1. Privacy Policy in accordance with EU Regulation 2016/679

Pursuant to the EU General Data Protection Regulation (GDPR), hereby we acknowledge that the “CivicChampions: Empowering civil society organisations and activists championing human rights and democratic values in the EU” Consortium is committed to protecting your privacy. This Privacy Statement applies to collecting information and data relevant for conducting CivicChampions: Empowering civil society organisations and activists championing human rights and democratic values in the EU activities.

2. Who is the CivicChampions: Empowering civil society organisations and activists championing human rights and democratic values in the EU Consortium?

CivicChampions: Empowering civil society organisations and activists championing human rights and democratic values in the EU Consortium consists of the following institutions:

• CSD – Center for the Study of Democracy, Bulgaria
• CESIE ETS, Italy
• KMOP – Social Action and Innovation Centre, Greece
• CARDET, Cyprus

CivicChampions: Empowering civil society organisations and activists championing human rights and democratic values in the EU – co-funded by the European Union, the project’s implementation will last for 24 months, starting 01/05/2024 and ending 30/4/2026. CivicChampions: Empowering civil society organisations and activists championing human rights and democratic values in the EU project aims to fortify civil society’s resilience by providing reliable data, developing effective tools, and enhancing its capacity to tackle challenges such as the shrinking civic space, disinformation and online threats. By focusing on capacity building, establishing early warning systems, and implementing evidence-based actions, the project aims to safeguard fundamental rights and ensure a thriving civic environment.

3. What is personal data

In accordance with Article 4 of EU Regulation 2016/679, ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; ‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. We collect and process only the following types of information that you provide us with for the purposes of project activities:

• Personal information: name and surname of natural persons, contacts such as address, ZIP code, city, region, telephone number, email
• Data concerning professionals/organizations/businesses: information concerning businesses, name, fiscal address, and other identifiers (email and telephone number, tax code or VAT number)

Moreover, we may collect data provided when you access our sites, through cookies and other similar technology; and when you contact us via email, social media, or similar technologies.

Even though such data are not collected so as to be associated with the natural person, these online identifiers might be used and combined by third actors so as to create personal profiles. Among the online identifiers we may find IP address, browser type and plug-in details, device type (e.g. desktop, laptop, tablet, phone, etc.) operating system, local time zone. These data are used solely to produce statistical results.

4. Why we process your data

We will use your data in the following ways:

1. 1. for statistical purposes
   2. to carry out social marketing, fundraising and communication activities concerning the services provided by our organizations via email or mail

5. How we process “sensitive” personal information

We would like to remind you that processing sensitive data (i.e. personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation) shall be prohibited.

Derogating from such prohibition shall be allowed when processing is carried out in the course of legitimate activities with appropriate safeguards by a foundation, association or any other not-for-profit body with a political, philosophical, religious or trade union aim and on condition that the processing relates solely to the members or to former members of the body or to persons who have regular contact with it in connection with its purposes and that the personal data are not disclosed outside that body without the consent of the data subjects;

In the aforementioned cases, the subject should agree to data processing.

6. How we process your data

We will process and store your data solely for the execution of project activities and meeting project objectives, using digital and analogical devices and in relevant databases ensuring appropriate safeguards so as to guarantee ongoing confidentiality, integrity, availability and resilience of processing systems, as set out by EU regulation 2016/679. Only subjects who have obtained access to personal data from the controller or the processor can process such information.

7. Social networks

Our website may offer access to social networks. The terms of service and Privacy Policy applicable to such platforms are published on their website. We cannot control the way data shared on a public forum, chat or dashboard are used, being the data subject responsible of such communication.

8. Cookies

There are two main categories of cookies:

• Technical cookies. These are used for the sole purpose of “transmitting communications to an electronic communication network, or to the extent strictly necessary for the provision of a service by the information company explicitly requested by the contracting party or the user in order to provide the said service”. These are not used for any ulterior purposes and they are normally installed directly by the owner or the manager of the website (so-called “proprietary” or “editorial” cookies). These can be divided into: browsing or session cookies, which guarantee normal navigation and use of the website (making it possible for example, to make purchases or be authenticated in order to access reserved areas); analytics cookies assimilated by the technical cookies where they are used directly by the manager of the website to collect information, in an associated form (anonymous), about the number of users and the manner in which they visit the website; functional cookies that allow the user to navigate in relation to a series of select criteria (for example, the language or the products selected for purchase) in order to improve the service provided, provided that we inform our users as set out by article 13 EU Regulation 2016/679. Informed consent is not required for such cookies.
• Profiling cookies. These are used to create profiles of the users and are employed for sending advertising messages according to the preferences shown during their online activity. Due to their invasiveness with regard to the users’ private sphere, European regulations require that users are adequately informed about their use and are thus required to express their valid consent. An Internet page, such as an online newspaper, contains several objects and each domain can set cookies, therefore web browsers allow, and support such technology. Their purpose is to register, and trace information connected to users’ experience, as they journey between pages, they recognize the users and remember their preferences and settings when they return to the website, in order to deliver relevant contents and advertising. Disabling profiling cookies may have a negative impact on users’ browsing experience.

9. Sharing your data with third parties

We would like to inform you that your personal data might be shared with other parties in order to comply with the obligations under the applicable national and European regulations.

Parties to whom we may disclose your personal data are:law enforcement agencies, judicial authorities, audit bodies and professionals professionals, public administration and other entities who perform administrative, accounting and management tasks connected to our regular activities (legal obligations).

We will only use your personal data where we have a legal ground to do so, otherwise your data will not be shared with third parties.

10. International and European data transfer

Your data will be processed solely within the European Economic Area.

11. Subject rights

Your rights with regard to the personal data we hold under EU Regulation 2016/679

You can exercise your rights any time, as set out by Article 7, par. 3, and articles 15 and following of EU regulation 2016/679:

1. 1. right to access personal data
   2. right to rectification and erasure of personal data
   3. right to restriction of processing
   4. right to data portability
   5. right to object to processing of personal data
   6. right to lodge a complaint with the competent Data Protection Authority

You can exercise your rights by sending us an email at maria.yordanova@csd.eu or a letter addressed to CSD – Center for the Study of Democracy, via 3 Aleksandar Zhendov Str., Sofia 1113, Bulgaria. For further information, please contact us by phone telephone at +359 2 971 3000.

Further information concerning data processing can be added when collecting data.

For all matters not expressly regulated by this Policy, the Center for the Study of Democracy’s Personal Data Protection and Privacy Policy shall apply.