PRIVACY POLICY

1. Who is the Data Controller?

1.1. The Company with the company name “ECAS - European Citizen Action Service”, address: BeCentral Cantersteen 12 B-1000 Brussels, Belgium , Telephone: +32 (0) 2 548 04 90, email: info(at)ecas.org, is the Data Controller for the processing of the User’s Personal Data (herein after referred to as "Data Controller").

1.2. Data Controller's Contact details: For any issue or concern with regards to the present Privacy Policy and to the processing of User's personal data or data uploaded by the User to use the Platform, the User can communicate with the Data Controller, by using one of the following alternatives:

By calling at +32 (0) 2 548 04 90, from Monday to Friday from 10.00 a.m. to 18.00 p.m. EET (Eastern European Time)
By sending an email at the following email address: info(at)ecas.org
By sending correspondence to the following address: BeCentral Cantersteen 12 B-1000 Brussels, Belgium

2. What is the purpose and the legal basis for User’s data processing?

2.1. Platform's operational purpose is to collect opinions of users via questionnaires. The opinions are processed in order to gain insights, gather and present valuable ideas and suggestions on the topics addressed in the questionnaires. Users can respond anonymously (without providing any personal information) or can voluntarily register in order to submit eponymous answers. User's answers are translated into English and are presented in Reports. For the specific purpose of processing, the legal basis is User's prior consent.

2.2. To send User informative emails with the purpose to inform him about new activities, projects and other issues of interest of the Platform. For this purpose of processing the legal basis is the User's prior consent.

2.3 Processing of data for reasons related to Data Controller's compliance with legal obligations. In such cases processing of data takes place for only the necessary time period in order for Data Controller to comply with obligations imposed by various legal provisions.

In case of the above provisions where the legal basis is User's prior consent, the User can always withdraw his consent at any time without affecting the legitimacy of the data based on consent prior to its withdrawal.

3. Types of data collected

3.1 Personal data

3.1.1 Registration- account creation:
In order for a User to voluntarily create an account in the Platform, the User should fill in the necessary data: his nickname, email address, and password

3.1.2 Submitted questionnaire responses
The Platform collects user answers (that is opinions on various subjects) on questions made via Platform's questionnaires. These answers are analyzed and presented in a questionnaire results page. The User is strictly advised to conform the platform's "code of conduct for successful participation" and avoid posting publicly any personal data that do not wish to be publicly available on the Platform.

3.1.3. Platform's communication for reasons related to User's permitted use of the Platform.
In order for the Platform to communicate with the User for the above purposes, Data Controller can process all data relating to User's account, uploaded content and data related to the User's use of the Platform.

3.2 Usage data

We may also collect information how the webpage is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our webpage that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

4. How the Platform collects data

4.1 The information can be collected by the following ways:
4.1.1 When the User registers and creates an account on the Platform.
4.1.2 When the User submits answer's on the Platform's questionnaires
4.1.3 When the User visits the Platform and agrees to the installation of cookies (as per the Platform's Cookie Policy in article 11 below) and the collection of the User’s personal data such as the IP address, operation system, type and browser edition etc.

5. How long are User's data stored and when are they deleted?

5.1. User's account data:
Without prejudice to User's deletion/erasure right mentioned below, the Data registered and stored in the User's account will be stored as long as the User wishes to make use of the Platform for the purpose mentioned above. In case a User wishes to delete his account, he can delete his account through account's settings or contact Data Controller at the above mentioned contact details.

5.2. Platform's communication for reasons related to User's permitted use of the Platform.
Data related to such communication will be stored only as long as the User wishes to use the Platform and maintains his account. In case a User wishes to delete his account he can delete his account through account's settings or contact Data Controller at the above mentioned contact details.

5.3. Statistical analysis for the optimization of the Website
Regardless of the above mentioned provisions of article 5, Data Controller will store and process only necessary data for the period required in order to comply with its obligations imposed by law each time (compliance with fiscal obligations etc).

5.4. Processing of personal data for the purposes of conducting statistical analysis.
Please see cookies policy (article 11 ) below.

6. What are User's rights ιn relation to the processing of his data and how can he exercise these rights?

6.1 The Data Controller respects User's right in relation to data processing.

6.2 The User can exercise his rights by contacting the Data Controller at the following contact details: Telephone: +32 (0) 2 548 04 90, email: info(at)ecas.org

For User's facilitation, User's rights are included in the following table along with a short explanation of each right (reference to articles corresponds to article of GDPR 2016/679):

