Data Treatment Policy

Research on Developmental Progression of Handwriting Skills

 

1. Research Purpose

We analyse handwriting skills as well as executive functions in students living in countries with different education systems to find universal predictors of handwriting capabilities

Participation in the research is voluntary.

This document serves to give you all the information you need to adhere in a conscious way.

If you wish to withdraw your consent and stop participating, you can do so at any time.

 

1.1 Who may enrol?

Any parent with children, from 5 to 15 years old, attending primary or middle school.

 

1.2 What do you need to partecipate?

You need an Apple iPad with pencil and Oppimi Data App.

 

1.3 What happens to those who participate?

Your child will be asked to perform a sequence of simple exercises and games on a tablet with a digital pen. 

Before each exercise or game, a short tutorial will be displayed. In this way your child will be able to play autonomously without the help of an adult.

 

1.4 Expected Benefits

The objective of the study is to find universal predictors of handwriting capabilities. As a secondary objective we will try to identify exercises and algorithms that are best suited for monitoring and improving handwriting skills.

We cannot and do not guarantee or promise that you or your child will receive any benefits from this study.

 

1.5 Possible risks or discomforts

There are no risks in participating in the research. If some exercises prove to be too demanding, child can abstain from their execution.

 

 

2 Information Collected by the App 

There are two ways information can be submitted to us. The first is through direct submission or what we call ‘Manual Submission’ and the second is by way of ‘Automatic Submission’ triggered by any interaction with the App, through the tablet PC.

 

2.1 Personal Information

Personal information is information about you or your child through which you or your child can be identified (including where you can be identified by combining the information with other information).

 

2.2 Parent Information (Manual Submission)

During the registration process we ask to enter personal information. These include name, age, email address, mailing address, telephone number(s), spoken language and other contact and billing information.

 

2.2.1 Purpose

The purpose of this kind of information is:

  • unambiguously identifying the registering adult as a person of age and parent of the child that is going to play with the app;
  • getting free and voluntary consent to the processing of personal data relating to her/him and to her/his child;
  • authorizing the use the app;
  • providing reports;
  • offering and providing Oppimi Services
  • contacting customers to discuss their experience with the Services, current and future needs as a customer, or to communicate future promotions or special events which might benefit them
  • contacting a prospective customer
  • operating, maintaining, managing and administering the Services, including processing registrations and payments, and diagnosing technical problems
  • responding to questions and communications

 

2.2.2 Retention Period

Parent personal information will be retained until the parent expresses the will to be forgotten.

 

2.3 Child Information (Manual Submission)

After registration we ask the parent to enter personal information of her/his child. These include name, age, gender, handedness, spoken and school language, attended school, school grade.

 

2.3.1 Data concerning health

We happen to ask the parent to voluntarily enter information concerning the health of her/his child. In particular we ask:

  • Height
  • Weight
  • Visual impairments (i.e. use of glasses)
  • Diagnosed disorders

 

2.3.2 Purpose

The purpose of this information is to provide a “ground truthing” to the statistical analysis that will be performed on data collected with exercises and games.

The collection of “ground truth” data enables calibration of remotely collected data, and aids in the interpretation and analysis of what is being collected.

 

2.3.3 Retention Period

Child personal information will be retained until the parent expresses the will to erase those data.

If the parent expresses the will to erase her/his child information, Oppimi will de-identify collected data and permanently keep anonymous information, including sensitive and health information, in order to pursue the purpose of the research.

 

2.4 Exercises and games data (Automatic Submission)

Whenever the child interacts with the App, we gather data from the device and the App transmits a ‘request’ to us. That request includes non-personal information that is necessary to identify and route the information your device is requesting.

Additionally, we gather data of the handwritten interaction (the “Stroke”) child makes with the App (the “Raw Data”). This Raw Data can include:

  • Date and Time Stamp of the Stroke collected
  • Coordinates of the Stroke made on screen
  • Pressure used while making the Stroke
  • Pen movement on screen while the Stroke is collected

 

2.4.1 Purpose

Data collected through handwriting exercises and games is the core of our research, which is aimed to find universal predictors of handwriting capabilities.

 

2.4.2 Retention Period

Exercise and games data will be retained until the parent expresses the will to erase those data.

If the parent expresses the will to erase her/his child information, Oppimi will de-identify collected data and permanently keep anonymous information, including sensitive and health information, in order to pursue the purpose of the research.

