Data Protection Policy

Data Protection Policy

We would like to thank you accessing the website of the Black Sea Assistance Mechanism. Our data protection notice explains how and why we use the personal data we collect when you use our services or when you choose to subscribe to our newsletter.

The protection of your personal data privacy is important to us; therefore, we will never sell lists or email addresses to third parties.

Your personal data will be processed in compliance with Regulation 2018/1725 [1] of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data and in particular Article 5(1)(a) because processing is necessary for the performance of a task carried out in the public interest (or in the exercise of official authority vested in the Union institution or body) and  Article 5(1)(d) based on your explicit prior consent for non-compulsory data.

Please, note that the relevant documents such as data protection notices, which are mentioned below, are being reviewed & updated in light of the current transfer from the Executive Agency for Small- and Medium-sized Enterprises (EASME) to the new European Climate, Infrastructure and Environment Executive Agency (CINEA). Thus, after 1 April 2021 any reference to EASME shall be read as CINEA during the transition period.

Definitions

1. ‘Data controller’: the data controller of the processing operation is the Head of Unit EASME A.3 of the Executive Agency for Small and Medium-sized Enterprises (EASME).
2.  ‘Data processor’: The Consortium led by AETS S.A.  
3. ‘We’, ‘us’’ or "BSAM": the Black Sea Assistance Mechanism a service contract assigned by the Executive Agency for SMEs (EASME) – European Commission;
4. ‘Services’ or ‘website’: the Black Sea Assistance Mechanism website and the tools we provide you with;
5. ‘User’ or ‘you’: the individual who uses our Services, whose personal data is being processed;
6. ‘Subscriber’: the person that actively subscribes to the newsletter or that provides us electronic information via the tools included on the website;
7. ‘Usage data’: information on how the website is accessed and used.

Scope

Our Data Protection Notice is intended to be effective and applicable to any personal data we collect about our Users and Subscribers.

Which personal data we collect from you

Usage Data:  these may include information about:

• your computer's Internet Protocol address (e.g. IP address), browser type, browser version;
• the pages of our website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Subscribers:  in our website there are fields where you are asked to submit the following identification data through data entry fields:

• Full name
• Title/function (professional/functional)
• Name of the organisation, Address
• Email address, Country

What is the purpose of collecting your personal data

The personal information we collect from you is used in order to enhance user experience and protect you through your navigation in the website.

In particular:

• to notify you about changes to our website, like new features, version updates, releases, abuse warnings, and changes to our Data Protection Notice;
• to allow you to participate in interactive features of our website when you choose to do so;
• to provide member support and to communicate you about your account;
• to monitor the usage of our website;
• to better understand patterns relating to Site usage, through Cookies, so that we may further improve upon or services and Site offering;
• to detect, prevent and address technical issues;
• to send you newsletters and provide you with news on our organization, our events and general information about other related events, project or funding published opportunities.

Who has access to your data

The recipients of your personal data will be the central team of the Black Sea Assistance Mechanism as well as EASME or other designated Commission staff and/or bodies charged with monitoring or inspection tasks in application of EU law (e.g. internal audits, Court of Auditors, European Anti-fraud Office (OLAF).

Your personal data will not be transferred to third countries or international organisations.

The processing of your data will not include automated decision-making (such as profiling).

Your data Your choice

We fully appreciate that you trust us with your personal data. We would therefore like to inform you of your rights in case you may no longer wish to share your data with us.

You have the right, at any given time:

• to ask us to provide you with copies of personal information that we hold about you at any time, which include the right to ask us: whether we process your personal data, for what purposes, the categories of data, the recipients to whom the data are shared; we will provide you with this information within 30 days upon the receipt of your request;
• to ask us to update and correct any out-of-date or incorrect personal information;
• to ask us to verify which personal data is stored on your behalf by the data controller or the data processor, have it rectified, erased or restricted (if applicable);
• to withdraw your consent where such consent has been given without affecting the lawfulness of the processing of your personal data before your withdrawal;
• to data portability within the limits afforded by data protection legislation;
• to object to the processing of your data (if applicable);
• to request that we have your personal details opted-out of the personal profile, deleted or modified at any moment;
• to access or update your personal information;
• to unsubscribe from our newsletter service; you may opt out of receiving any, or all, of the news from us by following the unsubscribe link or instructions provided in any email we send;
• to ask for the deletion of any photos uploaded from you with respect to the BSAM events and/or workshops. In all our events we will ask for your written consent in order to further processing your personal data by means of uploading pictures of you; withdrawal of consent is possible should you change your mind.

Data treatment - Communication – Questions

Anytime and for any reason you are welcome to contact us by filling out the form Helpdesk Infoline. All official mail or any kind of communication sent via the Helpdesk Infoline is automatically forwarded to the central management office of the Black Sea Assistance Mechanism.

We use the Combell hosting services and we operate in the EU, therefore we owe to be compliant with the European Legislation in terms of privacy and data protection. Data collected from sources outside EU will anyway be treated in accordance with the applicable EU privacy and data protection Regulations, and in particular Regulation (EU) 2018/1725.

The data are stored in our highly secured servers with daily backups, to which only authorised personnel has physical access and can access the server file system via remote connection within the EU. We take high security measure to safeguard the information against possible misuse or unauthorized access.

You shall have right of recourse at any time to the EASME Data Protection Officer at EASME-DPO@ec.europa.eu and to the European Data Protection Supervisor at https://edps.europa.eu.

Public Information and Third Parties

Email distribution list

The Data Processor’s newsletter distribution list is provided through the Zoho campaigns platform which is responsible of the storage of personal data. We invite the visitors to read carefully the Zoho campaigns privacy policy and the Zoho-Cookie policy.

Social Media Platforms and Widgets

Our Newsletter and website include social media features. These features may collect information about IP addresses and which page you are visiting on our site, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are hosted by a third party. We also maintain presences on social media platforms like Twitter, LinkedIn and YouTube. Any information, communications, or materials you submit to us via a social media platform is done at Subscribers’ own risk. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Subscribers’ interactions with those features and platforms are governed by the privacy policies of the companies that provide them.

Links to Third-Party Sites

Our website and Newsletter include links to other websites, whose privacy practices may be different from the on applicable to the website. If you submit personal Information to any of those sites, your information is governed by their privacy policies. Within our website we also provide links to third party sites. Since we do not control them, we encourage you to review their privacy policies carefully. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Cookies and Tracking

When you access our Services, we ask for your permission to store ‘cookies’ which are strings of code, on your computer. We use those cookies to collect information about the users’ visits and use of our website or Services. The users may turn off cookies that have been placed on their computer by following the instructions on their browser, however, if they block cookies, it may be more difficult (and maybe even impossible) to use some aspects of the Services.

How we use Cookies

Our website uses technical cookies in order to enhance user experience and to provide services to users. You can control and/or delete cookies as you wish Tracking and third-party cookies may be used too when content from third party sites (like YouTube, Open Street maps, etc.) are embedded in this website. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work. We strongly suggest that you read our cookie policy in order to learn more details about the cookies we use.

Retention of Data

We will retain your Personal Data for the duration of the Black Sea Assistance Mechanism (48 months) or for as long as you choose to have an active account.

Version November 2019

[1] Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC (OJ L295/39 of 21.11.2018).

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