The privacy policy applies to Viblio
Privacy Notice on the Processing of Personal Data Applicable to Viblio
Last updated: 09/06/2026
Dear User,
This Privacy Notice is intended to provide you with a clear and comprehensive understanding of how your personal data are processed when you use the Viblio platform.
Depending on the type of user account assigned to you, Apprendo S.r.l. may assume different data protection roles. Specifically:
a) If you are an individual who independently registers on our platform, Apprendo is the Data Controller of your personal data and will process them for all the purposes set out in Section 3 below. You may contact the Data Controller using the contact details provided below.
b) If you are an employee or collaborator of a company that has chosen 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, you should contact the organisation to which you belong. In this case, Apprendo acts as a Data Processor on behalf of your company.
However, even in the circumstances described in point (b) above, Apprendo directly determines certain processing purposes for which it is necessary to collect and retain specific user data. Accordingly, solely for the purposes referred to in Sections 3.6, 3.7 and 3.9 below, Apprendo shall act as the Data Controller of your personal data and may be contacted using the details provided below.
Apprendo S.r.l. contact details:
Via Marinoni 12
33100 Udine, Italy
VAT No. 03029040304
Email: help@viblio.com
The following categories of personal data may be processed:
Data identified as mandatory during the registration process and within the “Book a Demo” section (such as first name and surname, email address and professional identification details);
Login credentials (email address and password);
Your role and competencies;
Your course preferences and information relating to your collections;
Information contained in the report generated on the basis of your responses to the soft skills self-assessment questionnaire.
Searches performed;
Content accessed within the platform;
Content accessed through external sources;
Content completion events;
Total learning time;
User reactions and interactions;
Competencies associated with completed content.
Information required to process payments (such as payment method details).
For this purpose, we use third-party service providers.
Any additional information that you freely provide when using our services.
Textual or voice content entered by the user during simulations;
Interaction data;
Information derived from the analysis of responses, including competency scores (on a scale from 1 to 100), indicative levels, competency gaps, strengths and recommendations for improvement.
Technical data necessary for the operation of the services, including:
Login data;
IP address;
IMEI identifier;
Operating system and device model;
Software version;
Additional technical logs.
Where you register with Viblio by connecting through your Google or LinkedIn account, we may collect your personal data directly from those third-party providers.
For information regarding data collected through cookies and similar technologies while browsing the website www.viblio.com, please refer to the Cookie Policy available on the website.
Your personal data will be collected and processed for the following purposes. The corresponding legal basis for each processing activity is indicated below.
Users who join the Viblio platform register through the dedicated online form by entering their email address and password or by connecting through their Google or LinkedIn account.
The personal data provided are processed in order to create a user account on the platform and enable access through authentication.
Legal basis: Performance of a contract.
Based on your role and the competencies selected by you, the Viblio algorithm identifies, among the content available across various digital platforms, the content deemed most appropriate to your profile, creating the learning pathway best suited to your needs and/or to the group to which you belong.
All content accessed by you will be displayed within the relevant dashboard.
Legal basis: Performance of a contract.
Viblio offers you the opportunity to complete a soft skills self-assessment test.
The test enables the evaluation of your transversal skills, including, by way of example, open-mindedness, learning orientation, intuition, creativity and efficiency.
The analysis of your responses is intended to identify your strengths and areas for development, which are described in a dedicated report made available to you.
The results are subsequently used by Viblio to generate a personalised system collection.
Legal basis: Performance of a contract.
Should you decide to use this service, the results obtained will not in any way influence the Viblio content recommendation engine, but will solely enable you to access learning content specifically selected for you.
We process your personal data in order to:
process payments;
manage your requests relating to demo bookings;
provide platform support services;
comply with legal obligations;
fulfil any reporting or communication obligations towards Public Authorities or other public bodies.
Legal basis: Performance of a contract and compliance with legal obligations.
Subject to your prior consent, we may send you our newsletter by email.
Legal basis: Freely given and optional consent, which may be withdrawn at any time.
The Viblio platform records a range of logs generated through user activity (for example, each time you access the platform or react to content).
Such processing is necessary to ensure platform security, monitor service functionality and improve the services offered.
