PRIVACY POLICY

LAST UPDATE: 06/03/2024

1. Who we are:

The DIGITAL FIRST project, funded by the Erasmus+ Programme and managed by the European Commission and the European Education and Culture Executive Agency (EACEA), aims to revolutionize informatics education across Europe. With participation from 10 European countries, DIGITAL FIRST seeks to enhance teaching methods and approaches in informatics across primary and secondary schools. By developing and testing innovative pedagogical approaches, the project aims to prioritize functional understanding over technical structures, aligning with the digital-native experience of today’s children. Through dialogue clubs and collaborative efforts, DIGITAL FIRST aims to create an inclusive method for teaching informatics, validating its effectiveness and adaptability through piloting in diverse educational settings. Ultimately, the project strives to equip children with essential digital skills, fostering critical thinking and preparing them to navigate and contribute meaningfully to the digital landscape. Collaborating across borders, Digital First partners are united in their pursuit of several key objectives: 

• Understanding informatics education theory and practice through extensive research and data collection. 
• Developing and testing innovative pedagogical approaches in informatics education, with pilot programs implemented in participating countries. 
• Defining a comprehensive competences catalogue for informatics teachers to ensure consistency and quality in education delivery. 
• Establishing a robust support network for informatics teachers, fostering collaboration and knowledge exchange. 
• Engaging stakeholders from across the education spectrum through dialogue clubs to shape the future of informatics education collaboratively. 

The partners of the DIGITAL FIRST consortium, listed below, process certain types of personal data for the project. Each partner is responsible for the personal data they collect and process during their activities under the framework of the project: 

• Algebra University (Croatia) 
• ALL DIGITAL (Belgium) 
• CFAE Póvoa de Varzim e Vila do Conde (CFAE-PVVC) (Portugal) 
• Industrial Technical Institute “Ferraris Pancaldo” (Italy) 
• Ministry of Education Slovenia (Slovenia) 
• Partners in Learning (Croatia) 
• Primary School Bratov Polančičev Maribor (Slovenia) 
• Primary School Toneta Čufarja Maribor (Slovenia) 
• Project LightHouse (Greece) 
• Secondary school “St. Cyril and Methodius” (Bulgaria) 
• T-HAP (Cyprus) 
• Turku Research Institute for Learning Analytics (TRILA), University of Turku (Finland) 
• Universidade da Coruna (Spain)
• University of Ljubljana, Faculty of Education (Slovenia) 
• Vilnius University (Lithuania) 

For further information, we can be contacted at: lab@algebra.hr 

2. How do we collect your data?

We collect personal data both directly and indirectly: 

Directly. We obtain personal data directly from individuals in a variety of ways, including but not limited to the following cases: 

• an individual subscribes to our newsletter/s; 
• an individual registers to attend meetings and events we host and during attendance at such events; 
• we establish cooperative relationships with an individual; 
• we provide professional services according to our contract with the European Commission; 
• an individual participates in an interview, focus group or survey organized by us. 

Indirectly. We obtain personal data indirectly about individuals from a variety of sources, including: 

• our research partners; 
• our networks and contacts; 
• public and open data sources such as public registers, news articles, and internet searches; 
• social and professional networking sites (e.g., LinkedIn).

3. What types of data do we collect?

We only collect the data that are necessary for the smooth implementation of our project. These data fall into the following categories: 

• contact details (name/surname, e-mail address, street address, mobile phone number, landline phone number); 
• professional information (job title, organization, field of expertise); 
• demographics (e.g., age, gender, nationality); 
• information about what a person knows or believes; 
• videos and photos (from people who attend our events). 

4. Bases of lawful processing

We process personal data on the following legal bases: 

Legal obligations – for processing activities required for compliance both with applicable national and European legislation as well as with the specific legal and regulatory framework of the Erasmus+ Programme. Consent – for processing activities such as organization of surveys, focus groups and interviews, completing of questionnaires, and dissemination of project’s results. 

Contractual obligations – for processing activities such as reporting to the European Commission and complying with the project’s publicity obligations. 

5. What we do with your data?

We process your data with the purpose of: 

• Conducting research (e.g., interviews, surveys, focus groups); 
• Disseminating our project’s results to different types of stakeholders; 
• Sending invitations and providing access to guests attending our events and webinars; 
• Administering, maintaining, and ensuring the security of our information systems, applications, and websites; 
• Processing online requests or queries, including responding to communications from individuals; 
• Complying with contractual, legal, and regulatory obligations. 

