Privacy Notice

This notice explains to you how «T.R.I. Technologos Research and Innovation Services LTD» (which is referred to as T.R.I. or company or we) will collect, process and use personal data about the user during the signing-up process. We are required to notify the user of this information under relevant data protection legislation. This Notice is communicated to all natural people who are interested in signing up for T.R.I. platform.

This Privacy Notice aims to inform and assure the user that T.R.I. handles their Personal Data (as defined below) with respect to their personality and their rights and in accordance with Regulation (2016/679 (EU) on the protection of natural people with regard to the processing of personal data and on the free movement of such data (the Regulation).

This Notice addresses all natural people who wish to participate and sign-up for T.R.I. platform. We ask you to read this Notice carefully as it contains important information on who we are, how and why we collect, store, use and share user’ s personal information, their rights in relation to their personal information and on how to contact us and the supervisory authorities in the event that they have a complaint.

1. Definitions

In this notice:

Personal Data means any information about the user that could identify them directly or indirectly, such as their name, surname, ID number, address, phone number.

Processing means any operation or set of operations which is performed on Personal Data, by automated means or otherwise, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Affiliates shall mean any company or other business entity or individuals who would like to affiliate and/or to be connected to T.R.I. either within or outside the European Economic Area.

2. Who collects and holds the user’ s personal data (Controller)?

T.R.I. acts as a controller in relation to itself as well as in relation to affiliate companies which provide ancillary services, such as administrative services, consultancy, translations, and other services.

Registration Number: HE393097
E-mail: [email protected]
Website: www.technologos.com.cy.

If the user has any questions, or wants more details about how we use their personal information, they can contact our Data Protection Officer at E-mail: [email protected]

3. Our sources of collecting Personal Data and the Personal Data we process

We process Personal Data that the user provides to us in the course of our services. For this purpose, we process and collect Personal Data that we receive from them and/or the Authorised Officials appointed from them and/or our Affiliates and/or third parties authorised or instructed by them. We may also collect and process Personal Data from databases and/or sources that are publicly accessible, such as the press, the media and/or third parties in order to enable us to comply with our regulatory obligations. We process Personal Data that we collect lawfully and that we are permitted to process.

4. About the information we collect and hold

During the signing-up process by the user, we collect the following information:

COMPULSORY:
  • Username
  • Password
  • Age
OPTIONAL:
  • Gender Identity
  • Topic Interests
  • Preferred Delivery Methods (text, video, infographics, simulations, games, quizzes)

During the practicing and learning process on the platform we collect the following information:

COMPULSORY:
  • Current knowledge, gaps, and needs (performance in initial assessment quiz)
  • Performance in quizzes and narrative games (score, time to complete)
  • Interaction and time spent with static content
  • Website interaction metrics (Visit occurrences to platform, navigation in the website)
  • Event logs indicating when a topic, activity or quiz was started and completed
  • User feedback

5. How we collect the information

We collect this information from the processes of user registration and user profile creation, from event logs, and from metrics and analytics.

6. Why we collect the information and how we use it (purpose for processing your Personal Data):

We collect the information in order to create a data set that will be analysed and used to modify the content to achieve a personalised experience for each user. The user will have the option to supply all the above information so that their experience is personalised. The user will have complete control of which data they supply (during their profile creation) for the purposes of analysis and personalization.

Due to your consent (Article 6 (1) (a))

If the user gives their consent on the processing of your Personal Data for specific purposes, such as for direct marketing purposes, the legal ground for the processing of user Personal Data is their express consent.

Please note that the user may at any time withdraw their consent. The validity of this revocation will concern the future. Furthermore, it should be noted that the above also applies if the user gave us their consent before 25 May 2018.

  • For the purposes of the legitimate interests pursued by us or by a third party (Article 6 (1) (f))

    • Except for the above case, either we or third parties, process user Personal Data when necessary, except if their fundamental rights and freedoms override the below interests. Below are some examples:

    • in court proceedings and/or to claim our legal claims.
    • in the context of the operation and security of the IT sector of the company.
    • in the context of preventing and clarifying criminal offenses.
    • For compliance with a legal obligation (Article 6 (1) (c))

      • T.R.I. may be subject to various legal obligations, such as the obligations arising from applicable tax legislation in general, the laws and regulations applicable in the Republic of Cyprus, any directives, rules or guidance issued by relevant authorities as well as any regulations issued by a competent organ of the European Union.

7. Who we share your data with

The data that the user will choose to supply to the platform will be shared:

Within T.R.I.

In the course of T.R.I.’s operation, the relevant employees responsible for the performance of our contractual and legal obligations receive the necessary data and/or for the performance of our services and/or to fulfill the user’s orders and/or comply with our regulatory obligations.

Outside T.R.I.

Under Article 28 of the Regulation, we have the right to designate a processor. In such a case, it is likely that the processor will receive user Personal Data for the above purposes. For example, we might designate as processors, consultancy companies such as IT services, accountants, law firms, recruiters, auditors as well as companies that provide licensed services or financial institutions.

