1. General


Thank you for using Wand.Education! Your privacy is important to us and we’re committed to protecting, respecting and being accountable for your privacy. We hereby present the principles for processing your personal data and the measures used by Wand.Education to protect your data.


Our Privacy Policy will help you to understand what information we collect at Wand, how Wand uses it and what choices you have. Specifically, this Policy provides information on the use, collection, disclosure to third parties by SIVECO Romania S.A., a Romanian legal entity with office in Bucuresti-Ploiesti Drive 73-81, District 1, Victoria Park Complex, C4 Wing, Bucharest, Romania, registered with the Trade Register Office under no. J40/14658/1992 (hereinafter “SIVECO”) of personal information in relation to the Wand.Education platform it provides. Furthermore, this policy explains how we keep personal information secure.


We may change this policy from time to time. This is so that measures put in place at the time the means of the processing is determined can be updated and adopted during the lifecycle of the data. Please check this page occasionally to ensure you’re happy with any changes. Any questions regarding this policy and our privacy practices should be sent to us by email at office@siveco.ro.


This Privacy Policy should be read in conjunction with the Terms and Conditions available here: Link to the Terms and Conditions.


2. What is Wand?


WAND.Education [1] is an interactive platform offered by SIVECO. The platform is designed to deliver digital interactive lessons to a wide community of schools, colleges, other educational providers, teachers and other school staff. We hope that Wand will make teaching and learning efficient and fun, while being a safe platform that protects its legitimate Users.


Through the use of Wand, the website at the https://wand.education website (the “Site”), the packages of lessons available at or through the Site and all associated services (the "Services"), and any other materials made available on the Site (the "Materials"), all of the above collectively referred to as the Wand Platform (“Wand Platform”), you provide and/or SIVECO collects personal data which it processed either as data processor or data controller and as described in the present Privacy Policy and the Terms.


The Wand Platform is available only to educational establishments, colleges and schools (each a “Subscriber”) and their designated teachers, relevant staff and students (the “Users”) during the 2 weeks trial period or during the subscription period provided that the Subscriber has acquired a subscription according to the Terms (“Subscription”) by concluding an agreement (“End User Subscription Agreement”) with SIVECO or its distributors (hereinafter together as “Partner”).


If you do not qualify as either a Subscriber or a User, you should not be using the Wand Platform. SIVECO may refuse to offer the Wand Platform to any person or legal entity at any time and may change its eligibility criteria, at any time, in its sole discretion, without breaching its’ obligations for the Subscriptions already concluded.


3. What type of information does Wand collect?


When beginning the trial period, the Subscriber is required to provide SIVECO the following personal data:


  1. full name of the representative of the Subscriber
  2. Subscriber name
  3. valid email address
  4. password for the account.

When concluding the End User Subscription Agreement, the Subscriber is required to provide Partner with the necessary information. Such information may contain full name of the Subscriber representative for Wand.education, Subscriber name, Subscriber address, VAT code or other fiscal identification number, country of fiscal residency, a valid email address and password.

4. Are there any personal data related obligations for Subscribers?

The Subscriber shall provide accurate and complete information. Failure to do so shall constitute a breach of the Terms, the End User Subscription Agreement and the Privacy Policy, which may result in immediate termination of the Subscriber’s Subscription or the trial period. In addition, the Subscriber shall maintain its registration information up to date to ensure that it is accurate and complete at all times.


When designating teachers and students and creating their User accounts, the Subscriber will provide SIVECO with the necessary information, including personal data of the Users. Such information may contain name, email address and password for each User account.


For the purpose of constantly improving and personalizing your Wand experience, SIVECO may also collect information about how Subscribers (directly or through their Users) use our Wand Platform, such as: types of content they view, the frequency and duration of the activities or the average number of lessons per teacher.


In order for schools and teachers to be able to monitor students’ progress, the Site will record information regarding time spent on the assignments, grades, answers, projects and other relevant data, which will be displayed only in the teacher's reports area.


Also, we ask you not to send us or disclose, any sensitive personal data (e.g. social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics) on or through the Wand Platform or otherwise.


5. How does Wand collect the information?


Teacher Accounts

Wand collects information from Subscribers when designating those teachers who are enrolled with the Subscriber and who will be allowed by the Subscriber to use the Wand Platform under a Teacher Account. In order to create the Teacher Accounts, the Subscriber or the teacher will provide name, e-mail address and password for each account.


