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Privacy Policy

Version 3
Updated 10/10/2022

What is it about?

On this page you will find all the information about how, why and to what extent we process your personal data on our platform.

Our Promise

We're committed to privacy by design, which means protecting our users' privacy is built into all of our systems and technologies by default.

Responsibly and the best way we can. See our manifesto for more.

We process your personal data primarily for the following purposes:

a) To provide you with services and features of our platform where you can:

  • Create your own personal profile by entering your registration details (in particular your full name, year and school, email, parent email, password and decision-making stage)
  • Choose your interests and ideas about fulfilling your future education and career
  • Complete quizzes and tests that will help you and us better understand your talents, specific interests and ideas about the future. Our algorithm will suggest the most suitable schools or employers accordingly, which you can then approach (it is your decision, we do not provide them with your data)
  • Choose from the offer of schools or employers that are most suitable - including your age and requirements
  • Contact the most suitable schools or employers
  • Communicate with us by email or phone if you need help or advice
  • And take advantage of many other great features as we develop them

All these purposes are part of the contract for the use of services available on the platform, which we conclude together the moment you register on our platform. Without your personal data, we cannot conclude this contract together and allow you to use the services on our platform.

Part of the fulfilment of the contract is also the creation of a user profile based on completed quizzes, questionnaires, and other activities within the platform, which will allow our algorithm to offer you suitable offerings, products, services and other solutions.

b) So that we can fulfil our legal obligations - as a company we have to keep accounts, fulfil tax obligations, archive prescribed documentation, submit documentation and data to public authorities, fulfil obligations regarding the processing of your personal data or the data of your legal representatives, etc.

Without your personal data, we would not be able to fulfil our obligations because the law requires us to do so.

c) we may also use personal data for the purposes of defending or exercising our rights and claims, if a possible dispute arises or if we want to avoid a possible dispute, or if we need to demonstrate that we are properly fulfilling our obligations, for the proper operation and development of our platform, to ensure its security and thus the security of your data and services provided, including maintaining backups of our databases. All these purposes represent our legitimate interest in processing personal data.

If you do not like any of our legitimate interests, you can file an objection and tell us why we should not use your data for our legitimate interests. You have the right to do so, and we will deal with your objection responsibly.

d) For all other purposes that require your consent to the processing of your personal data, if you or your legal representatives grant us such consent, e.g. if you want to receive emails from us with interesting promotions, educational courses, discounts on interesting products, and other useful things that we are sure may interest you.

Directly from you, either about you or your legal representatives, or companies with which you have an account and voluntarily use it to log in to the platform. What we know about you is therefore in your hands.

You entrust us with your personal data by creating a profile on the platform, namely (i) directly on the Wibo platform or (ii) through Talent Centrum on the website talentcentrum.sk, which is operated by ŠIOV (State Institute of Vocational Education). However, you always submit your personal data to us and create a profile on our platform Wibo.

By registering, we jointly conclude a contract on the basis of which we provide you with our services. Our services are transparent, understandable, and provided in a way that can be used easily and intuitively even by children aged 13 (and under). However, as an extra security measure to protect children, we have introduced consent for the registration of a child aged 13 (and under) on our platform by their legal guardian. This step is required by law only if the child gives consent to the processing of their personal data, but not in the case of concluding a contract for registration on our platform. Nevertheless, we took the step. Protection and safety are our top priority. Learn more in our manifesto.

Personal data about the legal representative, specifically their e-mail address in order to confirm the interest of a child aged 13 (and under) in creating a profile on the platform, we obtain directly from the child and the parent confirms their e-mail address and also the child's interest in creating a profile with their consent via e-mail communication in response to an e-mail verification sent by us.

We only need personal data to the extent of general personal data (e.g. name, surname, place of residence, grade and attended school, faculty or university, e-mail, legal representative's e-mail, or phone number, hobbies, interests, education, language level, stage of deciding on choosing a school or employer, login data, etc.), so that you can fully and without worry use our platform and the services it provides.

At Wibo, we constantly take all reasonable and appropriate security measures to protect us and you from unauthorized access or unauthorized alteration, disclosure or destruction of the personal data we process. Measures include encryption where applicable, firewalls, secure devices, and access rights systems, and we are constantly updating them.

