1. GENERAL PROVISIONS
We are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person. This Privacy Policy (the “Privacy Policy”) describes how IDC Italia srl (“IDC” or “we”), as a project coordinator, handles, processes and protects personal data within the project SAGE (Grant ID: 101195471) and subscribers and visitors to the website “https://www.greendealdata.eu” (the “users” or “you”)
The SAGE project will establish a fully operational Green Deal Data Space (GDDS) aimed at enhancing the accessibility, integration, and utilization of green and environmental data across the EU to support key pillars of the European Green Deal—Zero Pollution, Climate Adaptation, Biodiversity, and the Circular Economy Action Plan.
As used in this Privacy Policy, “personal data” means information that identifies or can identify you. This Privacy Policy also informs you about your rights regarding personal data processing and how and by what means you can exercise them.
We recommend that you carefully familiarize yourself with this Privacy Policy.
2. DATA CONTROLLER AND CONTACT DETAILS
The controller of your personal data is IDC Italia srl, with its registered office at Viale Monza 14, 20127 Milan, Italy.
For requests and/or complaints related to this Privacy Policy you can contact us via e-mail at Richard Stevens: rstevens@idc.com. IDC’s Privacy Compliance Officer can be contacted at privacy@idc.com.
3. PURPOSES AND LEGAL BASES OF THE DATA PROCESSING
The following table describes each processing activity covered by this Privacy Policy, the purpose, the personal data undergoing processing and the legal basis
| Processing | Purpose | Processed personal data | Legal Basis |
| Project management | Managing the project (e.g., sending emails to the Project Consortium, organizing meetings and events, administering the project, etc.) | Full nameEmail address | Necessity for the performance of a task carried out in the public interest (Art. 6(1)(e) GDPR) |
| Online meetings | Recording plenary online meetings for internal use to the benefit for the project | Full nameEmail addressAudio and video streams Screen sharing data (if enabled) Chat messages | Consent of the data subject (Art. 6(1)(a) GDPR) |
| Project’s outcomes | Publishing deliverables according to the Grant Agreement | Full nameEmail address | Necessity for the performance of a task carried out in the public interest (Art. 6(1)(e) GDPR) |
| Newsletter subscription | Disseminating project’s activities via newsletter | First and Last nameEmail addressIP address | Consent of the data subject (Art. 6(1)(a) GDPR) |
| Social media | Disseminating project’s activities via social media | First and Last nameSocial media profiles, incl. public postsPictures | Consent of the data subject (Art. 6(1)(a) GDPR) |
| Inquiry response | Responding to inquiries submitted through our contact form | First and Last nameEmail addressNametag / NicknameIP address | Consent of the data subject (Art. 6(1)(a) GDPR) |
| Security | Implementing security measures for the website and the project infrastructure | IP address | Legitimate interest of the data controller (Art. 6(a)(f) GDPR) |
4. COOKIES
This website uses cookies and other technologies (such as site measuring software and user experience software) to enhance your online experience and learn about how you use our website and other services in order to improve the quality of the SAGE project. We may combine data gained through cookies with other data you provide to us.
Upon visiting our website, we will ask for your consent to use cookies.
Below you will find the basic information about cookies and explanation on how exactly our website makes use of them.
What are cookies?
Cookies are small text files sent to your device. Although cookies contain identifying information, they do not contain any information that identifies you personally but rather allow us to recognize you upon return to our website. If you do not want to accept a cookie while visiting our website, you should be able to change the settings in your browser to disable this function (more information on how to do it – below), but there might be sections of the site that you will be unable to access if you do so.
Why cookies are being used on this website?
We utilize cookies to help us analyse how users use our services, and similar technologies (e.g. device identifiers, ad tags) to recognize you and/or your device(s) on, off and across different devices and our services, as well as to improve the services we are offering, to improve marketing, analytics, or website functionality.
What type of cookies are placed?
During your browsing sessions the following types of cookies may be employed by our website:
- user interface customization cookies (i.e. cookies memorizing your preferences);
- authentication cookies (i.e. cookies allowing you to leave and return to our websites without having to re-authenticate yourself);
- video player cookies (i.e. cookies storing data needed to play back video or audio content and storing your preferences);
- first party analytics cookies (i.e. cookies memorizing the pages you visited and providing information about your interaction with those pages); and
- third party analytics cookies (i.e. cookies from third party suppliers tracking our website’s statistics and vice versa).
Likewise, we will track your process across our website to verify that you are not a bot and to optimize our services:
- information regarding your browser and device;
- data collected through automated electronic interactions;
- application usage data;
- statistical information about your use of our website.
If you send us an email (e.g. to request information or provide feedback on website content), the information you provide will only be used to help us to gather the information requested and to respond to your message.
When you visit any of our websites, our servers also log your global IP address, which is a number that is automatically assigned to the network your computer is part of.
How long are the data collected by cookies retained?
The processing of your personal data collected by cookies is based on your consent which can be withdrawn at any time via browser settings. If you accept the cookies on our website, we will collect and process your personal data 12 months after the conclusion of the Project, i.e., until 28 February 2029. All persistent cookies are removed from your device after the expiration of this period, and we will no longer process your personal data.
How do I change my cookie settings?
