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PROTECTION OF YOUR PERSONAL DATA

This privacy statement provides information about the processing and the protection of your personal data.

Processing operation: EU projects websites in the Eastern Neighbourhood countries Armenia, Azerbaijan, Belarus, Georgia, Moldova and Ukraine under euneighbourseast.eu:

Data Controller: Directorate-General for Neighbourhood and Enlargement Negotiations (DG NEAR) /Directorate A / Unit NEAR.A1 Inter-institutional Relations and Communication

Record reference: DPR-EC-07086

Table of Contents

  1. Introduction
  2. Why and how do we process your personal data?
  3. On what legal ground(s) do we process your personal data?
  4. Which personal data do we collect and further process?
  5. How long do we keep your personal data?
  6. How do we protect and safeguard your personal data?
  7. Who has access to your personal data and to whom is it disclosed?
  8. What are your rights and how can you exercise them?
  9. Contact information
  10. Where to find more detailed information?

1. Introduction

The European Commission (hereafter ‘the Commission’) is committed to protect your personal data and to respect your privacy. The Commission collects and further processes personal data pursuant to Regulation (EU) 2018/1725  of  the  European  Parliament  and  of  the  Council  of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data (repealing Regulation (EC) No 45/2001).

This privacy statement explains the reason for the processing of your personal data, the way we collect, handle and ensure protection of all personal data provided, how that information is used and what rights you have in relation to your personal data. It also specifies the contact details of the responsible Data Controller with whom you may exercise your rights, the Data Protection Officer and the European Data Protection Supervisor.

The information in relation to processing operation EU projects websites in the Eastern Neighbourhood countries (Armenia, Azerbaijan, Belarus, Georgia, Moldova and Ukraine) undertaken by the Data Controller is presented below.

2. Why and how do we process your personal data?

Purpose of the processing operation: The Data Controller collects and uses your personal data for the purposes of the visibility and promotion of EU-funded projects and programmes in the Eastern Neighbourhood countries (Armenia, Azerbaijan, Belarus, Georgia, Moldova and Ukraine) directly linked with the EUDIGITOOL internal platform where most of the content automatically comes from.

Euneighbourseast.eu and the country websites are developed to respond to the need and demand for collating and consolidating project information presenting EU cooperation in action from a communication perspective enabling citizens to receive information about the EU-funded programmes and projects and EU-related opportunities in the Eastern Neighbourhood countries (Armenia, Azerbaijan, Belarus, Georgia, Moldova and Ukraine) for the purposes of the visibility and promotion of EU-funded projects and programmes in the Eastern Neighbourhood countries (Armenia, Azerbaijan, Belarus, Georgia, Moldova and Ukraine), namely:.

The ‘Young European Ambassadors’ (YEAs) initiative

The YEAs initiative is part of the EU’s strategic communication and public diplomacy approach to the Eastern Neighbourhood. The initiative is managed by the EU’s Regional Communication Programme for the Eastern Neighbourhood (2020-2024). The EU is partnering with young people in the Eastern partner countries to raise awareness of the EU’s cooperation in the region, help develop youth policies and work together for a better future. The YEAs initiative is a network connecting active young people from Armenia, Azerbaijan, Belarus, Georgia, Moldova and Ukraine as well as from the EU Member States and the United Kingdom. The YEAs foster youth cooperation in their local communities and talk about EU topics that matter. They are peer role models; they share their voice, build mutual understanding and help shape the views on the EU and its relations with the eastern neighbourhood.

News alerts

The news alerts enable citizens to receive information about the EU-funded programmes and projects and EU-related opportunities in the Eastern Neighbourhood countries (Armenia, Azerbaijan, Belarus, Georgia, Moldova and Ukraine) requested by registering to news alerts on the euneighbourseast.eu and/or a EU4country website.

Uploading photos and videos on interviews of the project beneficiaries

for consolidating project information presenting EU cooperation in action from a communication perspective.

All data processing is transparent and abides by the principle of users opting-in/out, and allowing the data they provide to be used for specific purposes.

Your personal data will not be used for an automated decision-making including profiling.

3. On what legal ground(s) do we process your personal data

We process your personal data, because:

  1. The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Union institution or body (Article 5 (a) of Regulation (EU) 2018/1725);

The basis for the processing is laid down by the following Union law:

Article 11 of the consolidated European Treaty on the European Union states: “The institutions shall, by appropriate means, give citizens and representative associations the opportunity to make known and publicly exchange their views in all areas of Union action. The institutions shall maintain an open, transparent and regular dialogue with representative associations and civil society”.

Article 21(1) of the Treaty on European Union (TEU): overall mandate and guiding principles in the field of EU development cooperation;

Articles 4(4) and 208 to 211 of the Treaty on the Functioning of the European Union (TFEU).

