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Full policy

This privacy policy applies solely to the above-mentioned website and not to any other websites that may be accessed by the user through specific links. Users/visitors should carefully read this Privacy Policy before submitting any personal information and/or filling out any electronic forms on the website. In compliance with the obligations arising from the EU Regulation No. 2016/679 on the protection of personal data, this website respects and protects the privacy of visitors and users.

The Data Controller is McArthurGlen UK Ltd, with registered office at Nations House, 103 Wigmore St, London, W1U 1QS, UK, hereinafter referred to as the "Controller," in its capacity as the data controller, hereby informs you, in accordance with Article 13 of EU Regulation No. 2016/679, that your data will be processed in the following manner and for the following purposes:

Consent

By using or accessing this website, visitors and users explicitly approve this privacy policy and consent to the processing of their personal data in relation to the methods and purposes described below, including any disclosure to third parties, if necessary for the provision of a service. The provision of data and the consent to the collection and processing of data is optional; the user can deny consent and can revoke any previously given consent at any time. However, denying consent may result in the impossibility of providing certain services, and the browsing experience on the website may be compromised.

Processing Purposes

The term "processing of personal data" refers to: recording, storage, organization, consultation, selection, extraction, comparison, processing, use, modification, interconnection, blocking, communication, erasure, and destruction, as well as transfer or disclosure, or the combination of two or more of these operations. The processing of data collected by the website, in addition to the purposes related, instrumental, and necessary for the provision of the service, is aimed at the following purposes:

·         Provision of e-learning courses;

·         Tracking the use of content on the platform;

·         Notifications and communications to the user (data subject) regarding specific events on the e-learning platform;

·         Collection of data and information for the purpose of protecting the security of the website and users (anti-spam filters, firewalls, virus detection) and for preventing or uncovering fraud or abuse against the website. The data is automatically recorded and may include personal data (IP address) that may be used, in accordance with applicable laws, to block attempts to damage the website itself or harm other users, or to engage in harmful or criminal activities. Such data is never used for the identification or profiling of the user and is periodically deleted.

Data Processor

The data processor is MODO Network Srl, with registered office at Via Don Sturzo 17/1, 31031 Caerano di San Marco (TV) - Italy, hereinafter referred to as the "Processor,". The website https://academy.modonetwork.com is owned and managed by the Processor, who ensures compliance with the aforementioned regulations on the protection of personal data.

Collected Data

This website collects user data in two ways.

1.       Data collected automatically

During user navigation, the following information may be collected and stored in the platform's log files:

·         Internet Protocol (IP) address of origin;

·         Type of browser used for access;

·         Parameters of the device used to connect to the website;

·         Internet service provider (ISP) name;

·         Date and time of visit;

·         Referral website (source) and exit page;

·         Data on the use of educational materials.

These data are used to analyze user trends and collect data in aggregated form, administer and ensure the security of the website, and are in no way attributable to the identity of the user.

2.       Voluntarily provided data

The website collects additional data in case of voluntary use of the e-learning training service, specifically:

·         Name and surname

·         Personal Email address

·         Job function

·         Brand

·         Affiliated center

·         Preferred language

This data is voluntarily provided by the user at the time of registration for the service and will be used exclusively for the provision of the requested service and processed for the time necessary to provide the service. The data collected by the website is not provided to third parties, unless it is a legitimate request from the judicial authority and only in the cases provided by law. However, the data may be provided to third parties if necessary for the provision of a specific service requested by the user, or for the execution of security checks or optimization of the website.

Storage and Transfer of Data

The personal data collected by the website is stored on servers located within the European Union, for the times prescribed by law, and processed by employees of the Controller or third parties who carry out the aforementioned activities under its direct supervision and responsibility.

Transfer of Collected Data to Third Parties

The personal data of users/customers are an important component of our work, and we do not engage in transferring them to third parties. However, in the course of our activities and the execution of services requested by users, this website may need to transfer some data to third parties who perform specific tasks instrumental and connected to those of the website. Providers have access only to the data necessary to perform their specific task. In any case, the data is not transferred to companies located outside the European Union.

