- Introduction
EdiTC Ltd, referred to in this Privacy Policy as “EDITC”, “we”, “us” or “our”, is committed to protecting the privacy and personal data of the individuals who interact with our organisation, website, training activities, projects and professional services.
This Privacy Policy explains how we collect, use, retain, share and protect personal data when you:
- visit the EDITC website;
- contact us or submit an enquiry;
- register for or participate in a training course, seminar, workshop or event;
- participate in an EU-funded or other project involving EDITC;
- complete a questionnaire, survey, assessment or evaluation form;
- collaborate with EDITC as a trainer, expert, project partner, customer, supplier or stakeholder; or
- otherwise use or engage with our services and activities.
EDITC processes personal data in accordance with the General Data Protection Regulation (EU) 2016/679, commonly known as the GDPR, and applicable data-protection legislation in Cyprus. The Office of the Commissioner for Personal Data Protection provides GDPR compliance guidance for controllers and processors, including guidance concerning appropriate organisational and technical measures. [dataprotec...ion.gov.cy]
- Data Controller
The data controller responsible for the processing activities described in this Privacy Policy is:
EdiTC Ltd
16 Imvrou Street
1055 Nicosia
Cyprus
Email: enquiries@editc.com
Website: https://editc.com
Questions concerning this Privacy Policy or the processing of personal data by EDITC may be submitted using the contact details above.
For certain EU-funded projects, consortium activities or collaborative services, EDITC may process personal data jointly with another organisation or on behalf of another controller. Where relevant, participants will be provided with additional privacy information concerning that particular activity.
- Personal Data We Collect
The personal data collected by EDITC depends on how an individual interacts with our organisation.
3.1 Contact and identification information
We may collect:
- name and surname;
- email address;
- telephone number;
- postal address, where necessary;
- organisation or employer;
- job title or professional role;
- country of residence; and
- preferred language.
3.2 Training and event information
When an individual registers for or participates in an EDITC course, seminar, workshop, conference or event, we may collect:
- registration details;
- course or programme information;
- attendance records;
- assessment results;
- assignments or other submitted work;
- participant feedback;
- evaluation responses;
- certification information; and
- any accessibility or participation information voluntarily provided and necessary for delivering the activity.
3.3 EU-funded project information
When an individual participates in an EU-funded or other collaborative project, EDITC may collect information necessary for:
- registration and participation;
- project implementation;
- attendance verification;
- project monitoring;
- quality assurance;
- research and evaluation;
- preparation of project indicators;
- reporting to coordinators or funding bodies; and
- communication and dissemination activities.
The exact information collected will depend on the requirements of the particular project and activity.
3.4 Enquiries and communications
When an individual contacts EDITC, we may retain:
- contact details;
- the content of the enquiry;
- correspondence and communication history;
- information required to respond to the request; and
- related administrative records.
3.5 Website and technical information
When an individual uses the EDITC website, certain technical information may be collected automatically, including:
- IP address;
- browser type and version;
- device type;
- operating system;
- referring website;
- pages visited;
- approximate location based on the IP address;
- date and time of visits; and
- interactions with website features.
This information may be collected through cookies and similar tracking technologies, subject to applicable consent requirements.
- Why We Process Personal Data
EDITC may process personal data for the following purposes:
- responding to enquiries and requests;
- managing applications and registrations;
- delivering training courses and professional services;
- communicating with participants, customers and partners;
- maintaining course-participation and attendance records;
- conducting assessments and issuing certificates;
- organising seminars, workshops, conferences and events;
- implementing EU-funded and other collaborative projects;
- administering project participation and activities;
- conducting surveys, evaluations and research;
- monitoring project results and indicators;
- preparing contractual, financial and project reports;
- communicating and disseminating project activities and results;
- managing relationships with customers, trainers, experts, partners and suppliers;
- fulfilling contractual, accounting, reporting and funding obligations;
- securing EDITC’s website, systems and information;
- analysing website usage and improving the user experience;
- measuring the effectiveness of communications and promotional activities; and
- complying with applicable legal and regulatory requirements.
- Legal Bases for Processing
EDITC processes personal data only where an appropriate legal basis exists.
Depending on the activity, the legal basis may be:
Contract
Processing may be necessary to provide a course, service or other activity requested by an individual, or to take the necessary steps before entering into a contract.
Legal obligation
Processing may be necessary for EDITC to comply with applicable legal, regulatory, accounting, employment or reporting obligations.
Legitimate interests
EDITC may process information where this is necessary for a legitimate organisational or business interest, provided that the interests, rights and freedoms of the individual do not override that interest.
