Privacy policy newsletter

1. Introduction

The European Commission (hereafter ‘the Commission’) is committed to protecting your personal data and to respecting 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. 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 the processing operation “Management of the subscription to the europeana.eu newsletter”, undertaken by the Europeana Foundation, on behalf of the Commission, is presented below.

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

Purpose of the processing operation: the Europeana Foundation, on behalf of the Commission, collects and further processes your personal data so that you can receive monthly updates on important developments, activities, events, initiatives or thematic issues in the area of European cultural heritage and stay in touch with our community. Your personal data will not be used for automated decision-making including profiling.

To facilitate the management of our newsletter, we rely on the services provided by Zoho Campaigns.

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

We process your personal data on the basis of the consent you provided (Article 5(1)(d) of Regulation 2018/1725) to the processing of your personal data for the purpose of receiving the europeana.eu newsletter.

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:

Your name, Your surname, and Your e-mail address.

They are needed to ensure the delivery of the service to you as a subscriber.

5. How long do we keep your personal data?

The Data Controller only keeps your personal data for the time necessary to fulfil the purpose of collection, namely until you unsubscribe from the newsletter. If you wish to unsubscribe from the newsletter, you can follow the unsubscribe link in the information email you have received and your request will be processed immediately. 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?

Personal data in electronic format (e-mails, documents, databases, uploaded batches of data, etc.) are stored on the servers of the Europeana Foundation and on the servers of Zoho Campaigns.

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.

In order to protect your personal data, the Commission has put in place a number of technical and organisational measures. 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 Europeana Foundation, as data processor, is bound by a specific contractual clause for any processing operations of your personal data on behalf of the Commission. The data processor and sub-processor have to put in place appropriate technical and organisational measures to ensure the level of security required by the Commission.

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

Access to your personal data is provided to:

• Commission staff responsible for carrying out this processing operation and to other authorised Commission staff according to the “need to know” principle. Such staff abide by statutory, and when required, additional confidentiality agreements.
• Europeana Foundation staff responsible for carrying out this processing operation according to the “need to know” principle.
• Zoho Campaign staff responsible for carrying out this processing operation according to the “need to know” principle.

Please note that 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.

The information we collect 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 have consented to provide your personal data for the present processing operation. You can withdraw your consent at any time by notifying the Data Controller at CNECT-G2@ec.europa.eu. The withdrawal will not affect the lawfulness of the processing carried out before you have withdrawn the consent.

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, 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, Unit G2, Directorate G, Directorate‑General for Communications Networks, Content and Technology (DG CNECT) of the Commission at: CNECT-G2@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: http://ec.europa.eu/dpo-register. This specific processing operation has been included in the DPO’s public register with the following Record reference: DPR-EC-03928.