products, and Services;
  • To respond to your requests for platform registration, in order to enable access to the reserved area and other services provided;
  • To send information, including confirmations, invoices, technical notes, updates, security alerts, and administrative messages;
  • To provide support or help desk services, as well as technical assistance by managing tickets opened by the User (filling in the online request form);
  • To interact, in some bSmart Labs srl Services, with other Users registered with bSmart Labs srl included in restricted and controlled access groups (for example, virtual classrooms of bSmart Classroom or screens that put the Student and Tutor in touch, between the Parent and Tutor in bSmart Tutors, or the screens that allow Parents to access their children's personal Data);
  • To create and promote contests and prizes promoted by bSmart Labs srl;
  • To respond to comments and questions by providing Customer Service and managing data voluntarily communicated for specific information and/or assistance services;
  • To communicate promotions, events, and other news about Products and Services offered free of charge exclusively by bSmart Labs srl;
  • To link or combine User information with other personal information;
  • To protect, investigate, and discourage fraudulent, unauthorized, or illegal activities;
  • To verify the necessary and automatic collection of data relating to interaction with the website, also by analyzing aggregated data on visitors' and users' behavior on the site;
  • To provide Products and Services requested by customers;
  • To send any invitations to trial bSmart Labs srl Services based on explicit actions performed by Users already registered with the Service (e.g., sharing content with someone through email input).

In some cases, we use Data (email or other) explicitly provided by Users registered with one or more bSmart Labs srl Services to send invitations or other communications to third parties not registered with bSmart Labs srl Services.

To enable the full functionality of some services provided by third parties (e.g., Google Drive, Dropbox), we ask the user to enter their access data for these services to access the content they own hosted by the respective platforms. bSmart Labs srl never directly accesses the user's content, does not save any files on its servers, and only makes viewing available to direct owners.

We retain this information solely for the purpose of sending communications regarding bSmart Labs srl Services. The recipient of such messages can contact us at privacy@bsmart.it to request the removal of their email address from our database.

The User also has the option to decide whether to grant the use of their Data for the following two purposes:

  • To receive communications, promotions, and other news about paid Products and Services offered by bSmart Labs srl, as well as communications, promotions, and other news about Products and Services offered by our selected partners (e.g., periodic newsletters or other messages about initiatives related to education, school, and the world of Education);
  • To transfer or communicate the user's personal data to third parties (in the previously indicated economic and merchandise sectors) so they can carry out promotional initiatives.

For each of the two consents mentioned above, the User has the option to authorize or withdraw consent on their profile page. Alternatively, the User can inform us of a change of consent by sending an email to privacy@bsmart.it. We will correct the User's choice within the terms of the law.

Soft spamming

bSmart Labs srl may use the email addresses provided by the user during registration or purchase on the Site for direct sale purposes of the products and/or services offered through the Site (or to promote updates on different topics relating to the school world), even without their consent, provided it is a product or service similar to the one covered by the previous sale (so-called soft spamming). The user can object to this processing at any time by notifying bSmart Labs srl or unsubscribing within the received communication. The legal basis for processing is the legitimate interest of bSmart Labs srl in sending such communications, within its legitimate interest (which may be considered equivalent to the user's interest in receiving "soft spam" communications).

Mandatory nature of data provision and consequences of refusal

Some data provided in the forms available on the bsmart.it Website or accessible via applications may be mandatory and are essential for providing services or to comply with obligations arising from law or regulation. Refusal to provide them will make it impossible to provide the services displayed. The provision of other data, different from those that are mandatory, is optional and does not affect the use of the website and its services.

Depending on the circumstances, you will be duly informed of the mandatory or optional nature of providing your personal data. We will highlight the mandatory or optional nature of providing your data through a notice only for the data necessary for providing services. Please note that failure to provide optional personal data will not impose any obligation or disadvantage on our users.

Sharing and security of your data

Personal data may be made available to third parties (publishers) who process personal data autonomously solely to perform the contract for the purchase of products or access to content on the bSmart Labs srl Website and only when this purpose is not incompatible with the purposes for which your data were collected and subsequently processed and, in any case, in accordance with the law. It is specified that bSmart Labs srl and the publishers assume the role of independent data controllers. Therefore, users are invited to view the specific data processing information on the publisher's website to whom the property rights of the content used by the user belong.

Therefore, we do not share Users' personal Data with third parties, except for some particular cases listed below:

  • In order to fulfill specific contractual obligations towards publishers, we may share the name, surname, and email of Users who subscribe to access specific content, with (and exclusively) the copyright holders of the content and their agents, the latter for the purpose of verifying the status of free e-book assignment on the bSmart platform. In some cases - for example, for the transfer of data to third parties for marketing purposes - specific consent will be collected;
  • Categories of individuals performing activities connected and instrumental to the activities we perform, such as individuals providing User assistance and IT managers, may become aware of some Data;
  • Some personal Data may be visible within specific Services of bSmart Labs srl by other users of bSmart Labs srl Services. For example, Teachers in bSmart Classroom, the Tutor during their activities with Students in bSmart Tutors, and the Parent in the profile management page of their children, School Principals; where provided, this sharing is the sole responsibility of each user and aims to facilitate distance education by detecting user activity (e.g., for monitoring and controlling teaching activities or performing analysis - on aggregated data - about the learning of a class or group of classes);
  • We may provide some Data to supervisory authorities, for compliance with legal obligations, regulations arising from Community legislation, or instructions issued by public authorities;
  • The User has freely given optional consent (cf. par. "How do we use your data?") to the transfer/disclosure of their personal Data to bSmart Labs srl partners or previously indicated third parties (for their promotional purposes).

bSmart Labs srl undertakes to take all necessary security measures to best protect Users' personal Data, to prevent unauthorized access, disclosure, modification, or destruction of Personal Data. Processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the indicated purposes.

