Privacy policy

Privacy policy refers to viblio.com web site

Privacy Policy pursuant to Articles 13-14 of EU Regulation 2016/679 (GDPR)

Dear User,

This notice will allow you to clearly and comprehensively understand how your personal data is processed when you use the Viblio platform.

Please be informed that the Viblio platform involves the creation of different types of users with varying privileges, depending on the selected plan. Specifically:

  • If you are an individual who registers on our platform independently (as a “Supervisor” account), Apprendo is the data controller of your personal data and will process it for all purposes outlined in point 3. You can contact the data controller at the contact details provided below.

  • If you are an employee or a collaborator of a company that has decided to adopt Viblio (as a “Manager” or “Member” account), the data controller of your personal data is your company. Therefore, to obtain all the information regarding 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 acts as a data processor.

1. Data Controller

The data controller is the company APPRENDO S.r.l. with registered office in 33100 Udine, via Marinoni n. 12 (VAT number 03029040304). The Data Controller can be contacted at the following email address: help@viblio.com.

2. What personal data do we collect and process?

The following personal data may be subject to processing:

  • Data necessary to provide our services:
    • those marked as mandatory in the registration process and in the “Book a demo” section (such as name, surname, email, professional identification);
    • login credentials (email and password);
    • role and skills;
    • information regarding the service used (such as selected training courses);
    • information provided when you decide to conduct the video interview, such as: alphanumeric user-id, image and voice, gender, personal data, and contact information as well as the information communicated during the interview.
    • information regarding your personality, as resulting from the video interview;
    • Your preferences regarding courses and information about your collections;
  • Information necessary for payment processing (such as payment method). To this end, we use third-party services.
  • Additional information provided by you freely when using our services.
  • Automatically collected data necessary for the operation of our services: we collect information automatically for the operation of our service, such as login data, IP address, IMEI identifier, operating system, device model, and software in use.

In case you register on Viblio by connecting through your Google or LinkedIn account, we may collect your personal data directly from these third parties.

3. Purposes of the processing and legal basis

The data will be collected and processed to achieve the following purposes. The lawfulness conditions of the data processing are indicated as the last piece of information.

3.1 Registration on the platform and access

Users who join the Viblio platform proceed to register through the specific online form, entering email and password or by connecting through their Google or LinkedIn account. The personal data provided are processed to register the user on the platform and allow access through authentication.
Legal basis for processing: performance of the contract between the parties.

3.2 Use of personalized services offered to registered users

Based on your role and selected skills, the Viblio algorithm will select, among the available content on various digital platforms, those deemed most appropriate to your profile, creating the most suitable learning path for your needs and/or the group you belong to. All content consulted by you will be visible in the appropriate dashboard.
Legal basis for processing: performance of the contract between the parties.

3.4 Conducting the video interview

Viblio gives you the opportunity to conduct 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. Among the analyzed parameters are, for example, your language used in speech, body movements, responses provided, 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 level of reliability.

The analysis aims to create a detailed profile of the user’s personality, through 5 main personality traits:

  • Friendliness;
  • Conscientiousness;
  • Extraversion;
  • Emotional stability;
  • Propensity to change.

Once the analysis process is completed, this information is described in a report that is delivered to the user. The outcome of this analysis and the percentile positioning of personality traits will allow our algorithm to create a specific playlist of personalized content based on your personality traits.
Legal basis for processing: 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 recommender but will only allow you to access specific educational content dedicated to your personality traits.

3.5 Fulfillment of all obligations arising from the contract and/or legal obligations

We will process your personal data in order to process payments, manage your requests related to booking a demo or platform support, as well as to comply with legal obligations and to provide any communications to Public Administrations or other Public Entities.
Legal basis for processing: performance of the contract between the parties; legal obligations.

3.6 Newsletter subscription

To stay updated on Viblio news, you can subscribe to our newsletter.
Legal basis for processing: 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).
Legal basis for processing: legitimate interest of the Data Controller.

3.8 Assertion, exercise, or defense of a right in court

For purposes necessary to assert, exercise, or defend a right in court or related to cases where judicial authorities perform their functions.
Legal basis for processing: legitimate interest of the Data Controller.

Data provision and consequences of any refusal

The provision of the information required for the purposes indicated in points 3.1, 3.2, and 3.4 is necessary to fulfill contractual and legal obligations. Failure to provide such information will result in the impossibility for the Data Controller to execute the contract or to do so completely, to manage your requests, or to properly carry out all the obligations provided for by current regulations.

Conducting the video interview referred to in point 3.3 is optional. Failure to provide this data will have no effect on the correct use of our services. However, if you decide to conduct the video interview, the acquisition of data will be automatically performed and is necessary for the successful completion of the personality analysis. In this case, failure to acquire some or all of the requested data may result in the failure of the personality assessment by the application.

The provision of information required for the purpose referred to in point 3.5 is optional. Failure to provide such data will have no consequences on the use of our services, but it will only prevent you from staying updated on Viblio news. In any case, you have the possibility to revoke the previously given consent at any time by writing an email to help@viblio.com or by unsubscribing through the appropriate link located in the footer of each communication.

Retention periods

Contractual data will be retained for the period necessary to pursue the respective purposes and in any case no later than the terms provided by specific legal obligations.

Data relating to registration on the platform and profile creation will be kept for the entire duration of the contractual relationship between the parties and deleted after 1 year from the termination of the contract.

The audio and video data related to the video interview are processed without any direct connection to the user’s identifying data and are deleted from the systems that analyze the video interview within 24 hours.

The report is stored on the platform available to the user for the entire duration of the subscription (annually). Once the subscription expires and in the absence of renewal, the data will be deleted within a reasonable period.

Data received as part of information requests will instead be kept for the time necessary to provide feedback.


Your personal data may be processed by authorized personnel, suitably instructed and operating under the authority and responsibility of the Data Controller, or by third parties providing services instrumental to the Company, typically acting as data processors, such as communication service managers, providers of API services necessary to analyze the parameters acquired during the video interview and manage payment plans, technical services for platform management, IT service providers, and communication consulting companies.

Some data (system logs) may also be accessible to subjects managing the IT infrastructure necessary for the operation of online services.

Your data may also be communicated to the police forces or the judicial authority to ascertain and prosecute 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 request.

Your rights

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 help@viblio.com.

Right of access: you have the right to obtain information about the processing of personal data concerning you, obtain access to it and a copy also by electronic means of common use. We are committed to providing you with a report of the data we have in our possession.

Right to rectification: you have the right to obtain the updating, integration, or rectification of your data. If you believe that your data are in any way incorrect or outdated, please contact us – we will do our best to resolve the issue.

Right to data portability: if you wish, you can request the portability of your data processed based on the performance of the contract or on the basis of your consent.

Right to erasure: if you are interested, you have the right to request the erasure of your data. We are committed to giving you control of your data. In some cases, you can ask us for direct deletion, and we will proceed as soon as possible. However, please note that not all data can be deleted upon request because they may be necessary to comply with legal obligations or because they are 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 the restriction of processing, we are required to suspend, for a certain period, any further processing activities of your data.

If you believe that one or more processing activities carried out by us may be in violation of the regulations, or if you believe that your rights have not been protected, you can submit a complaint to the Supervisory Authority of the place where you normally reside, work, or where the alleged violation occurred. In Italy, you can contact the Guarantor Authority for Privacy.


The evolution of our services may entail changes to this privacy policy, which may be modified and supplemented over time, which may also be necessary in reference to new regulatory interventions concerning the protection of personal data.

Therefore, we invite you to periodically check its contents.

Last updated: 03/04/2024