GDPR:

Classe365 (“Classe365,” “We,” “Us,” “Our”) is committed to protecting the privacy of your information.The following Privacy Policy describes how we collect, use, and disclose information we receive from our users of our website, mobile applications, and products and services (collectively, the “Services”) in the European Economic Area (collectively, “you” or “users”).For the purposes of compliance with the EU General Data Protection Regulation (GDPR), we will be the “processor” of personal data we receive about you.

Effective Date:

This privacy policy is effective and last updated as of May 18th, 2018.

Who is subject to GDPR:

Individuals, organisations and companies that control or process personal data are subject to GDPR. In broad terms, there are three different actors:

Data subjects (students/learners, families, administrators, teachers/educators)
Data controllers (the school/organization/university/academy/college)
Data processors (Classe365) 

Obligations of Classe365 as Data Processors:

The Processor must have adequate information security in place:

Classe365 is hosted on the powerful Amazon web services (AWS) and the data will be hosted on the nearest data centre. 

a) Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, Classe365 has implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:

  1. The pseudonymization and encryption of personal data;
  2. The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
  3. The ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
  4. A process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.

b) In assessing the appropriate level of security account shall be taken in particular of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.

c) Adherence to an approved code of conduct as referred to in Article 40 oran approved certification mechanism as referred to in Article 42 maybe used as an element by which to demonstrate compliance.

d) Classe365 has taken steps to ensure that any natural person acting under the authority of the controller or the processor who has access to personal data does not process them except on instructions from the controller, unless he or she is required to do so by Union or Member State law.

Your Rights:

You have the following rights under the GDPR:

  • To access the personal data and your children data from Classe365
  • To be provided with the information about how we process your personal data
  • To correct your personal data and your children data in Classe365
  • To have your personal data and your children data erased
  • To object to or restrict how Classe365 processes your personal data and your children data
  • To request your personal data and your children data to be transferred to a third party.
  • If there is a need to exercise the above rights, please contact Classe365.We will consider and process your request within a reasonable period of time.Please be aware that under certain circumstances, the GDPR may limit your exercise of these rights.

Retention of Personal Data:

We will retain your Personal Data only as long as necessary to process request or other submission, fulfil the terms of our service contract with you, and comply with applicable law.

Processing under the authority of the controller:

Classe365 and any employee of the organization who has access to the personal data, shall not process the personal data except on instructions from the controller, unless required to do so by union or member state law. 

Restrictions on sub-contracting:

Even when the general consent is given by the Data Controller, Classe365 would still inform the Data Controller of any new sub-processors which gives the time for the controller to object. 

Classe365 is obliged to reflect the same contractual obligations that we have with the controller in a contract with any sub-processors and will remain liable to the Data Controller for the actions and inactions of any sub-processors. 

Compliance of all the processing activities:

Classe365 will maintain a record of all the processing activities which includes the details of the controllers and any other processors and of any relevant Data Protection Officers (DPO’s), the categories of processing carried out, details of any transfer to third countries and a general description of technical and organizational security measures. These records will be available on request to the concerned authority.

Notification of Personal data breach to the supervisory authority:

  1. In case of a personal data breach, the controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority competent in accordance with Article 55, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Where the notification to the supervisory authority is not made within 72 hours, it shall be accompanied by reasons for the delay. 
  2. Classe365 shall notify the controller without undue delay after becoming aware of a personal data breach. Classe365 will include the following in the notification following the personal data breach: 
  • Describing the nature of the personal data breach including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;
  • Classe365 will also describe the likely consequences of the data breach and describe in detail the measures taken or proposed to be taken by the controller to address the breach. 
  • Classe365 will provide the relevant DPO with all the information available without any undue delay.
  • Classe365 will document any personal data breaches, comprising the facts relating to the personal data breach, its effects and the remedial action taken. 

Data Protection Officers (DPO’s):

Classe365 has appointed a Data Protection Office (DPO) whose primary responsibility is to assist Classe365 with and advise on compliance with GDPR. The DPO appointed will have a degree of independence and is the contact point for any data subjects and for the supervisory authority. You may contact the Data Protection Office at dpo@classe365.com

Transfer of Data to third countries:

Classe365 has the right to exercise a degree of independence from the controller when deciding whether or not it can transfer personal data to a third country. 

Comments and Questions:

If you have any comment, question, or information related to the privacy policy, Please reach us at dpo@classe365.com

Updates to the Privacy Policy:

We may periodically revise the Privacy Policy in our sole and absolute discretion to reflect changes in the law or our business practices. If we revise the Privacy Policy, we post the updated Privacy Policy on our website. Changes to the Privacy Policy will become effective and will apply to the information collected starting on the date we post the revised Privacy Policy.

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