Privacy Policy

INTRODUCTION

Welcome and thank you for choosing to be part of our community at REST, the Approach App and Web Platform developed under the EU Erasmus Programme Ref Number 2020-1-UK01- KA204-078975 by the Approach Consortia, a group of EU based organisations: European Learning Network, BEST, Your Ideas Matter and International School of Entrepreneurship (collectively referred to as “company”, “we”, “us”, or “our”). The Approach App REST and the Web Platform is an innovative resource to help educators, trainers and others in the field of education and training with resilience and emotional management issues. It is and can be a resource for those who are generally interested in resilience and emotional management issues.

We are committed to protecting your personal information and your right to privacy when you access our services and products. The following terms and conditions govern all use of the content, services and products available at or through the Approach App or website (taken together collectively, the Website, and/or the Site). If you have any questions or concerns about our policy, and/or our practices with regards to your personal information, please contact us at admin@approachrest.eu

When you visit our website [www.approachrest.eu or partner website of the Appraoch consortia] (“Site”, “Website”) and use our services, you agree and allow us to use your personal information in order for you to access our services and/or products. By accessing or using any part of our web site or app, you agree to become bound by the terms and conditions of this agreement.

Therefore, we request that you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please immediately discontinue use of our site and our services and/or products.

This privacy policy applies to all information collected through our websites (such as [www.approachrest.eu or partner website of the Appraoch consortia]), [our mobile] [or] [our Facebook applications] ("Apps"), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Sites", and/or “Website”). Further, by accessing and using our website and services and/or products you agree that REST and the Approach Consortium reserves the right to vary these terms and conditions of use of the website, the app and privacy terms as and when appropriate and becomes necessary.

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us. As mentioned above, if there are any terms in this privacy policy that you do not agree with, please immediately discontinue use of our site and our services and/or products.

WHAT INFORMATION DO WE COLLECT?

We collect personal information that you provide to us such as name, address, contact information, passwords and security data, and social media login data in order that you may access our Website, Rest APP and our services and/or prodcuts.

We collect personal information that you have voluntarily provided to us when [registering at approachrest.eu or our Sites or Apps,] expressing an interest in obtaining information about us or our products and services, when participating in activities on the Approach Site and the APP [(such as posting messages in our online discussion panel or answering questions related to resilience and emotional management)] or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make and the products and features you use. The personal information we COLLECT can include the following:

Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data. This enables you, the user, to access our services and products in a seamless manner and enjoy the features of our products and services.

Credentials. We collect passwords, password hints, and similar security information used for authentication and account access. Again, this is for the benefit of you, the user, to access our services and products in a seamless manner and enjoy the features of our products and services..

Social Media Login Data. We provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called "Social Logins"

Payment Data. We DO NOT collect data or plan to collect data in the foreseeable future necessary to process your payment to make purchases such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. Our REST App and Website is made available on a free-of-charge basis so such data is not and will never be collected. Should such a request be made at any stage while you are using our services and/or products, please immediately shut down your App and Website usage of our products and services and check at your end for any viruses, trojans, malwares or other such issues. Also, immediately have your device checked by an expert to see if your device is affected by viruses, trojans or any other malwares.

We DO NOT collect data or plan to collect data in the foreseeable future necessary to process your payment. Our REST App and Website is made available on a free-of-charge basis so such payment data is not collected for this App and Website. As recommended above, should you come across such a request while using our App and/or Website please follow the above guidance. Also, take precautionary measures and immediately contact your bank and/or credit card provider while checking at your end for any viruses, trojans, malwares or other such issues.

All personal information that you provide to us must be true, complete and accurate so that you are able to enjoy our products and services. You must notify us of any changes to such personal information in order to be able to maintain your access to our App and Website.

Information automatically collected

We automatically collect certain information when you visit, use or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Site and other technical information. This information is primarily needed to maintain the security and operation of our App and/or Sites, and for our internal analytics and reporting purposes.

Like many businesses, we DO NOT collect information through cookies and similar technologies. However, as mentioned earlier you have options for logging to our App and/or Website. Should you use these options (such as your social media accounts) please thoroughly check their privacy policies and how they may use your personal data. Data collected by third parties (e.g. facebook, google etc.) are beyond our control and you are advised to check their privacy policy.

Information automatically collected

If you use our Apps, we may also collect the following information:

• Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s [Bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage,] and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
• Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.]
• [Facebook Permissions. We by default access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, checkins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.]

Information collected from other Sources

We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).

HOW DO WE USE YOUR INFORMATION?

