Privacy policy refers to viblio.com web site
Dear User,
this notice will allow you to understand clearly and completely how your personal data are processed when you use the Viblio platform.
Based on the type of user assigned to you, Apprendo S.r.l. may have different privacy roles; specifically:
However, even in the case referred to in point b) above, Apprendo directly determines some purposes for which it is necessary to acquire and retain some user data. Therefore, exclusively for the purposes under points 3.6, 3.7, 3.8, and 3.9 below, Apprendo will in any case be the data controller of your data and can be contacted at the details provided below.
Contact details of Apprendo S.r.l.: 33100 Udine, via Marinoni no. 12 (VAT ID 03029040304); e-mail help@viblio.com.
The following personal data may be processed:
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 legal grounds for data processing are indicated alongside.
3.1 Registration on the platform and access. Users who join the Viblio platform register through the specific online form, entering e-mail and password or connecting through their Google or LinkedIn account. The personal data provided are processed to register the user on the platform and allow access via authentication. | Execution of the contract between the parties. |
3.2 Use of personalized services offered to registered users. Based on your role and the skills selected by you, the Viblio algorithm will select, among the contents available on various digital platforms, those deemed most appropriate to your profile, creating the most suitable learning path for your needs and/or for the group to which you belong. All contents consulted by you will be visible in the appropriate dashboard. | Execution of the contract between the parties. |
3.3 Carrying out the video interview. Viblio gives you the possibility to carry out a video interview, through which you can access the personality trait evaluation service. Our application automatically processes about 430 verbal and non-verbal parameters extracted from the audio and video files produced during the interview. Among the parameters analyzed are, for example, your speech language, body movements, responses given, response time to questions, etc. The video interview analysis process is fully automated and uses algorithms for natural language recognition. The automated process is supported by a human review system to ensure a high reliability rate.
| Execution of the contract between the parties. If you choose to use this service, the results obtained from the video interview will in no way influence the Viblio content recommender but will only allow you to access specific training content dedicated to your personality traits. |
3.4 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 skills, such as, for example, open-mindedness, learning aptitude, intuition, creativity, and efficiency. The analysis of the answers aims to identify the User’s strengths and growth points, described in a specific report delivered to them. The results are then used by Viblio to generate a personalized system collection. | Execution of the contract between the parties. If you choose to use this service, the results obtained will in no way influence the Viblio content recommender but will only allow you to access specific training content dedicated to you. |
3.5 Fulfill all obligations arising from the contract and/or legal obligations. We will process your personal data to process payments, manage your requests regarding demo booking or platform support, as well as to comply with legal obligations and to handle any communications with Public Administrations or other Public Entities. | Execution of the contract between the parties; legal obligations. |
3.6 Sending promotional communications. With your prior consent, we may send you promotional communications via e-mail regarding products, services, initiatives, or events. | Free and optional consent, revocable at any time. |
3.7 Security and service improvement. The Viblio platform records a series of logs generated by user actions (for example, every time you access the platform). | Legitimate interest of the Controller. |
3.8 For purposes necessary to ascertain, exercise or defend a right in legal proceedings or in case judicial authorities exercise their functions. | Legitimate interest of the Controller. |
3.9 Participation in surveys or market research. With your prior consent, we may use your e-mail to invite you to participate in surveys or market research. The data collected through such questionnaires will be anonymous. | Free and optional consent, revocable at any time. |
The provision of information requested for the purposes indicated in points 3.1, 3.2, and 3.5 is necessary to fulfill contractual and legal obligations. Failure to provide such information will result in the impossibility for the controller to execute the contract or to do so completely, to handle your requests, or to correctly carry out all obligations required by applicable regulations.
Carrying out the video interview referred to in point 3.3 is optional. Failure to provide such data will not affect the proper use of our services. However, if you decide to carry out the video interview, the data acquisition will be performed automatically and is necessary for the success of the personality analysis. In this case, failure to acquire some or all of the required data may result in the application’s inability to perform the personality assessment.
