Privacy Statement Prowise Presenter

Prowise B.V. offers various services, including the web based service Presenter and the Presenter app for tablets (“Presenter”). With Presenter you can create your own lessons in a very user-friendly way.

When using Presenter, personal data is processed. The careful handling of personal data is of great importance to Prowise. Accordingly, we process and protect personal data with the greatest possible care. Below please find an explanation about how Presenter works and how the protection of your personal data is guaranteed.

Based on Article 4(1) of the General Data Protection Regulation (“GDPR”), personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly.

This privacy statement can be accessed, saved and printed at any time via this link (“Privacy Statement”).

Creating a Presenter account

You can create a free user account for Presenter via our website (www.prowise.com) or by downloading the Presenter app for Apple or Android tablets via Play Store or App Store. Registration always takes place via our Account Portal at https://account.prowise.com/register/ (“Account Portal”). When registering for an account the data entered in the input fields will be processed by us.

This includes the following data:

• emailadres
• first name
• surname prefix
• surname
• language/country
• type of user
• password

The data is required to create a user account for you.

When the registration is transmitted, the following data are also processed:

• your IP-adres
• date and time of transmission

Registration takes place according to a double-opt-in procedure. After registration, you will receive an activation link at the email address provided by you, which you must confirm and/or activate. In this way we check whether the email address entered on our website is actually yours. If the confirmation or activation link is not used within 48 hours, the registration process will be canceled and the confirmation or activation link will expire. In that case we will delete the registration data.

If you click on the activation link, we will process the following data as part of the double-opt-in procedure:

• your IP-adres
• date and time of transmission

We process the personal data in order to provide the user with their own user account. The purpose ofprocessing the double-opt-in data is to prevent misuse of the registration.

The provision of personal data is neither legally nor contractually required nor necessary for the conclusion of an agreement. You are not obliged to provide personal data either. However, without the required data we cannot create a user account for you and give you access to Presenter.

Use of Presenter

When using Presenter, the following data may be processed by us:

Contact details:

• First name
• Last name
• Username
• Password (encrypted or hashed)
• Email address

Single Sign-On (optional)

Login with:

• Google ID
• Microsoft ID
• Apple ID

Only for users of Belgian educational institutions:

• KlasCement ID

Only for users of Dutch educational institutions:

• SURFconext ID
• Basispoort ID

The following data will be processed:

• Third party user identifier (User ID)
• Given, Middle, Family name (if available)
• Email address

When logging in with Basispoort, the following additional data will be processed:

• ECK-ID
• Role
• Relationship to groups
• Relationship to licenses

Third party data storage (optional)

Storing files and data on your Google Drive, Dropbox or OneDrive account

• Third party user identifier (User ID)
• Email address (used to show which account is linked)
• Third party read/write Authorization

User content (optioneel)

Text, photos, video and/or sound images.

Functionalities can be used to store and share text, photos, video and sound images, i.e. by providing access to your photo/image gallery. The images and/or text may contain personal data.

User settings and actions:

• Two factor authentication
• Interest, such as primary education and secondary education and subjects
• Language/country settings
• How many times a password has been entered incorrectly
• How often someone is logged in
• How many tools and lessons are used per user
• Account delete date
• Agree or disagree terms and conditions, privacy policy, Creative commons agreements
• Date of registration of the user

Technical data

• Browser identification (user agent) to be able to see which software is being used by the user in case of problems and to solve problems
• IP address. For internal use for insight into user statistics and to prevent abuse (network overload)

The Presenter Community

You can participate in the Presenter Community. This is an online platform, available via the Prowise website, which enables users of Presenter to post and share content with other Presenter users. When posting and sharing content in the Presenter Community, your name and the name of the educational institution may be shown.

Security

We use strict security procedures, among others, to prevent unauthorised parties from gaining access to personal data. In particular, we make use of secure connections (Secure Sockets Layer or SSL), which shield any information shared between you and Prowise Presenter when you register or make use of Presenter. Our employees work according to strict guidelines when it comes to the protection of your privacy.

Retention period

Personal data and user content are retained for up to six (6) months after termination of the Presenter account, unless you explicitly request a shorter retention period. If a shorter retention period is requested, the account can still be restored by Prowise during this six month period.

Personal data may be retained for a longer period if this is required by law.

Data subject rights

You have the right to request access, rectification, to be forgotten, data portability, restriction of processing and to object to the processing of your personal data as specified below. To that end, see our contact details at the end of this privacy statement. In the interests of preventing misuse and fraud, we may ask that you provide proper identification.

Right of access (article 15 GDPR)

You have the right to access the information we hold about you. You can request this information from us by email. You can consult which data Prowise processes at any time via your account.

Right of rectification (article 16 GDPR)

You have the right to have your personal data corrected if they are incorrect or outdated and/or to have them completed if they are incomplete. You can send a request for correction or completion to us by email. You can correct or supplement your data at any time via your account.

Right to object (article 21 GDPR)

You have the right to object to the processing of your data if you do not agree with the way in which we process your personal data. This right applies to the data that we use for direct marketing. Should you object to the processing of your data for direct marketing purposes, we will no longer process your personal data for this purpose.

In addition, this right also applies if we use your personal data based on our legitimate interest. Should you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling and legitimate reasons for such processing that outweigh your interests, rights and freedoms, or where processing serves the assertion, exercise or defence of legal claims.