Legal basis: Legitimate interests of the Data Controller.
Your personal data may be processed where necessary for the establishment, exercise or defence of legal claims, or in connection with activities carried out by judicial authorities within the scope of their functions.
Legal basis: Legitimate interests of the Data Controller.
Participation in interactive simulations based on professional scenarios and the automated analysis of responses provided by users in order to generate indicative feedback regarding competencies, including:
numerical scores (on a scale from 1 to 100);
descriptive competency levels;
identification of strengths and areas for improvement;
recommendations and suggested learning activities.
The processing is carried out exclusively for competency development purposes and to provide a personalised learning experience.
The analysis is performed through automated systems, including systems based on artificial intelligence models.
The service is optional and activated at the user’s initiative.
Legal basis: Performance of a contract.
With regard to the purposes referred to in Sections 3.3 and 3.9, please note that the processing of your personal data involves profiling activities within the meaning of Article 4(1)(4) of the GDPR.
Within the soft skills self-assessment questionnaire referred to in Section 3.3, your responses are processed automatically in order to identify your strengths and development areas and to generate a personalised collection of learning content.
The automated processing described in Sections 3.3 and 3.9 is necessary for the performance of the contract.
The results of the self-assessment questionnaire and the interactive simulations:
are used exclusively for training and educational purposes;
are used to provide personalised recommendations within the functionalities used by the user.
Profiling activities may also include the analysis of user interactions within interactive simulations in order to generate personalised feedback and improvement recommendations.
In all cases, you retain the right to:
challenge the outcome of automated processing;
express your point of view;
obtain human intervention from the Data Controller for the review of the outcome.
To exercise these rights, you may contact us at help@viblio.com.
The provision of the information required for the purposes set out in Sections 3.1, 3.2 and 3.4 is necessary in order to fulfil contractual and legal obligations.
Failure to provide such information will prevent the Data Controller from performing the contract, or from performing it in full, managing your requests, or properly complying with all obligations imposed by applicable legislation.
Participation in the soft skills self-assessment questionnaire referred to in Section 3.3 is optional.
Failure to provide the relevant data will not affect your ability to use our services correctly. However, should you choose to complete the questionnaire, the provision of the requested data is necessary for the processing of your profile.
In such circumstances, failure to provide some or all of the requested information may result in the application being unable to complete the assessment of your soft skills.
The provision of the information required for the purpose referred to in Section 3.5 is optional.
Failure to provide such data will not affect your use of our services in any way, but will simply prevent you from receiving the Viblio newsletter.
In any event, you may withdraw the consent previously granted at any time by sending an email to help@viblio.com or by using the unsubscribe link included in the footer of each newsletter communication.
Contractual data shall be retained for the period necessary to achieve the relevant purposes and, in any event, no longer than the retention periods required by applicable legal obligations.
Personal data relating to registration on the platform and the creation of a user profile shall be retained for the entire duration of the contractual relationship between the parties and shall be deleted one (1) year after termination of the contract.
Responses provided within the soft skills self-assessment test are processed without any direct connection to the user’s identifying data. The corresponding report is stored on the platform and made available to the user throughout the duration of the subscription (annual subscription).
Upon expiry of the subscription, and in the absence of renewal, such data shall be deleted within a reasonable period of time.
Data relating to interactive simulations and assessments (including interaction content and competency analysis results) shall be retained for the duration of the contractual relationship and deleted within twelve (12) months following its termination, unless a longer retention period is required by law.
Contact details used for sending the communications referred to in Section 3.5 shall be retained within internal mailing lists until consent is withdrawn by the data subject.
Personal data received in connection with requests for information shall be retained only for the period necessary to provide a response to such requests.
Your personal data may be processed by authorised personnel who have been appropriately instructed and operate under the authority and responsibility of the Data Controller, or by third parties providing services ancillary to the Company’s activities.
Depending on the circumstances, such third parties act as Data Processors pursuant to Article 28 of the GDPR.