Filling out the self-assessment questionnaire on soft skills referred to in point 3.4 is optional. Failure to provide such data will not affect the proper use of our services. However, if you decide to complete the questionnaire, data acquisition is necessary for the processing of your profile. In this case, failure to acquire some or all of the required data may result in the application’s inability to perform the assessment of your soft skills.
Providing information requested for the purposes set out in points 3.6 and 3.9 is optional. Failure to provide such data will have no consequence on the use of our services but will only prevent you from receiving promotional and/or commercial communications from Viblio and/or participating in surveys or market research. In any case, you may revoke the previously given consent at any time by writing an email to help@viblio.com or by unsubscribing via the appropriate link placed in the footer of each communication.
Contractual data will be retained for the time necessary to achieve the related purposes and in any case no longer than the terms provided by specific legal obligations.
Data relating to registration on the platform and profile creation will be retained for the entire duration of the contractual relationship between the parties and deleted one year after contract termination.
Audio and video data related to the video interview are processed without any direct link to the user’s identifying data and are deleted from the systems analyzing the video interview within 24 hours.
The report is retained on the platform and made available to the user for the entire duration of the subscription (annually). Once the subscription expires and is not renewed, the data will be deleted within a reasonable period.
Answers to the soft skills self-assessment test are processed without any direct link to the user’s identifying data; the related report is retained on the platform for the entire duration of the subscription (annually). Once the subscription expires and is not renewed, the data will be deleted within a reasonable period.
Contact data used to send communications under points 3.6 and 3.9 will be retained in internal lists until consent is withdrawn by the data subject.
Data received as part of information requests will be retained for the time necessary to respond.
Your personal data may be processed by authorized personnel, properly instructed and operating under the authority and responsibility of the Controller, or by third parties providing instrumental services to the Company, typically acting as data processors.
These include providers of communication services, API services needed to analyze parameters obtained during the video interview and questionnaire responses, and to manage payment plans, technical services for platform management, IT service providers, and communication consulting firms.
Some data (system logs) may be accessible to entities managing the IT infrastructures necessary for the operation of online services.
Some data (personal data, contact information, platform usage, and professional title) may also be transferred to the company FUTURELEARN LIMITED, acting as an independent data controller, in order to allow you to access and use the platform and benefit from the available content.
Your data may also be communicated to law enforcement authorities or judicial authorities for the detection and prosecution of crimes and to exercise or defend a right.
A detailed list of all recipients is available at the Controller’s registered office and will be provided upon your request.
Within the purposes indicated above, 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 Article 45 of the GDPR, which recognizes the United Kingdom as providing an adequate level of personal data protection equivalent to that guaranteed in the European Union.
The 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 support@viblio.com
Right of access: you have the right to obtain information regarding the processing of your personal data, access them and obtain a copy, including by commonly used electronic means. We are committed to providing you with a report of the data we hold.
Right to rectification: you have the right to obtain the update, integration, or rectification of your data. If you believe your data are in any way incorrect or outdated, please contact us – we will do our best to resolve the issue.
Right to portability: if you wish, you can request the portability of your data processed on the basis of the contract or your consent.
Right to erasure: if you so wish, you have the right to request the erasure of your data. We are committed to giving you control over your data. In some cases, you can request direct deletion, and we will proceed as soon as possible. However, please note that not all data can be deleted upon request, as they may be necessary to fulfill legal obligations or still in use.
Right to restriction 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 processing restriction, we are obliged to suspend, for a specified period, any further processing of your data.
If you believe that one or more of the processing activities carried out by us may be in violation of the law or that your rights have not been protected, you can file a complaint with the Supervisory Authority of the place where you normally reside, work, or where the alleged violation occurred. In Italy, you can contact the Data Protection Authority.
In cases where consent constitutes the legal basis for the processing of personal data (Art. 6, para. 1, letter a), data subjects have the right to withdraw their consent at any time without affecting the lawfulness of the processing based on the consent given before the withdrawal. In any case, what is expressly stated and accepted by each data subject within the waiver forms completed shall remain valid.
The evolution of our services may result in changes to this privacy notice, which may undergo modifications and additions over time, which may also be necessary with respect to new regulatory interventions concerning personal data protection.
Therefore, we invite you to periodically check its contents.
Last update: 27/05/2025