Asylum and Migration

Personal Data Protection Policy

The protection of your personal data is very important to us. This Privacy Policy describes the purposes of data collection, storage and use by the Fund Operator, when visiting or using the website, pursuant to the Regulation (EU) 2016/679 of the European Parliament and Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), as applicable with effect by 25th May 2018, the respective laws of Greece, as well as the decisions of the Greek Data Protection Authority and any other more specific national or European legislation concerning specific fields.

1. About our website
This website belongs to the Fund Operator, i.e. SOL Consulting SA in cooperation with Human Rights 360.
The personal data you provide us, when you navigate through the website, are stored by the Fund Operator, who acts as Controller.

2. What is personal data?
“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.

3. What is “processing” of personal data?
“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;

4. When do we collect personal data through our website?

i. When you visit or navigate through our website
When you use our website browsing and viewing the information we have, we use cookies to allow the website to function properly.The operational cookies we use are necessary for the website’s functionality and no consent is needed.

ii. When you submit a question / request through the respective forms on the website
When you submit a question / request through the form, we request your name & surname, address, contact number, e-mail address.
We use this information to reply to your request, as well as to provide you with any relevant information.
The data can be accessed only by duly authorised staff or of competent authorities
We store this information, for the period necessary to complete/ resolve your request, unless further contact is required and in any case for your own interest.In specific cases, the Fund Operator reserves the right to maintain the correspondence history for as long as it is deemed appropriate in accordance with relevant contractual obligations.

iii. When you subscribe to our Newsletter
When you submit your e-mail address and subscribing to our newsletter in order to receive information material, we will keep this information for the period you wish until you activate the unsubscribe option. We will delete your information as soon as you declare that you do not wish to receive our newsletter.

iv. Use of hyperlinks on the website
This website links to other websites (Linked Sites) that are not affiliated with the Fund Operator and their content is not controlled by the latter. Consequently, the Company does not guarantee the accuracy, legality, completeness, timeliness, truthfulness, accuracy or quality of their content and is not responsible for any loss or damage that may be caused or caused by their use. Similarly, the Fund Operator cannot control the processing of your personal data by the Affiliate Pages and therefore bears no responsibility in relation to it. When you use the hyperlinks, the Terms and Conditions of each website apply accordingly. For any issues that may arise in relation to the content or the use of an affiliate website, you are kindly requested to contact the owner or administrator of the Website directly. The Fund Operator in no way endorses, accepts or endorses the content or services of the Linked Sites to which the user is referred through hyperlinks.

5. Connection and interaction with social media
Through our website you can connect and interrelate with social media on your initiative. In this case, the Fund Operator is not responsible for the processing of personal data, taking place in these media. For exercising your rights, you should contact the social media. We do not collect data, other than the data you provide yourself through our account in social media. The purpose of this processing is to achieve contact and interaction. The legal basis for this processing is your consent.
You provide your consent by pressing the “like” or “follow” button on our pages and you can withdraw your consent just as easily in the same way (unlike, unfollow).

6. Use of Portal for Applicants and Project Promoters
In order to optimize your service and facilitate your future report submission we have created a portal. You have to create a member account in order to submit your application form for the open call and submit relevant reports after your selection as a project promoter. The information you fill out and upload on the Fund Operator’s special form remains stored in our systems for as long as our contractual obligations are met and after this period your data is deleted. Once you place an order, your data will be kept for the necessary time to cover the tax and other obligations of the Controller based on the respective tax or other relevant legislation and / or provision.
All this information is necessary, relevant and appropriate for the transaction between us and the implementation of the respective activities on our behalf.
Also essential is the use of login information (code) that you must safeguard and keep secure.
Specifically for issues related to the processing of your data, you can contact the helpdesk (as mentioned below).

7. Individual Rights under GDPR

Data subject rights are one of the key areas under GDPR. The GDPR sets forth and protects individual rights that the data subject can exercise the following rights:

1. The right to be informed: it means the right of the subject to receive information about the processing of its data, e.g.the identity of the controller, the contact details of the data protection officers, the purposes of and the legal basis for processing, the recipients of its data, the intention of the controller to transfer data to a third country, the period for which the personal data shall be stored, its right to lodge a complaint and the ways to exercise its rights against the controller (Art. 13-14)

2. The right of access: it means the right of the subject to know if or which of its personal data are processed by the controller, and where that is the case, to receive the information stated in point (1) above (Art. 15)

3. The right to rectification: it means the right of the data subject to ask for rectification or supplementation of inaccurate or incomplete personal data (Art. 16)

4. The right to erasure: it means the right of the data subject to obtain from the controller the erasure of personal data concerning him or her without undue delay (Art. 17)

5. The right to restrict processing: it means the right of the data subject to obtain from the controller restriction of processing under the conditions set out by the GDPR (Art. 18)

6. The right to data portability: it means the right of the data subject to receive the data provided to the controller in a commonly used and machine-readable format and transfer them to another controller or have the personal data transmitted directly from one controller to another (Art. 20)

7. The right to object: it means the right of the data subject to object, on grounds relating to his or her particular situation, at any time to processing of personal data (Art. 21)

8. Rights in relation to automated decision making and profiling: it means the right of the data subject not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her (Art. 22). No automated decision making and profiling is implemented through our website.

8. Rights Exercise
To exercise your rights, you can send an e-mail to helpdesk (info@asylumand migration-eeagrants.gr).

9. When we respond to your requests
We reply to your request with no delay free of charge and in any case in one month from the date we receive the request. If the request will take longer than that because of the complexity and/or number of requests, then we shall inform you for the delay and a maximum of 90 days for reply is allowed.The Fund Operator may charge a reasonable fee in case the request is deemed manifestly unfounded or excessive (especially if it is repetitive) or the number of copies of the requested information is considerable, taking into account administrative costs. The Fund Operation reserve the right to refuse to implement the request.

10. Data Breach Notification

The Fund Operator will inform without undue delay” if the breach is likely to result in “a high risk to the rights and freedoms of natural persons”.

11. Submit a complaint to the Data Protection Authority

If you consider that your data are in any way violated, you have the right to submit a complaint to the Data Protection Authority (www.dpa.gr), which is the competent supervisory authority for the protection of the rights and freedoms of natural persons against the protection of their personal data. (address Kifisias 1-3, P.C. 115 23, Athens, tel. 210. 6475600, e-mail contact@dpa.gr ).

12. Changes to this Privacy Policy

We will update this Privacy Notice whenever deemed necessary.

If there are any significant changes in this Policy or in the way we process your personal data, we will inform you accordingly either by providing a more prominent notice on the website before the changes are implemented or in any other through any other appropriate means.
We recommend that you re-visit this Policy from time to time to learn of any such changes to this Policy.
In the case where it is deemed appropriate to use your personal data for any other reason than the original collection purpose, we will inform you accordingly providing all information needed and if deemed appropriate we will ask for your consent.

The Fund Operator may amend this information according to its applicable policy on the protection of personal data. The updated version shall at any time be published on the Fund Operator’s webpage.

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