Privacy Statement
The Consortium of the SPRING Project (“we”) have created this privacy statement in order to demonstrate our commitment to privacy. Your right to privacy and data security is a primary concern. This privacy statement sets out the basis on which any information we collect from you, or that is provided to us, will be processed by us. Please find below further information regarding the data you provide us and your rights in relation to the provision of such data.
INFORMATION GATHERING AND USAGE
Your personal data
We intend to give you as much control as reasonably possible over your personal data (information that can be used to identify you, such as your name, email address, telephone numbers, postal address etc.). There are times when we may need to collect and process personal data from you in order to service your needs. Set out below is a list of the types of personal data we might collect from you and the purposes for which we would use it.
Types of Information: Stakeholder Database information: first name, last name, work organisation, job position, work email or other email provided, area(s) of expertise, region/city of activity, language
Purpose: Stored in a database for dissemination managed by ISMU
Types of Information: Name of the organisation, website of the organisation, type of the organisation, country/city of establishment, governance level, area(s) of integration, main target group(s). Additionally, we will also display your first name, last name, work email or other email provided, if you have provided us with your consent to do so during the “Join us” registration process.
Purpose: Displayed in the publically available Stakeholder Database on the SPRING platform.
We will only collect personal information from you when we need this information and we will not process your personal information other than for the purposes for which you shared it with us. You will always have the option to unsubscribe from receiving information or to request to be deleted from our database which we will do accordingly.
We do not perform any profiling activities, including automated-decision making, where your personal data is processed by automated means.
Your consent
Before collecting any personal information from you, we will generally ask you for your consent. We may request this consent in varying forms, such as, by asking you to tick a box on a form, sign up to receive news through our website, or by asking you to provide a written or oral statement.
You may withdraw your consent at any time, by unsubscribing from the information you receive or by using the contact details below. Please note, however, that withdrawing your consent will not affect the lawfulness of our use of your information prior to withdrawal based on your preliminary consent.
Where we store your personal data
Your personal data is stored by ISMU [in Italy] and can only be accessed by selected ISMU staff for the purpose of sharing relevant information with other project partners.
Receiving newsletters
We offer various free electronic newsletters. Users sign up upon registration to the SPRING Stakeholder Database upon registration. We do not spam, sell or rent email addresses, and there is a link to unsubscribe from the newsletter in every email you will receive. Alternately you may remove your address from our mailing lists by sending an email to springproject@ismu.org.
Processing your data for our legitimate interests
In some cases we will process your personal data for our legitimate interests, rather than seeking your consent. This is largely so that we can efficiently provide you with information without having to seek individual consent for every communication with you (or where in some cases it might not be possible for us to seek your consent). We will, however, always provide you with information on our data processing activities on request.
Information sharing
The data collected will be publicly available under the SPRING Stakeholder Database and as part of your stakeholder profile. This section is under construction and will be made available at www.integrationpractices.eu. We will not otherwise use, share, disseminate, publish or disclose your personal data (except as may be required in response to litigation, investigations or other legally required disclosures).
Period for which we store your personal data
We will ensure that the period for which we store your personal data is limited to a strict minimum. We will store your personal data for no longer than is necessary for the purposes of providing the information you have requested or as required for legal compliance purposes. For further information on how long we will store your personal data in any particular case, please do not hesitate to contact us using the details below.
Links to third-party websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our website, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and such websites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Social networks
Through this website you have the possibiity of spontaneously connecting with the SPRING social media pages on Facebook, Linkedin and Twitter. Through the aforementioned social network channels ISMU may inform, update, communicate activities related to SPRING, and interact with users. The same aforementioned guarantees apply to these media, in accordance with the privacy policies of each social media platform to which the ISMU adheres.
YOUR RIGHTS
Access
You may contact us at any time in order to request access to the personal information we hold about you. We will confirm whether we are processing your personal data, provide details of the categories of personal data concerned and the reasons for our processing. We can also provide you with a copy of your personal information on request.
Rectification
If the information we hold appears to be inaccurate we will not use it, and not allow others to use it, until it is verified. You can ask us to correct or complete your personal data by contacting us at any time. To the extent possible, we will inform anyone who has received your personal data of any corrections we make to it.
