If you visit our website, take part in project activities or contact us, we may process your personal data. Here you will find all information regarding the collection and processing of personal data by us, as part of the START NOW + project.
Who processes your personal data?
The administrator of your personal data are:
In the field of data processed as part of project activities in Poland, and as part of the website and social media START NOW+:
- Stowarzyszenie Promocji Zdrowia i Profilaktyki ”HOPP” (Health related Organization for Promotion and Prevention), Plac Kopernika 13, 45 – 040, Opole, Poland, firstname.lastname@example.org
In the field of data processed as part of project activities in Norway:
- FURIM Institutt, Dronningens gate 16, Oslo 0152, Norway email@example.com
(hereinafter referred to as the Administrator).
In all matters related to personal data, you can contact us via the provided e-mail addresses or other online communication channels. Your personal data may also be processed by our subcontractors who help us in providing services. All these entities ensure proper protection of your personal data, based on relevant legal provisions.
Who do we share your personal data with?
Your personal data may be transferred to the following entities:
- MailChimp to operate the message system via the newsletter, only if you subscribe to the newsletter.
- In the case of complaints and legal disputes, your personal data may be entrusted to persons dealing with our organizations legal services in order to ensure legal protection.
- We may be required to provide information on personal data to authorized bodies based on lawful requests. Such claims most often relate to prosecution and punishment of punishable offenses.
- As part of reporting on the START NOW+ project, we may be required to provide participants’ personal data to entities implementing the Education Program (National Program Agency, Foundation for the Development of the Education System in Poland) or other EEA institutions authorized under the law, in order to fulfill the obligations incumbent on the Administrator.
- The image of participants can be forwarded to electronic media and traditional media (press, radio, etc.) as part of the promotion and dissemination of the results of the START NOW+ project.
For some technical solutions, your data may be located outside the European Economic Area. This is due to the provision of these solutions by American companies. Each such transfer always takes place in accordance with European regulations, including the GDPR, and meets the standards of personal data protection (e.g. the Privacy Shield program).
For what purpose we process your personal data?
When you contact us online (contact form, e-mail correspondence, social media, newsletter), we process your data to disseminate the results of the project and to include new beneficiaries in our project. If you contact us, we need your personal data to establish and communicate. In particular, we can process your data for the following purposes:
- Providing information on our START NOW+ project and its results on our website https://www.startnowplus.com
- Establish communication with you if you contact us via: any of the contact forms on our website or through the address of our mailbox. The personal data you provide in the forms are necessary to establish and maintain communication. In the case of email communication, we will process your email address, which may contain your personal data and other personal data provided by you in the message.
- In the event that you contact us via social media messengers, we process personal data that you provide in your profile and which are publicly available. As part of the correspondence with us through these messengers, you can also provide other personal data that will be processed by us for communication and for archiving. In each case, this data is stored on the servers of the owners of individual messengers (social media) and their processing is governed by separate agreements or regulations.
- As part of our social media profiles, your personal data may be processed through specific interactions resulting from the given system (e.g. likes, comments, sharing, observing). Personal data that is processed on our profile depends only on you and your profile settings in the system that supports selected social media. Each time you decide to leave such personal data.
- As part of the blog START NOW+, you can add comments under individual entries, we process them based on your consent, to initiate discussions on the educational results of the project and other START NOW + activities, and to build a project community.
When you are a beneficiary of the START NOW+ project (you take part in any of the official activities of the project), we process your data for the purposes of:
- ensuring the required reporting, determined by the organizational framework of the Education Program, in particular by providing personal data for the purpose of evidence (electronic and paper lists) of the project,
- keeping internal statistics and reporting (participation in activities, project evaluation),
- issuing documents confirming participation in the project,
- project visualization (promotion of activities) and dissemination of project results (enabling others to become familiar with its effects, in particular through photos and videos),
- ensuring participants’ safety (consent to participate, information about special needs, information collected from legal guardians in the case of underage participants),
- ensuring proper logistics of project activities (travel documents),
- financial aspects based on travel documents, which may contain personal data (usually: name and surname, date of birth) of the participant.
When you subscribe to the newsletter, you provide us with your email address, which may contain your personal data. By agreeing to the newsletter, you agree to the sending of information via electronic means of communication within the meaning of the Act of 18 July 2002 on the provision of electronic services (polish Act: ustawa z dnia 18 lipca 2002 roku o świadczenie usług drogą elektroniczną). The data provided during the subscription to the newsletter are used to send you the newsletter, and the legal basis for their processing is your consent (Article 6(1)(a) GDPR) expressed when subscribing to the newsletter.
Your consent can be withdrawn at any time.