Cookies

This website uses cookies and similar technologies. Cookies allow us to store information about visitor preferences, verify the correct functioning of the site, improve its features by personalizing the content of pages based on the type of browser used, simplify navigation by automating procedures (e.g., login, site language), and analyze the site usage by visitors. In particular, this website uses the following categories of cookies:

·         Technical Cookies

Cookies in this category include both persistent and session cookies. They allow distinguishing between connected users, preventing a service from being provided to the wrong user, and are a consequence of an explicit user request. They are also used for the security of the site and its users. Without these cookies, the site or some portions of it may not function properly. Cookies in this category are always sent from our domain, and consent is not required for them.

·         Analytical Cookies

Cookies in this category are used to collect information about the correct use of the website and the behavior of users for statistical analysis purposes, to improve the website and simplify its use. This type of cookie collects information anonymously about user activity on the site and how they arrived at the site and the pages visited. Cookies in this category are sent by the website itself or by third-party domains.

·         Third-Party Cookies The website does not use third-party cookies 

Consent for the use of cookies

By using the website, continuing to navigate the website, or clicking on the banner present on the first access to the website, the visitor expressly consents to the use of cookies and similar technologies, including the registration of such cookies on their device used to access the website for the aforementioned purposes, or access through cookies to information about their device.

Refusal or revocation of cookie consent

The user can refuse the use of cookies and can revoke any previously given consent at any time. Since cookies are tied to the browser used, they can be disabled directly through the browser, thereby refusing/revoking consent for the use of cookies. DISABLING COOKIES MAY PREVENT THE CORRECT USE OF CERTAIN FUNCTIONS OF THE WEBSITE.

Contact details of the data controller

The data controller, according to applicable laws, is McArthurGlen UK Ltd, Address: Nations House, 103 Wigmore St, London, W1U 1QS Email: Dataprotection@mcarthurglen.com

Revocation of consent

With reference to Article 6 of the GDPR 679/16, the data subject can revoke their consent at any time.

Rights of the data subject

As the data subject, you have the rights listed in Article 15 of the GDPR, namely the right to:

·         Obtain confirmation of whether or not personal data concerning you exists, even if not yet recorded, and their communication in an intelligible form.

·         Obtain information about the origin of personal data, the purposes and methods of processing, the logic applied in case of processing carried out with the aid of electronic tools, the identification details of the data controller, processors, and designated representative according to Article 3, paragraph 1, of the GDPR, the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it in their capacity as designated representative(s) in the territory of the State, processors, or persons in charge.

·         Obtain the erasure, anonymization, or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which it was collected or subsequently processed.

·         Object, in whole or in part, for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of collection. If applicable, you also have the rights listed in Articles 16-21 of the GDPR (right to rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object), as well as the right to lodge a complaint with the supervisory authority.

 

Updates This privacy policy is updated as of July 10^th, 2023

 

Full policy

1. THE SERVICES

The MODO Academy website and the MODO Academy application (collectively, the "Services") provide on-demand educational and training content. The content includes videos, interactive training modules, training and informative documentation.

MODO shall not be responsible for any consequences of brief or prolonged interruptions, delays or internet dysfunctions in the Site due to power blackouts, telephone line failures, Internet failures or circumstances beyond the control of MODO.

2. USE OF MATERIALS

The content - including, but not limited to, all data, information, news, pictures, charts or drawings (collectively, "Materials")- of this website (hereinafter the "Site") is the exclusive property of McArthur Glen Ltd., their affiliates or their licensors and all right and title in and to such Materials, including all copyrights are owned exclusively by McArthur Glen Ltd, their affiliates or their licensors. The Materials are provided for training and illustrative purposes only regarding McArthur Glen Ltd and its activities. The users of the Site (hereinafter the "Users") are not permitted to either register - totally or partially – said Materials on any storage device or to copy, broadcast or use the Materials for any commercial purpose without the relevant owner's prior written consent.

