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Privacy Policy

Data protection is a high priority for the CyberNEMO Consortium. Thus, as documented in this data protection declaration, the member organisations of the CyberNEMO Consortium, represented by the CyberNEMO coordinator Synelixis S.A., are committed to full compliance with the European Union General Data Protection Regulation no. 2016/679 (“GDPR”) as well as any other relevant legislation.

The processing of personal data, such as name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the CyberNEMO Consortium. Through this data protection declaration, we would like to inform anyone concerned and the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the data controller, the CyberNEMO Consortium has implemented numerous technical and organizational measures to ensure comprehensive protection of personal data processed through this website. However, Internet-based data transmissions may generally have security gaps. Thus, absolute protection cannot be guaranteed. For this reason, every data subject is free to provide personal data to us via alternative means, e.g. by telephone or letter.

1. Definitions

The data protection declaration of the CyberNEMO Consortium is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

  • Personal data – Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is someone 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.
  • Data subject – Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
  • Processing – Processing is 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.
  • Restriction of processing – Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
  • Profiling – Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
  • Controller or controller responsible for the processing – Controller or controller responsible for the processing is 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 – Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
  • Recipient – Recipient is any natural or legal person, public authority, agency or another body, to which personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the context of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of these data by the public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
  • Third party – Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
  • Consent – Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Data Controller

The data controller of the data processing is the CyberNEMO Consortium (“hereinafter referred to as “we” or “us” or “CyberNEMO”).

3. Name and Address of the project’s contact point on behalf of the CyberNEMO Consortium

The CyberNEMO Consortium has decided that the single contact point for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection shall be the Data Protection Officer and Ethics Manager of CyberNEMO project, namely:

Carmela Occhipinti (CyberSocial Lab. Srls).
The contact e-mail address for all enquiries or requests related to CyberNEMO is: cybernemo-ethics@cybernemo.eu.

Any data subject may, at any time, contact the CyberNEMO Ethics Manager as the single contact point on behalf of the CyberNEMO Consortium members directly with all questions and suggestions concerning data protection.

4. Personal data collection in CyberNEMO

The website of CyberNEMO Consortium, hosted at https://cybernemo.eu/ (hereinafter referred to as our “Website”), contains information that enables a quick electronic contact to our project consortium as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject decides to use the contact form or to send an email to the single point of contact as provided in section 3 above, the data subject will provide his/her full name, email address and/or phone number, and message and the personal data transmitted by the data subject are automatically stored. Moreover, through our Website you are being provided with the opportunity to sign-up to the CyberNEMO newsletter by providing us with your email address, to be kept updated with our latest news. In case you opt-in to our newsletter, we will be giving you the option, through every email that you will be receiving from us, to opt-out from our newsletter list. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject.

CyberNEMO Consortium may also publish video or photographs of images in case of events or workshops, provided that the relevant data subject gave its consent to the publication of it.

There is no transfer of this personal data to third parties outside the same CyberNEMO Consortium.

5. Purpose of processing personal data

The CyberNEMO project will process personal data exclusively within the purposes of the research within the project.

6. Cookies – Definition

The Internet pages of CyberNEMO Consortium use cookies. Cookies are text files that are stored in a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers which contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID. Cookies can be “session” or “persistent” cookies. A session cookie is a cookie that is automatically deleted when the user closes the browser, whereas a persistent cookie is a cookie that remains stored in the user’s terminal device until it reaches a defined expiration date

7. Cookies implemented

Through the use of cookies, the CyberNEMO Consortium can provide the users of this website with more user-friendly services that would not be possible without the cookie setting. By means of a cookie, the information on our website can be optimized with the user in mind, and, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user who uses cookies, e.g., does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user’s computer system.

In particular, the CyberNEMO Consortium on its website uses several cookies, either persistent or sessions, of which:

  • some are “necessary”. Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies. Necessary cookies preserve the visitor’s session state across page requests.
  • some are “statistics”. Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

For further information on cookies, our use of ‘cookies’ and/or on relevant similar technologies, please see our Cookie Policy [Cookies Policy Hyperlink].

8. Legal basis for the processing

When we use your personal data we are required to have a legal basis for doing so. There are various different legal bases on which we may rely on, depending on what personal data we process and why. Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose, for example with reference to the personal data that the data subject voluntary provides according to section 4 above.

If our project consortium is subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR.

Additional lawful basis for the processing may be the Regulation (EU) No 1291/2013 of the European Parliament and of the Council of 11 December 2013 establishing Horizon 2020 – the Framework Programme for Research and Innovation (2014-2020) and its annex.