In addition to bSmart Labs srl, in some cases, personal data may also be accessed by internal personnel involved in organizing this platform (administrative, sales, marketing, legal staff, system administrators), or external parties (such as third-party technical service providers, hosting providers, IT companies, providers of services for the development and maintenance of the web platform, provider of development, delivery, and operational management services of the technological platforms used, etc.), as well as third parties for whom it is necessary and indispensable (or otherwise functional) to perform the activities of bSmart Labs srl, appointed (if necessary) as Data Processors by the Data Controller. The updated list of Data Processors can always be requested from the Data Controller.

The contact details of registered users may also be accessible to other registered users, as part of the provision of services.

Social media: we may use social media plug-ins on our website. As a result, data will be shared with the social media service and possibly shared on your social media profile. Please refer to the Privacy Policy of these third-party social media providers for more information on these practices.

In any case, personal data will not be disseminated. In any case, communication or dissemination of data requested, in accordance with the law, by the Police, Judicial Authority, information and security organizations, or other public entities for purposes of defense or State security or for the prevention, detection, or suppression of crimes, is reserved.

How long do we keep your data?

Data will be retained for a period of time not exceeding that necessary for the purposes for which they were collected or subsequently processed. In some specific cases, such as traffic data collected with external Services, retention times are limited in time.

In particular, collected Data will be retained for the entire duration of the ongoing relationship and the requested services and, even after termination, for the fulfillment of any legal obligations related to them or arising from them, unless the User has given explicit consent regarding some of the services provided; in this last case, processing may last until consent is withdrawn.

Therefore, the criteria used to determine the retention period are established by:

  1. (i) specific legal provisions governing the activity of bSmart srl;
  2. (ii) tax legislation regarding the processing of administrative-accounting data;
  3. (iii) withdrawal of consent or, where permitted, objection to processing.

In any case, the personal data of registered users will no longer be used after 5 years without interactions or after the last use of our Site or its services, and this only if the user does not decide to directly close the account.

Some personal data may be retained for as long as allowed by Italian law to protect the legitimate interests of bSmart Labs srl.

Where do we store your Data?

The management and storage of personal Data will take place on servers owned by our external Data Processor and located within the European Union. Currently, the Services of bSmart Labs srl are hosted by Amazon Web Services in Ireland. It is always possible to request information from bSmart Labs srl about the appointed external Data Processor.

The Data will not be transferred outside the European Union, except for some anonymized Data that, for statistical Data processing purposes, is saved on servers located in the United States. It is understood that the Data Controller, if necessary, will have the right to move the location of servers to Italy and/or the European Union and/or non-EU countries.

In such cases, the Data Controller assures from now that the transfer will be in compliance with the applicable legal provisions by entering into, if necessary, agreements that guarantee an adequate level of protection and/or by adopting the standard contractual clauses provided by the European Commission.

How do we guarantee your rights

With regard to the processing of personal Data, the User may, at any time, exercise the rights indicated in Articles 15-22 of the General Data Protection Regulation (EU/2016/679) by writing to privacy@bsmart.it.

In certain circumstances, the User has the right:

1) to request confirmation of the existence or otherwise of the processing of personal data concerning them and, if so, to obtain access to such data and all information relating to the processing itself;

2) to obtain the rectification and correction of inaccurate personal data and to supplement incomplete ones, also by providing a supplementary statement;

3) to obtain deletion if:

  • the data is no longer necessary for the purposes for which it was collected or processed;
  • the data was processed unlawfully;
  • the data must be deleted to fulfill a legal obligation;
  • consent has been withdrawn;
  • the User objects to processing;

4) to obtain restriction of processing (and therefore to suspend it) when one of the following circumstances applies:

  • if the accuracy of the personal data is contested, for the period needed by us to verify said accuracy;
  • if the processing is unlawful and the User objects to the deletion of personal data and instead requests that its use be restricted;
  • if personal data is needed to establish or exercise a right in court by the data subject;
  • if the data subject has objected to processing, pending verification of whether our legitimate reasons override those of the User;

5) to request the transfer of their personal information in electronic and structured form to another party ("data portability");

6) to object, in whole or in part, to the processing;

7) to withdraw, at any time, the consent given (in these cases, the withdrawal of consent does not affect the lawfulness of processing based on consent before the withdrawal).

In addition, the User has the right to lodge a complaint with the Privacy Authority in the manner indicated on the Italian Privacy Authority's Website.

Where possible, bSmart Labs srl undertakes to make available to the User an autonomous means of accessing their personal Data used in our Services.

In the case of incorrect information, bSmart Labs srl undertakes to rectify errors or inaccuracies within a reasonable time or, if requested, to delete all information related to the User, unless it must be kept for legitimate legal purposes.

Cookies

For information about how we use cookies, please refer to the Cookie policy page.