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Summary

This privacy policy refers to the Nuclear Safeguards elearning platform ("Nuclear Safeguards"), developed by Politecnico di Milano ("Polimi") in order to deliver the master program implemented for the EU-funded SaTE - Safeguards Training and Education project (http://nuclearsafeguards.eu/).


Full policy

Introduction

This page describes how the Nuclear Safeguards elearning platform 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 Nuclear Safeguards service, which can be accessed electronically and pertains to the domain: https://www.nuclearsafeguards.polimi.it/. This privacy policy is issued solely in relation to the Nuclear Safeguards elearning platform.

Purpose of the personal data processing

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

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

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

    Nuclear Safeguards directly collects information when you:

    • request a user account;
    • participate in the master program and in the learning activities on the Nuclear Safeguards elearning platform;
    • send email messages, including messages to learner support.

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

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

  2. Cookies and tracking technologies

    Nuclear Safeguards uses cookies (small data files that are stored on user's computer when user accesses the website or parts thereof) and other common tracking technologies (web beacons, clear gifs, pixels, and similar technologies that are unique identifiers used to track your online activity but are not stored on your device) on the Nuclear Safeguards Site and in email communications to help Nuclear Safeguards better understand your use and needs of the Nuclear Safeguards Site, and how Nuclear Safeguards can improve. For example:

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

    Nuclear Safeguards uses Cookies and other Tracking Technologies for the following purposes:

    • when necessary for system administration, security, and integrity to ensure the Nuclear Safeguards Site works properly for you. Without these technologies, the Nuclear Safeguards Site may not function correctly;
    • to enable analytics, performance and functionality, to help Nuclear Safeguards gather information about how visitors use the Nuclear Safeguards Site and monitor Nuclear Safeguards Site performance, and to enhance your experience by recognizing and remembering whether you have visited the Nuclear Safeguards Site before and may have any personal preferences.

    Nuclear Safeguards uses only technical, first-party and third-party cookies to ensure the smooth functioning of the platform and to make improvements.

    Used cookies

    Nuclear Safeguards uses two types of cookies: session cookies for authentication (online services and reserved areas) and to balance website load and monitoring cookies (Google Analytics).

    Session cookies

    Nuclear Safeguards uses session cookies, essential to operate authentication to online services and reserved areas. Session cookies remember information for the duration of a visit to the website and expire when you close your browser. The use of these cookies is strictly limited to transmit session identifiers required to enable a safe and efficient site browsing. If you disable session cookies, you may not be able to access features on Nuclear Safeguards.

    Third-party monitoring cookies

    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' 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 (and Nuclear Safeguards falls under this case), 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.

    According to the Terms of service in place, Google will use this information, as the independent data controller, for the purpose of tracking and examining your use of the website, compiling reports on the website’s activities for the website operators and providing other services relating to the website’s activities, device and browser used etc. and where visitors have come to Nuclear Safeguards from. Google may also transfer this information to third parties in the event this is obligatory by law and where said third parties process the aforementioned information on behalf of Google. Google will not associate your IP address with any other data held by Google.

    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.

    Cookies used by Google Analytics are listed below:


    Name Expires
    __ga 1 year
    __gat 1 day
    __gid 1 day

    By using Nuclear Safeguards, you consent to the processing of your data on the part of Google for the procedures and purposes indicated.

    To consult the privacy policy of the Google company concerning the Google Analytics service, please visit the website http://www.google.com/intl/en/analytics/privacyoverview.html.

    Google’s privacy policy can be found here: http://www.google.com/intl/it/privacy/privacy-policy.html.

    Websites and third-party services

    Nuclear Safeguards might contain links to external sites that have their own privacy policy. Polimi is not liable for the processing of data carried out by these sites.

    Certain areas of Nuclear Safeguards contain third party cookies, e.g. embedded YouTube content. Nuclear Safeguards is not responsible for these cookies. Please refer to the appropriate third party website Privacy Policy for further information about them and their terms.