 Materials may only be accessed and used in accordance with the terms applicable to this Site and any misuse of Materials is strictly prohibited. Users may not: (i) reproduce or alter the Materials; (ii) use the Materials for any commercial purpose (other than obtaining information about the McArthur Glen Ltd policies or services to which the Materials relate), or for any public display; or (iii) remove from the Materials any copyright, confidentiality or other notations relating to intellectual property rights.

3. ACCOUNTS.

To access the content on the Services, you will be required to create an account (“Account”). When creating an Account, you agree that all information provided to us will be accurate, truthful, current, and complete. The data required to access the Services are the following: First Name, Last Name, EmailAddress, Center, Brand, Language and Job function.

You can create only one Account per person.

4. PASSWORDS.

You are solely responsible for maintaining the confidentiality of any password you create on the Services including your Account password. You should never share your password with third parties. If you believe that someone has gained access to your Account, you should change your password by accessing https://academy.modonetwork.com/login/change_password.php and following the instructions.

We reserve the right to terminate your Account for any reason, at any time, at our sole discretion. For example, we may suspend or terminate your Account if we suspect you do not meet the eligibility requirements, become aware of any suspicious activity, or we believe the use of your Account violates these TOU or any applicable law. If your Account is terminated by you or MODO for any reason, these TOU continue and remain enforceable between you and MODO. Your information will be maintained and deleted in accordance with our Privacy Policy, found at https://academy.modonetwork.com/admin/tool/policy/index.php

5. CHANGE USER PROFILE

You can change your user profile details at any time, by accessing the User Profile section from the drop down Menu within the platform.

6. SELECT LANGUAGE

You can change the language of the platform at any time, by selecting “Language” from the drop down menu within the platform.

7. UNSUBSCRIBE FROM THE SERVICE

You can unsubscribe from the Services at any time. Click on the Support section of the Menu, click on the Delete my Account button, provide comment for delition if you wish and click SAVE. Your request will be processed within 5 working days. Once fulfilled, you will receive an “Unsubscribed” confirmation email.

8. DSAR (DATA SUBJECT ACCESS REQUEST)

You have the right to request access to your data stored in the platform. To do that, go to the Support section on the platform, click on “Export all my personal data” and then on SAVE. Your request will be processed within 10 working days. Once fulfilled, you will receive an email providing access to all your data.

9. ASK FOR SUPPORT

In case of technical malfunctioning of the Services or need for assistance, you can contact Support by clicking on the bottom right icon (red dot with white question mark) and write a message to the Support Team that will process your request and get back to you with an estimated resolution time.

10. MODIFICATION AND TERMINATION OF YOUR ACCOUNT OR THE SERVICES.

We reserve the right to modify or terminate the Services, your Account, and/or your access to the Services for any reason, without notice, at any time and without liability to you. If we terminate your access to the Services or you deactivate your Account, your data will no longer be accessible through your Account, but those materials and information may persist and appear within the Services. 

11. CODE OF CONDUCT.

When You create an Account or otherwise use the Services, you acknowledge and agree that:

• You will abide by these TOU.

• You are solely responsible for your conduct and for any activity that occurs through your Account.

• You are responsible for keeping your Account password secret and secure.

• You are solely responsible for your interaction with anyone on the Services, including other users, whether online or offline. You agree that MODO is not responsible or liable for the conduct of any user.

• You are solely responsible for obtaining and maintaining all telephone, computer hardware, software, accessories and other equipment needed for you to access and to use the Services.

• You will treat others with respect both on and off the Services (including when communicating with any MODO representatives or other employees).

• You will not misrepresent your identity, employment history, qualifications, or any affiliations with a person or entity.

• You will not use the Services for any harmful, illegal, nefarious, or untoward purpose.

• You will not use or attempt to use any cheats, bots, automation software, hacks, or any third party software designed to interfere with the Services.