 

2.5 Other Automatically Collected data (Automatic Submission)

Data collected using the App can include:

  • Date and time
  • Model of the device
  • Type and version of the operating software running on the device
  • IP address
  • Geographic location
  • Time zone
  • Internet service provider

 

2.5.1 Purpose

The purpose of these information is:

  • to perform audits, research, measurements and analyses in an effort to maintain, administer, support, enhance and protect the Services, including determining usage trends and patterns and measuring the effectiveness of content, advertising, features or services
  • to create new features, products or services
  • to provide benchmarking and performance tracking solutions
  • to analyse market.

 

2.5.2 Retention Period

  • Parent personal information will be retained until the parent expresses the will to be forgotten.

 

3 Data Treatment

Oppimi devotes itself with passion to the education of children with learning difficulties. We believe that learning and personal development can best be achieved in a fun and safe atmosphere. Therefore, the trust in our privacy practices is essential to our success.

All data Oppimi collects will be used only within the above-mentioned purposes.

Data used for the Research Purpose, that is finding universal predictors of handwriting capabilities, will be de-identified and 

 and will be accessible only by professionals selected by the Research Participating Body, and only for the purposes above mentioned.

We implement technical and organizational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing. For more information on the appropriate safeguards in place, please contact us at the email address below.

 

3.1 Data De-Identification or Anonymization

Oppimi will process data meant to be used for the purpose of the Research, including sensitive and health data, in such a manner that these data can no longer be attributed to a specific child or parent, without the use of additional information.

We keep that additional information separately and subject to technical and organisational measures to ensure that the de-identified data cannot be attributed to an identified or identifiable natural person.

 

4 Controller

The legal person who determines the purposes and means of the processing of personal data is:

Oppimi Group
900-1000 de la Gauchetière Montréal, Québec, Canada, H3B 5H4 

[email protected] 

 

5 Data Protection Officer

Our appointed Data Protection Officer is Mr Marco Bonin, and is making sure all policies are up to date of the legislations and regulations.

 

6 Recipients

Oppimi reserves the right to use de-identified data, including sensitive and health information, within the above mentioned purposes and to anonymously disclose them, in its sole discretion, to third parties, such as, but not limited to partners, sponsors, universities, research centres and industry specialists.

If you have accepted Oppimi marketing program, your personal information may be shared with third parties within the marketing program purposes.

 

7 Transfer of personal data to a third country or international organisation

Your personal information may be shared with organizations outside your country and will be treated in compliance with applicable data protection laws, only within the purpose of the Research.

 

8 Your Rights

8.1 Right to access

Whenever you want you can have access to your data by logging into our App, unless you already have expressed your will to be forgotten and your data erased.

 

8.2 Right to rectification

To request corrections to your Personal Information when they are inaccurate, please send an email to the Controller’s mailbox.

 

8.3 Right to erasure (‘right to be forgotten’)

You have the right to request the erasure of your Personal Information or your child’s if you are no longer participating in the study. 

However, there are limits on your ability to request deletion of your Personal Information such as if deletion would seriously impair the integrity or the efficacy of the study or if your Personal Information is needed to comply with legal requirements.

Child Information and Exercises and Games Data will be de-identified and stored permanently, while other child personal information will be erased for good.

Your withdrawal has no effect on the lawfulness of the data processing that occurred prior to your withdrawal.

 

8.4 Right to restriction of processing

You can ask to restrict processing of data collected, keeping in mind that limiting the use of data collected for the purpose of the research is equivalent to a withdrawal of your consent.

If you withdraw from the study, no new information or samples will be collected about your child or from you by the App. 

Your withdrawal has no effect on the lawfulness of the data processing that occurred prior to your withdrawal.

After your withdrawal, your data and personal information may still be maintained to maintain the integrity of the study, to satisfy any legal or regulatory requirements including reporting and retention requirements, and/or for any other purposes permitted under applicable data protection and privacy laws.  Your Personal Information also may be anonymized so that the information does not identify you personally, and such anonymized information may be used for further research.

 

8.5 Right to data portability

To receive personal data concerning yourself or your child, please send an email to the Controller’s mailbox.

 

8.6 Right to object

To object to processing of your Personal Information, please send an email to the Controller’s mailbox.

This action is equivalent to a withdrawal of your consent.

No new information or samples will be collected about your child or from you by the App. 

Your withdrawal has no effect on the lawfulness of the data processing that occurred prior to your withdrawal.

 

8.7 Right to lodge a Complaint

You have the right to file a complaint with a data protection authority such as those listed on the following page.

 

8.7.1 Canada

https://www.priv.gc.ca/en/contact-the-opc

 

8.7.2 Europe

http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm

 

9 Provision of Data

The provision of data for the purposes mentioned above is compulsory and any refusal of authorisation makes it impossible to participate in the Research.