    How to disable cookies

    Disabling all cookies

    You may, if you wish, deny consent to the placing of cookies by using the cookie management setting tools of your browser. If you would prefer not to enable cookies, you will still be able to navigate Nuclear Safeguards, but certain features might not function correctly.

    The links below provide instructions on how to disable cookies in all mainstream browsers (in case of other browsers please consult the corresponding help menu).

    MS Edge

    Internet Explorer

    Google Chrome

    Mozilla Firefox

    Opera

    Apple Safari

    Disabling only Google Analytics cookies

    You can block just Google analytics cookies by using this Google Analytics Opt-out Browser Add-on for mainstream browsers. This will allow you to use also Nuclear Safeguards online services.

    Deleting cookies already saved on your device

    Even if you withdraw your consent to third party cookies, cookies may have been stored on your device prior to your withdrawal. Due to technical reasons these cookies cannot be deleted, but you can normally delete cookies already saved on your device by using the “Clear browsing data” option in the privacy settings of your browser.

  3. How your information is used

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

    • create and administer your account;
    • deliver the online learning activities of the master program;
    • improve Nuclear Safeguards service - this includes enabling you to navigate the platform and to learn effectively in such environment;
    • track Nuclear Safeguards elearning platform usage against goals and mission - this includes performing analytics to evaluate students' access to the platform and performance in the courses.

    Nuclear Safeguards 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.

  4. How your information is shared

    Polimi 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;
    • European Union;
    • SaTE - Safeguards Training and Education project partners;
    • employers, institutions or other entities that foster your enrollment in the master program for training or other educational purposes (if an entity supports your participation, Polimi may share information with that entity as needed to confirm your enrollment, participation, progress, and completion status);
    • subjects that provide outsourcing services or acting as technicians operating the Nuclear Safeguards equipment and service programs;
    • entities / authorities for issuing public key certificates.
  5. How to manage your personal information

    Access and correct your personal information

    Much of your Personal Information is available in your Nuclear Safeguards account. Your name, email address, and other identifiable profile information is editable through the profile settings.

    Nuclear Safeguards elearning platform does not track or index every time or every place on the Site when or where a learner may volunteer Personal Information, so Nuclear Safeguards elearning platform will not be able to help you locate or manage all such instances.

    Nuclear Safeguards elearning platform encourages you to use discretion before volunteering Personal Information on the elearning platform.

    Delete account and Personal Information

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

    With respect to your Nuclear Safeguards account, Nuclear Safeguards will permanently:

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

    With respect to your Personal Information, Polimi will permanently delete your account profile Personal Information from the Nuclear Safeguards elearning platform. By erasing the Personal Information in your Nuclear Safeguards account profile, the remaining information about your activity on the Nuclear Safeguards elearning platform 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 Nuclear Safeguards elearning platform.

    Exceptions:

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

    Nuclear Safeguards 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 as logn as needed to provide you with services.

  6. Storage & security

    Polimi stores information, including Personal Information, on its own servers located at Polimi. Polimi controls its own copy of information collected through the Nuclear Safeguards elearning platform 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 Nuclear Safeguards elearning platform or providing Personal Information to Nuclear Safeguards, you agree that Nuclear Safeguards can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Nuclear Safeguards elearning platform. If a security systems breach occurs, Nuclear Safeguards may post a notice on the Nuclear Safeguards platform homepage (https://www.nuclearsafeguards.polimi.it/) or elsewhere on the Nuclear Safeguards elearning platform and may send an email to you at the email address associated with your Nuclear Safeguards account.

  7. Privacy Policy updates

    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 Nuclear Safeguards elearning platform 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.

  8. Contact information

    If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the Personal Information that Nuclear Safeguards maintains about you, please contact the Polimi 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: 25 January 2021


Summary

Nuclear Safeguards uses cookies for analytics and to improve your user experience.


