The privacy policy applies to Viblio
Last update: 11/12/2025
Dear User,
this information notice will allow you to understand clearly and completely how your personal data is processed when you use the Viblio platform.
Based on the type of user assigned to you, Apprendo S.r.l. may play different privacy roles; specifically:
If you are an individual who registers on our platform autonomously, Apprendo is the Data Controller of your personal data and will process it for all the purposes listed in point 3. You can contact the Data Controller using the contact details provided below.
If you are an employee or collaborator of a company that has decided to adopt Viblio, the Data Controller of your personal data is Your company. Therefore, to obtain all information relating to the processing of your personal data and to exercise your rights, we invite you to contact the organization you belong to. In this case, Apprendo is a Data Processor.
However, even in the scenario under preceding point 2), Apprendo directly determines certain purposes for which it is necessary to acquire and store some user data. Therefore, exclusively for the purposes set out in points 3.6, 3.7, and 3.8 below, Apprendo will still be the Data Controller of your data, contactable at the details indicated below.
Apprendo S.r.l. contact details: 33100 Udine, via Marinoni n. 12 (P.I. 03029040304); email help@viblio.com.
The following personal data may be subject to processing:
Data necessary to provide you with our services:
Those marked as mandatory during the registration process and in the “Book a demo” section (such as first name and last name, e-mail, professional identification);
Login credentials (e-mail and password);
Role held and competencies;
The information you provide us when you decide to carry out the video interview, such as: alphanumeric user-id, image and voice, gender, personal and contact data, as well as the information you communicate to us during the interview.
Information relating to your personality, as resulting from the video interview;
Your course preferences and information relating to your collections;
Information contained in the report generated based on your answers to the self-assessment questionnaire of soft skills.
Data relating to the use of the service and interaction data: searches carried out, content opened on the platform, content opened externally, completion events, total learning time, user reactions, competencies associated with completed content.
Information necessary for payment processing (such as payment method). For this purpose, we use third-party services.
Additional information you freely provide to us when you use our services.
Technical data collected automatically necessary for the functioning of the services (login data, IP address, IMEI identifier, operating system and device model, software version, and additional technical logs).
If you register on Viblio by connecting through your Google or LinkedIn account, we may collect your personal data directly from these third parties.
The data will be acquired and processed to achieve the following purposes. The conditions for the lawfulness of data processing are indicated alongside.
| Purpose of Processing | Legal Basis |
| Registration on the platform and access. Users who join the Viblio platform register via the specific online form, entering an e-mail and password or connecting through their Google or LinkedIn account. The personal data provided is processed to register the user on the platform and allow access through authentication. | Performance of the contract between the parties. |
| Use of the personalized services offered to registered users. Based on your role and the competencies selected by you, the Viblio algorithm will select, from the content available on different digital platforms, those considered most appropriate for your profile, creating the learning path best suited to your needs and/or the group you belong to. All content you consult will be visible in the dedicated dashboard. | Performance of the contract between the parties. |
| Carrying out the video interview. Viblio gives you the opportunity to carry out a video interview, through which you can access the personality traits assessment service. Our application automatically processes approximately 430 verbal and non-verbal parameters extracted from the audio and video files produced during the interview. The parameters analyzed include, for example, the language used in the speech, body movements, answers provided, response time to questions, etc. The analysis process of the video interview is completely automated and uses algorithms for natural language recognition. The automated process is supported by a human review system to ensure a high reliability rate. The analysis aims to create a detailed user personality profile, through 5 main personality traits: Agreeableness; Conscientiousness; Extraversion; Emotional Stability; Openness to Change. Once the analysis process is complete, this information is described in a report delivered to the user. The outcome of this analysis and the percentile positioning of the personality traits will allow our algorithm to create a specific playlist of personalized content based on your personality traits. | Performance of the contract between the parties. If you decide to use this service, the results obtained from the video interview will not in any way influence the Viblio content suggester but will exclusively allow you to access specific training content dedicated to your personality traits. |
| Carrying out the self-assessment test on soft skills. Viblio gives you the opportunity to take a self-assessment test on your soft skills. The test allows you to evaluate your transversal competencies, such as, for example, open-mindedness, propensity to learn, intuition, creativity, and efficiency. The analysis of the answers aims to identify the User’s strengths and areas for growth, described in a specific report delivered to them. The results are then used by Viblio to generate a personalized system collection. | Performance of the contract between the parties. If you decide to use this service, the results obtained will not in any way influence the Viblio content suggester but will exclusively allow you to access specific training content dedicated to you. |
| Fulfilling all obligations arising from the contract and/or legal obligations. We will process your personal data in order to process payments, manage your requests relating to booking a demo or platform support, as well as to comply with legal obligations and to provide for any communications to Public Administrations or other Public Bodies. | Performance of the contract between the parties; legal obligations. |
| Newsletter subscription. Subject to your consent, we may send you our newsletter via email. | Free and optional consent, revocable at any time. |
| Security and service improvement. The Viblio platform records a series of logs generated by user actions (for example, every time you access the platform or click “like” on content). | Legitimate interest of the Controller. |
| For purposes necessary to ascertain, exercise or defend a right in court or related to cases where judicial authorities exercise their functions. | Legitimate interest of the Controller. |
The provision of the requested information for the purposes indicated in points 3.1, 3.2, and 3.5 is necessary to fulfil contractual and legal obligations. The failure to provide this information will make it impossible for the Controller to execute the contract or to do so completely, to manage your requests, or to correctly carry out all the obligations provided for by current regulations.
