Privacy Policy

AULA LMS PRIVACY POLICY

This Privacy Policy tells you how we, ASAP4D S.A.S., a duly registered (NIT 900.334.017) Colombian Corporation through providing you with access to our Aula LMS Teaching & Learning Platform (hereby referred to as the Aula LMS Services or we, us and our) will collect and use the Users (hereby referred to as you or your) personal data to provide our service which allows educators, of any kind, to create a private space online, filled with tools that will allow the users to easily create courses and activities, all optimized for collaborative learning. The Aula LMS Services are managed by us and hosted by Amazon Web Services (AWS) and this notice will tell you how we and/or AWS uses your data.

What is covered by this Privacy Policy?

Under the current gold standard regulation, 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”.

All data subjects whose personal data is collected, in line with the requirements of the GDPR.

Why do we need to collect and store personal data?

In order for us to provide you with Aula LMS Services, Aula LMS Apps Plans and/or other Aula LMS hosted Platforms we need to collect personal data for correspondence purposes and/or to allow us to provide you our service(s). We are committed to ensuring that the information we collect and use is appropriate for this purpose. ASAP4D S.A.S. is a company which values its users’ data protection and privacy rights and we have no interest in collecting data beyond what we need to make our service(s) work for you.

If you are going to be contacted by us for marketing purposes, we will not rely solely on this notice, but will always seek an additional confirmation from you that you are in agreement with this (opt-in).

In general, we collect personal data relating to you for specific purposes, with the nature of the data collected depending on your interaction with us.

Our legal basis for the processing of personal data are:

• Article 6.1(a), GDPR, Consent

• Article 6.1(b), GDPR, Contract

• Article 6.1(f), GDPR, Legitimate Interest

Any legitimate interests pursued by us, or third parties we use, are as follows:

• recruitment and Induction of new Candidates

• emergency Contacts for people who work with us, such as employees and contractors for health and safety purposes.

• business Development

• providing login systems to users via their existing social media accounts

Will ASAP4D S.A.S. share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to ASAP4D S.A.S. in the course of dealing with you. We do this because there are some services, such as our video conferencing facility, which will not work unless we are able to make these transfers. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to deliver the service they provide on our and of course, your behalf.

How will ASAP4D S.A.S. use the personal data it collects about me?

ASAP4D S.A.S will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary ASAP4D S.A.S maintains a register of its data processes which includes a record of the data retention policy for each type of data collected and is committed to only ever trying to process the minimum amount of data needed.

What about third party Integrations?

The Aula Abierta Website (www.aulabierta.co) and the Open Aula Website (www.openaula.co) uses Google Analytics and the Aula LMS teaching & Learning Platform (www.aulalms.co), hereby referred to as the Platform, uses an integration with Google that allows the user authorized on the Platform to access his/her own Google Drive and Doc, for the purposes of downloading these files during the process of designing and developing the users own educational materials.

How the Platform is using and/or allowing the user access to Google data is described below. The Platforms use of Google user data is limited to the practices explicitly disclosed in this privacy policy. If Aula LMS should change in any way how the application uses Google user data, we will notify you and request your consent to any updated privacy policy before we make use of Google user data in a new way or for a different purpose than what is disclosed here.

Google Integration: Aula LMS Teaching & Learning Platform

First it is important to note that the Aula LMS Teaching & Learning Platform (www.aulalms.co), is an educational platform service which includes sharing files and information, note taking, workgroup communications and classroom collaborations, that only use or access Google Drive files via the application’s user interface, the “File Picker”. This means that the Google Drive and/or Docs are only accessed by authorized, logged-in Platform users within this domain. All access to the users’ data is private and restricted to the user and other users within the Platform, authorized by the user him/herself and is not accessible to the public.

The Platform’s logged-in authorized user will be able to use the Platforms “File Picker” to access and download files to the platform. These files may be files from his/her computer or may be Google Doc or archives from the users own Google Drive and, if so, will be access from the Google Drive only as far as permitted by the user him/herself by logging into his/her own Google Drive using his/her own Google Drive OAuth account authentication. In no way will any data relating to the user Google log-in access and/or permissions on his/her Google Drive be either collected or stored by Aula LMS.

Aula LMS will not use or share the files the user downloads from his/her Google drive with anyone. The users’ files are stored on the Aula LMS servers, only as far as they are part of the users own developed courseware, and, as such, will be included in the Aula LMS regular backups, performed to ensure against any possible loss of user courses or content as a result of any infrastructure failures.