In particular, your personal data may be disclosed to the following categories of recipients:
Providers of cloud infrastructure and hosting services, for the storage and processing of data necessary for the operation of the platform;
Providers of user support and technical assistance services, including ticketing systems;
Providers of customer relationship management and pre-contractual enquiry management services, including the management of the “Book a Demo” form available on the website;
Providers of marketing communication and newsletter distribution services;
Providers of website traffic analysis and statistical services, as further described in the Website Cookie Policy;
Providers of API services and artificial intelligence services required to process responses submitted within simulations and competency assessment systems;
Providers of payment processing services;
Providers of digital learning platforms whose content is made available through Viblio, to whom user identification and usage data may be disclosed to the extent necessary to enable access to and use of such content.
Such parties may act, depending on the circumstances, either as independent Data Controllers or as Data Processors.
This includes, by way of example, FUTURELEARN LIMITED, which acts as an independent Data Controller for the purpose of enabling access to the content available through its own platform.
Certain data, including system logs, may also be accessible to entities responsible for managing the IT infrastructure necessary for the operation of the online services.
Your personal data may furthermore be disclosed to law enforcement authorities, judicial authorities or other competent public authorities for the prevention, investigation and prosecution of criminal offences, or where necessary for the establishment, exercise or defence of legal claims.
A detailed list of all recipients is available from the Data Controller and will be provided upon request.
For the purposes described above, certain personal data may be transferred to countries outside the European Union (“EU”) or the European Economic Area (“EEA”) (collectively referred to as Third Countries).
In particular, your personal data may be transferred to: FUTURELEARN LIMITED
Your personal data may be transferred to FUTURELEARN LIMITED, established in the United Kingdom.
Such transfer is carried out on the basis of the adequacy decision adopted by the European Commission pursuant to Article 45 of the GDPR, recognising that the United Kingdom ensures a level of protection for personal data essentially equivalent to that guaranteed within the European Union.
Certain service providers referred to above are established in the United States of America.
Transfers of personal data to such providers are carried out on the basis of:
the European Commission adequacy decision relating to the EU–US Data Privacy Framework (DPF); or
where the relevant provider is not certified under the DPF, the Standard Contractual Clauses (SCCs) adopted by the European Commission.
Where personal data are stored on infrastructure located within the European Union but managed by service providers established outside the EU, any potential access to such data by those providers remains subject to the safeguards described above.
The European data protection legislation (the GDPR) grants you a number of rights that allow you to maintain control over your personal data.
To exercise any of the rights described below, you may contact us at help@viblio.com.
You have the right to obtain information regarding the processing of your personal data, access to such data, and a copy thereof, including by commonly used electronic means.
We undertake to provide you with a report of the personal data concerning you that we hold.
You have the right to obtain the updating, completion or rectification of your personal data.
If you believe that any of your personal data are inaccurate, incomplete or no longer up to date, please contact us and we will endeavour to correct them promptly.
Where applicable, you may request the portability of personal data processed on the basis of the performance of a contract or your consent.
You have the right to request the deletion of your personal data.
We are committed to giving you control over your personal data and, where the legal requirements are met, we will delete such data as quickly as reasonably possible.
However, please note that certain personal data may need to be retained where required to comply with legal obligations or where their continued processing remains necessary.
You have the right to request the restriction of processing or to object, in whole or in part, to the processing of your personal data, including where processing is carried out for marketing purposes.
Where you request restriction of processing, we will suspend further processing activities relating to your personal data for the period required by applicable law.
If you believe that one or more processing activities carried out by us infringe applicable data protection legislation, or that your rights have not been adequately protected, you may lodge a complaint with the competent supervisory authority in the country where you habitually reside, work, or where the alleged infringement occurred.
In Italy, complaints may be submitted to the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali).
Where consent constitutes the legal basis for the processing of personal data pursuant to Article 6(1)(a) of the GDPR, Data Subjects have the right to withdraw their consent at any time.
Withdrawal of consent shall not affect the lawfulness of any processing carried out on the basis of consent before its withdrawal.
The evolution of our services may require amendments to this Privacy Notice.
Accordingly, this Privacy Notice may be modified, updated or supplemented from time to time, including where necessary to reflect changes in applicable data protection legislation.
We therefore encourage you to review this Privacy Notice periodically in order to remain informed about how your personal data are processed.