Privacy policy

This privacy policy refers to the AfricaInLead website ("AfricaInLead"), which is an online platform offered by Politecnico di Milano ("Polimi"). Polimi partnered with Politecnico di Torino, Italy to develop the Africa Innovation Leaders program.

This page describes how the AfricaInLead website 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 AfricaInLead service, which can be accessed electronically and pertains to the domain: africainlead.net and its subdomains. This privacy policy is issued solely in relation to the AfricaInLead website.

Purpose of the personal data processing

Personal data is processed according to all purposes related to design and delivery of AfricaInLead, that include:

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

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

Data Protection Officer: privacy@polimi.it - phone: +39 0223999378

This privacy policy is organized as follows:

1. Information that AfricaInLead collects from you (including Personal Information)
2. Cookies and tracking technologies on AfricaInLead site
3. Third Party Cookies
4. How your information is used
5. How your information is shared
6. How to manage your personal information
7. Storage & security
8. Privacy policy updates
9. Contact information

AfricaInLead directly collects information when you:

• login and participate in the online platform;
• send email messages to technical support (including messages to learner support);
• participate in forums, webinars, and other interactive experiences on the AfricaInLead site.

AfricaInLead also indirectly collects usage information about your visit to the AfricaInLead Site, as explained in the section below titled Cookies and tracking technologies.

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

AfricaInLead uses Cookies and other common Tracking Technologies on the AfricaInLead Site and in email communications to help AfricaInLead better understand your use and needs of the AfricaInLead Site, and how AfricaInLead can improve. For example:

• based on your cookie settings, AfricaInLead tracks information indicating, among other things, which pages of the AfricaInLead Site were visited, the order in which they were visited, when they were visited, and which hyperlinks and other user interface controls were used;
• AfricaInLead may log the IP address, operating system, and browser software (including mobile use and device type when you use AfricaInLead native mobile apps) you used when accessing the AfricaInLead website, and AfricaInLead 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;
• AfricaInLead may track and collect information from emails that AfricaInLead sends to you, for example whether you opened the email or clicked on any links from the email.

AfricaInLead uses cookies and other tracking technologies for the following purposes:

• when necessary for system administration, security, and integrity to ensure the AfricaInLead website works properly for you. Without these technologies, the AfricaInLead Site may not function correctly;
• to enable analytics, performance and functionality, to help AfricaInLead gather information about how visitors use the AfricaInLead Site and monitor AfricaInLead website performance, and to enhance your experience by recognizing and remembering whether you have visited the AfricaInLead Site 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 AfricaInLead's cookies, many functions and conveniences of the AfricaInLead website may not work properly.

This website 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 site. The information generated by the cookie about your use of the website 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 website Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website 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 website. 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 website 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 website 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.

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

• Create and administer your account.
• Provide and teach the online training courses (MOOCs).
• Improve AfricaInLead service - This includes enabling you to navigate the MOOCs and to learn effectively in such MOOCs.
• Communicate with you - This includes answering your course and platform questions.
• Track AfricaInLead website usage against goals and mission - This includes performing analytics to evaluate learners' access to the platform and performance in the courses and, in some specific cases, to report personal usage information to Politecnico di Torino.

AfricaInLead 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.

AfricaInLead 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;
• Politecnico di Torino;
• Agenzia Italiana per la Cooperazione allo Sviluppo (Italian Agency for Development Cooperation);
• subjects that provide outsourcing services or acting as technicians operating the AfricaInLead equipment and service programs;
• entities / authorities for issuing public key certificates.

Delete account and Personal Information

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

With respect to your AfricaInLead account, AfricaInLead will permanently:

• deactivate your AfricaInLead account,
• remove the active profile,
• retire your username, and
• remove you from AfricaInLead email lists.

With respect to your Personal Information, AfricaInLead will permanently delete your AfricaInLead account profile Personal Information from the AfricaInLead Site. By erasing the Personal Information in your AfricaInLead account profile, the remaining information about your activity on the AfricaInLead Site 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 AfricaInLead Site.

Exceptions:

• Deletion will not apply to historical activity logs or archives unless and until these logs and data naturally "age-off" the AfricaInLead system.
• AfricaInLead 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.
• AfricaInLead 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

AfricaInLead 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 a maximum of 3 years.

AfricaInLead stores information, including Personal Information, on its own servers located at Polimi. Polimi controls its own copy of information collected through the AfricaInLead Site 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 AfricaInLead Site or providing Personal Information to AfricaInLead, you agree that AfricaInLead can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the AfricaInLead Site. If a security systems breach occurs, AfricaInLead may post a notice on the AfricaInLead homepage or elsewhere on the AfricaInLead website and may send an email to you at the email address associated with your AfricaInLead account.

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 AfricaInLead Site 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.

If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the Personal Information that AfricaInLead maintains about you, please contact the 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: October 15, 2018