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
Links to External Websites
We may refer to, or establish relations with, other companies, organizations and public bodies that will enable you to access their websites directly from ours. Each of them will operate its own policy regarding the use of cookies and collection and use of information. If you have any concerns regarding the way your data will be used, we recommend referring to the privacy statements on relevant websites.
IDC will strive to provide you with links to high quality, reputable websites which we think will be of interest and relevance to you. However, please note that we are not responsible for the content of such websites and cannot accept responsibility for any issues arising in connection with the third party’s use of your data, the website content or the services offered to you by these websites.
Social media
When you visit, like, follow or otherwise engage with our social media pages or accounts (including, to the applicable extent, use of your social media user account), we may be considered joint controllers of your personal data with the provider of the particular social media/network. We do not use your personal data in any other way than described in this Privacy Policy. To find out more information about how the social media/network provider uses your personal data and other information, please contact the respective provider.
5. SHARING AND TRANSFER of PERSONAL DATA (RECIPIENTS OF PERSONAL DATA)
Your personal data may be shared with:
- other IDC entities or affiliates from the IDC group (“IDC Group”) based in the European Union. Updated contact details and other information on all companies of the IDC group can be found at https://www.idc.com/about/worldwideoffices
- other participants and contributors to the SAGE project, listed here, including their subcontractors, insofar as their activities fall within the scope of the SAGE project.
- providers of IT, marketing or administrative services used within the SAGE projects
- external auditors, consultants, tax advisors and legal representatives bound by confidentiality obligation for the protection of our legitimate interests;
- public prosecution bodies, courts and administrative authorities in accordance with our legal duties.
We have entered into agreements on processing of personal data with our processors of personal data (with the exception of cases where the conclusion of such agreement is not obligatory, for example, when transferring personal data to public authorities), which ensure at least the same level of protection thereof as this Privacy Policy.
6. DATA SECURITY
We have implemented and maintain appropriate technical and organizational measures, internal controls and information security processes in accordance with legal requirements and market standards corresponding to a possible threat to you as the data subject. We also take into consideration the state of technological development in order to protect your personal data from accidental loss, destruction, alterations, unauthorized disclosure, or access. Such measures may, among other things, include taking reasonable steps to ensure the liability of relevant employees who have access to your data, training of employees, regular backups, procedures for data renewal and management of incidents, software protection for devices on which personal data are stored, etc.
7. YOUR RIGHTS AS A DATA SUBJECT
If you wish to exercise any of your rights according to this Article or according to applicable legislation, please contact us using the contact information listed in Article 2 above.
Also, if applicable, we will inform each recipient to whom your data have been provided of the measures taken or of the erasure of your personal data or of the restriction of processing in accordance with your request, if such a notification is possible and/or does not involve disproportionate effort.
We do not carry out automated decision-making or profiling.
Access to and portability of your personal data
You have the right to obtain confirmation as to what personal data we process or do not process with respect to you. Should you request it, we can send some of your personal data (namely the data that we process on the basis of the fulfilment of a contract and/or your consent) directly to a third party (to another data controller) whom you state in your request, provided that such request does not affect the rights and freedoms of other persons, and provided that it is technically feasible You can access your personal data via aforementioned contact details.
Withdrawal of consent
Granted consent to the processing of your personal data can be withdrawn at any time without reason. For such purposes, please use the unsubscribe button in emails that we sent to you or contact us via the contact details set out in this Privacy Policy. In such a case, we will erase your personal data within 30 days from the withdrawal of your consent. Please note that the withdrawal of your consent does not affect the lawfulness of processing conducted based on consent prior to its withdrawal
Rectification of your personal data
According to applicable legislation, you have the right to rectify your personal data that we are processing if you find that it is inaccurate or incomplete. To request rectification of your personal data, please contact us via the contact details.
Erasure of your personal data
You can request erasure of your personal data at any time. The scope within which we can comply with your request for erasure of personal data may be limited by our statutory obligations to store some personal data, particularly based on accounting and tax regulations, etc. Further, we will also erase all your personal data (and ensure thereof by the processors that we engage) if you withdraw your consent.
Restriction of processing
If you request us to restrict the processing of your personal data, for example when you contest the accuracy, lawfulness or our need to process your personal data, we will limit processing of your personal data to a necessary minimum (storage), and if applicable we will only process this data to establish, exercise or defend legal claims or where necessary in order to protect the rights of other natural or legal person, or for other limited reasons required by the applicable law.. In case the restriction is lifted, and we continue processing your personal data, you will be informed accordingly without undue delay. The request for restriction of processing can be made using the contact details.
Objections to processing
You can object to data processing. If we do not demonstrate any compelling legitimate reasons for the processing which would override your interests or rights and freedoms, we will no longer process your personal data and will delete it without undue delay. Objections to processing can be raised using the contact details.
Complaint to a Data Protection Authority
You have the right to lodge a complaint pertaining to processing of data conducted by us with the competent data protection authority, i.e. the Italian Data Protection Authority, 121 Piazza di Monte Citorio, Roma 00186, Italy; website: www.garanteprivacy.it.
UPDATES TO the PRIVACY POLICY
We may modify or update the Privacy Policy from time to time. Any changes to this Privacy Policy shall become effective with publication of the updated Privacy Policy at https://www.greendealdata.eu/privacy-policy/