The newsletter contains information about the START NOW+ project and its results (educational materials) that can be addressed to you based on Article 6(1)(f) GDPR, which is the justified purpose of conducting information of the Administrator’s own activities.
If you unsubscribe from receiving the newsletter, your data will still be stored in our system to document the lawful processing of personal data (i.e. your consent) and to defend against any claims in this regard, on the basis of a legitimate interest referred to in Article 6(1)(f) GDPR.
Mailchimp is our subcontractor in the scope of operating the news system by the newsletter. Because the newsletter system uses tools provided by US companies, your data may be located outside the European Economic Area. Each such transfer always takes place in accordance with European regulations, including the GDPR, and meets the standards of personal data protection (e.g. the Privacy Shield program).
On what basis do we process your personal data?
Here you will find detailed legal basis for our online activities:
- The processing of personal data through individual communication and forms on the website is carried out on the basis of Article 6(1)(f) GDPR – a legitimate purpose, which is to answer requests and queries sent using the contact form or in another form. Personal data will also be processed after the contact pursuant to Article 6(1)(f) GDPR, which is the justified purpose of archiving correspondence for the purposes of demonstrating its future course and defending against potential claims.
- The basis for processing personal data on social media is Article 6(1)(a) GDPR, which is your consent resulting from adding a comment or any other interaction. Permissions related to personal data (deletion, modification) can be implemented as part of your user account in the system that supports your profile in social media.
- The basis for processing personal data through social media messengers (communicators) is Article 6(1)(f) GDPR, based on a legitimate purpose, which is to answer questions directed using social media messengers. Personal data will also be processed after the contact pursuant to Article 6(1)(f) GDPR, which is the justified purpose of demonstrating its future course and defending against potential claims. Data processed as part of social media messengers remain on the servers of the owners of individual messengers, and their archiving is governed by separate agreements or regulations.
- Based on data from social media (likes, observations or other interactions left) we can direct information of our own activity, pursuant to Article 6(1)(f) GDPR, that is the legitimate purpose, which is the promotion of the Administrator’s activities. Each time information activities are directed to the general followers of our profiles. As part of specific activities, we can use statistical tools provided by the owners of individual social media, regulated in separate agreements or regulations.
- In a social media system, we can block users (Article 6(1)(f) GDPR), based on a legitimate purpose, which is to prevent the addition of comments contrary to the law and decency.
- We collect and analyze anonymized statistical data based on Article 6(1)(f) GDPR, which is justified to improve our project.
- The basis for the processing of personal data left in the comments and information about their authors within our blog is Article 6(1)(a) GDPR, i.e. your consent resulting from adding a comment.
- The legal basis for sending the newsletter is your consent (Article 6(1)(a) GDPR) expressed when subscribing to the mailing list. By agreeing to the newsletter, you agree to the sending of commercial information via electronic means of communication within the meaning of the Act of 18 July 2002 on the provision of electronic services (polish Act: ustawa z dnia 18 lipca 2002 roku o świadczenie usług drogą elektroniczną). Your consent can be withdrawn at any time.
Here you will find detailed legal basis for our activities towards beneficiaries of the START NOW + project:
- Consents of persons or their legal representatives (minors), according to Article 6(1)(a) GDPR.
- The legitimate interest of the data administrator in the form of ensuring project implementation and its settlement in accordance with legal requirements, pursuant to Article 6(1)(f) GDPR.
What personal data do we process?
Depending on the area of your activity, we may process the following types of your personal data:
- cookie files;
- server logs;
- email address when using the newsletter;
- data provided in the contact forms or in the e-mail;
- identifying data (account name) of a person using social media, the amount of data provided depends on specific users and is regulated by separate agreements or regulations of social media owners,
- data included in the comments on our blog; when a visitor leaves a comment, we collect the data visible in the comment form, as well as the visitor’s IP address and browser signature to help detect spam.
To do not collect, monitor or verify information about your age or any other information that would determine whether you have legal capacity. Persons who do not have full legal capacity should not subscribe to the services provided by us or contact us, unless their legal representatives agree, if such consent is sufficient under applicable law.
In terms of data on START NOW+ participants, we limit the collection and use of information to the necessary specified in the requirements of the Education Program and ensuring the proper promotion and visibility of our activities. Depending on the area of your activity, we may process the following types of your personal data:
- participants list, including your name, email address, date of birth, country of residence and signature; lists are required for proper project reporting under the Education Program,
- data required to issue documents confirming participation in the project (name, surname, date of birth),
- Your image in order to visualize the project (promotion of activities) and disseminate the results of the project (enabling others to get acquainted with its effects, in particular through photos and videos),
- information about the special needs of participants,
- travel documents, which may contain personal data (usually: name and surname, date of birth).
