ARETE PROJECT: PILOT 1 - APP PRIVACY POLICY

EU H2020 Research and Innovation Action programme - Grant Agreement No. 856533.

PRIVACY POLICY for Arete PILOT 1 – AR-App

PERSONAL/RESEARCH INFORMATION for PILOT 1 App collected by ARETE Project.


1. Description

WordsWorth Learning Ltd, will provide access for each stakeholder that has volunteered to participate in this ARETE Project - Pilot 1 App to research whether the introduction of stateof-the-art Augmented Reality into the WordsWorthLearning programme will improve reading and spelling skills.

Your original personal data is reprocessed and pseudonymised before being made available and used to access the Pilot 1 App. This means you will not be identifiable, which is the responsibility of the DPO and Legal Team indicated in Section 3 below and you can always assert your rights as indicated in Section 3 below.

Your pseudonymised information will enable stakeholders, teachers and our research community, geographically spread across Europe (and beyond) to maintain a private space on the Internet where they can share research information, documents, participate in discussion fora, download software, subscribe to Joint Research Center (JRC) publications etc. Your data will be collected and further processed for the purposes detailed hereafter under point 2.

As the processing collects and further processes research data, Regulation (EC) 45/2001, of the European Parliament and of the Council of 18 December 2000 on the protection of individuals with regard to the processing of personal data by the Community institutions and bodies and on the free movement of such data, is applicable.


2. What personal/research information do we collect, what is the legal basis, for what purpose and through which technical means?


Identification Data:

The App does not use cookies and does not collect personally identifiable information, it uses pseudonymised data collected for research purposes only, and for future App development. Each stakeholder accesses the App using a unique 6-digit ID and PW provided for the project. Registration and participation of data subjects are provided on a purely voluntary basis.

Legal Basis of processing:

The European Parliament and Council Decision of Horizon2020 - https://ec.europa.eu/programmes/horizon2020/en/official-documents

Purpose of processing:

The purpose of the processing of research data for the Arete Pilot 1 project is to provide secure access and information exchange, including management of: communications to users, reports, distribution of reports, information sharing within research interest, groups, etc.

Technical Information:

The pseudonymised user data are collected through clicks and transmitted as xAPI statements via JSON files to a secure research data repository.

3. Who has access to your rights?

Data Controller: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Data Protection Officer: ensures, in an independent manner, that an organization applies the laws protecting individuals’ personal data. In particular, the DPO must:

Within the different Pilots of ARETE project, all partners involved are Data Controllers in their own right. For the communication purposes with the stakeholders involved, the Project Coordinator institution (UCD DPO) will act as an overarching communicator with the ARETE


Pilots’ Data Controllers and DPOs.

If any stakeholder would like to contact us in order to assert their rights at any point during the project lifetime and within 5 years after the project termination (April 2023), please email us to: arete@ucd.ie
If you feel that your private data or your rights were infringed under the GDPR, you may make an official complaint to the data protection authorities in your country: https://edpb.europa.eu/about-edpb/about-edpb/members_en
Access to the research data is only granted through User-ID & Password to appointed users

4. How do we protect and safeguard your information?

The location where the data processing activities take place is as follows:

The data is stored on a secure server at https://learninglocker.vicomtech.org. The server is using AWS infrastructure and is physically located in Frankfurt, Germany. All the traffic sent to the server is encrypted and only the users with administrative rights can access it. Once Pilot 1 is completed, the data collected will be removed from AWS and safely stored on a secure server on Vicomtech premises, located in San Sebastian, Spain.

5. How can you verify, modify or delete your information?

Registered users are able to update it or to cancel their registration or to request to unsubscribe from this specific project, more information can be found at the following link https://www.areteproject.eu/gdprpolicy

6. How long do we keep your data?

Your personal/research data will remain in the database for a period of 5 years after the end of the project.

7. Contact Information

Should you have any queries concerning the processing of your personal/research data, please address them to: https://www.areteproject.eu/gdprpolicy/

8. Recourse

We are committed to the protection of your privacy while you use our Mobile App.
By continuing to use our Mobile App, you acknowledge that you have had the chance to review and consider this Privacy Policy, and you acknowledge that you agree to it. This means that you also consent to the use of your pseudonymised information and the method of disclosure as described in this Privacy Policy. If you do not understand the Privacy Policy or do not agree to it, then you agree to immediately cease your use of our Mobile App.

9. Third Parties

WordsWorthLearning provide some of your "pseudonymised" Data to a Third-Party Service Provider (Soapbox Labs) in order to help us track and improve individual student reading performance, we also use this information for research data. There is an option within the App to disable this feature, however this information helps us to improve reading skills. Information about their Privacy Policy can be found at this link https://www.soapboxlabs.com/privacy/.

Store Links for "READ SPELL" app