European Commission, Directorate‑General for Communications Networks, Content and Technology (DG CNECT), Directorate G, Unit G2
Europeana Foundation, Prins Willem-Alexanderhof 5, 2595 BE The Hague, The Netherlands, email@example.com
The European Commission (hereafter ‘the Commission’) and the Europeana Foundation are committed to protecting your personal data and to respecting 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 (repealing Regulation (EC) n° 45/2001).
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 “Data processing on https://www.europeana.eu/ and https://pro.europeana.eu” undertaken by the Europeana Foundation, on behalf of the European Commission, is presented below.
2. Why and how do we process your personal data?
Purpose of the processing operation: The Commission’s Directorate-General for Communications Networks, Content and Technology offer a number of external websites. The technical setup collects and uses your personal information to be able to provide the websites which are physically located outside the Commission controlled hosting infrastructure.
Furthermore, feedback forms might be used as a contact channel.
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
We process your personal data on several grounds:
Article 5(1)(a) of Regulation (EU) 2018/1725: this 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.
Indeed, informing the broad public is a task resulting from the European Commission's own prerogatives at institutional level, as provided for in Article 58(2) (d) of Council Regulation (EC, Euratom) No 2018/1046 of 18 July 2018 on the Financial Regulation applicable to the general budget of the European Communities (OJ L 193, 30.7.2018, p. 1). We ensure that adequate and specific safeguards are implemented for the processing of personal data, in line with the applicable data protection legislation.
Article 5(1)(d) of Regulation (EU) 2018/1725: for the processing activities consisting in feedback forms, cookies and authentication measures, your consent is necessary. In compliance with Article 3(15) and Article 7 of Regulation (EU) 2018/1725, the consent must be freely given, specific, informed and unambiguous. We have obtained your consent directly from you. You may have expressed it by an email, submitted via e-registration form, or in any other written form.
4. Which personal data do we collect and further process?
In order to carry out this processing operation, the Data Processor collects the following categories of personal data:
- Internet Protocol address (IP address) or the device ID of the device used to access the website.
Without this processing you will not be able to establish a technical connection between your devices and the server infrastructure and therefore will not be able to access our websites.
In order for you to authenticate on https://www.europeana.eu/, the Data Controller collects the following categories of personal data:
- E-mail address and password;
In order for you to use our feedback form, the Data Controller collects the following categories of personal data:
- E-mail address;
5. How long do we keep your personal data?
The Data Controller only keeps your personal data for the time necessary to fulfil the purpose of collection or further processing, namely for the duration of the browsing session. In addition, IP addresses might be saved for one year in the log files of the services for security reasons. As to the analytics tool, the IP address and the device ID (e.g. IMEI number and WIFI MAC address) are deleted immediately at disconnection.
As to the feedback form, data is kept for 2 years from the moment the form is submitted.
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 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.
The Europeana Foundation is bound by a specific contractual clause for any processing operations of your data on behalf of the Commission, and by the confidentiality obligations deriving from the transposition of the General Data Protection Regulation in the EU Member States (‘GDPR’ Regulation (EU) 2016/679).
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.
7. Who has access to your personal data and to whom is it disclosed?
Access to your personal data is provided to the Europeana Foundation staff responsible for carrying out this processing operation and to authorised staff according to the “need to know” principle. Such staff abide by statutory, and when required, additional confidentiality agreements.
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.
9. What are your rights and how can you 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, rectify or erase your personal data and the right to restrict the processing of your personal data. Where applicable, you also have the right to object to the processing or the right to data portability.
You have the right to object to the processing of your personal data, which is lawfully carried out pursuant to Article 5(1)(a).
You have consented to provide your personal data for the present processing operation. You can withdraw your consent at any time by notifying the Data Controller. The withdrawal will not affect the lawfulness of the processing carried out before you withdraw your 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.
10. 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 ([email protected]) 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 ([email protected]) 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.
11. Where to find more detailed information?
The Commission Data Protection Officer (DPO) publishes the register of all processing operations on personal data by the 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-09706.1.