It is possible for us to share user Personal Data to other people/companies/organisations, other than the above, in the course of the provisions of our services to the user or if they have given us their express consent for such transfer. For example, it is possible to share user personal data with the organisation that recommended them (as part of an anonymous summary report of all organisation participants, and not as a personal individual report).

In all cases the data will be anonymous. However, because of the sensitivity of the data, the user should always feel they are in a safe space, by having full control of their data.

At any moment the user will be able to modify which data they are supplying to the platform, and to get a report of all the data we have from their interactions and profile.

8. How long we keep the user information for

We will keep the information for as long as the user has an active account (that was not deleted) with sGuide. However, again the user will be able to modify which data they are supplying to the platform at any time, and to get a report of all the data we have from their interactions and profile.

After the termination of the user account on sGuide, we hold their Personal Data for up to 10 years or the period required by the applicable AML law, or according to the relevant directive of the Commissioner of Personal Data and/or other applicable law.

  • The rights of the data subject.

    • The data subject has full control of all their data. They can select which data they want to share with sGuide for analysis, and with their organisation in the form of a summary report. They can contact T.R.I. at any time to request deletion of their data.

The user has a number of significant rights, under the Regulation. Specifically:
  • right to access their personal data (Article 15): meaning the user might receive information and/or copy of the personal information we hold free of charge.
  • right to rectification (Article 16): the user might ask us to correct any mistakes in their information which we hold.
  • right to erasure (right to be forgotten) (Article 17): the user might ask us to erase the personal information concerning them. However, we reserve the right to deny the erasure, if the processing is necessary for compliance with a legal obligation, for reasons of public interests or for the establishment, exercise or defense of legal claims.
  • right to restriction of processing (Article 18): the user might require us to restrict our processing of their personal data if they contest the accuracy of their personal data, the lawfulness of the processing, or they have objected to processing (according to article 21) and they wait for our reply whether we have legitimate grounds which override
  • right to data portability (Article 20): the user has the right to request and receive the personal information concerning them which they have provided to us, in a structured, commonly used and machine-readable format and they have the right to transmit those data to a third party under certain circumstances.
  • right to object (section 21): The user has the right to object at any time to the processing of their personal data, including profiling, which is conducted based on the legitimate and/or public interest (section 6 (1) (e) and (f)) when the user deems that it is justified due to a particular situation concerning them. In case that the user does not agree, we shall no longer process their personal data unless we demonstrate compelling legitimate grounds which override their interests, rights and freedoms or if the processing serves the establishment, exercise or defense of legal claims.
  • Automated individual decision-making (Article 22): the user has the right to object to decisions being taken by automated means which produce legal effects concerning them or similarly significantly affect them.
  • right to withdraw their consent: the user reserves the right to withdraw their consent at any time. However, the withdrawal of the consent does not affect the lawfulness of the processing based on consent before its withdrawal.

If the user wishes to exercise any of the above rights or to ask any questions or clarifications or to complain, they can contact our Data Protection Officer at: [email protected]

Moreover, the user also has the right to file a complaint at the Commissioner of Personal Data Protection. For more information concerning the process of filing a complaint, please visit the website www.dataprotection.gov.cy or via e-mail at [email protected].

9. How can the user file a complaint?

In case that the user has any complaint and/or dispute in regards to the way their Personal Data is used, they are invited to contact the Data Protection Officer at: [email protected].

10. Whether the data subject is obliged to provide their personal data to sGuide/T.R.I. Technologos Research and Innovation Services ltd?

The data subject under no circumstances will be obliged to provide any data apart from a username and password (in order to log in). They will also be obliged to provide their age, to verify the user is over 14.

During the creation of their profile, they will be encouraged to provide as much data as possible (always anonymously) in order for their own personal experience on the platform to be improved, as well as for research purposes, but they will not be obliged to do so (see section 4, page 2).

11. Does automated decision-making take place?

Profiling means any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, personal preferences, interests, reliability, behaviour, location or movements.

Profiling will be used as part of the personalisation aspect of the sGuide platform, in order to tailor the experience to each individual’s needs. For example, if from metrics it is deduced that a user learns better by following a simulation, rather than a serious game, in the future the modules will be formed accordingly, to include more simulations.

Automated decision-making will be used only in order to adjust the experience and the activities to the individual needs of each user.

12. Whether the data are used for automated profiling?

Automated profiling will be used, not so much to predict the users’ behaviour, but to understand their needs, and what helps them better embody the material. We do not want to predict the user’s behaviour, but to show them the consequences of the behaviours they currently express, in order to drive behavioural change.

Principal characteristics that drive users towards different habits or behaviours will be extracted, in order to recommend specific content or activities that will be more effective for the particular user group.

13. Changes in this Privacy Notice

We may change this privacy notice from time to time and in such case, we will inform you accordingly. This Privacy Notice was last updated on 15/01/2021.

14. General

Our Data Protection Officer can resolve any query or concern the user could raise concerning our use of their information or regarding this Notice.

Our platform and databases are hosted in Europe, and all our hosting and database providers are compliant with GDPR.