Prior to designating teachers, registering the Teacher Accounts and providing SIVECO with personal data of these teachers, the Subscriber shall make sure that it has:


  1. adequately informed its teachers and other staff about the processing required to be performed upon their personal data in order that the Subscriber or educational establishment, the teachers and ultimately the students enjoy the full use and benefits of the Wand Platform;
  2. adequately assured SIVECO that SIVECO can lawfully process the personal data of the teachers and other staff as data processor for the Subscriber; and,
  3. assessed and confirmed that there is a lawful basis for all the processing required to utilise the Wand Platform. In so doing the Subscriber will in particular ensure that:

    1. any legitimate interest meets the three-part requirements under the GDPR (more particularly set out at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/legitimate-interests; and,
    2. Any consent given meets the requirements under the GDPR
    and that any lawful basis for processing is undertaken on the bases set out in this or any other successor or related Privacy Policy.


Each teacher, User of a Teacher Account, can designate students to study groups on the Wand Platform.


Student Accounts (and all other Users)

Wand also collects information from Subscribers (directly or through its designated teachers) when designating those students (and other Users of the Wand Platform) who are enrolled with the Subscriber and who will be allowed to use the Wand Platform under a Student Account. In order to create the Student Accounts, the Subscriber or the designated teacher will provide the name and password for the students who do not have an e-mail account. For those students who have an e-mail address, the Subscriber or teacher will provide the name and e-mail address and the student will set their password.


The Subscriber shall ensure that:


  1. It has adequately informed its students (and all other Users) about the processing required to be performed upon their personal data in order that the Subscriber, the teachers and ultimately the students enjoy the full use and benefits of the Wand Platform;
  2. It has adequately assured SIVECO that SIVECO can lawfully process the personal data of the students and all other Users as data processor for the Subscriber;
  3. assessed and confirmed that there is a lawful basis for all the processing required to utilise the Wand Platform. In so doing the Subscriber will in particular ensure that:

    1. any legitimate interest meets the three-part requirements under the GDPR (more particularly set out at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/legitimate-interests; and,
    2. Any consent given meets the requirements under the GDPR
    and that any lawful basis for processing is undertaken on the bases set out in this or any other successor or related Privacy Policy.


Access to the Wand Platform is provided to the Subscribers. Users are the ultimate beneficiaries of the Subscription purchased by the Subscriber. Therefore, any personal data of these other Users or any personal data which are communicated by the Users will be processed by SIVECO as a data processor on behalf of the Subscriber who will at all times be a data controller.


The Subscriber acknowledges that for the processing of the personal data provided when beginning the trial period or acquiring a Subscription directly from SIVECO and not its distributors, SIVECO will act as a data controller. However, if the Subscriber has concluded the End User Subscription Agreement with a distributor, SIVECO will act as a data processor and the distributor will act as a data controller for such data.


For any other information provided by the Subscriber to SIVECO or collected directly by SIVECO according to this Privacy Policy and the Terms, the Subscriber is the data controller within the meaning of the GDPR. In this context, the Subscriber warrants that it has obtained, processed and transferred these data at all times in accordance with the GDPRand any other relevant legislation which may apply or come to apply.


If a User is enrolled on a course which uses Wand, his/her use of the Wand Platform may be logged and monitored. The User’s Subscriber and her/his teachers are able to access such information as: the number of times he/she logged onto the site, the pages he/she visited, and the dates and times that he/she visited them, his/her progress with work.


If SIVECO has previously closed an account due to a violation of an End User Subscription Agreement, the Terms or this Privacy Policy, SIVECO may retain the information concerning such an account for a reasonable period of time in order to be able to prevent future abuses.


6. What does Wand use my information for?


Any personal data communicated by a Subscriber during the registration process, when the Subscriber has concluded an End User Subscription Agreement with SIVECO, or when beginning the trial period will be processed by SIVECO, as the data controller within the meaning of the Data Protection Directive, the GDPR, once it comes into force, and any other relevant legislation which may apply.


For any other personal data provided by the Subscriber to SIVECO and/or collected directly by SIVECO, SIVECO will act as a data processor for the Subscriber, according to the Data Protection Directive, the GDPR, once it comes into force, and any other relevant legislation which may apply. SIVECO will process these data in order to make available the Wand Platform to the Subscriber and its Users.