Right	Explanation
Access (article 15)	The User can ask the Data Controller to: confirm whether the Data Controller processes User's personal data give the User access to data that the User does not dispose give the User other information related to User's personal data such as which are the data that the Data Controller disposes, what are the purposes of processing, to whom are these data disclosed, whether these data are transferred in foreign countries and how are these data protected, how long are the data stored, what are the User's rights, how can a complaint be lodged, where were the data taken from to the extent this information is not included in the present Privacy Policy.
Rectification (article 16)	The User can ask the Data Controller to rectify inaccurate personal data. The Data Controller can seek to verify the accuracy of the data before rectifying them.
Erasure/deletion (article17)	The User can ask the Data Controller to erase his personal data: whenever, when the personal data are no longer needed for the purposes for which they were collected when the User withdraws his consent the personal data have been unlawfully processed The Data Controller is not obliged to comply with User's request to erase his personal data, if the processing of User's personal data is necessary: for compliance with a legal obligation for the fulfillment of another legitimate purpose or another legitimate legal basis for the establishment, exercise or defense of legal claims
Restriction (article 18)	The User can ask the Data Controller to restrict (store but not process) User's personal data when: their accuracy is contested (see rectification), so that the Data Controller can verify the accuracy of the personal data or the personal data have been unlawfully processed but the User opposes the erasure of the personal data or they are no longer necessary for the purposes for which they were collected but the User still needs them for the establishment, exercise or defense of legal claims or there is another legitimate purpose of processing or other legal basis
Data portability (article 20)	When processing is based on consent and the processing is carried out by automated means, the User can ask the Data Controller to receive his personal data in a structured commonly used and machine readable format or ask the Data Controller to transmit them to another controller directly from the Data Controller. Nevertheless, according to the law, this right refers only to those data that have been given by the User himself and not to those data that are inferred by the Data Controller based on the data that the User has provided.
Objection (article 21)	The User can object at any time to the processing of personal data concerning him or her which is based on legitimate interest or performance of a task carried out in the public interest. When the User exercises his right to object, the Data Controller has the right to demonstrate that compelling legitimate grounds for the processing that override the interest, rights and freedom of the User or for the establishment, exercise or defense of legal claims.
Consent withdrawal (opt-out)	The User has the right to withdraw his consent where consent is the basis of processing. Withdrawal is valid for the future.
Supervisory Authority	The User has the right to lodge a complaint with the local supervisory authority related to data protection. In Greece the supervisory authority for Data Protection is Data Protection Authority https://www.dpa.gr/
Identity	The Data Controller takes seriously the confidentiality of all files that include personal data, thus he is entitled to ask the User proof of his identity if the User submits a request in relation to those files.
Cost	The User will not have to pay for the exercise of his rights in relation to personal data unless as provided by law, the request to acquire access to information is unfounded or excessive. In that case the Data Controller can charge the User with a reasonable fee under the specific circumstances. The Data Controller will inform the User for any possible charge before he completes the request.
Timetable	Data Controller aims at answering at User's valid requests the latest within one (1) month from their receipt, unless the request is extremely complicated or the User has submitted multiple requests, in which case the Data Controller aims at answering to them within three months. In case the Data Controller needs more than one month for the reasons above mentioned, he will inform the User. The Data Controller may ask the User if he wants to explain what exactly he wishes to receive or what is his concern. This will help Data Controller to act more quickly in relation to User's request. In any case the User should mention specific and true data and/or facts so that the Data Controller can answer and/or satisfy accurately to User's request. Otherwise, the Data Controller reserves his right for any faults that are outside of his control. Additionally the Data Controller can reject requests that are unfounded, excessive, abusive, made in bad faith or are illegitimate in the framework of the legal provisions.

7.How is data security safeguarded?

7.1 The Data Controller implements all appropriate security measures to ensure protection and confidentiality of personal data among which the following are included:

1. Strong password policies in all servers
2. HTTPS protocol for interacting with APIs and Web clients
3. SSH protocol for server connection
4. Periodical server updates with latest security fixes

7.2 Please note that only specifically authorized employees of the Data Controller, acting under the authority of the Data Controller and only on his instructions as well as recipients, where necessary, handle the data submitted by the User. For the processing, the Data Controller chooses persons with appropriate qualifications that have sufficient safeguards as to technical knowledge and personal integrity to protect confidentiality. The Data Controller takes all necessary security measures for the protection and safeguard of secrecy, confidentiality and integrity of personal data also through relevant contractual commitments of his associates. In any case the security of the Website may be infringed due to reasons that reside outside of the Data Controller control sphere as well as due to technical or other problem of the net or force majeure or accidental facts. In that case, the security of personal data cannot be guaranteed.

8. Who are the recipients of data?

8.1 The recipients of User's personal data are associate companies that provide technical infrastructure for the operation of the Website, hosting provider as well as the company that undertakes to send electronic communication related to the operation of the Platform to Users. Where necessary as per applicable laws, the Data Controller will sign agreements with such companies, which refer to the implementation and regular monitoring of security measures. In case data are transferred outside ΕU all necessary guarantees are in place.