9. Protection of personal data

All processing is carried out in compliance with Article 32 of the GDPR, with the adoption of appropriate security measures. Technical measures include appropriate actions to address online security, risk of data loss, alteration of data or unauthorized access, taking into consideration the risk of the processing and of the nature of the personal data. Organizational measures include restricting access to the personal data solely to authorized persons or third parties where legitimated by the data controller for the purposes of processing operation.

10. Access to processed personal data

Access to data subjects’ personal data is provided to the CyberNEMO Consortium responsible for carrying out this processing operation and to authorized staff according to the ‘need to know’ principle. Such staff abide by statutory, and when required, additional confidentiality agreements.

However, the consortium may disclose the data subject information in order to comply with the law, a judicial proceeding, court order, subpoena, or other legal process or where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or as evidence in litigation in which we are involved.

The personal data may be shared also with the website and repositories which are hosted in the European Union.

11. Period for which the personal data will be stored

Personal data provided to CyberNEMO Consortium as described above in section 3 will only be stored until the purpose for which they were processed has been fulfilled or – in the case of consent – until you withdraw your consent.

Insofar as retention periods under commercial and tax law must be observed, where applicable, the storage period for certain data can be up to 7 years. However, storage periods may also be amended due to our legitimate interest (e.g. to guarantee data security, to prevent misuse or to prosecute criminal offenders). After this period, and provided that there is no legal obligation and/or legitimate interest for your personal data to be kept longer, they will be irreparably destroyed. Any data kept by us for marketing and information purposes will be retained until you inform us that you no longer wish to receive such information.

Any requests for further information in relation to the continued processing of specific data and requests for destruction of data should be made as described in section 3 above.

12. Transferring personal data

We are not transferring personal data outside the EU/EEA. However, in case your data will be transferred to entities or other third parties whose headquarters or place of data processing is not located in a member state of the European Union or the European Economic Area, we ensure before forwarding the data that, outside of legally permitted exceptional cases pertaining to the recipient, either an appropriate level of data protection exists (e.g. through an adequacy decision of the European Commission, through suitable guarantees, or through the agreement of EU standard contractual clauses between us and the recipient), or your sufficient consent exists.

13. Rights of the data subject

As a data subject, you may contact us at any time to make use of your rights which are the following:

    1. Right of confirmation
    Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may, at any time, contact any employee of the controller.
    2. Right of access
    Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information.
    3. Right to rectification
    Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
    4. Right to erasure (Right to be forgotten)
    Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary.
    5. Right of restriction of processing
    Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

    • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
    • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
    • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
    • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

    If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by CyberNEMO Consortium, he or she may at any time contact any employee of the controller. The employee of CyberNEMO Consortium will arrange the restriction of the processing.

    6. Right to lodge a complaint.
    The data subject has the right to lodge a complaint about the way the CyberNEMO Consortium handles or processes his/her Personal Data with the relevant national Data Protection Authority
    7. Right to data portability
    Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others. In order to assert the right to data portability, the data subject may at any time contact any employee of CyberNEMO Consortium.
    8. Right to object
    Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions. CyberNEMO Consortium shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims. If CyberNEMO Consortium processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to CyberNEMO Consortium to the processing for direct marketing purposes, CyberNEMO Consortium will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by V Consortium for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest. In order to exercise the right to object, the data subject may contact any employee of CyberNEMO Consortium. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

    9. Automated individual decision-making, including profiling
    Each data subject shall have the right granted by the European legislator 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, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent. If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, CyberNEMO Consortium shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision. If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of CyberNEMO Consortium.
    10. Right to withdraw data protection consent
    Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of CyberNEMO Consortium.

In response to such requests, we reserve the right to require the individual making the request to provide certain details about herself/himself so that the we can validate that the individual is indeed the person whom the data refers to. We are required to respond to the request of the individual within 30 days and we will endeavour to do so wherever possible.

For further information on each of those rights, including the circumstances in which they apply, please contact us as described in section 3 above.

In the event that you wish to complain about how we have handled your personal data, you may contact us as described in section 3 above. We will then look into your complaint and work with you to resolve the matter. If you still feel that your personal data have not been handled appropriately according to the applicable laws, you can submit your complaint with the competent Supervisory Authority of your Member State.

14. Changes

Where appropriate, the CyberNEMO Consortium will notify the data subject of any changes to this privacy declaration, for example by email or push notification.

CyberNEMO Data Protection Declaration is valid since the 1st of October 2024.