If, despite the security measures, there should be a breach of the security of our systems or the occurrence of other security incidents that are likely to have a negative impact on your privacy, we will inform you of the breach as soon as possible.

How we can verify the users age

We meet all standard standards - we require each user to enter their age. If the user is 13 years old or younger, they must confirm their registration with parental consent, otherwise they cannot register on our platform.

Although, the honest answer is that we cannot verify the user's true age with absolute certainty.

We are however, constantly looking for ways to develop new solutions to solve this problem.

Whether it's to find registered accounts that don't belong to the age group they entered during registration, as well as new ways to better verify the user's age in the first place before they start using wibo.

How specifically?

Reporting

Anyone who suspects a minor can report this account to us. If the user cannot prove their age, their account will be deleted.

Help us achieve a higher level of protection for children and young people on our platform! If you have reason to believe that a registered user of ours is of a different age than the one stated in their profile, please contact us at info@wibo.ai and we will investigate the situation. Your security and privacy is our top priority.

Artificial intelligence

The main pillar of our initiative to solve this problem is through artificial intelligence. We are already developing a technology that allows us to estimate people's age based on their behaviour on the platform. We train our technology to analyse and then react to signals. Specifically, we analyse the common behaviour of age groups and then compare them with each other. We look at things like what users browse, what they watch, what they save. All anonymously of course.

Example: A user who entered the age of 16 at registration largely views high schools and videos that are primarily of interest to the younger age group. The system will identify such a user and we will then contact them and check their age. Of course, this technology is not perfect and we are working diligently to improve it.

ID verification?

Many argue that collecting ID cards (eg ID cards) is the answer to this problem. In addition to the unnecessary risk to the user's privacy, this approach also has significant limitations: many young people do not have ID cards, and the implementation of such technology is very timely and financially demanding.

Partnerships

We've partnered with online security experts to proactively address this issue together, applying the latest research and solutions directly to Wibo.

Only for as long as you have a registered profile on our Wibo platform. After cancelling your profile, our service contracts will also be cancelled and we no longer need your personal data, so they will be deleted together with your profile. We will retain only data which we must archive according to law or which will help us defend our rights or claims or prove the fulfilment of our legal obligations, but always at the longest during the limitation period or the period established by law, during which public authorities can inspect or store us fine. After this time, we will delete the remaining data. Until then, we will take all necessary measures to ensure that your data is always safe.

If you give us your consent, we will process your personal data until you withdraw your consent or until their processing is no longer necessary.

Other entities that process your personal data are our intermediaries who help us with the operation of our platform, with accounting, provide us with various analytical tools to improve our platform for you, etc. Intermediaries process your personal data only on the basis of our authorization, according to our instructions and on our behalf.

Our intermediary is also Talent Centrum, in which employees help you and your legal representatives with registering to our platform and advise you on how to make the right decisions on your future studies and employment.

We also use the services of third parties with whom you have an account, to use that account for your login to our platform. For such a login, you can use, for example, your Facebook account, Google account, Apple account, etc. You can find the current login options on our website. We use your data from these accounts only for the purposes of creating your account and logging in via these accounts. In such case, we may have access to certain information from the social media or authentication services of these third parties if you log into our platform through such account. Any access we may have to your account information is in accordance with the authorization procedures established by this service and is strictly limited to the purpose of your registration and login on our platform. Information on how your personal data is processed by third parties with whom you have an account can be found published on their websites.

Social Media Widgets: Our Websites may contain various social media features, such as a social Like button, and widgets, such as a Social Share button, that run on our websites. These features may collect your IP address, the page you visit on the websites, and may set a cookie in order for the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the websites. Your interaction with these features is governed by the privacy policies of the companies that provide them.

Your personal data is stored on our servers located within the European Union.

It may happen that some service providers, who mainly perform various analytical activities for us, may in exceptional cases also send some data to servers outside the EU, especially the USA. In such a case, we always make sure that a specific entity meets the appropriate guarantees required by the GDPR, for example, meets the conditions of the European Commission's decision on adequacy or is bound by properly approved standard contractual clauses. They should always have these published on their website where you can find them, or contact us and we will provide you with their contents.

