1. Introduction
The RealHyFC consortium is committed to ensuring GDPR 1compliance. Two aspects of the project will require collecting and managing personal data. This policy informs hereinafter the “User” on how the RealHyFC consortium collects, processes and protects personal data. The User must carefully read this privacy policy hereinafter “Privacy Policy” and decide freely if he intends to provide his personal data. Firstly, AXELERA and ERASME will collect personal data for dissemination, communication and networking beyond the consortium. Secondly, Dynergie will be responsible for maintaining the partner contact database for overall project management. This Privacy Policy informs of the type of data that will be collected in both cases.
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2. Joint Data Controllers for the processing of personal data
• AXELERA, registered at the INSEE as a non-profit organization (association) with VAT code FR49485210082, registered headquarters at Rond-Point de l’Echangeur, les Levées 69360 Solaize (France) and contact DPO at rgdp@axelera.org
• ERASME, registered at Polytech Clermont, 2 Avenue Blaise Pascal, 63170, Aubiere, France, and contact DPO at eduard@erasmecentre.eu
• Dynergie, registered at the Lyon Register of Commerce and Trade (“Registre du Commerce et des Sociétés de Lyon”) (France) with VAT code FR68490474343, and contact DPO at craoul@dynergie.eu
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The parties have transparently and by mutual agreement determined their respective responsibilities for the best protection of Users’ personal data. This Privacy Policy embodies the essential elements of the agreement regarding the roles assumed by each of the joint controllers in relation to the data subjects.
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3. Types of data collected in RealHyFC, why they are collected and an overview of the GDPR policy
Users’ personal data will be processed for the purposes of communication, dissemination and networking activities within the framework of the RealHyFC project.
The lawful basis for the processing is the consent provided by the data subject in accordance with Article 6.1 a) of the GDPR, which may be withdrawn at any time simply and free of charge through the channels provided in Section “User Rights”.In addition, personal data may be processed, if necessary, exclusively for the fulfillment of legal obligations to which the Joint Data Controllers are subject in accordance with their applicable legal framework pursuant to Article 6.1 c) of the GDPR.
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4. AXELERA – Personal Data for Communication, Dissemination and Networking
In order to carry out communication, dissemination and networking activities in the framework of the RealHyFC Project (for WP7), AXELERA will collect personal contact data, on the basis on your consent for send newsletters and/or send invites about RealHyFC project, invites for workshops and symbiosis meeting. The purpose is to ensure the dissemination, replication and broad uptake of the results of the RealHyFC project.
AXELERA confirms that it has appointed a Data Protection Officer (DPO), Frédéric Laroche of AXELERA. The DPO’s email address (rgdp@axelera.org) will be provided on the RealHyFC website and in all newsletters and invitations to events so that all data subjects involved in RealHyFC, can contact for any questions regarding the processing of their personal data, about exercising rights and requesting deletion of their data.
Regarding informed consent, the following case applies: A data subject can sign-up to be added to the RealHyFC contact list via the RealHyFC website.
The User shall specify for which purpose he/she consents to be contacted:
To receive the RealHyFC 6-monthly newsletters
• To be invited to RealHyFC workshops, symbiosis meetings
• To be contacted by a RealHyFC partner in order to discuss project results and possible collaborations individually.
Unless he/she request that his/her data be erased, then collected data will be stored for a period of four (4) years following the last correspondence between AXELERA (leader of RealHyFC dissemination and networking) and he/she.
Regarding the storage, correction, use and erasing of personal data within the scope of RealHyFC:
• Personal data handled by AXELERA within the scope of RealHyFC will be collected, stored, and processed only within AXELERA’s Partner Relationship Management (CRM) Tool, EUDONET, and PLEZI (marketing tool) which is a GDPR-compliant and secure tool. Password protected access is limited to AXELERA staff, the CRM service provider, AXELERA’s website developer and the RealHyFC website developer.
• If a data subject requests that his/her data be corrected, AXELERA’s W7 leader will correct the data in the CRM.
