Privacy Policy

NOTICE: On May 25, 2018, we adopted an amended privacy policy under the provisions of Article 13 of European Union GDPR - General Data protection Regulation (679/2016/EU).

This privacy policy refers to the Tomorrow's land elearning platform ("Tomorrow's land"), developed by Politecnico di Milano ("Polimi") in order to deliver the online courses implemented for the EU-funded Tomorrow's land project.

Introduction

This page describes how the Tomorrow's land elearning platform is managed under the provisions of Article 13 and Article 14 of European Union GDPR - General Data protection Regulation (679/2016/EU) in relation to the processing of the personal data of its users.

This privacy policy provides information to those who interact with the Tomorrow's land service, which can be accessed electronically and pertains to the domain: http://www.tland-learning.eu. This privacy policy is issued solely in relation to the Tomorrow's land elearning platform.

Purpose of the personal data processing

Personal data is processed according to all purposes related to design and delivery of Tomorrow's land, that include:

  • purposes related to monitoring, analyzing and assessing the use of the service;
  • purposes related to teaching, learning and research.

Data processing procedure

In relation to the stated purposes, the data processing is carried out with digital tools. In any case the protection is ensured by password.

Data Controller: Politecnico di Milano - Directorate General upon authorisation of the pro-tempore Rector dirgen@polimi.it
Piazza Leonardo da Vinci 32 - 20133 Milan Italy
Phone +39 0223992243
PEC: pecateneo@cert.polimi.it



  1. Information that Tomorrow's land collects from you (including personal information)

    Tomorrow's land directly collects information when you:

    • sign up for a Tomorrow's land user account and create a user profile;
    • enroll and participate in the online courses;
    • request a certificate of accomplishment;
    • participate in public forums, webinars, and other interactive experiences on the Tomorrow's land elearning platform.

    Tomorrow's land also indirectly collects usage information about your visit to the Tomorrow's land platform, as explained in the section below titled Cookies and tracking technologies.

    Tomorrow's land encourages you to use discretion before voluntarily sharing additional Personal Information on the Tomorrow's land elearning platform. (If you later choose to delete your Tomorrow's land account, deletion of your Personal Information will be subject to the process and limits outlined below).

  2. Cookies and tracking technologies on the Tomorrow's land elearning platform

    Tomorrow's land uses Cookies and other common Tracking Technologies on the Tomorrow's land elearning platform and in email communications to help Tomorrow's land better understand your use and needs of the Tomorrow's land elearning platform, and how Tomorrow's land can improve. For example:

    • based on your cookie settings, Tomorrow's land tracks information indicating, among other things, which pages of the Tomorrow's land elearning platform were visited, the order in which they were visited, when they were visited, and which hyperlinks and other user interface controls were used;
    • Tomorrow's land may log the IP address, operating system, and browser software (including mobile use and device type when you use Tomorrow's land native mobile apps) you used when accessing the Tomorrow's land elearning platform, and Tomorrow's land may be able to determine from an IP address your Internet Service Provider and the geographic location of your point of connectivity;
    • Tracking is performed via Google Analytics based upon anonimyzation of IP addresses;
    • Tomorrow's land may track and collect information from emails that Tomorrow's land sends to you, for example whether you opened the email or clicked on any links from the email.

    Tomorrow's land uses Cookies and other Tracking Technologies for the following purposes:

    • when necessary for system administration, security, and integrity to ensure the Tomorrow's land elearning platform works properly for you. Without these technologies, the Tomorrow's land elearning platform may not function correctly;
    • to enable analytics, performance and functionality, to help Tomorrow's land gather information about how visitors use the Tomorrow's land elearning platform and monitor Tomorrow's land elearning platform performance, and to enhance your experience by recognizing and remembering whether you have visited the Tomorrow's land elearning platform before and may have any personal preferences.

    You have some options for managing Cookies and other Tracking Technologies. These include modifying your browser settings: You should be able to control how and whether your web browser accepts Cookies by adjusting its privacy and security settings. The "help" feature of the menu bar on most browsers will tell you how to stop accepting new Cookies, how to receive notification of new Cookies, and how to disable existing Cookies. If you reject Tomorrow's land's Cookies, many functions and conveniences of the Tomorrow's land elearning platform may not work properly.

  3. Third party cookies

    This elearning platform uses Google Analytics, a web analytics service provided by Google Inc. of 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics uses 'cookies', which are text files placed on your computer, to help the web team analyse how Users use the elearning platform. The information generated by the cookie about your use of the elearning platform will generally be transmitted to and stored by Google on servers in the United States. In case of activation of a IP-anonymisation, Google will reduce your IP address within the member states of the European Union and other member States to the Treaty on the European Economic Area. Only in exceptional cases, the full IP-address will be transmitted to a server of Google in the United States and be reduced there. In assignment of the operator of this elearning platform Google will use this information for the purpose of evaluating your use of the elearning platform, compiling reports on elearning platform activity for elearning platform operators and providing other services relating to elearning platform activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.

    Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this elearning platform. You may also deactivate Google Analytics by installing a so called browser-input-group-addon, which is provided by Google under the following address: http://tools.google.com/dlpage/gaoptout?hl=en.
    Please note that this elearning platform extended Google Analytics for the code "gat._anonymezlp();" to ensure an anonymised recording of IP-addresses (IP masking).

