1. Introduction
This Privacy Policy informs about the data we collect, why we collect it, how we treat it, to where it can be transferred and how you can update and delete some of said data. Our services, processes and communication systems aim to ensure the highest possible degree of compliance with the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation or GDPR).
This Privacy Policy covers all data subjects located in a country in the European Economic Area (which includes the European Union) or in any included other country or territory (collectively referred to as the European Region).
2. Controllers
The controllers for the processing of the data collected are:
• Centro Europeo de Empresas e Innovación del Principado de Asturias, established in Technology Park of Asturias, CEEI Asturias Building, 33428 Llanera, Asturias Spain.
• Laval Mayenne Technopole, established in 6 Rue Leonard de Vinci, CS 20119, 53001, Laval Cedex, France.
• Instituto Pedro Nunes, established in Rua Pedro Nunes 3030-199 Coímbra, Portugal.
• South West Business and Technology Centre Ltd., established in NSC Campus, Mahon, Cork, Ireland.
• Sociedad de Salvamento y Seguridad Marítima (Centro de Formación Jovellanos), established in Camín del Centro de Salvamento 279, 33393 Gijón, Asturias, Spain.
• Cork Institute of Technology (National Maritime College of Ireland), established in National Maritime College of Ireland, Riganskiddy, Co. Cork P43XV65, Ireland.
• Fundación Tecnalia Research and Innovation (ICT Division), established in Parque Científico y Tecnológico de Gipuzkoa, Mikeletegi Pasealekya, 2, E-20009 Donostia – San Sebastián (Gipuzkoa), Spain.
(hereinafter referred to as “we”).
We hereby inform you that we will process your data in accordance with applicable laws and regulations and in full respect of your rights and, in particular, your privacy and your previous consent for your personal data processing.
3. Data Collection
We collect data about yourself and/or concerning you at the following moments when you use the AT-VIRTUAL Platform:
1. When you send a message through our contact form (‘Contact us’) in the project platform.
2. When you submit the responses to the self-diagnosis online tool for Maritime Safety Training Centres (‘MSTC Diagnosis Tool’) through the project platform.
3. When you subscribe to the project newsletter through the project platform.
4. When you leave a comment and/or write an article on the project platform, if and when this option is available.
5. When you apply to an open call and send the information required.
6. When you visit and browse our platform if you accept the cookies.
3.1. Sending of messages by contact form
You do not need to be registered in the platform to contact us. Whenever you contact us through the contact form, the following data are collected: email address, name, topic of the contact and the message you are sending. We usually store the emails we receive for archive purposes and later contacts.
3.2. Submitting the responses to the self-diagnosis online tool
When you fill in and submit the self-diagnosis online tool for Maritime Safety Training Centres (‘MSTC Diagnosis Tool’) through the project platform, we collect a series of data in order to determine the digitalization status of your organization, which we store and process in order to make analysis to be exclusively used for the purposes of the project (analysis of the organization digitalization status, as well as research on the digitalization status of the Atlantic Area).
3.3. Subscription to newsletter
When you subscribe to the newsletter of the project, we ask that you provide your email address and your name.
3.4. Comments and articles
When you leave a comment on the platform or post an article (when these options are available), the data in the comments/article form as well as the IP address and browser user agent are saved to help with the detection of spam. Generally, the data in the comment form are: email address, name, date and content of the comment.
3.5. Applying to open calls
When you fill in all the templates, send the documents and submit the information for applying to an open call through the project platform, we collect a series of data in order to be able to assess the compliance with the requirements of the call as well as to assess the quality of your proposal with regard to the challenges proposed. We store and process that information in order to exclusively rank the best proposals submitted, select the most appropriate one, and, in agreement with the applicants, disseminate best practices on digitalization solutions for the maritime and safety sector in the Atlantic Area.
3.6. Visiting and use of the platform
Information is collected every time you visit the platform. This collected information is described and explained in the section on the use of cookies.
4. Purposes and grounds for personal data processing
Your personal data will be processed with the following purposes:
• To analyse the level of digitalization of Maritime and Safety Training Centres in the Atlantic Area.
• To provide you with our services (site navigation, newsletter, contact form, etc.).
• To perform scientific research.
• To protect and improve our services and develop new ones.
• To protect the technical functioning of our system.
• To comply with reporting and auditing obligations of the AT-VIRTUAL Project near the financing authorities.
• To fulfil other legal obligations and/or comply with orders from public authorities, including the judicial authorities.
• To process and diffuse statistics, graphic representations and research but only in aggregate and anonymous form.
