This privacy statement applies to the registration form for providing institutions on the Europeana website https://www.europeana.eu/en/share-your-data. Please note that only the English version of these terms should be considered legally valid. We take no legal responsibility for any differences or discrepancies created in the translations of these terms.
Processing operation Management of the subscription to the Europeana.eu usage statistics subscription
Data Controller European Commission, Directorate‐General for Communications Networks, Content and Technology (DG CNECT), Directorate G, Unit G2
Data Processor Europeana Foundation, Prins Willem-Alexanderhof 5, 2595 BE The Hague, The Netherlands
Data Sub-processor Zoho CRM, Zoho Corporation B.V., Beneluxlaan 4B, 3527 HT UTRECHT, The Netherlands
Record reference DPR-EC-03928
1. Introduction
The European Commission is committed to protect your personal data and to respect your privacy. The Commission collects and further processes personal data pursuant to 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.
This privacy statement explains the reason for the processing of your personal data, the way we collect, handle and ensure protection of all personal data provided, how that information is used and what rights you have in relation to your personal data. It also specifies the contact details of the responsible Data Controller with whom you may exercise your rights, the Data Protection Officer and the European Data Protection Supervisor.
The information in relation to the processing operation Management of the subscription to the Europeana.eu usage statistics subscription, undertaken by the Europeana Foundation, on behalf of the European Commission, is presented below.
2. Why and how we process your personal data?
Purpose of the processing operation: the controller collects and further processes your personal data so that you can receive your usage statistics and information about other services Europeana offers to boost your digital tranformation activities.
Your personal data will not be used for automated decision-making including profiling.
3. On what legal ground(s) do we process your personal data?
You have subscribed to receive the information on important developments, activities, events, initiatives or thematic issues in the area of (a) service(s) of the European Commission.
We process your personal data, because you have given your consent to the processing of your personal data for the purpose of receiving the requested information.
4. Which personal data do we collect and further process?
In order to carry out this processing operation, the controller collects the following categories of personal data:
- Your name, surname and email address are needed to ensure the delivery of the service to you as a subscriber.
The following personal data is needed for providing you with a more personalised experience (i.e. better targeting the content of the information) and for generating anonymised statistics:
- Country of residence
- Sector of activity / interest
- Organisation
5. How long do we keep your personal data?
The controller only keeps your personal data for the time necessary to fulfil the purpose of collection, namely until you unsubscribe from the mailing list.
Depending on the technical solutions available, you can either write to the dedicated functional mailbox and ask to be unsubscribed from the mailing list or follow the unsubscribe link in the information email you have received. Appropriate action shall be taken within a week of receiving the request.
In case where data is kept for statistical purposes, some subscriber's optional data may be kept for 5 years after the un-subscription, providing these do not allow to identify the subscriber any more and that these are available to a very restricted number of authorised persons performing the processing operation on a need to know basis, for the sole purposes of generating anonymised statistics.
6. How do we protect and safeguard your personal data?
All personal data in electronic format (e-mails, documents, databases, uploaded batches of data, etc.) are stored on the servers of the Europeana Foundation, the Commission, and Zoho CRM. All processing operations are carried out pursuant to the Commission Decision (EU, Euratom) 2017/46 of 10 January 2017 on the security of communication and information systems in the European Commission.
In order to protect your personal data, the Commission has put in place a number of technical and organisational measures. Technical measures include appropriate actions to address online security, risk of data loss, alteration of data or unauthorised access, taking into consideration the risk presented by the processing and the nature of the personal data being processed. Organisational measures include restricting access to the personal data solely to authorised persons with a legitimate need to know for the purposes of this processing operation.
Europeana Foundation, as data processor, is bound by a specific contractual clause for any processing operations of your personal data on behalf of the Commission. The processors have to put in place appropriate technical and organisational measures to ensure the level of security required by the Commission.
7. Who has access to your personal data and to whom is it disclosed?
Access to your personal data is provided to:
- Commission staff responsible for carrying out this processing operation and to other authorised Commission staff according to the “need to know” principle. Such staff abide by statutory, and when required, additional confidentiality agreements.
- Europeana Foundation staff responsible for carrying out this processing operation according to the “need to know” principle.
- Zoho CRM staff responsible for carrying out this processing operation according to the “need to know” principle.
Please note that pursuant to Article 3(13) of Regulation (EU) 2018/1725 public authorities (e.g. Court of Auditors, EU Court of Justice) which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients. The further processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing. The information we collect will not be given to any third party, except to the extent and for the purpose we may be required to do so by law.
8. What are your rights and how can we exercise them?
You have specific rights as a ‘data subject’ under Chapter III (Articles 14-25) of Regulation (EU) 2018/1725, in particular the right to access your personal data and to rectify them in case your personal data are inaccurate or incomplete. Where applicable, you have the right to erase your personal data, to restrict the processing of your personal data, to object to the processing, and the right to data portability.
You have consented to provide your personal data to the controller for the present processing operation. You can withdraw your consent at any time by notifying the Data Controller. The specific privacy statement will explain how consent can be withdrawn. The withdrawal will not affect the lawfulness of the processing carried out before you have withdrawn the consent.
You can exercise your rights by contacting the Data Controller, or in case of conflict the Data Protection Officer. If necessary, you can also address the European Data Protection Supervisor. Their contact information is given under Heading 9 below. Where you wish to exercise your rights in the context of one or several specific processing operations, please provide their description (i.e. their Record reference(s) as specified under Heading 10 below) in your request.
9. Contact information
- The Data Controller
If you would like to exercise your rights under Regulation (EU) 2018/1725, if you have comments, questions or concerns, or if you would like to submit a complaint regarding the collection and use of your personal data, please feel free to contact the Data Controller Unit G2, Directorate G, Directorate‐General for Communications Networks, Content and Technology (DG CNECT) of the European Commission at: CNECT-G2@ec.europa.eu
- The Data Protection Officer (DPO) of the Commission
You may contact the Data Protection Officer data-protection-officer@ec.europa.eu with regard to issues related to the processing of your personal data under Regulation (EU) 2018/1725.
- The European Data Protection Supervisor (EDPS)
You have the right to have recourse (i.e. you can lodge a complaint) to the European Data Protection Supervisor (edps@edps.europa.eu) if you consider that your rights under Regulation (EU) 2018/1725 have been infringed as a result of the processing of your personal data by the Data Controller.
10. Where to find more detailed information?
The Commission Data Protection Officer (DPO) publishes the register of all processing operations on personal data by the European Commission, which have been documented and notified to him. You may access the register via the following link: http://ec.europa.eu/dpo-register.
This specific processing operation has been included in the DPO’s public register with the following Record reference: DPR-EC-03928.