Restriction
In certain circumstances, it may be possible to require us to limit the way in which we process your personal information (i.e., require us to continue to store your personal data, but not otherwise process it without your consent). Such circumstances include:
1. where you think the data we hold about you is inaccurate, processing can be restricted while it is being rectified;
2. where you object to our processing, (which is being carried out on the grounds that it is necessary for our legitimate interests) processing can be restricted while we determine whether such grounds override your interests;
3. where processing is unlawful but you oppose the erasure and request restriction of your data instead;
4. where we no longer need the personal data but you require the data in order to establish, exercise or defend a legal claim, our processing can be restricted.
Removal of your data
You may ask to have the information on your account deleted or removed. We will try to do so promptly, and, to the extent possible, we will inform anyone who has received your personal information of your request. However, we must keep track of certain transaction information, such as past event registrations and similar information, for legal compliance purposes of our funders and accountants, so we may not be able to fully delete your information in certain circumstances.
Receiving/transferring your personal data
You may also ask us to send you the personal data we hold on you in an electronic, structured and user-friendly format, or you may ask us to send this data to another person.
Object
Where we are processing your personal information without your consent to pursue legitimate interests, you may object to us processing your personal data. In particular, where we are using your personal data to contact you for purposes of sharing information and resources, you may object to such processing at any time.
Complaints
If you are located in the EEA and you believe that our processing of your personal data is in breach of data protection law, you have the right to lodge a complaint with the relevant data protection supervisory authority in the country where you are based or any place in the EEA where you believe the infringement has occurred. You may also contact us at any time if you wish to complain about our processing of your personal data.
For any of the requests listed above, please use the contact details below. We will make reasonable efforts to respond promptly and at the latest within one month. Our response to such requests may be limited to information under our direct control.
SECURITY
Security measures
We limit access to personal data that we collect about you to our employees, who we reasonably believe need to have access to your information to provide you with the information you request from us. We have security measures in place to help protect against the loss, misuse and alteration of the information under our control. While we cannot guarantee that loss, misuse or alteration to data will not occur, we ensure that our systems adhere to market security standard so as to help safeguard against such occurrences. In case you have any questions about these measures, please use the contact details provided below. We will use commercially acceptable means to protect your personal data, but we cannot guarantee its absolute security. If you have any questions about our security, you can email us through the contact below.
Children’s privacy protection
SPRING does not target and its websites are not intended for children under the age of 16. SPRING will not knowingly collect personal data from children and will delete such data upon discovery. Where SPRING requires personal data pertaining to children for the purpose of providing information, the consent of an adult with parental responsibility for that child will be required.
OPTING OUT
If you do not wish to receive certain communications from us you may opt out by: (1) following the opt out instructions that we include in each of our communications with you or (2) informing us at springproject@ismu.org that you no longer wish to receive such communications. We will comply with such requests unless such communications from us are required by law or do not require your consent under applicable laws. Your opting out may restrict our ability to provide you with the full extent of our services.
CONTACT DETAILS
If you would like to get in touch with us with regards to your personal data, please contact us SPRING coordinator (ISMU) at:
Fondazione ISMU
Via Copernico 1
20125 Milan, Italy
+39026787791
springproject@ismu.org
The Data Protection Officer (DPO) responsible for data protection on behalf of ISMU is Mariarosa Gaetano. The DPO can be contacted at avv.mariarosagaetano@pec.it
CHANGES IN THIS PRIVACY STATEMENT
This statement was last updated on 19th May 2021. If we decide to change our privacy policy, we will post those changes to this privacy statement on our website and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you by email, or by means of a notice on our website home page.
COPYRIGHT
All information, data, images, photos, videos on this site are the property of the SPRING Project. Any form of reproduction is prohibited without the express consent of the owner.
SPRING Consortium:
In collaboration with:
The contents of the website are the sole responsibility of the SPRING consortium and do not necessarily reflect the views of the European Union. The European Commission and the European Research Executive Agency (REA) are not responsible for any use that may be made of the information it contains.
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