Informing the broad public is a task resulting from the European Commission’s own prerogatives at institutional level, as provided for in Article 58(2) (d) of Council Regulation (EC, Euratom) No 2018/1046 of 18 July 2018 on the Financial Regulation applicable to the general budget of the European Communities (OJ L 193, 30.7.2018, p. 1).

In addition, the processing is necessary for the fulfilment of the European Commission’s obligation to ensure visibility of the Union’s financial support, as stipulated in recital 28, Article 46(2), (3) and

  1. of Regulation (EU) 2021/947 of the European Parliament and of the Council of 9 June 2021 establishing the Neighbourhood, Development and International Cooperation Instrument – Global Europe, amending and repealing Decision No 466/2014/EU and repealing Regulation (EU) 2017/1601 and Council Regulation (EC, Euratom) No 480/2009, OJ L 209, 14.6.2021,

The Young European Ambassadors initiative is part of the EU’s strategic communication and public diplomacy approach to the Eastern Neighbourhood. The initiative is managed by the EU’s Regional Communication Programme for the Eastern Neighbourhood (2020-2024) for which the legal basis is Regulation (EU) No 236/2014 of the European Parliament and of the Council of 11 March 2014 laying down common rules and procedures for the implementation of the Union’s instruments for financing external action and Regulation (EU) No 232/2014 of the European Parliament and of the Council of 11 March 2014 establishing a European Neighbourhood Instrument.

  1. The data subject has given consent to the processing of his or her personal data for one or more specific purposes (Article 5 (d) of Regulation (EU) 2018/1725):

If you have subscribed to receive information on important developments, activities, events, initiatives or thematic issues related to the EU-funded programmes and projects and EU-related opportunities in the Eastern Neighbourhood countries (Armenia, Azerbaijan, Belarus, Georgia, Moldova and Ukraine), we process your personal data, because you have given your consent to the processing of your personal data for the purpose of receiving the requested information.

If we are processing photos and videos, including their publication, we process your personal data because you have given your consent to the processing.

All data processing is transparent and abiding by the principle of users’ opting-in/out, and allowing the data they provide to be used for specific purposes.

We do not process special categories of personal data (Article 10 of the Regulation (EU) 2018/1725.

4. Which personal data do we collect and further process?

In order to carry out this processing operation the Data Controller collects the following categories of personal data:

Young European Ambassadors:

For the selection of the applicants:

      • First name and last name
      • Country of origin
      • Place of residence
      • Date of birth
      • Education/employment status
      • E-mail address
      • Phone number
      • Online so-me accounts*

For the selected applicants, the following data are published:

  • First name and last name
  • Photographs
  • Videos   
  • Short biography
  • Occupation
  • Online so-me accounts *

*not mandatory

Newsletter subscribers:

    • Frist name and last name
    • E-mail address
    • Country of residence

Data are collected by means of the news alert registration interface in which the data subjects enter their data directly.

Project beneficiaries interviewed for communication purposes:

  • Promotional videos/photos of the stories published on the website

Website visitors:

  • IP address

5. How long do we keep your personal data?

The controller only keeps your personal data for the time necessary to fulfil the purpose of collection.

Young European Ambassadors

Data are kept as long as the website operates as a tool of DG NEAR’s promotion policy and the data subject is registered as YEA (until the data subject erases his/her account or unsubscribes from the mailing list or until the data subject ceases to be an YEA  due to his/her age, resignation or no extension of their mandate). The data controller removes his/her profile and any other publicly available information.

News alert subscribers

Depending on the technical solutions available, you can either write to the dedicated functional mailbox and ask to be unsubscribed from the mailing list or follow the unsubscribe link in the information email you have received. Appropriate action shall be taken within a week of receiving the request.

Project beneficiaries interviewed for communication purposes

Data are kept as long as the website operates as a tool of the Data Controller’s promotion policy unless they are not removed earlier as not being anymore relevant for the purpose of their processing.

Website visitors

Data are kept for the duration of the browsing session (browsing sessions are saved anonymously by analytics until the expiration of the service contract i.e. until the respective domain accounts are closed.

In case where data is kept for statistical purposes, some subscriber’s optional data may be kept for 5 years after the un-subscription, providing these do not allow to identify the subscriber any more and that these are available to a very restricted number of authorised persons performing the processing operation on a need to know basis, for the sole purposes of generating anonymised statistics.

6. How do we protect and safeguard your personal data?

All personal data in electronic format (e-mails, documents, databases, uploaded batches of data, etc.) are stored either on the servers of the European Commission or of its contractors. All processing operations are carried out pursuant to the Commission Decision (EU, Euratom) 2017/46 of 10 January 2017 on the security of communication and information systems in the European Commission.

