Last update: April 26, 2024
This Privacy Policy describes how the project ValEUs – Research & Education Network on Contestations to EU Foreign Policy (hereinafter ‘ValEUs’) processes your personal data concerning its internet presence set out below.
https://valeus.eu/
https://twitter.com/ValEUsProject
https://www.youtube.com/@ValEUsProject
https://www.facebook.com/ValEUsProject
https://www.linkedin.com/company/valeus-project/
https://podcasters.spotify.com/pod/show/valeus-project
Types of data processed
- Content data (e.g. text entries, photographs, videos)
- Contact data (e.g. email, phone numbers)
- Meta/communication data (e.g. device information, IP addresses)
- Usage data (e.g. internet presence visited, interest in content, access times)
- Location data (data that indicates the location of an end user’s end device)
For what purposes do we process personal data (exemplary)?
- Provision of the ValEUs internet presence and improvement of its user-friendliness
- Contact requests and communication (e.g. the ValEUs newsletter)
- Reach analysis (e.g. access statistics, recognition of returning visitors)
- Security measures
- Tracking (use of cookies)
- Server monitoring and error detection
- Reporting towards granting authorities (e.g., the European Education and Culture Executive Agency (EACEA) co-funding the ValEUs project)
Legal grounds
General Data Protection Regulation (GDPR):
- Consent (Article 6(1) GDPR) – The data subject has given their consent to the processing of their personal data for one or more specific purposes.
- Legitimate interests (Article 6(1) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by ValEUs or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National data protection and privacy law:
- In addition to compliance with the GDPR, ValEUs partners will comply with applicable national data and privacy protection legislation.
ValEUs website and channels
Website
Personal data we process in respect of visitors to our websites includes:
- Content data (e.g. text entries, photographs, videos)
- Contact data (e.g. email, phone numbers)
- Meta/communication data (e.g. device information, IP addresses)
- Usage data (e.g. website visits, interest in content, access times)
Contact data will be collected based on consent, primarily concerning email addresses, through voluntary enrolment in the ValEUs newsletter. ValEUs only sends newsletters, emails, and other electronic notifications (hereinafter ‘newsletters’) based on consent.
Social media and podcast
ValEUs maintains an online presence within social networks and podcast services. Processing user data in this context to communicate with active users or offer information about ValEUs.
Personal data we process in respect of visitors to our online presence within social networks and podcast services includes:
- Content data (e.g. text entries, photographs, videos)
- Contact data (e.g. email, phone numbers)
- Meta/communication data (e.g. device information, IP addresses)
- Usage data (e.g. online presence visits, interest in content, access times)
Please note that user data may be processed outside the European Union. This may result in risks for the users because, for example, the enforcement of the users’ rights could be made more difficult.
Furthermore, user data within social networks and podcast services is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behaviour and the resulting interests. The user profiles can, for example, be used to place adverts within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on users’ computers, mobile devices, or any other device, where usage behaviour and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used (especially if the users are members of the respective platforms and are logged in to them).
ValEUs refers to the data protection notices and information provided by the operators of the respective networks, which provide a detailed description of the respective forms of processing and the possibilities of objection (opt-out).
Requests for information and the assertion of data subject rights can be most effectively asserted with the providers. Only the providers can access the user’s data, take appropriate measures, and provide information directly.
Special information for Facebook: ValEUs is jointly responsible with Facebook Ireland Ltd. for collecting (but not further processing) data from visitors to the ValEUs Facebook page (so-called ‘fan page’). This data includes information about the types of content that visitors view or interact with or the actions they take (see under ‘Things you and others do and provide’ in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under ‘Device information’ in the Facebook Data Policy: https://www.facebook.com/policy).
Cookies
Cookies are text files that contain data from websites or domains visited and are stored by a browser on the user’s computer, mobile device, or any other device. Cookies are primarily used to store information about a user during or after their visit to an online service. The information stored may include, for example, the language settings on a website, the login status, or the location where a video was watched.
The legal basis on which ValEUs processes your personal data with the help of cookies depends on whether ValEUs asks for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your consent. If your consent is not requested, the data processed using cookies will be used to fulfil ValEUs’ tasks (e.g., to ensure the reliable operation of the ValEUs’ internet presence and to improve it).
A distinction is made between the following cookie types and functions:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after users have left an online service and closed the browser.
- Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or favourite content can be displayed directly when users visit a website again. The interests of users who are used for reach measurement or marketing purposes can also be stored in such a cookie.
- First-party cookies: First-party cookies are set by ValEUs itself.
- Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process usage information.
- Necessary (also: essential or absolutely necessary) cookies: Cookies may be absolutely necessary for a website’s operation (e.g., to save logins or other user input or for security reasons).
- Statistical, marketing and personalisation cookies: Cookies are also generally used to measure reach and when users’ interests or behaviour (e.g. viewing specific content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This process is also referred to as ‘tracking’, i.e. tracking the potential interests of users. If cookies or ‘tracking’ technologies are used, you will be informed separately in the data protection information or when consent is obtained.