Full policy

Nuclear Safeguards uses cookies (small data files that are stored on user's computer when user accesses the website or parts thereof) and other common tracking technologies (web beacons, clear gifs, pixels, and similar technologies that are unique identifiers used to track your online activity but are not stored on your device) on the Nuclear Safeguards Site and in email communications to help Nuclear Safeguards better understand your use and needs of the Nuclear Safeguards Site, and how Nuclear Safeguards can improve. For example:

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

Nuclear Safeguards uses Cookies and other Tracking Technologies for the following purposes:

  • when necessary for system administration, security, and integrity to ensure the Nuclear Safeguards Site works properly for you. Without these technologies, the Nuclear Safeguards Site may not function correctly;
  • to enable analytics, performance and functionality, to help Nuclear Safeguards gather information about how visitors use the Nuclear Safeguards Site and monitor Nuclear Safeguards Site performance, and to enhance your experience by recognizing and remembering whether you have visited the Nuclear Safeguards Site before and may have any personal preferences.

Nuclear Safeguards uses only technical, first-party and third-party cookies to ensure the smooth functioning of the platform and to make improvements.

Used cookies

Nuclear Safeguards uses two types of cookies: session cookies for authentication (online services and reserved areas) and to balance website load and monitoring cookies (Google Analytics).

Session cookies

Nuclear Safeguards uses session cookies, essential to operate authentication to online services and reserved areas. Session cookies remember information for the duration of a visit to the website and expire when you close your browser. The use of these cookies is strictly limited to transmit session identifiers required to enable a safe and efficient site browsing. If you disable session cookies, you may not be able to access features on Nuclear Safeguards.

Third-party monitoring cookies

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' 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 (and Nuclear Safeguards falls under this case), 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.

According to the Terms of service in place, Google will use this information, as the independent data controller, for the purpose of tracking and examining your use of the website, compiling reports on the website’s activities for the website operators and providing other services relating to the website’s activities, device and browser used etc. and where visitors have come to Nuclear Safeguards from. Google may also transfer this information to third parties in the event this is obligatory by law and where said third parties process the aforementioned information on behalf of Google. Google will not associate your IP address with any other data held by Google.

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.

Cookies used by Google Analytics are listed below:


Name Expires
__ga 1 year
__gat 1 day
__gid 1 day

By using Nuclear Safeguards, you consent to the processing of your data on the part of Google for the procedures and purposes indicated.

To consult the privacy policy of the Google company concerning the Google Analytics service, please visit the website http://www.google.com/intl/en/analytics/privacyoverview.html.

Google’s privacy policy can be found here: http://www.google.com/intl/it/privacy/privacy-policy.html.

Websites and third-party services

Nuclear Safeguards might contain links to external sites that have their own privacy policy. Polimi is not liable for the processing of data carried out by these sites.

Certain areas of Nuclear Safeguards contain third party cookies, e.g. embedded YouTube content. Nuclear Safeguards is not responsible for these cookies. Please refer to the appropriate third party website Privacy Policy for further information about them and their terms.

How to disable cookies

Disabling all cookies

You may, if you wish, deny consent to the placing of cookies by using the cookie management setting tools of your browser. If you would prefer not to enable cookies, you will still be able to navigate Nuclear Safeguards, but certain features might not function correctly.

The links below provide instructions on how to disable cookies in all mainstream browsers (in case of other browsers please consult the corresponding help menu).

MS Edge

Internet Explorer

Google Chrome

Mozilla Firefox

Opera

Apple Safari

Disabling only Google Analytics cookies

You can block just Google analytics cookies by using this Google Analytics Opt-out Browser Add-on for mainstream browsers. This will allow you to use also Nuclear Safeguards online services.

Deleting cookies already saved on your device

Even if you withdraw your consent to third party cookies, cookies may have been stored on your device prior to your withdrawal. Due to technical reasons these cookies cannot be deleted, but you can normally delete cookies already saved on your device by using the “Clear browsing data” option in the privacy settings of your browser.