This Privacy Policy sets out the obligations of the UNDERPIN project (Project) regarding data protection and the rights of clients and business contacts (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “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.

This Privacy Policy outlines the Project’s responsibilities concerning the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles outlined herein are binding on the Project, its consortium partners, agents, contractors, or other parties acting on behalf of the Project. Your use of our webpage implies agreement with this Privacy Policy and any other governing agreements for the Services; please refrain from using our webpage if you do not agree with these terms.

1. Ways we Collect and Use Personal Information

“Personal Information” is information that, either alone or in combination with other information collected, identifies an individual. When we combine other information (i.e., information that does not, on its own, identify an individual) with Personal Information, we treat the combined information as Personal Information.

When you engage with us through email, telephone, or in person, we may collect Personal Information, including but not limited to your name, email address, phone number, and contact preferences. This Personal Information may be utilized to communicate with you, providing important updates about the Project and notifying you of significant changes to this Privacy Policy.

2. Other Uses of Personal Information by the UNDERPIN project

The UNDERPIN project may utilize Personal Information for internal statistical, marketing, or operational purposes. This includes measuring and understanding demographics, user interests, identifying technical issues, and exploring new solutions to enhance the overall experience.

3. Sharing Personal Information

We engage third-party service providers to assist us in administering specific activities on our behalf, including sending emails, analyzing the usage of our websites and portal, and tracking the effectiveness of our marketing campaigns. Personal Information about you may be shared with these third-party service providers solely for the purpose of enabling them to perform services on our behalf. Below are examples of third-party service providers we utilize:

• MailerLite: MailerLite is used to help us collect emails, sending them and to automate some process.
• Analytics Services: We uses third-party service providers to help us better understand usage of our portal and web pages and for related purposes. The third parties we currently use to provide such analytics and related services are described under Cookies Policy.
• Other Disclosures: We may disclose Personal Information about you to others if we have your consent to do so in such form of consent as may be required under applicable law.

Subject to applicable laws in your jurisdiction, we may also disclose Personal Information about you to others as we believe to be necessary or appropriate: (a) under applicable law or regulation, including laws or regulations outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public authorities and law enforcement officials, including officials outside your country of residence; (d) to assist or support theft investigations involving Project’s products or property, (e) to enforce any of our terms and conditions or policies; (f) to protect our operations or those of any of our affiliates and subsidiaries; (g) to protect the rights, privacy, safety or property of our Project or our products, its affiliates and subsidiaries, you or others; or (h) to permit us to pursue available remedies or limit the damages that we may sustain.

5. Cookies and Similar Technology

To analyze how you and other visitors navigate our websites and compile aggregate statistics about site usage and response rates, we, with the assistance of third-party analytics service providers, collect certain information when you visit our site. This information may include your IP address, the geographic location of your device, browser type, browser language, date and time of your request, times of your visits, demographics, page views, and page elements (e.g., links) that you click. We may use cookies, pixel tags, web beacons, clear GIFs, or other similar tools on our site or in our email messages to assist us in collecting and analyzing such information.

This information is utilized to provide better, more relevant content on our site, measure the effectiveness of advertisements, identify and address problems, and enhance your overall experience.

Cookie Policy

To ensure the proper functioning of this site, our websites and portal use ‘cookies’ to enhance the user experience and track attendance. While most browsers support cookies, users have the option to set their browsers to decline them and can delete them at their discretion. You have control over how you accept and use cookies through your internet browser settings.

By using our website, it is considered that you consent to the storing of cookies. Turning off and / or blocking the cookie storage, you can still browse our sites, but there is a chance that some of their features / functionalities will not be available.
According to the regulations of the European Union of 25.03.2011. we have an obligation to ask for your consent before saving these data.

What are cookies?

A cookie is a small text file that the website you are visiting saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

What are the different types of cookies?
A cookie can be classified by its lifespan and the domain to which it belongs:

• session cookie which is erased when the user closes the browser or
• persistent cookie which remains on the user’s computer/device for a pre-defined period of time.
• first-party cookies which are set by the web server of the visited page and share the same domain
• third-party cookies stored by a different domain to the visited page’s domain. This can happen when the webpage references a file, such as JavaScript, located outside its domain.