Storage period: If ValEUs does not provide explicit information on the storage period of permanent cookies (e.g. as part of a so-called cookie opt-in), please assume that the storage period can be up to two years.
General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as ‘opt-out’). You can initially declare your objection using your browser’s settings, e.g., by deactivating the use of cookies (although this may also restrict the functionality of the online offer).
Web analysis, monitoring and optimisation
Web analysis (also known as ‘reach analysis) is used to analyse the flow of visitors to the ValEUs’ internet presence. With the help of the reach analysis, it can be recognised, for example, at what time the ValEUs’ online offer or its functions or content are most frequently used. It also enables ValEUs to understand which areas require optimisation. This includes the following purposes:
- Reach analysis (e.g. access statistics, recognition of returning visitors)
- Tracking (use of cookies) and visitor action analysis
- Security measures, server monitoring and error detection
For these purposes, so-called user profiles can be created and stored in a file (so-called ‘cookie’), or similar procedures with the same purpose can be used. This information may include, for example, content viewed, websites visited, and elements used there, technical information such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.
The IP addresses of users are also stored. However, ValEUs uses an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored for web analysis, A/B testing, and optimisation; instead, pseudonyms are used. This means that both ValEUs and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.
ValEUs website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to analyze how visitors interact with our website. Google Analytics collects data such as frequency of visits, the pages accessed, and prior websites visited before arriving at our site. This information is processed to enhance our website and the services we offer, ensuring a better user experience. The data collected includes only the IP address assigned to users on the date of their visit and is anonymized to prevent personal identification. We do not merge this data with any personally identifiable information. Google Analytics uses cookies to identify a unique user during return visits; however, these cookies are only operable by Google, adhering to Google Analytics Terms of Service and the Google Privacy Policy. Users have the right to refuse the use of cookies by selecting the appropriate settings on your browser, and they can also opt-out of Google Analytics by installing the Google Analytics opt-out browser add-on.
Plugins, embedded functions and content
ValEUs integrates functional and content elements into its online offering that are obtained from the servers of the respective providers (hereinafter referred to as ‘third-party providers’). These may be, for example, graphics, videos or social media buttons as well as contributions (hereinafter uniformly referred to as ‘content’). The integration always requires that the third-party providers of this content process the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is, therefore, required to display this content or function. ValEUs aims to only use content whose respective providers only use the IP address to deliver the content. YouTube videos are integrated in ‘Enhanced Privacy’ mode so that data is only transmitted to Google when the video file is played.
Data processing by third parties
As part of the processing of personal data, data may be transferred to other bodies, companies, legally independent organisational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such a case, ValEUs observes the legal requirements and, in particular, concludes corresponding contracts or agreements with the recipients of your data that serve to protect your data.
Furthermore, ValEUs can be required to provide selected personal data towards granting authorities co-funding the project to demonstrate its successful implementation. In such cases, personal data is only transferred if compliance with the GDPR is guaranteed by the respective third party. In particular, this concerns the European Education and Culture Executive Agency (EACEA). ValEUs will exclusively transfer data to the EACEA through the Funding & Tenders Portal. Please find the respective Privacy Statement below:
Data processing outside the EU
If data is processed in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.
Subject to express consent or transfer required by contract or law, the data will only be processed in third countries with a recognised level of data protection and contractual obligations through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR), see the information page of the EU Commission:
Retaining personal data
ValEUs will not retain your personal data for any longer than necessary for the purposes for which we use them. Further explanations on the retention specific of personal data can also be found in the individual sections of this Privacy Statement
Furthermore, ValEUs will retain and use your personal data to the extent necessary to comply with our legal obligations (e.g., reporting on the implementation of ValEUs towards the European Education and Culture Executive Agency (EACEA) up to 5 years after the official conclusion of the project).
Erasure of data
The data processed by ValEUs will be deleted in accordance with the legal requirements as soon as the consents permitting processing are revoked or other authorisations cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose); if the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise or defence of legal claims or to protect the rights of another natural or legal person. Further explanations on the erasure of personal data can also be found in the individual sections of this Privacy Statement.
Security measures
- SSL encryption (https): SSL encryption is used concerning all ValEUs internet presence. You can recognise such encrypted connections by the prefix https:// in the address bar of your browser.
What are your data protection rights?
As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you, which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw any consent you have given at any time.
- Right to information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: You have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you in accordance with the legal requirements.
- Right to erasure and restriction of processing: You have the right to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the legal requirements.
- Right to data portability: You have the right to receive the data concerning you, which you have provided to ValEUs, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.
- Complaint to the supervisory authority: You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.
Changes to our privacy policy
ValEUs asks you to inform yourself regularly about the content of this Privacy Statement. ValEUs will adapt this Privacy Statement as soon as changes to the data processing carried out make this necessary. ValEUs will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification. If ValEUs provides addresses and contact information of companies and organisations in this Privacy Statement, please check this information before contacting these companies or organisations, as the addresses provided may change over time.
Contact
If you have any questions about how we process your personal data, please let us know by sending an email to contact@valeus.eu. We will be happy to assist you.