    More information on Google Inc. and Google Analytics can be found here: http://www.google.com/intl/en/policies/terms/.
    This elearning platform also use YouTube, another service by Google, to provide you video lectures and YouTube can collect additional cookies. Google's privacy policy can be found here: http://www.google.com/intl/en/privacy/privacy-policy.html.

  4. How your information is used

    Your data is processed in accordance with Polimi policies; Polimi uses information, including Personal Information, to carry out the following purposes:

    • Create and administer your account.
    • Provide and teach the online courses.
    • Improve Tomorrow's land service - This includes enabling you to navigate the course and to learn effectively in such course.
    • Track Tomorrow's land elearning platform usage against goals and mission - This includes performing analytics to evaluate students' access to the platform and performance in the courses.

    Tomorrow's land may also seek your consent for additional uses of information, including Personal Information, and will use it only for the purpose described to you. All use of Personal Information is subject to applicable law.

  5. How your information is shared

    Polimi may share information, including Personal Information, only as needed to fulfill the relevant purpose(s), with the following third parties:

    • staff authorised to process personal data;
    • European Union;
    • Tomorrow's land project partners;
    • subjects that provide outsourcing services or acting as technicians operating the Tomorrow's land equipment and service programs;
    • entities / authorities for issuing public key certificates.
  6. How to manage your personal information

    Access and correct your personal information

    Much of your Personal Information is available in your Tomorrow's land account. Your name, email address, and other identifiable profile information is editable through the profile settings.

    Tomorrow's land elearning platform does not track or index every time or every place on the Site when or where a learner may volunteer Personal Information, so Tomorrow's land elearning platform will not be able to help you locate or manage all such instances.

    Tomorrow's land elearning platform encourages you to use discretion before volunteering Personal Information on the elearning platform.

    Delete account and Personal Information

    To request deletion of your Tomorrow's land account and Personal Information, you should send a request to privacy@polimi.it. Because deletion on the Tomorrow's land system is a permanent action and cannot be reversed, Tomorrow's land may ask you to complete a process that aims to confirm your authority to manage the Tomorrow's land account affected by your request.

    With respect to your Tomorrow's land account, Tomorrow's land will permanently:

    • deactivate your Tomorrow's land account,
    • remove the active profile,
    • retire your username, and
    • remove you from Tomorrow's land email lists.

    With respect to your Personal Information, Polimi will permanently delete your account profile Personal Information from the Tomorrow's land elearning platform. By erasing the Personal Information in your Tomorrow's land account profile, the remaining information about your activity on the Tomorrow's land elearning platform will no longer be associated with you, except as noted below. These changes will be applied to data stores that are used for operation of the Tomorrow's land elearning platform.

    Exceptions:

    • Deletion will not apply to historical activity logs or archives unless and until these logs and data naturally "age-off" the Tomorrow's land system.
    • Tomorrow's land will archive course data (in a manner and to the extent permitted under applicable law) to enhance the service offered. These archives may be used to produce encrypted research data packages.
    • Tomorrow's land will retain and use Personal Information as necessary to comply with its legal obligations, enforce its agreements, and as otherwise permitted by applicable law.

    Data retention

    Tomorrow's land will retain your Personal Information for as long as your account is active or as needed to provide you with services. Your Personal Information may be retained for as logn as needed to provide you with services.

  7. Storage & security

    Polimi stores information, including Personal Information, on its own servers located at Polimi. Polimi controls its own copy of information collected through the Tomorrow's land elearning platform and has an information security program designed to protect information in its possession or control. This is done through a variety of privacy and security policies, processes, and procedures. Polimi uses administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the information that it collects, receives, stores, or transmits. Nonetheless, no method of transmission over the Internet, or method of electronic storage, is 100% secure; and therefore, Polimi cannot guarantee its absolute security. While Polimi works hard to ensure the integrity and security of its network and systems, Polimi cannot guarantee that its security measures will prevent "hackers" or other unauthorized persons from illegally accessing or obtaining information.

    If Polimi learns of a security breach involving its copy of your Personal Information, Polimi may attempt to notify you electronically so that you may take appropriate protective steps. By using the Tomorrow's land elearning platform or providing Personal Information to Tomorrow's land, you agree that Tomorrow's land can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Tomorrow's land elearning platform. If a security systems breach occurs, Tomorrow's land may post a notice on the Tomorrow's land platform homepage (http://www.tland-learning.eu/) or elsewhere on the Tomorrow's land elearning platform and may send an email to you at the email address associated with your Tomorrow's land account.

  8. Privacy Policy updates

    This privacy policy will be reviewed and updated from time to time. When changes are made, the privacy policy will be labeled as "Revised (date)," indicating that you should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. By accessing the Tomorrow's land elearning platform after any changes have been made, you accept the modified privacy policy and any changes contained therein. In case you miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this privacy policy.

  9. Contact information

    If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the Personal Information that Tomorrow's land maintains about you, please contact the Polimi Data Protection Officer at privacy@polimi.it or phone +39 0223999378.

    If you consider the answer provided to be unsatisfactory, you may lodge, free of charge, a complaint with the Italian Authority for Data Protection - Garante per la protezione dei dati personali (www.garanteprivacy.it)

Effective date: May 25, 2018