Last updated: 24.03.2020
- Data Controller
The data controller of the EMPLOY Platform is the EMPLOY Consortium the (“mEntoring prograMme for young People at risk for Labour fOrce entrY”). The Partners of the EMPLOY Consortium are acting as joint data controllers since they are determining the purposes and the means of processing.
- Categories of Personal Data
The EMPLOY Consortium collects, processes and uses personal information concerning the Users (i.e. the person who registers on the EMPLOY Platform and uses the Services provided on the Online Platform) on the basis of the concluded contract between the parties and in accordance with the General Data Protection Regulation 2016/679 (GDPR). The information may include any data, which you as the User enter, use, or voluntary provide when using the Services of the EMPLOY Platform (such as email, name, position, field of experience), or, respectively any other information which becomes otherwise accessible for the EMPLOY Consortium as a result of requesting and using the Services, as well as any information provided by the User to the Consortium or the EMPLOY Network such as messages, posts, etc.
In order to register on the EMPLOY Platform, the User may be asked to provide e-mail and to enter his/her password. After registration, the User may provide additional personal data to the User’s Account such as name or pseudonym, position, experience, photo. It should be noted that these fields are not marked as mandatory, hence the Users are not obliged to fill them /provide this information/. The EMPLOY Consortium ensures that the information requested to be mandatorily entered by the User, for registration on the EMPLOY Platform, is only the relevant and necessary information for registration, as the website is built in compliance with the requirements for data protection by design and data protection by default.
While visiting the EMPLOY Platform or using our Services the Consortium is also processing online identifiers such as IP address, log files, and/or any other information necessary to reproduce electronic statements made by the User when using the Services of the EMPLOY Platform and for identification of the User in the event of a legal dispute.
Also, if the User wants to subscribe to an EMPLOY event, he/she might be asked to fill in his/her email address.
- Purposes of data processing
The above-mentioned categories of personal data are processed for the following purposes:
- to provide the User with the Services available on the EMPLOY Platform;
- to identify the User, if necessary;
- to register User or Visitor to an EMPLOY event;
- to comply with the legal obligations;
- to exercise or defend the rights and interests of a Partner or the EMPLOY Consortium as a whole protected by law;
- to ensure the proper functioning of the EMPLOY Platform, also ensure network and information security;
- other purposes explicitly provided for in the Terms and Conditions of Use or in this Policy Privacy;
- as well as for statistical purposes;
The EMPLOY Consortium undertakes the due care and bears responsibility for the protection of the User’s information, which has come to its notion in the conduct of provision of the Services, except in the event of force majeure events or Malicious Actions of third parties.
- Legal basis for processing
- Data subject has given consent to the processing of his/her personal data for a specific purpose;
- Data processing is necessary for the performance of a contract to which the User is party, in cases where the Services available on our Website are provided to the User;
- Data processing operations are carried out on the same basis being a part of the steps at the request of the User before concluding the contract - for example when the User registers on the Website;
- Data processing is necessary for the purposes of the legitimate interest pursued by a Partner or the EMPLOY Consortium – as e.g.: in the event of a legal dispute; to prevent or investigate unauthorized access to the User account; to protect the User from malicious attacks and to ensure his/her personal safety;
- Recipients or categories of recipients of the personal data
The personal data of the User will only be disclosed to third parties in certain sporadic cases where the data controllers shall comply with a legal obligation or shall protect their rights. The EMPLOY Consortium may disclose the personal data of the User in cases where he/she has provided an explicit consent upon registration or at a later stage; or where this information is requested by state authorities, court bodies or officials that according to the applicable legislation are competent and authorized to request and obtain such information in compliance with the procedures established by law. In the event that the User or third parties under his/her control has performed Malicious Actions within the meaning of the Terms and Conditions of Use or have violated any rights or lawful interests of third parties, the EMPLOY Consortium shall be entitled to provide the relevant competent authorities with the User’s data in order to initiate the necessary legal procedures, in accordance with the applicable law.
The above-mentioned categories of personal data are accessed solely by the Admins of the EMPLOY Platform.
As the Website is developed under Erasmus + Programme, only anonymized data (statistics) will be provided to the European Commission.
- Transfers of personal data to third countries or international organisations
The data controller does not intend to transfer the personal data of the User to data controllers or processors established in third countries or international organisations.
Should the cases of data transfer to data controllers or processors in third parties or international organizations arise, the data controller shall keep the User informed. In any event, the transfer will be carried out in full compliance with the GDPR in respect of personal data transfer to third countries and only on the provision that the adequate level of protection is satisfied.
- Period for personal data storage
The personal data is stored on the EMPLOY Website, as long as the User is registered. After the User’s account is deleted, all personal data is immediately erased. Thus, the User Account shall no longer exist, and the account name will be anonymized, hence all the messages and posts on the EMPLOY Platform would not lead the identification of the data subject.
The Users have the right to delete his/her own messages and or/posts, which means that this information would no longer be stored on the EMPLOY Platform.
For reporting purposes, statistical data is kept for 5 years after the project end. The statistical data will not render any of the EMPLOY Website users identifiable.
- Data Subject Rights
The following rights pursuant to Art. 13-20 GDPR, and to the applicable national data protection legislation could be exercised:
- the right to be informed about the categories of personal data being processed on the Platform, the legal grounds for processing, the purposes for which the data processing is carried out, etc.;
- the right of access to the personal data processed on the EMPLOY Platform, as well as additional information under Art. 15 GDPR;
- the right to rectification of inaccurate personal data concerning the User or to have incomplete personal data completed;
- the right to erasure (‘right to be forgotten’) of personal data concerning the User, in the cases, set out in Art. 17, paragraph 1 of GDPR;
- the right of restriction of processing – this right applies in several cases stipulated in Art. 18 of GDPR;
- the right to data portability, i.e. the right to receive all personal data processed on the EMPLOY Platform, concerting the User in a structured, commonly used and machine-readable format and to transmit those data to another controller without hindrance from the controller to which the personal data have been provided. This right applies only where the processing is based on consent (Art. 6, paragraph 1, point a), or Art. 9, paragraph 2, point a)), or on a contract (Art. 6, paragraph 1, point b) AND the processing is carried out by automated means.
- Exercise of Data Subject Rights
All Data Subjects (Users) can exercise their rights by sending a message to the following e-mail address: (add the address)
Also, any User has the right to submit a complaint to his/her national data protection authority, if he/she deems that their data is processed in unlawful way.
- Links to other websites
The Consortium has no control over and assumes no responsibility for the content, privacy policies or practices of any third-party sites or services.
By changing the settings of the User’s browser, he/she would be informed about the usage of cookies and be able to decide whether some cookies should be downloaded or to prohibit their storage on his/her device.
- Amendments and updates of this policy
The terminology used in the current document (such as User, Visitor, EMPLOY Consortium, EMPLOY Project) is described in the Terms and Conditions of Use.