1. RADA STATEMENT ON PRIVACY

RADA (platform RADA.eu / “Platform”) is managed by the Tallinn University on behalf of RADA project. The purpose of this Privacy Policy is to explain how RADA (“RADA” “us,” “we,” or “our”) collects, uses and shares information about you through our Platform and services.
This document addresses privacy aspects in RADA, whereby RADA refers to the Platform and related services. RADA collects different types of data from the user: personal information, log information and non personally-identifiable information, and information about the user activities.

RADA platform and related services ensure that data is tracked and stored only for RADA purposes and treated in accordance with the EU directive.

Before accessing the Platform, users must be aware of the RADA Privacy Policy, which informs and regulates data use and describes the purpose of RADA monitoring services.

RADA privacy policy is addressed to all RADA users - in any role - when they register to the RADA platform or play Activities anonymously. RADA has done all in its power to ensure that all the requisite technical and organisational security measures to prevent unauthorised access to users’ personal information are put in place.

The RADA platform may contain links to external websites published by other content providers. These other websites are not under our control and we encourage you to review the privacy policies of each website you visit and use.

1.1 Definition of personal information

Personal information is information which you provide to RADA which personally identifies you, such as your name, email address or other data which can be reasonably linked to such information. You provide this when you register as a user.

RADA acts in accordance with European legislation for collection and treatment of personal data, and in particular RADA aims to follow the principles of the OECD Privacy Framework (OECD, 2013):

1. Data should be obtained by lawful and fair means and, where appropriate, with the knowledge or consent of the data subject;
2. Personal data should be relevant to the purposes for which they are to be used, and to the extent necessary for those purposes. Data should be accurate, complete and kept up-to-date;
3. The purposes for which personal data are collected should be specified not later than at the time of data collection;
4. Personal data should not be disclosed, made available or used for purposes other than specified – except with the consent of the data subject or by the authority of the law;
5. Personal data should be protected by reasonable security safeguards against loss or unauthorised access, destruction, use, modification or disclosure;
6. Information on the existence and nature of personal data, purpose of their use and the identity and location of the data controller should be available.

Please read this notice carefully to understand what we do with the information you leave through your navigation in RADA.

If you do not understand any aspects of our Privacy Policy you can contact us at info@RADA.eu

2. COLLECTION OF INFORMATION

2.1 Data collected in RADA can be of two types:

1. Data provided by the user, i.e. through registration forms, mail contacts etc.
2. Data collected through the use of RADA services, i.e. navigation, games.
3. When you create content or information using the Game or Task content type, be aware that you are allowing everyone, to access and use that information, and to associate it with you (i.e., your username and profile picture).

2.1.1 Personal information - when a user registers in RADA platform, the following data is being collected and stored: full name, email address and role (e.g., Zoo Member). After creation of Game or Task, the following information is made public: name of the creator and any information you voluntarily add into the creation form.

Personal information is collected and used with the following purposes: 

1. to provide, maintain, protect and improve the quality of the Platform and the content that RADA offers; this includes conducting anonymised user research;
2. to provide you with personalised feedback;
3. to conduct evidence-based pedagogical improvements;
4. for purposes of scientific research, mainly in the areas of technology-enhanced learning;
5. to manage your account that you hold with us;
6. to allow you to make full use of RADA features and services.

Personal information is stored in secured servers. RADA has put in place technical and organisational security measures to prevent the loss or unauthorised access of users’ personal information.

2.1.2 Tracking RADA tracks user activities related to participation in our Games, your performance while answering the question and the occasional GPS position, for the aim of scientific research.

2.2. No individual analytics will be knowingly made available to other people outside RADA.

3. CONSENT

3.1. The RADA platform is hosted on servers located in Estonia. Data concerning registration to the Platform, platform cookies, data related to game results are all collected and stored on those servers.  Since Estonia belongs to the European Economic Area (EEA), the EEA legislation on privacy and the protection of personal data has been implemented. However, some usage data - mainly concerning analytics and client-side error tracking - may be stored in non-EU (e.g., Switzerland) or non-European Countries (e.g., United States). All of that data is anonymous and cannot be directly associated with users of the platform.

3.1.1 When registering, you are asked for consent before any data is collected, in accordance with the European Union (EU) Data Protection Directive 95/46/EC.

3.1.2 Registration is not allowed without user consent to Privacy and Terms and Conditions policies.

3.1.3 The Platform may, from time to time, contain links to the websites of third parties. If you follow a link to any of these websites, please bear in mind that these websites have their own privacy policies and that we do not accept responsibility or liability for any of these policies. Please check these policies before you submit any personal information to these websites.