• If a data subject requests that his /her data be erased, AXELERA’s DPO will erase the data subject in the CRM.
• The voluntary forms on RealHyFC’s website will feed personal contact data and the purpose for which AXELERA has the right to use the contact data to AXELERA’s CRM.
• The Newsletters and invitations to RealHyFC events will be sent only to those contacts having given consent for each type of emailing.
Each emailing will offer the possibility to cancel the subscription to that type of emailing or to request corrections / erasure by sending an email to rgdp@axelera.org.
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5. ERASME – Personal Data for Communication, Dissemination and Networking
In order to carry out communication, dissemination and networking activities in the framework of the RealHyFC in WP7 ERASME will also collect personal contact data, for the purpose of managing the RealHyFC organizing events such as debates and podcasts on circular economy. The aim is to ensure the dissemination and wide acceptance of the RealHyFC project towards the large public. ERASME will also contact stakeholders for participation in workshops, with the purpose of assessing the systemic socio-economic impact of innovation.
ERASME confirms that it has appointed a Data Protection Officer (DPO), Claudiu Eduard Nedelciu of ERASME to manage GDPR matter in the framework of RealHyFC project. The DPO’s email address (eduard@erasmecentre.eu) will be provided in all invitations to these events so that all data subjects involved in RealHyFC, as specified in Article 10.6 of the Consortium Agreement, can request that their data be erased.
Regarding informed consent, the following case applies: A data subject can sign-up to be added to the RealHyFC contact list via the RealHyFC website. The User shall specify for which purpose he/she consents to be contacted:
• To be invited to RealHyFC workshops, symbiosis event meetings
• To sign up for RealHyFC newsletters
• To be contacted by a RealHyFC partner in order to discuss project results and possible collaborations individually.
Regarding the storage, correction, use and erasing of personal data within the scope of RealHyFC:
• Personal data handled by ERASME within the scope of RealHyFC will be collected, stored and processed only within ERASME’s secure file manager provided by one.com and for the period of time necessary to organize these events. Password protected access to this data is only available to ERASME staff.
• If a data subject requests that his/her data be corrected, ERASME will correct it and also inform AXELERA’s WP7 leader will correct the data in the CRM.
If a data subject requests that his /her data be erased, ERASME’s DPO will erase the data subject in the CRM and also inform AXELERA.
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6. Dynergie – GDPR Policy for the online project shared space
In order to ease the exchange of confidential documents in the framework of the RealHyFC Project (for WP8 mainly and other workpackages as well), DYNERGIE will collect personal contact data, on the basis on your consent to add you to our future Sharepoint site.
DYNERGIE confirms that it has appointed a Data Protection Officer (DPO), Cédric RAOUL of DYNERGIE. The DPO’s email address craoul@dynergie.eu will be provided on the Sharepoint interface so that all data subjects involved in RealHyFC, can contact for any questions regarding the processing of their personal data, about exercising rights and requesting deletion of their data.
Unless he/she request that his/her data be erased, then collected data will be stored for a period of four (4) years, duration of the RealHyFC project. All data related to the subjects participating in RealHyFC will be erased when the Sharepoint is completely deactivated by the end of the project.
Regarding the storage, correction, use and erasing of personal data within the scope of RealHyFC:
• Personal data handled by DYNERGIE within the scope of RealHyFC will be collected, stored, and processed only within DYNERGIE’s Tool, Microsoft Sharepoint. Password protected access is limited to DYNERGIE staff only.
• If a data subject requests that his/her data be corrected, DYNERGIE’s will correct the data within Sharepoint.
• If a data subject requests that his /her data be erased, DYNERGIE’s DPO will erase the data subject within Sharepoint.
are subject in accordance with their applicable legal framework pursuant to Article 6.1 c) of the GDPR.
