1.- Responsible for the data:
1.1 Your personal data are processed by the consortium partners of the DEFACTO Project, which has received funding from the European Union’s Horizon 2020 research and innovation programme under grant agreement Nº875247. You can contact us via e-mail at info@defacto-project-project.eu.
1.2 The partners reserve the right to modify, change or amend this Privacy Policy at their own discretion and from time to time. Such modifications, changes or amendments shall be communicated via the Website. In case of questions or comments with regard to the modifications, changes or amendments, you can inform us by sending an e-mail to info@defacto-project-project.eu.
2.- Categories of personal data:
2.1 When you fill out this form, the contact form on our Website, or contact us via e-mail, telephone, fax or Social Media Channels, we collect:
• the basic identity information you provide us with, such as name, e-mail address, postal address, telephone number, the company you work for, your function;
• the content of your communication and the technical details of the communication itself (with whom you correspond at our end, date and time, etc.);
• your preferences regarding receiving our e-mail communications, such as newsletters, advertisements, etc;
• electronic identification data, such as IP address;
• publicly available information of your profile on Social Media Channels and any other personal data you choose to provide to us.
2.2 When attending the online workshop, you acknowledge that the session will be recorded and later distributed on different project channels, such as the website, LinkedIn, and Twitter, among others.
3.- Purposes:
3.1 The DEFACTO partners process your personal data to provide you in a personalized and efficient way with the information, products and/or services you request via the Website, e-mail, telephone, fax, Social Media Channels and fairs and events.
3.2 The DEFACTO partners process your personal data to communicate with you as a result of our contact at a trade fair and/or event or as a result of your approach via the Website, e-mail, telephone, fax or one of our Social Media Channels.
3.3 The DEFACTO partners process your personal data to perform statistical analyses so that we may improve our Website, our products and services or develop new products and services.
3.4 The DEFACTO partners process your personal data to comply with legal obligations or to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities. Your personal data may be transferred upon DEFACTO PROJECT’s own initiative to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through your registration with or use of the Website, our Social Media Channels or other communication with us.
3.5 The DEFACTO partners may use your image and voice, if it is part of the recorded online workshop, during its distribution on different digital channels, such as the project website, social media networks, the newsletter, etc.
3.6 The DEFACTO partners may process your personal data for the preservation of the legitimate interests of DEFACTO PROJECT, its partners or a third party if and when your registration with, or use of, the Website, Social Media Channels or other communication channels can be considered (a) a violation of any applicable terms of use or the intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Website, (c) a danger to the Website or any of DEFACTO PROJECT’s or its subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (d) in any way hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some other way inappropriate or illegal.
3.7 The DEFACTO partners process your personal data mentioned under clauses 2.1, 2.2, 2.3 above for marketing purposes, i.e. to provide you with targeted communications, promotions, offerings and other advertisements of DEFACTO PROJECT and selected partners. DEFACTO PROJECT will only send you communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communications channels if you have explicitly consented to receiving such communications, newsletters and other advertisements.
4.- Legitimate processing of personal data:
4.1 For the processing of your personal data for the purpose outlined in clause 3.1, we ask for your consent.
4.2 The processing of your personal data for the purpose outlined in clause 3.4 is necessary to allow DEFACTO PROJECT to comply with its legal obligations.
4.3 The processing of your personal data for the purposes outlined in clauses 3.2, 3.3, 3.6 and 3.7 is necessary for the purpose of the legitimate interests of DEFACTO PROJECT, which are:
• being able to appropriately respond to your requests for information and other requests;
• communicate your personal data to our partners in the DEFACTO project to provide you with adequate information;
• allowing us to defend ourselves in legal proceedings;
• continuous improvements to the Website, our Social Media Channels, products and services to ensure that you have the best experience possible;
• keeping our Website, Social Media Channels, products and services safe from misuse and illegal activity;
• safeguarding our commercial and business interests and needs in light of changing market conditions.
• marketing and promotion of our products, services, brands an overall successful commercialization of our products and services.
4.4 For processing your personal data for the purposes outlined in in clause 3.1, the DEFACTO partners as the responsible parties ask for your consent. By consenting to our processing of your personal data for sending you communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communications channels, you agree that we are allowed to process your personal data for this purpose in the manner and under the conditions outlined in this Privacy Policy.
