DiGiNN Privacy Notice

DiGiNN (https://www.diginn.eu/ ) is a three-year project funded by the Digital Europe Program. DiGiNN is a strategic partnership of 11 Cypriot organisations and focuses on providing digital transformation services to small-medium enterprises (SMEs) and the public sector. The purpose of this notice is to inform you how your personal data will be processed and stored in relation to the DiGiNN project and the services you will receive.
The DiGiNN consortium is committed to user privacy and data protection. Any personal data you provide will be processed in compliance with relevant EU 2016/679 and Cyprus data protection laws. By agreeing to submit your information to DiGiNN, we will process your personal data in accordance with the purposes, requirements and restrictions as set out in this notice.

DATA CONTROLLERS
The data controller is the individual or organisation/ body which, alone or jointly with others, determines the purposes and means of the processing of your personal data. In other words these individuals know how your personal data is handled and what is used for in relation to DiGiNN. The DiGiNN data controllers are:
▪ Christiana Papamichael, KIOS CoE, University of Cyprus, papamichael.christiana@ucy.ac.cy
▪ Dimitrios Katsouras, The Cyprus Institute, d.katsouras@cyi.ac.cy
▪ Anixi Antonakoudi, The Cyprus Institute, a.antonakoudi@cyi.ac.cy
▪ Katerina Loizou, The Cyprus Institute, k.loizou@cyi.ac.cy
▪ Styliani Petroudi, CYENS Centre of Excellence, styliani@cyens.org.cy
▪ Konstantina Ioannou, PwC Cyprus, konstantina.ioannou@pwc.com
▪ Christiana Kyriacou, PwC Cyprus, christiana.kyriacou@pwc.com
▪ Stalo Demosthenous, CCCI, stalo@ccci.org.cy
PURPOSES AND LEGAL BASIS FOR PROCESSING PERSONAL DATA
For the delivery of the DiGiNN services, we will collect Personal Data that may include the following:
● Identity data: such as first and last names, ID/passport number, and other information to check and verify your identity, eligibility and for reporting verification purposes. Gender data for gender balance reporting purposes.
● Contact information: such as work/organisation’s address, email address and telephone number.
● Photo or a video you appear in during services or delivery of events: we may use them for dissemination and reporting purposes including, in print and digital media such as websites, press-releases, social media, and live streaming. Also, images from CCTV systems installed in our premises for security purposes.

If we ask you to provide any other personal data not described above, then the personal data we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect it. If we ask you to provide personal data that we consider to be mandatory for us to perform the purpose for which the data was originally collected, we will inform you of such at the time of collection. In addition, we will also inform you of the consequences for not providing us with the mandatory personal data.

Your personal data will be processed to:
● Deliver the DiGiNN services you subscribe to.
● Inform you about DiGiNN findings and results via newsletters or emails.
● Create promotional material/content (photos from events/ service delivery).
● Engage you in consultations, surveys, interviews, and events.
● Respond to your queries.

We will only collect personal data that are necessary to achieve the processing purposes above. Your personal data will not be used for other purposes than those stated here. We will not share data with third parties, which in this case means people that are not in the DiGiNN project.

The primary legal basis for processing your personal data is your consent. It is important to know that you have the right to withdraw consent at any time. If you withdraw your consent, we may not be able to provide certain services to you. An additional legal basis on which we process your personal data is our legitimate interest to ensure our project can communicate with you, its stakeholders.

We may also use anonymised data, meaning data from which you cannot be identified, for the purposes of event evaluation. Anonymised data may also be used in published reports and at conferences.

WHO RECEIVES AND PROCESSES YOUR PERSONAL DATA
The personal information you enter herein, on user registration forms, surveys etc. will be received and processed by the data controllers. If it is required, this data may be processed by other members of the DiGiNN consortium (researchers, administrative staff), in order to respond to requests, queries, managing facilities access or service provision. Access to information will be restricted to members of the consortium using access controls, which include secure logins to DiGiNN data repositories.

DATA RETENTION PERIOD
Under the GDPR, we may only keep your personal data for as long as necessary to fulfil the purposes for which we originally collected and continue to process it, and to satisfy any legal, accounting or reporting requirements.
Your personal information will be used until the purpose for which it was collected ends; it may be archived per contractual requirements for up to 5 (five) years after the end of the project (expected date 31 November 2025) or until you withdraw your consent, after either of these points, it will be deleted.

NATURE OF DATA PROCESSING
The list below outlines how your personal data may be used and processed by DiGiNN.
● To provide our services;
● To manage our relationship with you;
● To execute service agreements or other contracts;
● To run, administer and protect our business;
● Gathering and providing information and making filings required by law or relating to audits, enquiries or investigations by regulatory bodies or authorities;
● External audits, quality checks and relevant information pursuant to the applicable Cyprus laws and EU Funding requirements.
THE RIGHTS OF THE INDIVIDUAL
As a DiGiNN user you have the right to:
● Request the controllers to give you access to the personal data about you that is in our possession.
● Request the controllers to correct any errors in your personal data to ensure it is accurate.
● Request that the controllers erase your personal data.
● Request that the controllers restrict future processing of your personal data,
● Object to the processing of your personal data.
● Data portability, which means that upon your request, the data controller should provide you with a copy of all the data that we have about you in a structured, commonly used, and machine-readable format.
● Withdraw your consent at any time, as the processing of your personal data occurs based on your consent. At this point, we will cease further processing of your personal data. Please note that this does not affect the lawfulness of any processing that we have already performed (before you withdraw your consent).
● Place a complaint with a supervisory authority, for example, your national data protection authority.

AMENDMENTS TO DATA PROTECTION NOTICE
We may change this data protection notice in the future. In such case, a summary of the changes will be provided to external users for information.

EXERCISING YOUR RIGHTS & COMPLAINTS
If you wish to exercise any of your rights stated above you may contact the Data Protection Officer at the organisation where you register to receive DiGiNN services:
● University of Cyprus (KIOS CoE): Ms. Chrysso Agapiou, Tel: +357 22 894 361, Email: dpo@ucy.ac.cy
● The Cyprus Institute: Tel: +357 22 397 512, Email: dpo@cyi.ac.cy
● CYENS Centre of Excellence: Anthoula Fotsiou Psoma, Tel: +357 22 757 474  Email: dpo@cyens.org.cy
● PwC Cyprus: Tel: +357 22 555 000, Email: cy_dataprotection_office@pwc.com
If you have a concern about the way we are collecting or using your personal data, we request that you raise your concern with the relevant DPO in the first instance.
Alternatively, you can contact the Information Commissioner’s Office:

Office address: Iasonos 1, 1082 Nicosia
Postal address: P.O. Box 23378, 1682 Nicosia
Telephone: +357 22818456
Fax: +357 22304565
Email: commissionerdataprotection.gov.cy
Website: http://www.dataprotection.gov.cy

DiGiNN Data Use Consent

In order to receive any of the DiGiNN services, users are kindly requested to indicate below if they consent to the collection, storage, processing and use of their personal data according to the Privacy Notice provided to them.
Note you can withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

By accepting the privacy notice i confirm that:

  • I have been informed of, and understand, my rights in relation to the processing of my personal data for the purposes of the DiGiNN project.
  • I agree that the DiGiNN service providers can contact (email, telephone) me to:

1. Deliver the DiGiNN services I subscribe to.

2. Communicate DiGiNN findings and results via newsletters or emails.

3. Engage me in consultations, surveys, interviews, and events.
4. Respond to my queries.

  • I freely consent to the collection, handling, processing, and storage of my personal data according to the attached Privacy Notice.