These interests may include administering services, managing professional relationships, securing systems, improving activities and maintaining appropriate organisational records.
Consent
EDITC may request consent for a specific use of personal data, such as:
- non-essential website cookies;
- optional photographs or audiovisual recordings;
- publication of testimonials;
- particular communication activities; or
- another purpose for which consent is legally required.
Consent must be freely given, specific, informed and unambiguous. Individuals may withdraw their consent at any time, without affecting processing that took place lawfully before withdrawal. [dataprotec...ion.gov.cy]
- Training Courses, Events and Certification
EDITC processes registration, participation, attendance and assessment information where necessary to administer training courses, workshops, seminars and events.
Where applicable, participant information may also be processed to:
- confirm eligibility;
- communicate logistical information;
- maintain attendance records;
- evaluate the effectiveness of an activity;
- issue certificates of attendance or achievement;
- respond to verification requests; and
- meet contractual or funding requirements.
Only information relevant to the administration and delivery of the particular activity will be requested.
- EU-Funded and Collaborative Projects
EDITC participates in EU-funded and other collaborative projects.
For these activities, relevant personal data may need to be shared with:
- the project coordinator;
- authorised consortium partners;
- external evaluators or auditors;
- programme-management bodies;
- funding authorities; and
- other organisations authorised to monitor or verify the project.
Information will only be shared where it is necessary for project implementation, monitoring, evaluation, auditing, reporting or compliance with funding requirements.
When a project requires processing that is not adequately described by this general Privacy Policy, EDITC may provide participants with a supplementary privacy notice.
- Surveys, Evaluations and Research
EDITC may invite participants, stakeholders or members of relevant target groups to complete questionnaires, surveys, assessments and evaluation forms.
Survey and evaluation information may be used to:
- assess participant needs;
- evaluate training activities;
- measure project results;
- improve services;
- prepare statistical information;
- produce project reports; and
- support research or quality-assurance activities.
Where possible and appropriate, results will be aggregated or anonymised before being presented in reports or publications.
If identifiable information is required, respondents will receive appropriate information about the purpose of the data collection and its intended use.
- Photographs, Video and Online Activities
Photographs, video recordings or other audiovisual content may be produced during certain EDITC courses, meetings, conferences, workshops or project activities.
When consent or another legal basis is required, participants will be informed before the material is collected or used.
Subject to the applicable legal basis, such material may be used for:
- documenting an activity;
- project reporting;
- dissemination;
- publications;
- project or organisational websites; and
- relevant social-media channels.
Individuals may raise concerns or withdraw consent for future uses by contacting EDITC, where consent is the applicable legal basis.
- Cookies and Tracking Technologies
The EDITC website uses cookies and similar technologies to provide website functionality, measure usage and evaluate communications.
Google Analytics
EDITC uses Google Analytics to obtain information about how visitors use the website, such as the pages visited, length of visits, general location and device or browser information.
Google Analytics should only be activated where the visitor has provided the required cookie consent.
Meta Pixel
EDITC uses the Meta Pixel to measure website activity and evaluate the effectiveness of content or advertising delivered through Meta platforms.
The Meta Pixel may collect information about website visits and interactions. It should only be activated after the visitor has provided the required consent.
Google Maps
The EDITC website uses Google Maps to display location information. Loading an embedded map may result in data being transferred to Google, including technical information such as the visitor’s IP address.
Where required, embedded Google Maps content should remain blocked until the visitor has provided consent.
Managing cookie choices
Visitors must be given an opportunity to accept or reject non-essential cookies through the website’s cookie-consent mechanism.
Essential cookies required for the basic operation or security of the website may not require consent. Rejecting optional cookies should not prevent access to the website’s essential content and services.
More detailed information about the specific cookies used, their providers, purposes and lifetimes should be provided in EDITC’s separate Cookie Policy or cookie-preference interface.
- Marketing Communications
EDITC does not currently operate an email newsletter service.
If EDITC introduces newsletters or other direct electronic marketing in the future, this Privacy Policy and the relevant registration or consent notices will be updated before such processing begins.
Where legally required, marketing communications will only be sent after appropriate consent has been obtained. Recipients will also be provided with a clear method of withdrawing their consent or unsubscribing.
- Microsoft 365
EDITC uses Microsoft 365 for organisational productivity, document management, email, communication and collaboration.
Personal data may therefore be processed within Microsoft 365 when individuals:
- correspond with EDITC by email;
- participate in a Microsoft Teams meeting or activity;
- share documents with EDITC;
- complete a form provided through a Microsoft service;
- collaborate on project or training materials; or
- otherwise communicate with EDITC through Microsoft 365.
