Privacy Policy

Privacy Information regarding Pericles’ recorded and online classes, online student resources, grading, finances, and other information

Pericles would like to inform you about the processing of your personal data when you participate in any Pericles courses and events.
We use software tools such as Zoom, Big Blue Button, YouTube and Moodle to conduct online and bimodal classes and to record classes for students to watch later. We use 1C and Robokassa to process bank payments. The following explains our understanding of what data is processed about you and where it is held.

Use of Technology During Classes

Zoom:
While visiting a Zoom meeting, Zoom controls your information and is responsible for the processing of your personal data for the duration of the meeting and for any recording maintained on its platform. Zoom is operated by Zoom Video Communications Inc., a company based in the USA. Zoom hosts the personal data processed in the course of online meetings in servers located outside the Russian Federation. For the most part, these servers are located in Western Europe, it appears they are mainly in Germany.
To participate in an online class or other meeting, you will be required to at least provide your name.
When you download the Zoom app, the app collects certain personal data—your name, email address and whatever other information you input when creating your account. Once you register as a Zoom user, your email and information you entered when downloading the app can be tied together with the meetings you register for or attended. Zoom may store reports about the online meetings you attended including metadata for up to one month.
If you prefer to participate without installing the Zoom application, you can use the Zoom in your browser. In this case, Zoom cannot connect your personal data to the meeting ID. However, in this case, you will only be able to use basic functionalities. Even if you participate via web browser, Zoom can process participants IP addresses together with the meeting ID and topic name.
Pericles requires that you use your audio and video to be counted present in a class. It is technologically possible for Zoom to use the display of your video or broadcasting of your audio, together with facial recognition or voice recognition software to process your voice and image and to identify you. But Zoom states that it does not do this.
Zoom states that it uses end-to-end encryption while the meeting is taking place.
Zoom stores the number of minutes that you participate in a meeting, which Pericles then uses to help professors track online attendance.
If you use the chat, question or survey tool during an online meeting, the text you entered will be displayed during the meeting and possibly afterwards in the meeting recordings, together with the name under which you entered the meeting.
Pericles requires that students participate in classes at least with their first names and last initials, thus you could potentially be identified with your video, chat comments or survey responses.

Big Blue Button:
When Pericles uses Big Blue Button to host a class or a meeting, information on your participation is only stored on Pericles servers located in Russia. You do not have to install any application to run it, but you can only run it from within your Moodle account. Big Blue Button will record your participation in the meeting, the amount of time you are present, and the amount of time you speak.
Big Blue Button automatically retains logs of meeting participant information for approximately one to two weeks (depending on the log). After that the logs are automatically deleted.
Pericles does not sell or share your data from Big Blue Button with anyone unless directed to do so by law.
Big Blue Button does not use end-to-end encryption. It is technologically possible that audio and video content during a Big Blue Button video conference could be picked up by an outside party. However, as Big Blue Button is a very limited tool for educational teleconferencing, and as it is only available to Pericles students inside their encrypted Moodle login, it is very unlikely to be hacked.

Class and Event Recordings and Registrations

On Zoom or Big Blue Button:
Pericles records classes in which we use Zoom or Big Blue Button so that students may replay the recordings if they missed a class or need to refresh their memory or improve their understanding of a class. When a class is being recorded on Zoom, you will have an audible or written notice that the class is being recorded when you log on or when the recording is turned on, and you will be asked to agree to continue. On Big Blue Button you generally will not receive a notice that the class is being recorded. On both programs, however, you will be able to tell if the recording is on via the recording icon.
Recordings are deleted from Zoom and Big Blue Button soon (usually within 24 hours) after being recorded, and copies are kept on a portable drive that is detached from Pericles server and not linked to the internet. It is located in Moscow, Russia.
When recordings are stored on Pericles server, before they are uploaded to Youtube, the Professor for the course has the right to, and often does, delete parts of the course that might have been accidentally recorded or during which the Professor deems that personal information was recorded that should not be contained in the class recording.

On Youtube:
After Pericles removes class recordings from Zoom or Big Blue Button, and removes any material the Professor deems inappropriate, it posts the recordings as an “unlisted” video on YouTube for the duration of the course, meaning that only those with the link can watch the recording The class recordings are not made visible to the public.
As stated above, the purpose of this posting is to facilitate students being able to easily watch the videos to see classes they missed, refresh their memories or improve their understanding of the class.
These recording links are only available to participants in the course and, if the course is being conducted on behalf of a company, to the appropriate persons within that company.