8.2. In case the Data Controller receives a request to notify or transfer data following a request by the appropriate Administrative Authority, Attorney, Court or other Authority, he may notify / transfer those data in order to fulfill his duty executed in favor of the public interest towards these authorities (with or without User's previous notification) in accordance with the appropriate legal provisions. If the User should be previously notified in accordance with the legal provisions, then the User has the right to object to this processing as provided in article 7 above.

9. Communication with the Data Controller

9.1. For any issue related to the present privacy policy, User's data processing as well as exercise of User's rights, the User can contact the Data Controller using one of the following ways:
Telephone: +32 (0) 2 548 04 90,
Email: info(at)ecas.org

In case the User becomes aware of any data breach incident, he is kindly requested to notify the Data Controller immediately.

9.2. The present terms are governed and supplemented by the Terms and Conditions and consist along with them a uniform text.

10. Connection to other Websites/social media

This Website connects with other websites through hyperlinks. These websites are not related to Data Controller's Website and their content is neither checked nor recommended by the Data Controller. Thus, the accuracy, legitimacy, completeness or quality of their content and legitimacy of the processing of User’s personal data cannot be checked and no guarantee is provided for them. The Data Controller cannot be held liable for them or any damage that may be caused to the User due to or following their use. The Data Controller cannot check the processing of the User's personal data by those linked Websites and thus does not bear any liability. When the User accesses those websites he should take under consideration that terms and conditions of each website apply. For any issue that may occur as to the content or the use of the linked website, the User should directly contact the operator or administrator of each website. The Data Controller does not approve or embrace the Content or the services of the linked websites, which the User accesses through the Website.

The Website gives the User the possibility to connect and interact with social media following his own initiative and will. In that case the Data Controller is not liable for the processing of User's data taking place through or by the social media. The User should directly address each specific social media in order to exercise his legitimate rights.

11. Cookies

11.1. The Platform uses cookies to be operational or more efficient in its operation, to improve User's navigation, to provide User with the full potential of the Platform, to ensure the correct display of the content as well as for analytical and statistical purposes.

11.2. Cookies are small text files stored on User's computer when he visits a digital platform, which are used as a means of identifying his computer.

11.3. Cookies apart from absolutely necessary cookies are only installed if the User accepts their installation when he visits this Platform. By accepting cookies when entering this Platform, the User expressly states that he has read and understood the specific terms and conditions regarding the installation, function and purpose of the cookies and that he provides his consent for their use.

11.4. Alternatively, the User may not accept cookies. In this case, only cookies that are technically and functionally necessary for the operation of the Platform will be installed.

11.5. The User can manage the use and installation of cookies at any time through a panel, where he can choose which category of cookies he wants to accept and which ones not (or request to install only the technically necessary cookies).

11.6. In particular, the cookies used by the Platform are the following:

Type of cookies	Explanation	Examples of cookies	Duration of each cookie installation	Transfer of data to third parties
Absolutely necessary Cookies	The absolutely necessary cookies are essential for the proper operation of the Platform. These cookies allow User to browse and use Platform features such as access to secure areas. These cookies do not recognize User's individual identity and without them, the smooth operation of the Platform is not possible.	crowdsourcing_app_cookies_consent_selection (Stores the user's cookie consent state for the current domain ) crowdsourcing_app_cookies_consent_targeting (Stores the user's cookie consent state for the current domain ) XSRF-TOKEN (Ensures visitor browsing-security by preventing cross-site request forgery. This cookie is essential for the security of the website and visitor. ) ecas_lets_crowdsource_our_future_session (When the app needs to “remember” the logged in user while (s)he navigates to the Platform) Crowdsourcing_anonymous_user_id (used to store anonymous answers on the questionnaires by assigning an integer number to user that is submitting the response)	1 year 1 day Session 5 years	No No No No
Statistics/analytical Cookies	These are cookies that evaluate the way visitors use the Platform (for example, which pages are visited more often and whether they receive error messages from webpages). These cookies are used for statistical purposes and to improve the performance of a Platform.	_ga_4S9N5MK4VE, _gat,_ga, _gcl_au, _gid: Google Analytics cookies are used to measure traffic on the Platform. A unique textstring is saved to identify browser, timestamp for interactions and the browser/sourcepage that led the user to the Platform. No sensitive information is saved.	_ga_4S9N5MK4VE: 2 years _gat:1 minute _ga:2 years _gcl_au:3 months _gid:24 hours	Yes (Company that provides statistical and analytical services if considered as third party)

12. Children's Privacy

Our project does not address anyone under the age of 18 ("Children"). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

13. Amendments to this Privacy Policy

The Data Controller reserves the right to amend this present Privacy Policy, for example when this is necessary to comply with new requirements imposed by applicable laws, guidelines or technical requirements, or in the course of a revision of the Data Controller's processes and practices. The User will be notified of any amendment to this Privacy Policy through the Platform. The User should regularly check this Privacy Policy for any amendments.