The Commission’s contractors are bound by a specific contractual clause for any processing operations of your data on behalf of the Commission, and by the confidentiality obligations deriving from the transposition of the General Data Protection Regulation in the EU Member States (‘GDPR’ Regulation (EU) 2016/679).

In order to protect your personal data, the Commission has put in place a number of technical and organisational measures in place. Technical measures include appropriate actions to address online security, risk of data loss, alteration of data or unauthorised access, taking into consideration the risk presented by the processing and the nature of the personal data being processed. Organisational measures include restricting access to the personal data solely to authorised persons with a legitimate need to know for the purposes of this processing operation.

The collected personal data and all information related are stored on the servers of the contractors during the implementation and the maintenance of the website.

Personal data in electronic form: access to your personal data, as well as any other information collected in the website is exclusively provided through an identification system with password, accessible to a restricted number of users, without prejudice of a possible future transmission of these data to the bodies charged with the control and inspection of the Commission’s activities in conformity with EU law.

The website uses cookies.

Cookies are pieces of text generated by the web services that a user has visited; these text files can be set on the users’ devices by the website they are currently visiting (“first party persistent cookies”) or by a different website to the one they are currently visiting (“third party cookies”). To facilitate the functioning of our website we may – subject to visitors’ consent – place small data files called cookies on your device. They enable the website to remember your actions and preferences (such as login, language, and font size and other display preferences) over a period of time, so you do not have to keep re-entering them whenever you come back to the site or browse from one page to another.

Four different types of cookies will be in use:

• First party persistent cookies

• Technical session cookies

• Third party cookies (including the Google Analytics cookies)

• Third party cookies from the Share widget. On this promotional website, the following types of cookies are used: ‘first- party persistent cookies’, and ‘session cookies’.

‘First party persistent cookies’ enable the tracking of the following information about the visitors to our website:

• IP address (anonymised)

• Location: country, region, city, approximate latitude and longitude (Geolocation)

• Date and time of the request (visit to the site)

• Title of the page being viewed (Page Title)

• URL of the page being viewed (Page URL)

• URL of the page that was viewed prior to the current page (Referrer URL)

• Screen resolution of user’s device

• Time in local visitor’s time-zone

• Files that were clicked and downloaded (Download)

• Links to an outside domain that were clicked (Outlink)

• Pages generation time (the time it takes for webpages to be generated by the webserver and then downloaded by the visitor: Page speed)

• Main language of the browser being used (Accept-Language header)

• Browser version, browser plugins (PDF, Flash, Java, …) operating system version, device identifier (User-Agent header)

• Language of the visited page

• Campaigns

• Site Search

• Events

The collected data will not be shared with any other organisations for marketing, market research or commercial purposes. Moreover, the abovementioned data cannot be used to identify a particular visitor.

‘First party persistent cookies’ are created by this website and enable:

• proper functioning of the website;

• the collection of statistics to improve website functionalities – for this purpose, the website uses Google Analytics (more information is provided below);

• social media sharing functions.

‘First party persistent’ cookies expire after thirteen months (13), after which they are automatically removed from the users’ device. ‘Technical Session’ cookies do not contain any data – they are placed for the duration of a user session (time spent browsing the website).

These cookies are necessary to keep the visitor’s choice selection when the website is accessed. Once the visitor leaves the website, the session cookie is deleted.

‘Third party cookies’ (including the Google Analytics cookies) are detailed below. ‘Third party cookies’ from the Share widget are placed on the computer – if the user opted-in – in order to allow users to share content on social media.

The website does not set cookies with the display of links to our social media when you are browsing our website

OPTING-IN

When the website is accessed first, the website visitor is provided with a choice to accept (“OK, I agree”) or refuse (“Decline cookies”) the placement of cookies.

Accept cookies: By clicking this option, the visitor gives consent to the placement of all the cookies for the:

• Optimal functioning of the website

• Social media sharing function

• Collection of statistics

Decline cookies: By clicking this option, the visitor does not give consent to the placement of any of the abovementioned cookies. In this case, only a session cookie is placed; this is a technical cookie, the main purpose of which is to remember the visitors’ selection choice. This cookie is placed for the duration of a user session (time spent browsing the website) and will automatically be deleted when said session expires. Choosing not to accept cookies does not hinder your navigation experience on the website.

No selection made: If a visitor neither accepts nor refuses cookies, the website treats this as a refusal to the placement of cookies and all related functions are on hold until a selection is made.

No cookies shall be placed on visitors’ devices, unless consent has been given by clicking on the “OK, I agree” option.

OPTING-OUT

In case a visitor has opted-in to the placement of cookies, it is always possible to change this decision and opt-out. In order to opt-out, visitors need to delete all the cookies from their browser. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.

