Spinaker (“we” “us”, or “our”) respects your privacy and is committed to protecting your personal data. Spinaker uses the Moodle learning platform as part of its teaching provision for students and for staff training activities. Moodle is an open source project, for more about Moodle please see: https://docs.moodle.org/34/en/About_Moodle. The Moodle instance used by Spinaker is maintained and managed by Spinaker in Slovenia on shared web servers. Please read this Privacy Notice carefully – it describes why and how we collect and use personal data and provides information about your rights. It applies to personal data provided to us, both by individuals themselves or by third parties. We keep this Privacy Notice under regular review. It was last updated on 22nd November 2019.

Personal data that we keep about you:

As part of its operation, Moodle logs user activity. We will gather the following data via these logs:
· User ID
· Username
· User Email
· User First and Last name
· User City and country
· Other users' non mandatory information
· Moodle Course ID
· Time stamp of activity
· Action type
· Moodle object the action was on e.g. Quiz.
From these logs Moodle generates a number of reports that are accessible to the administrators on each Moodle course. Moodle reports enable course administrators to monitor activity in the course and to see what resources in the course are or are not being accessed. These may be used by course teams to support your teaching and learning.

Who we share your data with:

We do not share any data but data may be accessible by our web hosting provider.

For guests (unregistered):

Guests will be automatically enrolled onto Moodle courses when they enter them. Guests are not able to take a quiz or to access the simulators. If they wish to do so, they should self-register and become students.

For students (registered):

Students will be automatically enrolled onto Moodle courses when they enter them. Quiz results will be stored in the Moodle database along with the user activity logs. Simulators are available to students only upon payment (Paypal).

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have established procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. At the end of each academic year a snapshot is taken and the data is stored and made available to Moodle users in a read-only format. Each Moodle snapshot is retained for 5 years from the date of capture. After this time period, the files are then destroyed.

Your rights

Under certain circumstances, you may have the following rights under data protection laws in relation to your personal data: • Right to request access to your personal data; • Right to request correction of your personal data; • Right to request erasure of your personal data; • Right to object to processing of your personal data; • Right to request restriction of the processing your personal data; • Right to request the transfer of your personal data; and • Right to withdraw consent. If you wish to exercise any of these rights, please contact us using the details set out below.

Contacting us

You can contact Spinaker by writing to: Spinaker d.o.o., Sončna pot 8, 6320 Portorož Slovenija
or admin@egmdss.com

Complaints

If you wish to complain about our use of personal data, please send an email with the details of your complaint to admin@egmdss.com so that we can look into the issue and respond to you. You also have the right to lodge a complaint with the Information Commissioner's Office (the Slovenian data protection regulator). For further information on your rights and how to complain to the Information Commissioner, please refer to the ICO website at https://ip-rs.si/en.