Carrying out the video interview referred to in point 3.3 is optional. Failure to provide this data will not produce any effect regarding the correct use of our services. However, should you decide to carry out the video interview, the data acquisition will be performed automatically and is necessary for the successful outcome of the personality analysis. In this case, failure to acquire some or all of the requested data may result in the application failing to successfully complete the personality assessment.
Carrying out the self-assessment questionnaire on soft skills referred to in point 3.4 is optional. Failure to provide this data will not produce any effect regarding the correct use of our services. However, should you decide to complete the questionnaire, the acquisition of data is necessary for the processing of your profile. In this case, failure to acquire some or all of the requested data may result in the application failing to successfully complete the assessment of your soft skills.
The provision of the requested information for the purpose referred to in point 3.6 is optional. Failure to provide this data will have no consequence on the use of our services, but will only prevent you from receiving the Viblio newsletter. In any case, you have the possibility to revoke the consent previously given at any time by writing an email to help@viblio.com or by unsubscribing via the dedicated link located in the footer of every communication.
Contractual data will be retained for the period of time necessary to pursue the related purposes and in any case no later than the terms established by specific legal obligations.
Data relating to platform registration and profile creation will be retained for the entire duration of the contractual relationship between the parties and deleted 1 year after the termination of the contract.
Audio and video data relating to the video interview are processed without any direct connection to the user’s identification data and are deleted from the systems that analyze the video interview every week. The report is stored on the platform, available to the user, for the entire duration of the subscription (annual). Once the subscription expires and in the absence of renewal, the data will be deleted within a reasonable period.
The answers relating to the self-assessment test on soft skills are processed without any direct connection to the user’s identification data; while the related report is stored on the platform, available to the user, for the entire duration of the subscription (annual). Once the subscription expires and in the absence of renewal, the data will be deleted within a reasonable period.
The contact data used to send you the communications referred to in point 3.6 will be kept in the internal lists until the interested party revokes consent.
The data received within the context of information requests will instead be kept for the time necessary to respond.
Your personal data may be processed by authorized personnel, appropriately instructed and operating under the authority and responsibility of the Controller, or by third parties who provide instrumental services to the Company, typically acting as Data Processors, such as communication service managers, suppliers of the API services necessary to analyze the parameters acquired during the video interview, the answers provided in the questionnaire and to manage payment plans, technical services for platform management, IT service providers and communication consulting companies.
Some data (system logs) may be accessible to those who manage the IT infrastructures necessary for the functioning of the online services.
Some data (personal details, contact details, platform usage data, and professional title) may also be transferred to the company FUTURELEARN LIMITED, which acts as an independent Data Controller, in order to allow you to access and use the platform and to use the available content.
Your data could also be communicated to the police forces or the judicial authority for the ascertainment and prosecution of crimes as well as to exercise or defend a right.
The detailed list of all recipients is available at the Data Controller’s headquarters and will be provided upon your request.
Within the scope of the aforementioned purposes, some of your personal data may be transferred to countries not belonging to the European Union or the European Economic Area (“Third Countries”). In particular, your data may be transferred to the company FUTURELEARN LIMITED, based in the United Kingdom. The transfer of data to the United Kingdom takes place in compliance with current legislation, based on the adequacy decision adopted by the European Commission pursuant to Art. 45 of the GDPR, which recognizes that the United Kingdom ensures an adequate level of personal data protection to that guaranteed in the European Union.
European data protection law (“GDPR”) provides a series of rights that you can exercise to have control over your data. To exercise your rights, you can write to help@viblio.com.
Right of access: you have the right to obtain information regarding the processing of personal data concerning you, to obtain access to it, and a copy also via common electronic means. We undertake to provide you with an account of the data we hold.
Right to rectification: you have the right to obtain the updating, integration, or rectification of your data. If you believe your data is incorrect or outdated in any way, please contact us – we will do our best to resolve the matter.
Right to data portability: if you wish, you can request the portability of your data processed by reason of the performance of the contract or based on your consent.
Right to erasure (right to be forgotten): if you are interested, you have the right to request the erasure of your data. We want to give you control over your data. In some cases you can ask us for direct erasure, and we will take care to proceed as quickly as possible. However, we inform you that not all data can be erased upon request, because it may be necessary to fulfil legal obligations or because it is still in use.
Right to restriction of processing and objection: You have the right to request the restriction of processing or to object, in whole or in part, to the processing of personal data concerning you, including for marketing purposes. When you request the restriction of processing, we are obliged to suspend, for1 a determined period, any further processing activity of your data.
If you believe that one or more processing activities carried out by us may be in violation of the regulations, or you believe that your rights have not been protected, you can send a complaint to the Supervisory Authority of the place where you habitually reside, work, or where the alleged violation occurred. In Italy, you can contact the Italian Data Protection Authority (Garante Privacy).
In cases where consent constitutes the legal basis for the processing of personal data (Art. 6, paragraph 1, letter a), Data Subjects have the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
The evolution of our services may lead to changes to this information notice, which may undergo modifications and additions over time, which may also be necessary in reference to new legislative measures regarding the protection of personal data.
We therefore invite you to periodically check its contents.