Right to data portability (article 20 GDPR)

You have the right to receive data that you have provided to us within the framework of the agreement(s) that you have concluded with us (e.g. your account data) in a machine-readable format, so that you can store this data in your database or the database of a third party.

Right of restriction (article 18 GDPR)

You have the right to request restriction of the processing of your personal data. This means that we are allowed to store your data but are not allowed to use them. You have this right under specific circumstances as specified in article 18 of the GDPR. If you believe that such a circumstance applies, please contact us by email.

Right to be forgotten (article 17 GDPR)

You have the right to request us to delete all personal data we hold about you. When you request deletion of your Personal Data, we will remove any information that can be traced back to you except for the information that we are required to retain by law.

Right of withdrawal (article 7 GDPR)

You have the right to withdraw any consent you have previously given with effect for the future at any time without this affecting the lawfulness of the processing that took place on the basis of the consent given until the moment withdrawal.

Right to submit a complaint (article 77 GDPR)

Personal data from United States K-12 students

In our role as school service provider for United States elementary and secondary schools we have committed ourselves to the Student Privacy Pledge. For more information about the Student Privacy Pledge, please visit this website.

The Student Privacy Pledge commitments apply to Student Personally Identifiable Information (“PII”) which has the same definition as “covered information” under California’s Student Online Personal Information Protection Act (“SOPIPA”).

In our role as school service provider we will:

• collect, use, share, and retain Student PII only for purposes for which we were authorized by the educational institution/agency, teacher or the parent/student.
• disclose clearly in contracts or privacy policies, including in a manner easy for institutions and parents to find and understand, what types of Student PII we collect, if any, and the purposes for which the information we maintain is used or shared with third parties.
• support access to and correction of Student PII by the student or their authorized parent, either by assisting the educational institution in meeting its requirements or directly when the information is collected directly from the student with student/parent consent.
• maintain a comprehensive security program that is reasonably designed to protect the security, confidentiality, and integrity of Student PII against risks – such as unauthorized access or use, or unintended or inappropriate disclosure – through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information.
• provide resources to support educational institutions/agencies, teachers, or parents/students to protect the security and privacy of Student PII while using the educational service.
• require that our vendors with whom Student PII is shared in order to deliver the educational service, if any, are obligated to follow these same commitments for the given Student PII.
• allow a successor entity to maintain the Student PII, in the case of our merger or acquisition by another entity, provided the successor entity is subject to these same commitments for the previously collected Student PII.
• incorporate privacy and security when developing or improving our educational products, tools, and services and comply with applicable laws.

In our role as school service provider we will not:

• collect, maintain, use or share Student PII beyond that needed for authorized educational/school purposes, or as authorized by the parent/student.
• sell student PII.
• use or disclose student information collected through an educational/school service (whether personal information or otherwise) for behavioral targeting of advertisements to students.
• build a personal profile of a student other than for supporting authorized educational/school purposes or as authorized by the parent/student.
• make material changes to School Service Provider education privacy policies without first providing prominent notice to the users and/or account holder(s) (i.e., the institution/agency, or the parent/student when the information is collected directly from the student with student/parent consent) and allowing them choices before data is used in any manner inconsistent with terms they were initially provided; and not make material changes to other policies or practices governing the use of Student PII that are inconsistent with contractual requirements.
• knowingly retain Student PII beyond the time period required to support the authorized educational/school purposes, or as authorized by the parent/student.

Provision of data to third parties

We will not provide your data to third parties, unless this is required to provide you with Presenter or this is required by law. If there is a suspicion of fraud or abuse of our services, we can provide personal data to the competent authorities.

Third-Party Apps

Presenter enables you to use third-party applications and services to make content, products, and/or services available to you (“Third-Party Apps”). Your use of these Third-Party Apps is governed by and subject to the (licensing) conditions and privacy policies of the relevant Third-Party Apps. We recommend that you read the privacy statement of the Third-Party Apps before making use of these apps.

The following Third-Party Apps are available in Presenter:

YouTube API Services

When you search for YouTube videos, the Google Privacy Policy applies.

Bing Search

When you search for images via Bing Search, the Microsoft Privacy Statement applies.

Flickr Search

When you search for images via Flickr Search, the Flickr Privacy Policy applies.

Rijksmuseum Search (only available for users in the Netherlands and Belgium)

When you search for images via Rijksmuseum Search, the Rijksmuseum Privacy Policy applies.

Schooltv (only available for users in the Netherlands and Belgium)

When you search for SchoolTV videos, the NTR Privacy Statement applies.

Google Drive

When you store data in your Google Drive account, the Google Privacy Policy applies.

Dropbox

When you store data in your Dropbox account, the Dropbox Privacy Policy applies.

. OneDrive

When you store data in your OneDrive account, the Microsoft Privacy Policy applies.

Changes to this Privacy Statement

We reserve the right to amend our Privacy Statement. We recommend that you check this statement regularly, so as to be aware of these changes. We will inform you if we make material changes to our Privacy Statement and will request your consent the first time you login following the change.

Contact details

Prowise B.V. Luchthavenweg 1b 6021 PX Budel Nederland

Dhr. L. Loeff (privacy officer) (+31) (0) 495 497110 privacy@prowise.com www.prowise.com