In addition, Aula LMS will not access, aggregate, or analyze any user data such as for the purpose of being displayed, sold, or otherwise distributed to a third party conducting surveillance. Aula LMS will at all times take all reasonable and appropriate steps to protect all applications or systems that make use of Google API Services against unauthorized or unlawful access, use, destruction, loss, alteration, or disclosure.

Aula LMS is committed to not transfer any data whatsoever to anyone, except as necessary to comply with applicable law or as part of a merger, acquisition, or sale of assets with notice to users. All other transfers or sales of the user data are expressly prohibited in this Privacy Policy.

Google Analytics: Aula Abierta and Open Aula Web Sites

The Aula Abierta Website (www.aulabierta.co) and Open Aula (www.openaula.co) Website uses Google Analytics, a web analysis service of Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, www.google.com (“Google Analytics” or “Google”). Google Analytics employs cookies that are stored to your computer in order to facilitate an analysis of your use of the site. The information generated by these cookies, such as time, place and frequency of your visits to our site, including your IP address, is transmitted to Google’s location in the US and stored there.

In using Google Analytics our website employs the extension “anonymizeIp”. In doing so, Google abbreviates and thereby anonymizes your IP address before transferring it from you. Google uses this information to analyze your use of our site, to compile reports for us on internet activity and to provide other services relating to our website. Google may also transfer this information to third parties where required to do so by law or where such third parties process this data on Google’s behalf. Google states that it will in never associate your IP address with other data held by Google. You can prevent cookies from being installed by adjusting the settings on your browser software. You should be aware, however, that by doing so you may not be able to make full use of all the functions of our website.

Google Analytics also offers a deactivation add-on for most current browsers that provides you with more control over what data Google can collect on websites you access. The add-on tells the JavaScript (ga.js) used by Google Analytics not to transmit any information about website visits to Google Analytics. However, the browser deactivation add-on offered by Google Analytics does not prevent information from being transmitted to us or to other web analysis services we may engage.

Google Analytics also uses electronic images known as web beacons (sometimes called single pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our site is used.

You can find additional information on how to install the browser add-on referenced above at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

For the cases in which personal data is transferred to the US, Google has self-certified pursuant to the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework).

Can I find out what personal data ASAP4D S.A.S. holds about me?

ASAP4D S.A.S at your request, can confirm what information we hold about you and how it is processed. If ASAP4D S.A.S does hold personal data about you, you can request the following information:

• the categories of personal data collected, stored and processed.

• recipient(s) or categories of recipients that the data is/will be disclosed to.

• how long the data will be stored.

• details of your rights to correct, erase, restrict or object to such processing.

• information about your right to withdraw consent at any time.

• how to lodge a complaint with the relevant supervisory authority.

• the source of personal data if it wasn’t collected directly from you.

What form of ID will I need to provide in order to access my data?

ASAP4D S.A.S accepts a request made through an Aula LMS account while the person making the request is logged in. In certain circumstances ASAP4D S.A.S could ask for additional information and the following forms of ID when information on your personal data is requested:

• A color copy of a Passport, driving license or National ID Card

Agreeing to these terms is your consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Where consent is required for ASAP4D S.A.S to process both standard and sensitive types of personal data, it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

Agreement with this Privacy Notice and its accompanying terms and conditions (as applicable) (and any Data Processing Agreements, if they apply to you) will be considered to be explicit consent and we will keep a copy of the records of that consent for audit purposes.

Retention period

ASAP4D S.A.S will process different forms of personal data for as long as is necessary and proportionate for the purpose for which it has been supplied and will store the personal data for the shortest amount of time possible, taking into account legal and service requirements.

Your rights as a data subject

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

• right of access – you have the right to request a copy of the information that we hold about you.

• right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

• right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.

• right to restriction of processing – where certain conditions apply to have a right to restrict the processing.

• right of portability – you have the right to have the data we hold about you transferred to another organization.

• right to object – you have the right to object to certain types of processing such as direct marketing.

• right to judicial review: in the event that ASAP4D S.A.S refuses your request under rights of access; we will provide you with a reason as to why. You have the right to complain as outlined in the section named “Complaints” below.

Where ASAP4D S.A.S are your Data Controller, you may make a request using the email address admin@asap4d.co

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by ASAP4D S.A.S (or third parties as described above), or how your complaint has been handled, you should contact us at admin@asap4d.co.

If you wish to make a complaint about how your personal data has been processed by Aula LMS, you should contact us at admin@aulalms.co.