LAST UPDATE: 12/05/2023
1. Who we are:
This privacy policy governs the use of your personal data by FrontAg Nexus project – this project has received funding from the European Union’s Horizon 2020 Research and Innovation Programme under grant agreement 2242.
NOTE: If you want information on how we process personal data via cookies on our Website, you are kindly referred to our Cookie Policy.
CONTACT DETAILS
Organisation name: reframe.food
Address: Leontos Sofou 20, 57001 Thermi, Thessaloniki – Greece.
Phone: +30 2310 462 885.
2. How we collect your personal data
We collect your 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 in meetings and events we host and during attendance at such events;
- we establish cooperative relationships with an individual;
- we provide professional services pursuant to our contract with the European Commission;
- an individual participates in an interview 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 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, land line phone number);
- professional information (job title, organization, field of expertise);
- demographics (e.g. age, gender, nationality);
- information about what a person knows or believes;
- electronic identification data, such as IP address;
- videos and photos (e.g. from people that 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 Horizon 2020 Framework Programme for Research and Innovation of the European Union.
Consent – for processing activities such as organization of surveys 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 project’s publicity obligations.
5. What we do with your personal data
We process your personal data with the purpose of:
- Conducting research (e.g., interviews, surveys);
- 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.
- Appointment of 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 in accordance with applicable law or regulation;
- The European Commission according to our relevant contractual obligations.
8. Do we transfer your personal data outside the European Economic Area?
We do not own file servers located outside the European Economic Area (EEA). However, we 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. Your rights
You have the following rights regarding our processing of your personal 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 personal 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 personal data if you contest the accuracy of your personal 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 personal 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: or . 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 from you some kind of identification (e.g., photocopy of your identity card or passport) to avoid non-authorized reveal of your personal data. If, for reasons of 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.
10. How long do we retain personal data?
We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations, and contractual obligations to which we are subject. Please note that we have an obligation to retain data concerning projects funded by the Horizon Europe Framework Programme for Research and Innovation of the European Union 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 in a secure manner.
11. 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.
12. Revisions of this Privacy Policy
This Privacy Policy is valid from 12/05/2023 and replaces any other previous notifications that we had issued in the past regarding our personal data management practices. We reserve the right to revise this Policy at any time and we commit to notify you for such revisions if they significantly affect your interests or fundamental rights and freedoms as a data subject.