SIVECO will process these personal data according to the End User Subscription Agreement, the Terms and other instructions from the Subscriber, for the personal data processed by SIVECO as a data processor, for the following purposes:


  1. to enable SIVECO to make available the Wand Platform to the Subscribers and Users;
  2. to contact the Subscribers for the purpose of enhancing their experience with Wand (such as offering assistance for specific tasks);
  3. to send the Subscribers and teachers our newsletter if they have previously opted-in;
  4. to make occasional offers of SIVECO and its affiliates products or services to Subscribers or to make the Subscribers aware of other products or services offered by SIVECO from time to time if they have opted-in to receiving the newsletter;
  5. to manage the payment of the subscription fees;
  6. to administer, support, improve and develop the Wand Platform; and
  7. to assist the Subscribers with complying with any applicable regulations by providing the necessary information to them or by making such information available for download or similar.

SIVECO will not send any newsletters or other marketing information, offers, recommendations or updates to students and will not contact students directly, except for notifications email regarding assignments or reminders to change the password if needed.


SIVECO also uses Google Analytics to analyse information gathered from visitors to the Site. This information can include how Subscribers or Users arrived at the Site, how long they used the Site for, what type of device they are using, and other information about their device and visit to the Site.


This information allows SIVECO to better understand the Subscribers and Users of the Wand Platform and how they use it. SIVECO may also compile aggregate statistics such as the number of visitors to the Site, and how the Site is used. No personally identifying information is included in this type of reporting. Each Subscriber or User can opt-out of certain types of this processing, but this may impact on the ability to use the Site. You can find more information about Wand use of cookies in our Cookie Policy.


Also for more information about analytics please visit https://analytics.google.com.


7. How long is my information retained?


SIVECO retains your information only for as long as needed or permitted in light of the purposes for which it was obtained. Your information will be kept (a) as long as your account is active; (b) as required by a legal obligation to which we are subject to; or (c) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigations, or regulatory investigations).


8. Does Wand share any information with third parties?


SIVECO may transfer your personal data only through secured applications to its affiliated entities and other commercial partners of SIVECO (e.g. cloud hosting, chat support and email services), with whom SIVECO has made the necessary contractual agreements required by EU and national regulations. By using the Wand Platform, the Subscribers also acknowledge the transfer of their personal data to these data processors.


SIVECO may release personal data in order to comply with the law or in response to a request from a court or other legal authority, such as a warrant or a subpoena. SIVECO might also share the information if we believe in good faith that it is necessary to prevent or address frauds, protect SIVECO and its employees, other Wand Subscribers or Users or to enforce the Terms.


9. How is children’s personal information handled?


SIVECO acknowledge that the processing of data on children merits special protection. We acknowledge that children may be less aware of the risks, consequences and safeguards and of their rights in relation to the processing of personal data.


SIVECO does not collect or process any data in relation to any child unless it is satisfied that there is a legitimate interest established under the terms of Article 6 (2) of the GDPR. This means that Siveco will continually appraise the three elements of the legitimate interests test:


9.1 The overarching educational, advancement and wellbeing purpose for processing the childrens’ data which provides a more engaging, stimulating experience for the child


9.2 The necessity of processing the childrens’ data via the Wand Platform to provide the maximum benefit to the Subscriber and child in each and every case (noting the severe restrictions to the educational and wellbeing benefits and the lack of any other less intrusive mechanism to delivering the benefits other than the Wand Platform)


9.3 The balancing of the rights and interests of the children to have their privacy specially protected, with their general understanding of the value of the lesson being delivered using the Services and the Wand Platform.


SIVECO does not knowingly collect any information from students under the age of 13, unless and until consent is given or authorised by a person with parental responsibility over the child.


A school (or other Subscriber) must confirm that SIVECO may lawfully process such personal data as a data processor for the subscriber and for SIVECO to collect and process such information from students.


Please contact SIVECO at office@siveco.ro if you believe that SIVECO is processing personal information from a child unlawfully, in order that we can stop such processing and delete the information as soon as possible.


If you are aged 12 or under, you should not use our web pages without being registered by your school and/or teacher.


10. Is my personal information secure?


Wand and SIVECO take the security of your personal information seriously. We must make a proper assessment of risk and apply safeguards to ameliorate those risks. In order to assess the risk to Subscribers and Users the controller and processor must consider the nature, scope, context and purposes of the processing and the potential risks from processing.


We have taken appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. These steps take into account the sensitivity of the information we collect, process and store.


In order to carry out its tasks as a processor, the Subscriber allows SIVECO to use sub processors within the European Union. SIVECO maintains a record of all processing activities carried out on behalf of each controller.


11. What happens in case of a breach of security?


Our security systems are designed so as to facilitate the discovery of any breach as soon as is possible.


The Data Controller must document all personal data breaches, however minor and record:


  1. The facts relating to the breach;
  2. The effects of the breach (if any);
  3. The remedial actions to be taken to deal with the breach in accordance with =the GDPR.