You are always in control of your personal data. Want to know how and why? Read our manifesto.

You have the following rights, in particular:

  1. The right to request access to your personal data we process.

    In particular, you have the right to confirmation of whether or not we process your personal data and where we do so, access to the personal data together with certain other information. This additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. This does not affect the rights of others; we will only supply you with a copy of your personal data. The first copy will be provided free of charge.
    You can always access most of your personal data in your registered account on our platform.

  2. The right to correct incorrect or complete incomplete data

    You have the right to correct any inaccurate personal data concerning you and, taking into account the purposes of processing, to supplement incomplete personal data about you.

  3. The right to restrict the processing of your personal data if the legal conditions are met

    In certain circumstances, you have the right to restrict the processing of your personal data. Specifically, if: you dispute the correctness of your personal data; the processing is unlawful, but you oppose the deletion of your personal data; we no longer need your personal data for the purposes of our processing, but you need them for the purposes of establishing, exercising or defending your legal claims; or you have objected to the processing of your personal data based on our legitimate interest, until your objection has been verified. Where processing has been restricted on this basis, we continue to store your personal data. However, we will only process it differently: with your consent; to establish, exercise or defend legal claims; to protect the rights of another natural or legal person; or for reasons of important public interest.

    We always inform you in advance about the planned cancellation of the restriction on the processing of your personal data.

  4. The right to portability of personal data to another operator if the legal conditions are met

    You have this right if the legal basis for our processing of your personal data is:
    a) your consent; or
    b) processing is necessary for the fulfilment of a contract to which you are a party, or for the purpose of taking steps based on your request before concluding a contract,
    and such processing is carried out by automated means.

    If all conditions are met, you have the right to receive your personal data from us in a structured, commonly used, and machine-readable format. However, this right does not apply if it would adversely affect the rights and freedoms of others.

  5. The right to delete your personal data if the legal conditions are met

    You have the right to delete your personal data if the following conditions are met: if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; if you revoke consent to processing based on consent; if you successfully object to processing based on our legitimate interest; if you object to processing for direct marketing purposes; and the personal data has been unlawfully processed or its deletion is our legal obligation.

    It is not necessary to delete personal data if the processing is necessary: for the exercise of the right to freedom of expression and information; to fulfill a legal obligation; or for proving, exercising, or defending legal claims, etc.

  6. The right to withdraw your consent if you have given it to us

    However, the processing of your data until the withdrawal of consent will not affect the legality of the processing before its withdrawal

  7. The right to object to the processing of personal data based on our legitimate interest

    You have the right to object to our processing of your personal data for reasons related to your specific situation, but only to the extent that the legal basis for the processing is the necessity of the processing to: fulfill a task in the public interest or in the exercise of any public authority entrusted to us; or purposes of legitimate interests pursued by us or a third party. If you raise such an objection, we will stop processing your personal data unless we demonstrate compelling legitimate grounds for the processing that outweigh your interests, rights and freedoms, or unless the processing is for the purposes of establishing, exercising or defending legal claims.

    You always have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes if we do so). If you raise such an objection, we will stop processing your personal data for this purpose.

    You have the right to object to our processing of your personal data for the purposes of scientific or historical research or statistical purposes, if we process your personal data for these purposes, for reasons relating to your particular situation, unless the processing is necessary to fulfil a task carried out for reasons of public interest.


You can exercise your rights above with us:

  1. Via e-mail at the e-mail address: info@wibo.ai;
  2. By mail at the address: ARMSTRONG CC, s.r.o., with registered office at Martine Granca 8, 841 02, Bratislava.

You also have the right to file a complaint with the Personal Data Protection Office of the Slovak Republic, Hraničná 12, 820 07 Bratislava. You can also do so in the EU member state in which you have your usual residence, place of work or where the alleged violation of your rights is located.

When we update this privacy statement, we will publish the new version on our Wibo platform.

We will also notify you by email of any significant changes to this instruction or our other policies.

Contact

In case of questions, problems or comments, please contact us.

Operator:
ARMSTRONG CC, s.r.o.
Headquarters:
Martine Granca 8, 841 02, Bratislava

Get in touch

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