• You will not solicit, collect, use, or attempt to use the Account login credentials of any other user of the Services.

• You will not solicit money or any other items of value from another user through the Services or use MODO in relation to any fraud, pyramid scheme, or other activities.

• You will not defame, stalk, bully, spam, abuse, harass, threaten, impersonate, or intimidate anyone on the Services, and you must not post or otherwise use information via the Services that may lead to violations of data privacy laws, or other harmful violations of personal identity or privacy, including, without limitation, your or any other person’s credit card information, non-public phone numbers, or non-public e-mail addresses.

• You will not cause harm to minors in any manner whatsoever.

• You will not impersonate any person or entity, falsely claim an affiliation with any person or entity, access the Accounts of others without permission, misrepresent the source, identity, or content of information transmitted via the Services, or perform any other similar fraudulent activity.

• You will not interfere or disrupt the Services or its servers or networks connected to the Services including by transmitting any worms, viruses, spyware, malware, malicious code, or any other code of a destructive or disruptive nature. You may not inject content or code or otherwise alter or interfere with how any MODO page is rendered or displayed in a browser or on a device.

• You will not crawl, scrape, cache, or otherwise access any content or information on the Services via automated means.

• You will not create an Account through any unauthorized means, including but not limited to by using an automated device, script, bot, spider, crawler, or scraper. Should you use any automatic, macro, program, or similar method, or otherwise commit fraud with regard to the Services, MODO NETWORK Srl reserves the right to pursue legal action against you.

• You will not reproduce, perform, display, distribute, copy, reverse engineer, decompile, disassemble, or prepare derivative works from any software used to implement the Services that belongs to another user or someone else. 

14. PRIVACY POLICY.

Please review MODO NETWORK Srl's Privacy Policy found at https://academy.modonetwork.com/admin/tool/policy/index.php for a summary of MODO NETWORK Srl's personally identifiable information collection and use practices. 

15. AVAILABILITY AND CONTINUITY OF SERVICE.

You acknowledge and accept that MODO reserves the right, at its own and complete discretion, to temporarily or permanently (i) suspend or eliminate the Services, and/or (ii) disable any access to the Services. 

16. LINKS TO OTHER SITES.

The Services may facilitate access to other sites or on-line social media networks or pages for Your convenience. These sites, networks, or pages have not necessarily been reviewed by MODO and are maintained by third parties over which MODO exercises no control. Accordingly, MODO expressly disclaims any responsibility for the content, the materials, the accuracy of the information, and/or the quality of the products or services provided by, available through, or advertised on these third party sites. Moreover, these links do not imply an endorsement with respect to any third party or any website or the products or services provided by any third party. 

17. INDEMNITY.

By using this application, you agree to defend, indemnify and hold harmless the MODO Parties against any loss, damage, liability, cost, expense (including legal fees) asserted by any third party and arising from: (i) your use of and access to the Services; (ii) any User-Posted Content; (iii) Your breach of any of these TOU; (iv) your infringement of any third party rights, including without limitation any property, privacy or intellectual property rights; and (v) your violation of any laws, rules, regulations, codes, statutes, ordinances, or orders of any governmental and quasi-governmental authorities, including, without limitation, all regulatory, administrative, and legislative authorities; or (vi) any misrepresentation by you. This indemnity shall survive the duration of your use of the Services. 

18. TERM AND TERMINATION.

This TOU will take effect at the time you begin using the Website. This TOU will terminate automatically if you fail to comply with its terms and conditions. Termination will be effective without notice. You may also terminate this TOU at any time by ceasing all use of the Services. 

19. JURISDICTION AND APPLICABLE LAW.

This TOU and all rights and obligations of the parties shall be governed by and construed in accordance with the laws of Italy without regard to its conflict of laws provisions. 

20. CONTACT US.

If You have any questions or concerns, please contact Us at https://academy.modonetwork.com/user/contactsitesupport.php