As a data processor, if a breach occurs, we must notify the Subscriber, acting as a sata controller and/or the relevant supervisory authority. This will be done without undue delay after becoming aware of the breach. (A Subscriber will immediately in writing notify SIVECO if any of its User Accounts, or the personal data contained in them become lost or subjected to unauthorised access, modification, disclosure, or other misuse or interference, or suffers from any kind of related data security breach of which it becomes aware.


A Subscriber shall put arrangements in place so that its Users whether they are teachers, members of staff, students or other connected persons shall be aware of the need to report and escalate any suspected data breach they encounter or suspect through to the Subscriber. This shall be in direct adherence to the GDPR to allow the relevant data controller where feasible, without undue delay, not later than 72 hours after having become aware of it, notify the personal data breach to the relevant supervisory authority in that jurisdiction or territory. Subscribers should note the obligation to notify the regulator, and potentially affected data subjects, falls on you as data controller to update and inform within 72 hours from the breach first happening). The test for reporting is as follows:


Where a personal data breach is likely to result in some degree of risk to the rights and freedoms of natural persons the controller must notify the breach to the supervisory authority without undue delay and, where feasible, within 72 hours of having become aware of the breach.


Where the breach is likely to result in a high risk to the rights and freedoms of the Subscribers and Users, notice must also be given to the persons whose data have been compromised.


12. Will Subscribers or designated teachers receive any emails from Wand?


In order to ensure communication with Subscribers and designated teachers, SIVECO will send Subscribers and designated teachers notification emails, which are application related, such as: password confirmations, expiration of the account.


Also, Subscribers and/or designated teachers may receive the latest information concerning Wand products or other marketing campaigns if the Subscriber and/or teacher have opted-in to receiving the newsletter according to the Terms and Conditions.


13. Will students receive any emails from Wand?


Students will only receive notification emails, such as: announcements of new assignments or closed assignments or reminders to change the password if needed.


SIVECO will not send any newsletters or other marketing information, offers, recommendations or updates to students.


14. How can I manage my personally identifiable information?


Upon request, SIVECO will provide Subscribers and Users with information about the personal data that we hold and process.


Subscribers and Users have the right to access and rectify their personal data, as well as the right to object to the processing of their personal data for direct marketing purposes, the right to restrict the processing of personal data or the right to receive a copy of the personal data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by the applicable law). Moreover, the Subscribers and Users can contact us if they believe that personal information was provided unlawfully or without the necessary consents.


Subscribers and Users may exercise their data protection rights by sending a written and dated request accompanied by a proof of their identity to SIVECO through the contact details provided in the ‘Contact’ section of this Privacy Policy and we will try to comply with your requests as soon as reasonably practicable.


Please note that even if you request the change or deletion of your personal data, SIVECO may retain certain information for recordkeeping purposes and/or as required by the applicable law. There may also be residual information that will remain within our databases and other records, which will not be removed.


However, you understand that you can use the Wand Platform only as long as you allow SIVECO to process your personal data.


15. Will there be any change to the privacy policy?


We will change and update this policy to move with the times we live in and the rapidly evolving world around us. SIVECO as trademark owner and domain owner of Wand.education reserves the right to modify or replace the Privacy Policy at any time, at its sole discretion. SIVECO will notify Subscribers of any changes on the Privacy Policy by sending an update email. Subscribers shall take all appropriate measures to ensure that these changes do not affect the lawful processing made by SIVECO as a data processor for the Subscriber and that SIVECO may continue to process the personal data of the Subscribers and their designated Users.


Should Subscribers have any queries regarding any changes to the Privacy Policy please contact SIVECO at the address detailed below.


16. Contact


IF YOU HAVE ANY QUESTIONS ON THE WAND PLATFORM, THE TERMS OT THIS PRIVACY POLICY, YOU CAN CONTACT SIVECO THROUGH THE FOLLOWING CONTACT DETAILS:

Bucuresti-Ploiesti Drive 73-81, District 1, Victoria Park Complex, C4 Wing, Bucharest, Romania, for the attention of the Customer Care Manager, address: office@siveco.ro.


You can also send an e-mail at: office@siveco.ro, together with a proof of your identity, to request access to, correct, or delete any personal information that SIVECO processes about you. You also have the right to oppose to the processing of your personal data for direct marketing purposes by contacting SIVECO through the same contact details.




[1] WAND.Education is a trademark owned and registered by SIVECO and/or its affiliates.