We use personal information collected via our App and/or Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes"), in order to enter into or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

• To facilitate account creation and logon process [with your Consent]. If you choose to link your account with us to a third party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below headed "Social Logins" for further information.
• To send you marketing and promotional communications [for Business Purposes and/or with your Consent]. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the "Your Privacy Rights" below).
• To send administrative information to you [for Business Purposes, Legal Reasons and/or possibly Contractual]. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
• Fulfill and manage your orders [for Contractual reasons]. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Sites.
• To post testimonials [with your Consent]. We post testimonials on our APP and/or Sites that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at [admin@approachrest.eu] and be sure to include your name, testimonial location, and contact information.
• Deliver targeted advertising to you [for our Business Purposes and/or with your Consent]. We may use your information to develop and display content and advertising (and work with third parties such as Google , Apple, and Facebook; who do so) tailored to your interests and/or location and to measure its effectiveness.
• Administer prize draws and competitions [for our Business Purposes and/or with your Consent]. We may use your information to administer prize draws and competitions when you elect to participate in competitions.
• Request Feedback [for our Business Purposes and/or with your Consent]. We may use your information to request feedback and to contact you about your use of our Sites.
• To protect our Sites [for Business Purposes and/or Legal Reasons]. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention).
• To enable user-to-user communications [with your consent]. We may use your information in order to enable user-to-user communications with each user's consent. This is applicable during your participation on our discussion panel on our website.
• To enforce our terms, conditions and policies [for Business Purposes, Legal Reasons and/or possibly Contractual].
• To respond to legal requests and prevent harm [for Legal Reasons]. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We only share and disclose your information in the following situations:

• Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties (e.g., Google and/or Apple) to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Sites. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our partner organisations and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
• Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
• With your Consent. We may disclose your personal information for any other purpose with your consent.
• Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Sites) or otherwise interact with public areas of the Site [or App], such personal information may be viewed by all users and may be publicly distributed outside the Site [and our App] in perpetuity. [If you interact with other users of our Sites and register through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity.] Similarly, other users will be able to view descriptions of your activity, communicate with you within our Sites, and view your profile.
• Offer Wall. Our Apps may display a third-party hosted “offer wall.” Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for acceptance and completion of an advertisement offer. Such an offer wall may appear in our mobile application and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will leave our mobile application. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account.]

HOW DO WE HANDLE YOUR SOCIAL LOGINS?

Our Sites and App offers you the ability to register and login using your third party social media account details (like your Apple, Facebook, Google or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e- mail address, friends list, profile picture as well as other information you choose to make public. [If you login using Facebook, we may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.]

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Sites and/or the App via our Terms & Conditions for using our services and products. Please note that we do not control, and are not responsible for, other uses of your personal information by any of your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

Our servers are located in Europe. If you are accessing our Sites from outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "Disclosure of Your Information" above), in countries .

If you are a resident in the European Economic Area, then these countries may not have data protection or other laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.

Binding Corporate Rules (our Terms and Conditions for using our Website and the App)

These include, a set of Binding Corporate Rules ("BCRs") established and implemented by [Approach REST]. Our BCRs provide an adequate level of protection to the personal information we process internationally. You can find a copy of our BCRs here T&Cs

HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy and our BCRs mentioned above, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than [6 months past the termination of your account].

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.

DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Site [and App]. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at [admin@approachrest.eu].

WHAT ARE YOUR PRIVACY RIGHTS?

[In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data- protection/bodies/authorities/index_en.html

[Account Information

You may at any time review or change the information in your account or terminate your account by:

• Logging into your account settings and updating your account
• Contacting us using the contact information provided below
• [Other]

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms & Conditions of Use and/or comply with legal requirements.]

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites. To opt-out of interest-based advertising by advertisers on our Site visit http://www.aboutads.info/choices/.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. You can also opt-out by:

• Noting your preferences at the time you register your account with the Sites.
• Logging into your account settings and updating your preferences.
• Contacting us using the contact information provided below

DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. While we endaevour to please all our users of the Webiste and the App, please note that as a Euroepan group and developers we are, first and foremost, bound by EU’s GDPR rules which we have explained extensively here and in our T&Cs. Our privacy policy and T&Cs extensively, and in details, explain your privacy rights and T&Cs for usage of the Wesite and/or the App.

If you are under 18 years of age, reside in California, and have a registered account with the [Sites/ Mobile Application/ Facebook Application], you have the right to request removal of unwanted data that you publicly post on the [Sites/ Mobile Application/ Facebook Application]. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the [Sites/ Mobile Application/ Facebook Application], but please be aware that the data may not be completely or comprehensively removed from our systems.

DO WE MAKE UPDATES TO THIS POLICY?

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, email us to:

APPROACH REST

Data Controller

[Approach Rest]

[admin@approachrest.eu]

NB/ WE are a Green organization and hence use methods to minimize our carbon footing and encourage the use of emails and electronic communication methods.

Approach Rest, Talking Seeds (part of European Learning Network cluster), admin@approachrest.eu

[If you are a resident in the European Economic Area, the "data controller" of your personal information is [Approach Rest]. You can contact them directly regarding the processing of your information by our App and/or Website, by email at [admin@approachrest.eu]

If you have any further questions or comments about us or our policies, email us at or contact us by post at:

Data Controller

[Approach Rest]

[admin@approachrest.eu]