Data Protection Policy

We would like to thank you accessing the website of the Facility for Blue Growth in the Black Sea. 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 dataand in particular Article 5(a) and 5(d).

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 Kantor Management Consultants and comprising of AETS S.A..
3. ‘We’, ‘us’ or ‘Facility team’: the Facility for Blue Growth in the Black Sea, a service contract assigned by the European Commission (EC);
4. ‘Services’ or ‘website’: the Facility for Blue Growth in the Black Sea 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 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.

Users

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

Mailing List Subscribers

The following identification data are also requested in order for us to contact or identify you: Email address, Name, Organisation (if any).

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.

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.

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 whish personal data is stored on your behalf by the data controller or the data processor, have it rectified, erased or restricted;
• 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;
• to opt out of the public profile, delete or modify any of your personal details;
• 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 Assistance Mechanism’s 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 in Belgium of the Facility for Blue Growth in the Black Sea.

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. Data collected from sources outside EU will anyway be treated with the same regulations adopted for EU member states.

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.

If a security breach or personal data breach causes an unauthorized intrusion into our system that materially affects the Users or the Subscribers, we will act without any undue delay and inform the Data Controller in accordance with the applicable legal framework[2]. The Data Controller shall inform the European Data Protection Supervisor at https://edps.europa.eu.

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 Facebook, Twitter 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.

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 1 year or for as long as you choose to have an active account. You may contact us and inform us in case you disagree or would prefer specific time limit to the retention of your data.

We will however retain and use your Personal Data to the extent necessary to comply with our legal obligations or court orders, resolve disputes, and enforce our legal agreements and policies, as well as to provide information to representatives and advisors, like attorneys and accountants, to help us comply with legal, accounting, or security requirements.

We will also retain Usage Data for internal analysis purposes for 1 year from the first submission of your personal data. We may only retain the Usage Data for longer time periods if this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

[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).

[2] Art. 34 and 35 of Regulation 2018/1725.