How long do we process personal data?
Your personal data is processed for periods indicated by law or when it is necessary to perform our services and keep the accountability principle.
Personal data on our social media will be processed until our profile operates, unless you decide to delete the interaction, like or comment in advance.
The data provided for the purposes of subscribing to the newsletter will be processed for the duration of the newsletter. If you opt out of receiving it earlier, we will store your data in the system for the purpose of demonstrating your consent, which is our legitimate interest (Article 6(1)(f) GDPR).
In the case of data contained in the blog comments system, until the system operates, unless you decide to delete the comment first.
Personal data is processed during the period necessary for the implementation of the project and after its completion in the aspect of its evaluation, financial issues, promotion and dissemination. Part of the data, in particular related to activities financed and conduct under the Education Program, can be processed without a timely delivery.
What are your rights regarding data processing?
You have the right to request: access, rectification, deletion, restriction of processing, objection or transfer of your personal data. These rights may be limited based on our legitimate interests (e.g. storage of certain personal data in the event of a defense against claims).
If the processing of personal data is based on your consent, you have the right to withdraw consent at any time without affecting the lawfulness of the processing that was carried out before the consent was withdrawn. In the event of withdrawal of consent and no other legal basis for the processing of personal data, we will immediately delete your personal data.
In all matters related to personal data, you can contact us by: telephone number (0048) 501361677, e-mail address: firstname.lastname@example.org or by correspondence to the above Administrator’s address.
You always have the right to lodge a complaint with the supervisory body – the President of the Office for Personal Data Protection in your country, if you feel that we have violated personal data protection regulations.
Within the scope of individual rights, your rights may be limited by:
- The need to ensure proper reporting with the competent authorities in the case of financial and accounting documents.
- The need to properly demonstrate the course of the project and its activity, including the participation in the form of visual and written documents.
- Providing evidence of your consent to data processing.
- Storing personal data needed to defend against claims, until the limitation period expires (e.g. archiving correspondence content).
Can you opt out of selected services?
Yes, every newsletter user can do this by using the unsubscribe option. This can be done by following the instructions attached to the content of emails sent (newsletter). If you opt out of receiving it, we will store your data in the system for the purposes of demonstrating your consent, which is our legitimate interest.
If you no longer want to follow our profiles on social media, you can undo your follow / like or other interaction at any time by visiting our profile. The rules for following profiles, displaying information about them, and withdrawing likes are governed by social media owners who are beyond our control.
For data contained in the blog comments system, you will appear as a commenter until you delete the comment.
Social media tools in the form of a Facebook plugin on our website. If you have a Facebook profile, your browser can establish a direct connection to it. As part of these plugins, we collect information about your display of our website. Plugins also allow direct transfer of content from our site to your social media profiles (interaction buttons marked with icons of individual social media).
These data are transferred outside the European Economic Area, however, each such transfer always takes place in accordance with European regulations, including the GDPR, and meets the standards of personal data protection (e.g. the Privacy Shield program). Details of the processing of your personal data as part of Facebook can be found in the privacy policies https://www.facebook.com/help/239070709801747
How do we use server logs?
As part of using our website, queries are sent to the server on which the page is located. Each such query is saved in the server logs. Thus, information about your use of the site is subject to logging in the server layer. The above data is not associated with specific persons browsing the pages and is not used by us to identify you. These data are used only to administer the site and to ensure the most efficient service provided to you.
The viewed resources are identified by URL addresses. In addition, the following may be subject to registration:
- information about your IP address,
- information about the browser and operating system you use,
- the time of receipt of the inquiry and the time of sending the reply,
- name of the client station – identification carried out by the HTTP protocol,
- information about errors that occurred during HTTP implementation,
- URL address of the page previously visited by you (referrer link) – in the case when the transition was through a link.
What safeguards protect personal data?
Our site is equipped with security measures aimed at protecting data under our control against loss, misuse or modification. Any information you disclose to us is protected, in accordance with our security and confidentiality standards. Access rights to personal data have been limited so that this information is not in the hands of unauthorized persons. Access to personal data has only a limited number of people managing our site, social media and supervising their work.
Where can you complain about our personal data activities?
Yes, you always have the right to lodge a complaint with the supervisory body – in Poland the President of the Office for Personal Data Protection, ul. Stawki 2, 00-193 Warsaw, if you find that we have violated personal data protection regulations. For more information on the supervisory body, please visit: https://uodo.gov.pl
Can we profile you based on the collected personal data?
No, our organizations do not use personal data for automated decision making that is based solely on automated processing, including profiling.