PRIVACY & COOKIES POLICY

PULCHRA is committed to protecting your privacy. This Privacy Policy explains how we collect and use your personal data and which rights and options you have in this respect. Please also refer to our Cookie Policy which explains the use of cookies and other web tracking devices via our website.

We collect, use and are responsible for certain personal data about you. When we do so, we are subject to the General Data Protection Regulation, which applies to the processing of personal data in the context of the activities of an establishment of a controller or a processor in the Union. We are responsible as ‘controller’ of that personal information for the purposes of those laws. By submitting any Personally Identifiable Information to us, you consent and agree that we may collect, use and disclose such Personally Identifiable Information in accordance with this Privacy Policy.

WHICH PERSONAL DATA DO WE COLLECT?

We may collect and use the following personal data about you:

• Your name and contact information, including email address and telephone number, job title and company/organisation details
• In relation to specific projects, we may collect information including your nationality, geographical location, such as city, region, or country; gender, age, sector of employment
• Your responses to surveys, competitions and promotion of events
• Any special requirements or points of interest you indicate during your registration to events.

HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect most of this personal data directly from you — in person, by telephone, text, email and via our website and platform (online forms). In particular, we may collect information in the following cases:

1. If you visit us through PULCHRA’s website available at https://pulchra-schools.eu/ (“Site”) or visit and register on PULCHRA platform (“Platform”)  at https://platform.pulchra-schools.eu, or contact our staff members directly.

• • We may collect your personal data when you contact us with individual questions via the form to be accessed in our Site or by contacting our staff directly through the email addresses provided in our Site.
  • We may collect your personal data when you contact us for the registration of PULCHRA events, including our PULCHRA City Challenges, PULCHRA workshops, and other events related to the work of PULCHRA.
  • We may collect information from cookies on our website. For more information on our use of cookies, please see our cookies policy. In addition, we may collect, use and share anonymous data such as statistical information about the use of the Site.

2. If you are an external stakeholder seeking information about PULCHRA and our activities.

• • We may collect your name and contact information, including but not limited to name, job title, business address, email address and telephone number following the exchange of business cards or when you request orally or in writing to be added to our mailing list.
  • We may use your details to contact you about PULCHRA’s activities, programmes and events and to organise such activities, programmes and events.

3. If you register as a representative of a member of PULCHRA for the PULCHRA online platform and newsletters.

• • We collect personal data, such as name, email address, business address, job title, phone number, user name, and password, from you, if you are a representative of an PULCHRA member when registering for the PULCHRA tools. We use this information to provide you with access to the PULCHRA tools.
  • We may also use your details to contact you about PULCHRA’s activities, programmes and events and to organise such activities, programmes and events.

4. If you register as a learner using any PULCHRA learning platform.

• • We may collect your name and contact information, including but not limited to name, address, email address and telephone number during your signing up on the learning platform.
  • We may use your details to contact you about any relevant PULCHRA training activities, programmes and events.

Your personal information is required to provide services to you. If you do not provide the personal information we ask for, it may delay or prevent us from providing services to you.

FOR WHICH PURPOSES WILL WE USE YOUR PERSONAL DATA?

Under data protection law, we can only process your personal information if we have a proper reason for doing so, e.g.:

• to comply with our legal and regulatory obligations;
• for the performance of our contract with you or to take steps at your request before entering into a contract;
• for our legitimate interests; or
• where you have given consent such as in the case of specific projects where your data is shared for reporting purposes (for example with the European Commission) and for targeted communications

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

We do not sell or otherwise disclose personal data we collect about you, except as described in this Privacy Policy or as we disclosed to you at the time the personal data are collected.

PROMOTIONAL COMMUNICATIONS AND OPT-OUT

We may use your personal data to send you updates (by email, text message, telephone or post) about PULCHRA’s activities and events.

We will always treat your personal information with the utmost respect and never share it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

• using the ‘unsubscribe’ link in emails/newsletters received;
• leaving the PULCHRA platform via editing the personal settings in the account;
• writing a personal message to the coordinator with the request to remove your data from PULCHRA’s databases

WITH WHOM WILL WE SHARE YOUR PERSONAL DATA?

We might share personal information with:

• third parties we use to help us run our project, e.g. website hosts,
• third parties approved by you, e.g. social media sites you choose to link your account to;

We only allow our service providers to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. Our Site contains links to third-party websites which are not managed by PULCHRA. Moreover, any personal data you provide on third-party websites is subject to those third-parties’ privacy policies.  We are not responsible for the practices and policies of such third-party websites.

WHERE IS YOUR PERSONAL DATA HELD?

Personal data may be held at our offices and those of our third-party agencies, service providers, representatives and agents as described above.

FOR HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

We will keep your personal data as long as we share information with you and as long as we are providing services to you. Thereafter, we will keep your personal data for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law.

We will not retain your personal data for longer than necessary for the purposes set out in this policy.

TRANSFERRING YOUR PERSONAL DATA OUT OF THE EU

To deliver services to you, it is sometimes necessary for us to share your personal data outside the EU, e.g.:

• with your and our service providers located outside the EU;
• if you are based outside the EU;
• with services providers used to provide services to our members’ legitimate interests

These transfers are subject to appropriate safeguards as outlined in Article 46 GDPR.

KEEPING PERSONAL DATA ABOUT YOU SECURE

We have appropriate security measures to prevent personal information from being accidentally lost, used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

HOW TO COMPLAIN?

We hope that we can resolve any query or concern you may raise about our use of your data.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Greece is the Hellenic Data Protection Authority who may be contacted by telephone at +30-210 6475600 or email at contact@dpa.gr

UPDATES TO THIS PRIVACY POLICY

This Privacy Policy is effective from 01/02/2020. We reserve the right to update and change this Privacy Policy from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. In case of any such changes, we will post the changed Privacy Policy on our website or publish it otherwise. The changes will take effect as soon as they are posted on this website.

HOW TO GET IN TOUCH WITH PULCHRA?

We welcome your views about our websites and our Privacy Policy. If you would like to contact us with any queries or comments, please send an email to pulchra.greece@gmail.com

Cookie Policy

HOW DO WE USE COOKIES?

We use cookies to automatically collect information about website users when they navigate on our Site. Cookies are small text files placed on your web browser by websites that you visit while browsing the Internet. Cookies are widely used to help make websites work efficiently as well as to analyse traffic on websites. Cookies also allow websites to tailor information to individuals based on browsing preferences. You can enable, disable or delete cookies through your Internet browser. In order to do this, follow the instructions provided by your browser.  However, if you choose to disable cookies, some features of our Site may not work properly.

WHAT COOKIES DO WE USE?

• Strictly necessary cookies. Some cookies are strictly necessary in order to enable you to browse on our Site and use its features.
• Performance cookies. We use Google Analytics cookies to collect information about the use of our Site, for instance which pages visitors go to most often, and if they get error messages from web pages. This helps us improve your browsing experience. Google Analytics analyses your interaction with our website and stores information about IP address, operating system, web browser, pages visited, demographics of the users, the device used, and where the visit originated. Google provides certain privacy options and choices in this regard, which are described here.

SOCIAL WIDGETS

Our Site has buttons that link to Facebook, LinkedIn, Twitter and YouTube. The providers of these third-party social widgets may set cookies to collect information regarding our Site users and their interactions with the social widgets.  Please review the privacy policies of the social widget providers for more information.