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Privacy policy

Introduction

Reaktor Innovations (hereafter called Reaktor) is developing the Digital SkillUp website, which is subject to the privacy policy set-out below.

This Digital SkillUp website is developed as part of the European Digital Academy project (Grant Agreement LC-01390449) an 18 months’ project funded by the European Commission (Directorate-General for Communications Networks, Content and Technology), coordinated by EUN Partnership aisbl.

This Privacy Policy is governed by EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR). In line with its obligations under the GDPR, Reaktor takes the protection of your privacy seriously. We exclusively collect, store, and retain our users’ personal data to provide the best possible service and treat this data with the utmost care. In this statement, we explain which data we collect, why we do this, how we collect and store it and how users of the website may exercise their rights. 

What Personal Data do We Collect via the website?

a) Public website

The Digital SkillUp website consists of a public website, for guest users, including a searchable catalogue of learning resources on emerging technologies. 

On the Digital SkillUp website data is collected only in connection to the hosting (see ‘Hosting’ below). Browsing through the content and executing searches on the website can be done without creating or login into any account or profile. 

When you visit our public website, you may be invited to participate in events, surveys or questionnaires launched by the DigitalSkillUp initiative and you may choose to contact us and/or the other partners by e-mail. If you choose to contact us directly, we will only use the personal data you have provided us with for the purposes of responding to your message and, in case, providing the service you require.

Please note that we use third parties to manage hosting (Heroku), forms/questionnaires and participants’ registration for events (EUSurvey, Go2Webinar and MS Teams) and this processing may additionally be subject to the third party's own terms and conditions and privacy statement.

The Digital SkillUp website is hosted in Heroku EU. All data connected to the hosting is saved physically inside the EU region. The application only processes IP addresses as personal data. The use of IP addresses falls within the standard operating clause of Heroku Salesforce. Read more here: https://www.salesforce.com/content/dam/web/en_us/www/documents/legal/Agreements/data-processing-addendum.pdf

Questionnaire and registration to events will include their own privacy statements and the form will require you to consent to share your personal data for those purposes. The privacy statements will describe the type of personal data we will collect (for example, name, surname, e-mail address, photographs, information on your activities etc.), the purpose of the processing, who will have access to the data and the period of time for which the data will be kept.

The privacy statements will also detail your rights in respect of the data we collect, for example, your right to contact us to have confirmation of the data we hold on you, the right to have your data rectified or to have such data deleted. These privacy statements will also tell you where you can get further information on our privacy policy and the official organisations to which you can complain in the event that you feel that your data rights have been infringed.

b) Other forms of Collection

Please note that we also collect anonymous information about your activity on our website in order to improve our website. We use a service called Matomo for this (see ‘Matomo’ and ‘Cookies’ sections below). Aggregated statistics will be retrieved regularly on the analytic information collected through the public site.

2. Who do we share your data with and how

Please note that the European Digital Academy project is a collective effort in which organisations from multiple countries participate. 

This network includes:

  • the European Digital Academy initiative partners

  • Experts contracted by one or more organisations part of the network, which support the initiative for coordination and for the evaluation of the activities.

  • The European Commission, for the purposes required in managing the project.

Your personal data is shared between the subjects of the network listed above insofar as this is necessary: 

  • to manage the project activities

  • to respond to you and to provide the service you require.

  • to enable us to use the responses to the surveys and questionnaires to manage the activities and for evaluation and research purposes.

  • to process your participation in events.

The analytics of the site are shared as aggregated data between the subjects of the network listed above and external stakeholders insofar as this is necessary to further develop the educational offering and user experience of the site.  

We do not sell your data to third parties. We use the tools by the service providers listed above to manage the activities (section 1 of this notice). Apart from these service providers and the European Digital Academy network, no third parties will receive your data, unless this is disclosed to you in advance in a separate privacy policy.

3. How long do we store your data?

We store your personal data for 5 years after the end of the project.

For events and surveys, the period of retention will be indicated in the separate privacy policy for the activity concerned. 

If you wish to stop receiving communication from us, you can change your mind at any time by contacting us at digitalskillup@reaktor.com 

4. Matomo

Matomo is used in the Digital SkillUp site for analytics. 

Matomo is a web analytics tool that uses cookies to track visitor interactions, helping website owners understand how visitors engage with their website. Matomo customers can view a variety of reports about how visitors interact with their website so that they can improve it. Matomo collects information without identifying you directly. It reports website trends to its users such as us without identifying individual visitors. Specifically, and depending on whether Matomo has access to this information, customers can get information on the data outlined here:

https://matomo.org/faq/general/faq_18254/

You can find Matomo privacy policy here: https://matomo.org/privacy-policy/

Opt-out of website tracking

You can opt out of being tracked by our Matomo Analytics.

5. Cookies

To make this site work properly, we sometimes place small data files called cookies on your device. Most big websites do this too.

What are cookies?

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, 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.

How do we use cookies?

On our site, we are currently use only one cookie: internal tracking for whether the user has already answered the cookie consent form.           

However, we may add additional cookies to improve the functionality of the site in the ways defined above. Non-essential cookies are always opt-in only. 

More detailed information about the type of cookies we are using can be found in the following.

  • Name: has_answered_cookie_consent

  • Type: true / false

  • Purpose: Internal tracking for whether the user has already answered the cookie consent form.

How to control cookies?

You can control and/or delete cookies as you wish – for details, see aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. 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.

6. Site security

The Digital SkillUp website has implemented and continues to maintain appropriate state-of-the-art technical and management measures to keep your personal information secure and safe from loss, damage, corruption, or deletion.

7. Changes within this privacy policy

Any and all changes to this privacy policy will be posted here and will take effect upon their publication. If you have any questions or concerns about this privacy policy, at any time, please contact digitalskillup@reaktor.com 

8. Contacting Reaktor

For any questions related to the Digital SkillUp website, you can contact us:

Data controller

via email: digitalskillup@reaktor.com      

via post: Reaktor, Yliopistonkatu 4, 00100, FI-Helsinki

via telephone: +358 40 7622 019

You can also contact us in order to exercise your right to request data portability or to access, rectify and, as the case may be, erase, any personal data relating to you, or restrict the processing of your personal data, in compliance with applicable laws. Please note that we may ask you to provide proof of identity (such as a copy of your ID card or passport) before we can comply with your request. Whenever we process your personal data based on your consent, you also have the right to withdraw your consent at any time.

9. Making an Official Complaint

If you feel that we have infringed your data protection rights, you may make an official complaint to the data protection authorities in your country of residence or The Office of the Data Protection Ombudsman (Finland) at the following addresses:

https://tietosuoja.fi/en/contact-information

via email: tietosuoja(at)om.fi

via post: PL 800, 00531 Helsinki, Finland

via telephone: +358 29 566 6700