4. YOUR RIGHTS

4.1. You have the right to know what kind of data is being collected about you and for what purposes, how your data are processed, and this information must be available in a clear and understandable way.

4.2. You have the right to cancel or correct any information in your user profile. This does not include anonymous information that has already been collected (e.g., reports, scientific publications).

4.3. You have the right to unsubscribe from the Platform and email communications.

4.4. You have the right to be treated with respect, regardless of race, religion, gender, sexual orientation, maternity, marital or family status, disability, age or national origin.

4.5. You have the choice to use an anonymous name or your clear name when registering as display name.

5. SECURITY

5.1. RADA cares for your privacy and procedural and technological measures are in place to protect your Personal Information. Such procedures protect the confidentiality of the personal information or user traffic that RADA creates, receives, stores and transmits.

5.2. RADA has done all in its power to ensure that all the requisite technical and organisational security measures to prevent unauthorised access to users’ personal information are in place. As far as security measures under the direct control of RADA are concerned, we ensure:

1. Authenticated access control using a password - all administrator users accessing the system will be required to use passwords;
2. Firewall measures;
3. Security Socket Layer - SSL "Secure Sockets Layer" installed (see 7.);
4. Regular back-ups of the system

5.2. RADA protects all stored data from misuse and respects the rights of the data owners which are guaranteed by the European Union's (EU) Data Protection Directive 95/46/EC. 
5.3. RADA protects all personal data no matter where it is sent, processed or stored, even outside the EU, and therefore must comply with the EU standard contractual clauses.

5.5. RADA may disclose your Personal Information only:
(a) if we are required to do so by law, regulation or other government authority or otherwise in cooperation with an investigation of a governmental authority;
(b) to enforce the RADA Terms and Conditions of Use;
(c) to protect the safety of users of the RADA platform and services.

6. COOKIES AND SIMILAR TECHNOLOGIES

6.1. RADA uses cookies and similar technologies. Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website.  Cookies are used by our servers to identify the user and its device.  We use cookies to adapt to the user needs and improve the user experience. Informed consent on cookies is required by the so-called “Cookies Law” on the RADA platform.

Cookies features:

1. Cookie name(s): __utma, __utmb, __utmc, __utmv, __utmz are for example the names of Cookies used by Google Analytics; laravel_session is the name of the Cookie used by RADA to identify any authenticated users.
2. Data stored: A random unique number or string of letters and numbers to identify your browser, the times and dates that you interacted with the site recently and the marketing materials or referring pages that led you to the site.
3. Expiry: Some cookies have no expiration date. Others are deleted after certain amount of days and the moment you close your browser.

Web storage features:

1. Both Session Storage and Local Storage are used in addition to Cookies, those store certain data on the client side that is not directly need to be accessed on the backend server side.
2. Examples: Cookie Consent is stored within Local Storage in order not to show the consent screen again to the same user on the same device, information on user already being shown a screen with game instructions is stored in Session Storage.
3. Expiry: Any entries from Session Storage will be deleted as soon as the browser is closed. Local storage would be stored for a longer period of time that could either be explicitly deleted by the user, from browser settings, or by the browser, in case there is a need for that.

6.2. RADA uses Google Analytics. Google Analytics is a web analytics service provided by Google, Inc. (“Google”), to help us see how our Platform is used. The data collected by Google Analytics is used to analyse how frequently the same people revisit the Platform, how the Platform is found (from advertising or referring websites), and which pages are most frequently viewed. This information is combined with data from other users to create an overall picture of Platform use.

7. RADA uses Secure Sockets Layer (SSL). The Secure Sockets Layer is a protocol that aims to allow the applications to transmit information in a secure and protected way. The applications that use the SSL certificates are able to manage sending and receiving of the protection keys, and encrypt and decrypt information transmitted using the same keys. In this way, all sensitive data that travels inside the Platform maintains a heightened level of security. The same SSL certificate technology is used by RADA partners when communication between different platforms is needed; this keeps the data transfer secure not only within the RADA platform but also when transferring data to and from the partner platforms.  

8. CHANGES/MODIFICATIONS IN OUR PRIVACY POLICY

We will review our privacy policy from time to time. Our privacy policies are subject to change and modification. Any change, update or modification will be effective immediately upon posting on our Platform.  Any material change to this Privacy Policy will be made known by changing the effective date (located at the bottom of this page). An alert will also be published on the RADA platform to inform users of any significant changes. Please return to this page periodically to make sure that you are up to date with the most current version of this Privacy Policy.

For any additional information please contact: info@RADA.eu
Effective as of 01/01/ 2018