How do we use cookies?

• Our pages use cookies to remember your display preferences, such as contrast colour settings or font size
• If you have already replied to a survey pop-up that asks you if the content was helpful or not (so you won’t be asked again)
• If you have agreed (or not) to our use of cookies on this site
• some videos embedded in our pages use a cookie to anonymously gather statistics on how you got there and what videos you visited
• To monitor and analyze usage and traffic patterns on our web sites: we use Google Analytics system to measure attendance on websites. If you want to turn off the storage of cookies, you can do so at the link Google Analytics page
• To provide you a better user experience
• For proper operation of the website (when such action is necessary).

The UNDERPIN project website offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
When you submit data to through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.

In order to provide you with a great experience on UNDERPIN website, we provide the functionality to set your preferences for how UNDERPIN runs when you use it. In order to remember your preferences, we need to set cookies so that this information can be called whenever you interact with UNDERPIN is affected by your preferences.
Enabling these cookies is not strictly necessary for UNDERPIN to work but it will provide you with a better browsing experience. You can delete or block these cookies, but if you do that some features of the UNDERPIN site may not work as intended.
The cookie-related information is not used to identify you personally and the pattern data is fully under our control. These cookies are not used for any purpose other than those described here.

Third Party Cookies

In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.

UNDERPIN utilizes Google Analytics, one of the most widespread and trusted analytics solutions on the web, to help us understand how you use the site and identify ways to enhance your experience. These cookies may track details such as the duration of your visit and the pages you access, enabling us to continually produce engaging content. For more information on Google Analytics cookies, refer to the official Google Analytics page opt-out.

SOCIAL MEDIA We also use social media buttons and/or plugins on UNDERPIN web that allow you to connect with your social network in various ways. For these to work the social media that we use, such as Facebook, X platform/Twitter, LinkedIn, or other, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.

How to control cookies
You have the ability to control and/or delete cookies according to your preferences—refer to aboutcookies.org for details. You can delete all cookies already on your computer, and most browsers can be configured to prevent their placement. However, please note that doing so may require you to manually adjust some preferences each time you visit a site, and it may impact the functionality of certain services.

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7. Security
We take reasonable security measures to help protect against loss, misuse, unauthorised access and unauthorised disclosure or alteration of the Personal Information under its control.

8. Policy with Respect to Children
Our websites and portal are not intended for individuals under the age of 18, and we kindly request that individuals under 18 do not provide Personal Information to our Project through any of our websites. Should we become aware that we have inadvertently collected Personal Information from a person under 18, we will promptly take steps to delete the information.

9. Privacy Statement Updates
We reserve the right to modify this Privacy Policy periodically as we add new information, enhance our current website, and adapt to changes in technologies and laws. To determine the last revision date, please refer to the ‘LAST UPDATED’ legend at the top of this page. Any revisions will take effect upon the posting of the updated Privacy Policy on our affected websites. In the event that these changes are substantial, we will notify you, and, where required by applicable law, seek your consent. Such notifications will be provided via email or by posting notices of the changes on our affected websites or products/apps, in accordance with applicable laws.

10. Retention of Personal Information
We will retain your Personal Information for the period necessary to fulfill the purposes for which your Personal Information has been collected as outlined in this Privacy Policy unless a longer retention period is required by law.

11. How You Can Review, Correct, Update and Delete Your Personal Information
We take reasonable steps to ensure that the Personal Information collected from you is accurate, complete, and current. You have the right to request access to your Personal Information, seek corrections for erroneous or inaccurate details, and request the deletion of your Personal Information. We will promptly respond to your requests in accordance with applicable law. For your security, we may only implement requests related to the Personal Information associated with the specific email address used to submit the request, and we may need to verify your identity before processing your request. We reserve the right to decline requests that jeopardize the privacy of others, are highly impractical, or would necessitate actions not permissible under applicable laws.

For access, correction or deletion requests can be made via email info@underpinproject.eu.