5.- Quality assurances:
5.1 The DEFACTO partners do its utmost to process only those personal data which are necessary to achieve the purposes listed under the purpose for processing.
5.2 Your personal data is processed only for as long as necessary for the purposes listed above or up until such time where you withdraw your consent for processing them. The DEFACTO partners will de-identify your personal data when they are no longer necessary for the purposes outlined in the purpose for processing, unless there is:
• an overriding interest of DEFACTO PROJECT or any other third party in keeping your personal data identifiable;
• a legal or regulatory obligation or a judicial or administrative order that prevents DEFACTO PROJECT from de-identifying them.
5.3 The DEFACTO partners will take the appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss, tampering or destruction. Such measures and procedures will be disclosed in more detail within the Data Management Plan of DEFACTO, following the FAIR data principles stipulated by the EU. Access by personnel of the DEFACTO partner companies or their third party processors will only be on a need-to-know basis and subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations only, which can never be guaranteed.
5.4 Currently, the DEFACTO partners use Microsoft’s Teams SharePoint as the intranet/repository to manage, share, and collaborate on the data and documents related to the project. Microsoft Teams enforces team-wide and organization-wide two-factor authentication, single sign-on through Active Directory, and encryption of data in transit and at rest. Files are stored in SharePoint and are backed by SharePoint encryption. The Microsoft Teams Sharepoint project workspace is under coordinator CIDETEC organization account and the data is physically stored in servers in European Union. Therefore, Microsoft Teams follows all the security practices and procedure to assure a safe collaboration working platform. Network communications are encrypted by default using industry-standard encryption techniques such as OAUTH, TLS, Secure Real-Time Transport Protocol (SRTP). In addition, it follows an authentication procedure for the provision of user credentials to a trusted server or service. On another note, DEFACTO consortia will associate a DOI (Digital Object Identifier) to each dataset in order to make data findable and easily identifiable.
6.- Your rights:
6.1 You have the right to request access to all personal data processed by the DEFACTO partners pertaining to you. The DEFACTO partners reserve the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to DEFACTO PROJECT.
6.2 You have the right to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If a request for correction is submitted, such request shall be accompanied of proof of the flawed nature of the data for which correction is asked.
6.3 You have the right to withdraw your earlier given consent under clause 4.4 for processing your personal data.
6.4 You have the right to request that personal data pertaining to you will be deleted if they are no longer required in light of the purposes which are outlined above or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by the DEFACTO partners against:
• overriding interests of DEFACTO PROJECT or any other third party;
• legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.
Instead of deletion you can also ask that the DEFACTO partners limit the processing of your personal data if and when (a) you contest the accuracy of that data, (b) the processing is illegitimate or (c) the data are no longer needed for the purposes which are outlined above, but you need them to defend yourself in judicial proceedings.
6.5 You have the right to oppose the processing of personal data if you are able to prove that there are serious and justified reasons connected with his particular circumstances that warrant such opposition. However, if the intended processing qualifies as direct marketing, you have the right to oppose such processing free of charge and without justification.
6.6 You have the right to receive from us in a structured, commonly used and machine-readable format all personal data you have provided to us.
6.7 If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to info@defacto-project.eu for all data subject rights matters. An e-mail requesting to exercise a right shall not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should clearly state and specify which right you wish to exercise and the reasons for it if such is required. It should also be dated and signed, and accompanied by a digitally scanned copy of your valid identity card proving your identity.
DEFACTO PROJECT will promptly inform you of having received this request. If the request proves valid, DEFACTO PROJECT shall notify it as soon as reasonably possible and at the latest thirty (30) days after having received the request.If you have any complaint regarding the processing of your personal data by the DEFACTO partners, you may always contact DEFACTO PROJECT via the e-mail address mentioned in the first paragraph of this clause. If you remain unsatisfied with DEFACTO PROJECT’s response, you are free to file a complaint with the competent data protection authority, i.e. the data protection authority of the country where you reside or the Spanish data protection authority (Agencia Española de Protección de Datos). For more information, visit https://www.aepd.es/