Access to information held within Microsoft 365 is limited according to organisational roles and operational requirements.
- Sharing Personal Data
Where necessary and legally permitted, EDITC may share relevant personal data with:
- Microsoft, as a technology and cloud-service provider;
- website hosting and technical-support providers;
- trainers, experts and facilitators involved in delivering activities;
- project coordinators and consortium partners;
- funding, programme-management and auditing authorities;
- financial institutions and payment-service providers;
- accountants, auditors, legal advisers and professional consultants;
- competent public authorities or regulators; and
- other service providers acting on behalf of EDITC.
EDITC does not sell or rent personal data.
Where a third party processes personal data on behalf of EDITC, appropriate contractual and data-protection arrangements will be established where required.
- International Data Transfers
Some technology providers, project partners or service providers may process personal data outside Cyprus or the European Economic Area.
Where personal data is transferred internationally, EDITC will use an appropriate transfer mechanism and safeguards as required under applicable data-protection legislation.
These safeguards may include an adequacy decision, approved contractual clauses or another legally recognised transfer mechanism.
- Data Retention
EDITC generally retains personal data and associated organisational records for a period of 10 years.
This retention period supports EDITC’s contractual, financial, certification, funding, auditing, project-monitoring and reporting responsibilities.
Personal data may be retained for a shorter period where it is no longer necessary, or for a longer period where this is required by law, a funding programme, an active legal matter or another binding obligation.
At the end of the applicable retention period, personal data will be securely deleted, destroyed or anonymised, unless its continued retention is legally required.
- Information Security
EDITC implements appropriate technical and organisational measures intended to protect personal data against:
- unauthorised access;
- unlawful processing;
- accidental loss;
- alteration;
- disclosure;
- destruction; and
- damage.
Measures may include access controls, account-management procedures, secure cloud services, staff awareness, system updates and appropriate backup and recovery arrangements.
In the event of a personal-data breach, EDITC will assess the incident and meet applicable notification and communication requirements. The Cyprus supervisory authority explains that reportable breaches must be notified without undue delay and, where feasible, within 72 hours after the controller becomes aware of them, subject to the conditions and exceptions in Article 33 GDPR. [dataprotec...ion.gov.cy]
- Your Data-Protection Rights
Subject to the conditions and limitations established by the GDPR, individuals may have the right to:
- access personal data held about them;
- correct inaccurate or incomplete personal data;
- request deletion of personal data;
- request restriction of processing;
- object to certain processing;
- receive relevant personal data in a portable format;
- withdraw consent where processing is based on consent; and
- lodge a complaint with the competent supervisory authority.
To exercise a data-protection right, contact EDITC at:
Email: enquiries@editc.com
Address: EdiTC Ltd, 16 Imvrou Street, 1055 Nicosia, Cyprus
EDITC may need to request information to confirm the identity of the person making the request before disclosing or changing personal information.
Individuals also have the right to submit a complaint to the Office of the Commissioner for Personal Data Protection in Cyprus. The Cyprus authority provides official GDPR compliance guidance for organisations and data controllers. [dataprotec...ion.gov.cy]
- Data Relating to Minors
EDITC does not intentionally offer services to minors and does not intentionally collect or process minors’ personal data.
Individuals below the applicable legal age should not submit personal data through the EDITC website, registration forms or communication channels.
If EDITC becomes aware that a minor’s personal data has been collected unintentionally, appropriate steps will be taken to remove that information, unless retention is required by law.
- Third-Party Websites and Services
The EDITC website and project activities may contain links to, or embedded content from, third-party websites and platforms.
Third parties may process personal data under their own terms and privacy policies. EDITC is not responsible for the content or independent privacy practices of third-party websites.
Visitors should review the privacy information of external services before providing personal data or enabling embedded third-party content.
20. Automated Decision-Making
EDITC does not use the personal data described in this Privacy Policy to make decisions based solely on automated processing that produce legal or similarly significant effects on individuals.
If this changes, affected individuals will be given appropriate information about the processing, its significance and their applicable rights.
21. Changes to This Privacy Policy
EDITC may update this Privacy Policy to reflect changes in its:
- services and activities;
- EU-funded projects;
- website technologies;
- service providers;
- legal obligations; or
- personal-data processing practices.
The latest version will be published on the EDITC website and identified by the “Last updated” date appearing at the beginning of the policy.
22. Contact EDITC
Questions, requests or concerns about this Privacy Policy or the processing of personal data can be addressed to:
EdiTC Ltd
16 Imvrou Street
1055 Nicosia
Cyprus
Email: enquiries@editc.com
Website: https://editc.com