6. How we secure your personal data when we process it?

We continuously apply a personal data risk assessment process to identify, analyse, and evaluate the security risks that may threat your personal data. Based on the results of this risk assessment, we define and apply a set of both technical and organizational measures to mitigate the above security risks, including but not limited to: 

• Data Protection Policies to guide our personnel when processing your data; 
• Written contracts with organizations that process personal data on our behalf; 
• Non-Disclosure Agreements with our personnel; 
• Back up process, antimalware protection, access control mechanisms, etc. 
• Some of our partners have appointed a Data Protection Officer. 

7. Do we share personal data with third parties?

We may occasionally share personal data with trusted third parties to help us deliver efficient and quality services. When we do so, we ensure that recipients are contractually bound to safeguard the data we entrust to them before we share the data. We may engage with several or all the following categories of recipients: 

• Parties that support us as we provide our services (e.g., cloud-based software services such as Dropbox, Microsoft SharePoint, Google); 
• Our professional advisers, including lawyers, auditors, and insurers; 
• Dissemination services providers (e.g., Mailchimp); 
• Law enforcement or other government and regulatory agencies or other third parties as required by, and following applicable law or regulation; 
• The European Commission according to our relevant contractual obligations. 

8. Do we transfer your data outside the European Economic Area?

We do not own file servers located outside the European Economic Area (EEA). However, some partners may use cloud and/or marketing services from reputable providers such as SharePoint, Dropbox, Mailchimp, Google, etc., situated both inside and outside the EEA. We always check that such providers comply with the relevant GDPR requirements before start using their services. 

9. Do we use cookies?

Our websites use cookies. Where cookies are used, a statement will be sent to your browser explaining the use of cookies. To learn more, please refer to our cookie policy. 

10. Your rights

You have the following rights regarding our processing of your data: 

• Right to withdraw consent – You can withdraw consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. 
• Right of access – You can ask us to verify whether we are processing personal data about you and, if so, to have access to a copy of such data. 

• Right to rectification and erasure – You can ask us to correct our records if you believe they contain incorrect or incomplete information about you or ask us to erase your data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected. 
• Right to restriction of processing – You can ask us to temporarily restrict our processing of your data if you contest the accuracy of your data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction. 
• Right to data portability – In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another entity. 
• Right to object – You can object to our use of your data for direct marketing purposes, including profiling or where processing has taken the form of automated decision-making. However, we may need to keep some minimal information (e.g., e-mail address) to comply with your request to cease marketing to you. 
• Right to make a complaint to your local Data Protection Authority (DPA) (see https://ec.europa.eu/justice/article-29/structure/data-protection authorities/index_en.htm) regarding any concerns you may have about our data handling practices. 

To ask us to do anything of the above, you can contact us by email: lab@algebra.hr. We will promptly examine your request against the relevant requirements of the laws and regulations governing privacy and personal data protection and we will answer the latest within 30 days after receiving your request. We will ask you for some kind of identification (e.g., photocopy of your identity card or passport) to avoid the unauthorized reveal of your data. If, for reasons of the complexity of the request or a multitude of requests, we are unable to respond promptly, we will notify you within 30 days of any delay, which in no case may exceed two months from the expiration of the 30-day deadline. 

11. How long do we retain personal data?

We retain personal data to provide our services, stay in contact with you, and comply with applicable laws, regulations, and contractual obligations to which we are subject. Please note that we must retain data concerning projects funded by the Erasmus+ Programme for up to five years after the end of the project (unless further retention is requested by auditors). After the expiry of the retention period, and unless further legitimate grounds for retention arise, we will dispose of personal data securely. 

12. Disclaimer of liability for third-party websites

Although our site may contain links to third-party sites, including the sites of the consortium partners, we are not responsible for the privacy practices or content of these sites, and we expressly disclaim any liability for any loss or damage that may be caused using these links. We do not monitor the privacy practices or the content of these sites. If you have any questions about the privacy practices of another site, you should contact the site’s responsible personnel. We suggest you read the privacy policy of each website you interact with, before allowing the collection and use of your personal data. 

We may also provide social media features that allow you to share information on your social networks and interact with our project on various social media sites. The use of these social media features may result in the collection or sharing of information about you. We recommend that you check the privacy policies and regulations of the social networking sites you interact with, so that you can be sure that you understand what information may be collected, used, and disclosed by these sites. 

13. Children

We do not knowingly collect, use, or disclose information from children under the age of 16. If we learn that we have collected the personal information of a child under 16 we will take steps to delete the information as soon as possible. Please immediately contact us if you become aware that a child under 16 has provided us with personal information. 

14. Revisions of this Privacy Policy

This Privacy Policy is valid from 06.3.2024. and replaces any other previous notifications that we had issued in the past regarding our data management practices. We reserve the right to revise this Policy at any time. The current version will be always uploaded to our website indicating the date of entry into force, so you know when the most recent revision took place. If there are critical changes in this policy or our data practices change significantly in the future, we will notify you.