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7. Recipients
Personal data may be communicated to a suitable service provider retained by RealHyFC consortium, who shall process the data solely and exclusively for the purposes established by RealHyFC consortium and according to the latter’s instructions. Data may further be communicated to third parties if the transmission is required to comply with a statutory requirement, a resolution of the any roper supervisory authorities, or a court order; or where the data are communicated to protect vital interests of the data subjects, or any other legitimate purpose provided for by law.
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8. INTERNATIONAL DATA TRANSFERS
When the processing of personal data involves the communication of such data to third countries established outside the territory of the European Economic Area (EEA), the Joint Data Controllers shall ensure that such transfer has adequate guarantees for the processing of personal data, taking into account the exposure to risk of the data subjects, in accordance with the mechanisms provided for in the applicable regulations in order to guarantee an adequate level of security.
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9. USER RIGHTS
In accordance with data protection regulations, the User, at any given time, has the right to:
• Withdraw his/her consent at any time, without prejudice to the lawfulness of the processing previously carried out.
• Access to his/her personal data and to obtain confirmation on which personal data is being processed.
• Rectify inaccurate or incomplete data.
• Request the erasure of his/her data when they are no longer necessary for the purposes for which they were collected, among other reasons.
• Restrict the processing of personal data, by suspending the processing or by restricting the scope of the processing to certain categories of data or processing purposes of the processing of the data when any of the conditions provided for in the regulations in force are met.
• Request the portability of his/her data, either for himself/herself or for transfer to another Data Controller.
• Object to the processing of the data, where appropriate.
These rights must be exercised under the conditions provided for by the regulations in force.
These rights can be exercised by sending an e-mail request to either of the following Joint Data
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Controllers:
AXELERA:
Contact: rgdp@axelera.org or via post to the following address:
AXELERA
Rond-Point de l’Echangeur, les levées
69360 Solaize, France
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ERASME:
Contact: eduard@erasmecentre.eu or via post to the following address:
Polytech Clermont, 2 Avenue Blaise Pascal, 63170, Aubiere, France With the right to make a claim to the National Data protection Authority (CNIL) through their official website www.cnil.fr
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Dynergie:
Contact: craoul@dynergie.eu or via post to the following address:
To the attention of Cédric Raoul, Dynergie, 1 place Giovanni da Verrazzano, 69009 Lyon, FRANCE
With the right to make a claim to the National Data protection Authority (CNIL) through their official website www.cnil.fr
The User may exercise the rights concerning the processing of his or her personal data against each of the joint controllers.
Data subjects are further entitled to lodge a complaint with the supervisory authority concerned if they consider that their personal data have been breached.
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10. CHANGES TO THE PRIVACY POLICY
RealHyFC consortium reserves the right to change this privacy policy at any time. The changes shall be duly notified using the contact details provided by the data subjects. GDPR Compliance Report by AXELERA
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11. Hypertext Links and cookies
The website RealHyFC, contains a number of hypertext links to other sites. However, AXELERA does not have the possibility to check the content of these sites thus visited, and therefore will not assume any responsibility regarding these sites. The User should inquire about the privacy and practices of these sites before sending any personal information to them.
The RealHyFC website, uses cookies, but it may also use third-party technologies to present a better display and certain services, in particular to track audiences. The User is informed that, during his/her visits to the website, a cookie can be automatically installed on his browser software. The cookie is a block of data which does not identify the User but is used to record information relating to the browsing of the latter on the website. These are mainly used to study and optimize the User experience on the website.
When visiting, the RealHyFC website, the User will be informed upon connection to the website that the website uses cookies. Before gaining access to the page, the User will be given the choice between accepting all cookies, only essential cookies and learning more. If the User requests to learn more, he or she will gain access to a summary of the GDPR policy and will be given the choice between:
• Essential and strictly necessary cookies – These are cookies essential for the proper functioning of the site and strictly necessary for the provision of a service that the user has expressly requested. These essential cookies make it possible to memorize from one page to another the information that a User communicates to the website during his/her navigation, for example the language of use.
• Site audience analysis cookies – They allow AXELERA to establish anonymous statistics of visits to the pages of its site in order to improve its ergonomics and content.
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1 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