After Deletion from Youtube:

Approximately six weeks to two months after a course ends, recordings are deleted from Youtube to help ensure that students’ privacy is protected and to further ensure that recordings are not inadvertently made public. After that time, the only way to access the recordings is to come to Pericles office and view them on Pericles computers in Moscow.
Students may not take copies of the class recordings.

Recordings of Free Seminars and Public Events:

Pericles uses Zoom and other video conferencing tools to conduct open master classes, free seminars and other events. For these meetings we post recordings to our Youtube channel and may also place links to the recording on our website, Facebook page and other social media sites.
Usually, recordings posted on our website will only show the hosts and speakers, however if you choose to actively take part, for example by asking questions or making comments, please note that your image and voice will become part of the recording. If you do not wish for recordings of your image or voice to be included you may opt out by deactivating your microphone and camera.
You will be able to tell via the recording icon in the respective application, when we are recording a meeting.

Storage of Event Registrations:

Upon registering for our event, we will add you to the list of participants. Usually the personal data we collect will include your name, job title, company or educational institution affiliation, telephone and e-mail address. This data may be processed directly through our website or through Timepad.ru, which processes your data on its own system with its own privacy policies. When we co-host an event we will share the list of participants with our partner organization, or our partner organization may process your information according to its own privacy policies and may share your information with us. We do not sell your registration information or otherwise share this information with any other parties.
Registered participants will be entered into our database so we may contact them about similar future events. If you do not want to receive event invitations from us, you may opt out, simply by sending an e-mail to info@pericles.ru.

Moodle & Student Data:

Pericles uses the learning management system, Moodle, to distribute and store course assignments and other resources. Pericles Moodle is hosted on a server located in Russia. Pericles Moodle stores whatever data students have entered into their profiles, which is, at a minimum, names and email addresses, and makes that information available as the student has designated. Students can choose to share their email addresses and other data with other class members, with any other student registered on Moodle, or with no one but their professors and Pericles administrators.
Records of courses taken, students’ marks on specific course assignments, and other information input by the teacher may also be stored on Moodle, depending on the Professor’s practices in the particular course.
Courses taken with Moodle pages are shared with whomever the student has elected to share information with. Badges earned, if the professor has set up badges, are also shared. Marks on course assignments and comments given by the teacher are not shared with other students unless the assignment is a group assignment, in which case other students in the group will also know the marks and comments.
Pericles uses the information Moodle collects in order to ensure accurate classroom records, communicate with you, and provide you updates and information regarding your courses and other Pericles information and events.
Pericles uses its own proprietary enrollment system for storing student course and LL.M. application information. This information is stored locally in Russia. External IT service providers under contract with Pericles may have termporary access to students’ information for the purposes of setting up or improving features in our enrollment and course management systems.
Pericles does not share any of your information with third-parties with the exception of sharing your name, email addresses, host schools (if attending certain special courses limited to university students), and expected graduation dates with legal research databases such as Lexis and Westlaw, and may ask you to start accounts with CALI, Core Grammar for Lawyers and other programs that could collect information about you. Pericles shares information with such databases and resources solely for the purpose of granting you access to these databases and resources. If you wish to avoid giving information to these third party providers please communicate with us through e-mail. Understand that requesting not to share this information with these providers will probably mean you do not have access to the database and, depending on the course, might make it impossible to complete the work for the course.
To better ensure your privacy, final grades in Pericles courses and transcript information are not stored on Moodle or on Pericles enrollment system but are stored locally on Pericles computers, on a program that does not connect to Moodle, to the enrollment system, or to the internet. Pericles, however, makes no representation or warranty that our system is unhackable. Data breaches can always occur in any company.

Financial Data:

Pericles contracts with Robokassa and IT solution providers to allow students to process payments through the web if students want. In which case, Robokassa’s staff and external IT providers may have temporary access to students’ information for the purposes of setting up and improving features in our payment systems. Pericles is dependent on Robokassa’s security for the security of any financial information that you input into the system.
Pericles retains financial data regarding student payments on 1C accounting software maintained in Russia, and we do not retain information related to student’s bank accounts or payments online.
In the event that student payment records could be hacked, Pericles maintains paper backups of financial transactions to assure that the information is not compromised.

Your Rights as a Data Subject:

You have the right of access to any personal data processed about you. Any personal or course notes taken by your Professors are not included in such data.
You must contact us in writing for such access and must specify particularly which information you are seeking. We may require you to provide proof of your identity.
You have the right to correction or deletion of information about you as far as you are legally entitled. You do not have the right to have course records or grades changed or deleted without proving that such records are erroneous.
To the extent that any course information to which you want access also contains information on other students, such as information on teammates in group projects or classmates in class recordings, you must pay for our work in deleting the information on others before we can grant you access to the information.