To learn about how to clear cookies in different browsers, visit: https://www.aboutcookies.org/

DO NOT TRACK OPTION

Do Not Track is a technology that enables visitors to opt out from being tracked by websites for whatever purpose, including the use of analytics services, advertising networks and social platforms. You can enable the ‘Do not track’ option directly in your web browser. Google Analytics will not track users who have enabled this option in their web browsers.

GOOGLE ANALYTICS

The website uses Google Analytics in order to track the information of visitors described above. For this purpose, the abovementioned collected data are transmitted to Google Inc. The IP addresses of visitors are anonymised by the website prior to their transmission to Google Inc; this protects the anonymity of the visitors that have opted for the full website functionalities. Google Analytics has implemented a data retention control feature. This feature provides website owners with the flexibility to define a retention period for the data stored within the Google Analytics account. The defined retention period is 26 months; any data beyond this period is deleted from Google servers.

7. Who has access to your personal data and to whom is it disclosed?

Access to your personal data is provided to the Commission staff responsible for carrying out this processing operation and to other authorised staff according to the “need to know” principle. Such staff abide by statutory, and when required, additional confidentiality agreements. For some specific processing, access to personal data is provided to EEAS staff on a “need to know” basis.

Staff of OLAF, IDOC, IAS (Internal Audit Services), the Legal Service of the Commission as well as staff of other DGs (SG, DG BUDG and clearinghouse) upon request necessary in the context of official investigations or for audit purposes.

Pursuant to Article 3(13) of Regulation (EU) 2018/1725, public authorities (e.g. Court of Auditors, EU Court of Justice) which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients. The further processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

Access to personal data is provided to EEAS staff in the EU Delegations responsible for carrying out this processing operation and to authorised staff according to the “need to know” principle. Such staff abide by statutory, and when required, additional confidentiality agreements.

Access to personal data is provided to external contractors working on behalf of and under contractual agreement with the Data Controller and engaged in creation, maintenance, management, archiving of websites and communication activities according to the “need to know” principle and for the purpose of managing subscriptions to receive information.

Processing of personal data by the contractor and the communication companies contracted by the EU Delegations on behalf of the Commission may involve international transfer when the contractors are non EU/EEA companies or use local offices in the country where the project/programme is implemented. In the context of external action activities.

These transfers are based on

      • adequacy decision – Commission Implementing Decision (EU) 2021/1772 of 28 June 2021 pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council on the adequate protection of personal data by the United Kingdom;
      • derogations – namely for important reason of public interest (Article 50(1)(d)).

Information collected will not be given to any third party, except to the extent and for the purpose we may be required to do so by law.

8. What are your rights and how can you exercise them?

You have specific rights as a ‘data subject’ under Chapter III (Articles 14-25) of Regulation (EU) 2018/1725, in particular the right to access, your personal data and to rectify them in case your personal data are inaccurate or incomplete. Where applicable, you have the right to erase your personal data, to restrict the processing of your personal data, to object to the processing, and the right to data portability.

You can exercise your rights by contacting the Data Controller, or in case of conflict the Data Protection Officer. If necessary, you can also address the European Data Protection Supervisor. Their contact information is given under Heading 9 below.

Where you wish to exercise your rights in the context of one or several specific processing operations, please provide their description (i.e. their Record reference(s) as specified under Heading 10 below) in your request.

9. Contact information

  • The Data Controller

If you would like to exercise your rights under Regulation (EU) 2018/1725, or if you have comments, questions or concerns, or if you would like to submit a complaint regarding the collection and use of your personal data, please feel free to contact the Data Controller, Directorate-General Neighbourhood & Enlargement Negotiations / Unit NEAR.A1 Inter- institutional Relations and Communication, using the functional mailbox:

NEAR-A1@ec.europa.eu

  • The Data Protection Officer (DPO) of the Commission

You may contact the Data Protection Officer (DATA-PROTECTION-OFFICER@ec.europa.eu) with regard to issues related to the processing of your personal data under Regulation (EU) 2018/1725.

  • The European Data Protection Supervisor (EDPS)

You have the right to have recourse (i.e. you can lodge a complaint) to the European Data Protection Supervisor (edps@edps.europa.eu) if you consider that your rights under Regulation (EU) 2018/1725 have been infringed as a result of the processing of your personal data by the Data Controller.

10. Where to find more detailed information?

The Commission Data Protection Officer (DPO) publishes the register of all processing operations on personal data by the Commission, which have been documented and notified to him. You may access the register via the following link: DPO Public register (europa.eu).

This specific processing operation has been included in the DPO’s public register with the following Record reference: DPR-EC-07086.