Pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27

April 2016 (General Data Protection Regulation – GDPR) and Regulation (EU) 2018/1725, we

hereby inform you that:

§1 Entities processing data

1. The Data Administrator is the European Commission (Directorate-General for Education, Youth, Sport and Culture – DG EAC). https://commission.europa.eu/about/contact_en

2. The data Processor is the Foundation for the Development of the Education System (FRSE), Al. Jerozolimskie 142A, 02-305 Warsaw, iod@frse.org.pl acting as the Polish National Agency of the Erasmus+ and European Solidarity Corps programmes.

3. The sub-processor is the Ornament Foundation, ul. Karpacka 66, 33-159 Zalasowa, Poland contact@ornament-foundation.com, acting as the beneficiary of the grant agreement concluded with FRSE.

 

§2. Categories of data

1. Identification and contact data: first name, last name, date of birth, institutional affiliation, e-mail address, telephone number;

2. Professional and organisational data: information related to participation in training activities, learning outcomes, evaluations, and records of participation in project events;

3. Image data: photographs and video or audio recordings documenting participation in project activities, within the scope of the consents granted;

4. Special categories of data: information concerning health, disability, dietary requirements or other accessibility needs, processed only to the extent necessary to ensure safety and accessibility;

 

§3. Data Source

1. Data is obtained directly from project participants or partners involved in its implementation, as well as through IT tools used as part of project activities.§4. Purposes and basis of processing

1. Project implementation and accountability of the project 2024-1-PL01-KA220-YOU-000247051 “Delay instant gratification for a better life”, 24 lasting months starting on 01/12/2024 and finishing on 28/02/2027 including recruitment, organization of educational and training activities, monitoring, evaluation, reporting, auditing, and archiving – pursuant to Article 6(1)(c) and (e) of the GDPR in conjunction with Regulation (EU) 2021/1060, Regulation (EU) 2021/1057, the Act of 28 April 2022 on the principles of implementing tasks financed from European funds in the 2021-2027 perspective, and the Public Finance Act;

Specifically:

a. Ensuring the safety and accessibility of participants, including educational adaptations

b. Organizational and substantive communication with participants - pursuant to

a. Promotional and informational activities, including image publication of the EU Act on Copyright and Related Rights;

b. establishing, pursuing, or defending legal claims, and archiving evidence

 

§5. Voluntary Provision of Data

1. Providing personal data is voluntary but necessary to participate in the project. Refusal to provide data makes participation impossible. Consent for the use of image is separate and voluntary.

2. Data are stored for the duration of the project and for the legally required archiving period, not shorter than 5 years after the project’s completion. In the case of proceedings or claims, data will be retained until their final conclusion and the expiry of limitation periods.

3. Data are not transferred outside the European Economic Area.

4. Data subjects have the right to: access their data, rectify them, erase them (unless exceptions under Article 17(3) GDPR apply), restrict processing, transfer data (whereprocessing is based on a contract and carried out automatically), object (Article 21 GDPR), and lodge a complaint with the Polish President of the Personal Data Protection Office (UODO).

5. A data subject may object at any time to data processing based on Article 6(1)(e) or (f) GDPR for reasons related to their particular situation. In case of an objection to data processing for informational and promotional purposes, the Foundation will cease processing the data for those purposes.

6. Data are not used for automated decision-making or profiling that produces legal effects. Analysis of activity within digital systems is used solely for the organization of the educational process.

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§6. Security Measures & Final provisions

1. The Ornament Foundation applies appropriate technical and organizational measures, including access control, encryption, pseudonymization, data backups, supervision of IT providers, and staff training.

2. For underage participants, consent from a legal guardian is required for participation in the project; publication of a participant’s image requires separate consent. Lack of consent for image publication does not exclude participation.

3. Requests regarding personal data should be sent via email to: contact@ornament- foundation.com or by post to the Foundation’s address: ul. Karpacka 66, 33-159 Zalasowa, marked “GDPR”. Responses are provided within 1 week.