Seren Project wishes to emphasize that it always attempts to act in accordance with the EU General Data Protection Regulation of 2016 concerning the protection of individuals with regards to the processing of personal data, the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred as “the GDPR”).
The terms used in this agreement shall have the meaning given in the national data protection laws or in the GDPR. If a term is used or defined in both legal frameworks, its definition or meaning shall e the one of the GDPR.
For the purposes of the present agreement, ‘personal data’, ‘processing’, ‘controller’ and ‘processor’ and shall be defined as by Article 4 “Definitions”, para. 1, 2, 7 and 8 of the GDPR:
– ‘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, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
– ‘controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law
– ‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
Types of Personal Data
Provided the purpose and its proportionality of the collection, Seren Project can collect and process the following personal data:
– First Name
– Family name
– E-mail address
– Telephone or mobile numbers
– Company information
– Geographical location data
– Credentials required to access restricted webpages, online tools, forums
– Invoicing details, payment and billing information
– Vehicles plate numbers
All personal data freely provided to Seren Project (e.g. disclosed in the correspondence with Seren Project).
Seren Project also automatically collects anonymous information regarding data subject’s use of the Websites.
As such, Seren Project shall, for example, automatically log which sections of the Websites and Platform data subjects visit, which web browser is used, which website is visited when obtained access to the Website.
We cannot identify data subjects through these data, but it allows Seren Project to draw up statistics regarding the use of the Websites.
Methods of Personal Data Collection
– Collaboration with Seren Project
– Incoming and outgoing correspondence with Seren Project
– Visiting the Websites or the Seren Project office
– Subscription to the newsletter
– Appealing on the services of Seren Project, whether or not through the Websites and/or whether or not via a mobile device
– Subscription and registrations to Seren Project webinars/seminars/events/workshops/etc.
– Taking pictures and video recording, taken during events or voluntarily received
– Exchanging of business cards
– Verification of one’s identity (e.g. when a data subject contacts customer service)
All personal data, collected by Seren Project, are thus expressly and voluntarily provided by the data subject.
Providing certain personal data is (sometimes) a requirement to be able to enjoy certain services (e.g. to gain access to certain parts of the Websites, to subscribe to newsletters, to participate in certain activities and events). In this respect, it shall be indicated which data must be provided mandatory and which data is optional.
Use of Personal Data
– Performance of the agreements stipulated with Seren Project (incl. follow-up thereof)
– Responding to inquiries (whether or not received through the contact form)
– Optimizing the quality, management and content of the Website
– Sending newsletters and Seren Projectss releases
– Targeted marketing and advertising, membership updates based on data subject’s communication preferences and – where applicable – upon explicit consent
– Creating statistics
– Drawing-up quotes (articles, papers, minutes and other written statements)
– Follow-up meetings
– Creation of an account and the confirmation thereof
– Providing support/assistance (e.g. in case of problems)
– Conducting members’ satisfaction studies, surveys and other market research
– Registration of visitors to the office/building of Seren Project
– Confirmation of the subscription or registration to a webinar/seminar/event/etc.
– Issuing of invoices and the collection thereof
– Securing parking spaces
Processing takes place on the following legal grounds, as the case may be:
– Upon prior consent to the processing of data subject
– Processing is necessary to protect data subject’s vital interests or of another natural person
– Processing is necessary for the performance of a task carried out in the public interest
– Processing is necessary for the purposes of the legitimate interests pursued by Seren Project or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require protection of personal data
Disclosure of personal data to third parties
Seren Project shall not disclose personal data to third parties, unless it is necessary in the context of performing the agreement and optimisation thereof (including but not limited to Seren Project). In this respect, personal data might be disclosed to payment providers, software providers, cloud partner, external IT-consultants, insurance and employment companies, financial institutes and service providers (among others, translators and photographers).
Notwithstanding the foregoing, it is however possible that Seren Project discloses personal data:
to the competent authorities (i) if Seren Project is obliged to do so under the law or under legal or future legal proceedings and (ii) to safeguard and defend your rights.
If Seren Project, or the majority of its assets, are taken over by a third party, in which case your personal data – which Seren Project has collected – shall be one of the transferred assets
Exchange of the information among members – they do not have contractual agreements among each other
In all other cases, Seren Project will not sell, hire out or pass on personal data to third parties, unless (i) approval from the data subject, or (ii) has completed a data processing agreement with the third party in question, which contains the necessary guarantees regarding confidentiality and privacy compliance of your personal data.
Cross-border processing of personal data
Any transfer of personal data outside the European Economic Area (EEA) to a recipient whose domicile or registered office is in a country which does not fall under the adequacy decision enacted by the European Commission, shall be governed by the provisions of a data transfer agreement, which shall contain (i) the standard contractual clauses, as referred to in the ‘European Commission decision of 5 February 2010 (Decision 2010/87/EC)’, or (ii) any other mechanism pursuant to privacy legislation, or any other regulations pertaining to the processing of personal data.
Storage of Personal Data
Data Subject’s Privacy Rights
In light of the processing of personal data, data subjects (you) enjoy the following privacy rights:
– Right of access to your personal data
– Right to rectification, completion or update of your personal data
– Right to delete your personal data (‘right to be forgotten’). (Seren Project wishes to point out that in this context certain services will no longer be accessible and/or can no longer be provided after deletion or pending a request for deletion for certain required personal data)
– Right to limit the processing of your personal data
– Right to transferability of your personal data
– Right to object to/oppose the processing of your personal data
If a data subject wishes to invoke privacy rights, he or she can do so by submitting a written request by email (firstname.lastname@example.org)
In principle, data subjects can exercise these rights free of charge. In addition, data subject can always, via the personal account, update, modify and/or verify personal data, which were required to submit when registering.
If a data subject no longer wishes to receive newsletters or information about the services of Seren Project, he or she can unsubscribe at any time by clicking the “unsubscribe” button, where available, or by notifying the sender.
Security of personal data
Seren Project undertakes to take reasonable, physical, technological and organisational precautions in order to avoid (i) unauthorised access to personal information, and (ii) loss, abuse or alteration of personal data.
Seren Project shall store all personal data, which it has collected on its servers.
Notwithstanding Seren Project’s security policy, the checks it carries out and the actions it proposes in this context, an infallible level of security cannot be guaranteed. Since no method of transmission or forwarding over the internet, or any method of electronic storage is 100% secure, Seren Project is, in this context, not in a position to guarantee absolute security.
Finally, the security of data subjects’ accounts will also partly depend on the confidentiality and complexity of their passwords. Seren Project will never ask for passwords, meaning that data subjects will never be required to communicate it personally. If nonetheless communication of the password was forwarded to a third party – offering for example additional services – this third party will have access to the account and to the personal data. In such case, data subjects are liable for the transactions which occur as a result of the use made of their account. Seren Project therefore strongly advises the data subjects, to immediately change passwords and contact us when breaches have been reported.
The Websites may potentially contain hyperlinks to other websites. When data subjects click on one of these links, they might be redirected to another website or internet source that could collect information about them through cookies or other technologies. Seren Project does not bear any responsibility, liability or control authority over these other websites or internet resources, nor about their collection, use and disclosure of personal data. Data subjects must check the privacy statements of these other websites and internet sources in order to be able to judge whether they act in accordance with the Privacy Legislation.
Contact Seren Project
processes personal data, please contact us:
Via e-mail: email@example.com
In case data subjects are not satisfied with the way Seren Project handled inquiries and/or remarks or have any complaints about the way Seren Project collects, uses and and/or processes personal data, data subjects have the right to lodge a complaint with the Privacy Commission.