5. Processing methods
Your data will be:
• Collected electronically.
• Stored in digital format on the server in our availability.
• Protected from risk of destruction, modification, deletion and unauthorized access with efficient physical, logical and organizational security measures.
• Further processed, also in paper format, to the extent and within the time strictly necessary to give effect to the purposes outlined above.
6. Communication to third parties
We may:
• Communicate your data to third parties who work with us and deal with phases of the processes necessary for the proper performance of our activities solely for the purposes indicated above who, if necessary, will be assigned to such processing (and then they will become subcontractors for the processing of your data).
• Communicate and diffuse your data, but only in anonymous and aggregate form, for the purposes indicated above.
• Communicate your data to third parties to comply with reporting and auditing obligations of the AT-VIRTUAL Project and any other legal obligations or, to comply with orders from public authorities, including the judicial authorities, to reply to complaints that the contents you disseminated using our services violate third party rights, or to protect ours rights or third parties under law and / or in accordance with the terms of service.
7. Third party services
We use the following services to process your data.
• MailChimp:
Email address management and message sending service provided by The Rocket Science Group, LLC. (with servers located in the United States) that allows us to manage the contact form. It also allows The Rocket Science Group, LLC. to collect, store and process your email and related usage data in accordance with the terms of its Privacy Policy (
https://mailchimp.com/legal/privacy).
• Like button and Facebook social widgets:
Interaction services with the Facebook social network provided by Facebook Inc. (with servers located in the United States) that use cookies and allow us to make you share your content on the same social network. They also allow Facebook Inc. to collect, store and process usage data of the services under the terms of its Terms of service (
https://www.facebook.com/legal/terms) and Privacy Policy (
https://www.facebook.com/privacy/explanation).
• Tweet button and Twitter social widgets:
Interaction services with the Twitter social network provided by Twitter Inc. (with servers located in the United States) that use cookies and allow us to make you share your content on the same social network. They also allow Twitter Inc. to collect, store and process usage data of the services under the terms of its terms of service (
https://twitter.com/tos) and Privacy Policy (
https://twitter.com/privacy).
• LinkedIn button and LinkedIn social widgets:
Interaction services with the LinkedIn social network provided by LinkedIn Corporation (with servers located in the United States) that use cookies and allow us to make you share your content on the same social network. They also LinkedIn Corporation to collect, store and process usage data of the services under the terms of its terms of service (
https://www.linkedin.com/legal/l/service-terms) and Privacy Policy (
https://www.linkedin.com/legal/privacy-policy).
8. Use of Cookies
The AT-Virtual platform uses cookies to identify information about your session use and personalization of your browser each time you visit. A cookie is a small data file that is stored by the browser when you access the platform.
Many Internet sites and servers use cookies. Many cookies contain a cookie ID, which is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers which contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.
Through the use of cookies, the AT-Virtual consortium can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.
By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to use AT-Virtual website. The website user who uses cookies, e.g., does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.
The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.
9. Data retention period
Your personal data will be kept for the minimum period of time necessary for the purposes described above in 4. and/or for compliance with legal obligations.
The minimum time required is the duration of the project (three years) plus an additional one year. Thus, AT-Virtual will keep your data for four years. After this period, your data will be deleted from the database.
10. Your rights
At any time, you can request:
1. Right to Access - to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data;
2. Right to Rectification - to request that we rectify or update any personal data that is inaccurate, incomplete or outdated;
3. Right to Erasure - to request that we erase your personal data in certain circumstances, such as where we collected personal data on the basis of your consent and you withdraw your consent. This obligation shall, in every case, be compliant with any data retention mandatory obligations to be observed by the data controllers identified above in 2;
4. Right to Restriction of Processing - to request that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal data;
5. Right to Withdraw Consent - where you have given us consent to process your personal data, to withdraw your consent; and
6. Right to Data Portability - to request that we provide a copy of your personal data to you in a structured, commonly used and machine-readable format in certain circumstances.
To exercise your rights, please contact us through the following e-mail:
info@at-virtual.eu. Your requests will be treated with care, so that we can ensure the effectiveness of your rights. You will be asked to prove your identity, so to ensure that personal data are shared only with the owner.
Please note that, in certain cases and in accordance with applicable law, your request may not be satisfied immediately or in full.
In all cases, you will be informed of the measures taken, within 30 days from the time the request is made.
11. Clarifications or doubts
If you have any questions regarding this policy or other privacy issues, or if you wish to exercise any of your rights, please contact us at:
info@at-virtual.eu.