Privacy & Cookies Policy

PRIVACY & COOKIE POLICY
APPLICABLE ON THE EUPATI OPEN CLASSROOM PLATFORM

Read this policy carefully as it contains your rights and obligations towards the European Patients’ Academy on Therapeutic Innovation (hereafter: EUPATI).

This Privacy & Cookie Policy can regularly be revised or updated, and we advise you to check these regularly.

1 - General 

1.1. This Privacy Policy shows how your personal data are processed in the use of the Platform. The processing takes place under the responsibility of EUPATI with registered office at Daltonlaan 600, 3584BK Utrecht, Netherlands and registered in the Dutch Chamber of Commerce under number 80089019.

1.2. EUPATI aims to comply with the European Regulation 2016/679 of 27 April 2016 concerning the protection of personal data, as well as the provisions regarding the use of cookies on websites in the framework of the ePrivacy Directive 2002/58, as amended from time to time.

1.3. To be able to make use of the Platform and/or to provide personal data to EUPATI, you need at least to have reached the correct age to be able to make us of the Platform. You confirm explicitly to have reached the correct age and to be at least 16 years old. EUPATI cannot be held liable for the consequences of the people who have not reached the correct age, although they claimed the contrary. EUPATI reserves the right, in case of discovery, to remove the personal data of these people and to deny them the use of the Platform.

1.4. By using the Platform and/or providing personal data to EUPATI, you agree unconditionally and irrevocably with the stipulations of this Privacy & Cookie Policy.

2 - Personal data you provide to us 
2.1. At registration on the Platform:
- Username;
- First name and surname;
- Password;
- E-mail address;
- City;
- Country.

2.2. while visiting the Platform:
- IP-address;
- user name, password, e-mail address, login-data;
- via cookies: see article 9. 

2.3. when registering for one of our newsletters:
- E-mail address.

2.4 as User of the Platform:
- Picture;
- Interests;
- Institution;
- Courses or learning plans;
- Grades or certificates;
- Preferred language;
- Mailing address;
- Mobile or landline number;
- Notes, posts (including third-party links) or comments on the forum of the Platform;

Do not forget to inform EUPATI about a modification of your personal data if this information is relevant to EUPATI. This modification can be transmitted via the contact data mentioned in clause 11.

3 - Personal data we collect indirectly 
3.1. Public data: 

EUPATI sometimes processes public data, e.g. data subject to a publication obligation, or data that you yourself have made public, such as information on your social media profiles, website, or data that are generally known or accessible. 

4 - Objectives of the processing 
4.1. General objectives: 

EUPATI will use the collected personal data exclusively for the following purposes:

  • user name, first name, surname, password, e-mail address, city, country, picture, interests, institution, Courses or learning plans, grades or certificates, language, mailing address, mobile or landline number, Notes, posts (including third-party links) or comments on the forum of the Platform (see article 2.1 and article 2.4) when registering via the Platform and using the Platform: for the purpose of managing your account on this Platform, to be able to provide you with the requested information or services and to meet the legal prescriptions, with as legal base the execution of an agreement that you requested;
  • IP-address (see article 2.2.): for the care and the improvement of the Platform and the inclusion of personal data in anonymous statistics from which tracing the identity of specific people or companies is impossible, with as legal base the legitimate interests of EUPATI to continuously improve its Platform and services;
  • e-mail address (when registering for the newsletter) (see article 2.3) with a view to sending you direct marketing (automatic e-mail messages or other electronic messages), newsletters, or information on planned activities (such as lectures, seminars, new courses, etc.), with as legal basis your prior explicit consent;

4.2. Transfer to third parties:

EUPATI will never pass on your personal data to third parties:

  • With the exception of the related organisations of EUPATI, in this case Sustaining Partners who would be interested in engaging and/or working with a learner from the Platform;
  • with the exception of technical service providers who deliver technical support as far as necessary for the technical services and/or when they are obliged, on the basis of a legal stipulation or a judicial sentence.

EUPATI will reasonably try to inform you beforehand of the fact that EUPATI discloses your data to the mentioned third-party, but you also acknowledge that this is not under all circumstances technically or commercially feasible. 

EUPATI will not sell nor rent, distribute or otherwise make your personal data commercially available to third parties, except as described above or unless with your prior consent.

4.3. Legal requirements: 

In rare cases, it is possible that EUPATI must disclose your personal data due to a court order or to respond to other obliging legal regulations. EUPATI will reasonably try to inform you previously, unless it is subject to any legal limitation. 

5 - Duration of the processing
The personal data are kept by us and processed for a period that is necessary in function of the objectives of the processing such as described in article 4 of the contractual relation between EUPATI and you: 
  • user name, first name, surname, password, e-mail address, city, country, picture, interests, institution, Courses or learning plans, grades or certificates, language, mailing address, mobile or landline number, Notes, posts (including third-party links) or comments on the forum of the Platform (clause 2.1 and 2.4): for the duration of the requested provision of services and according to the applicable legislation;
  • IP-address (see article 2.2.): for the duration of your visit to the Platform;
  • E-mail address (when registering for the newsletter): for the duration of the requested delivery of the services;

The mentioned personal data are in any case recorded according to the specific legal requirements and limitation periods that oblige us to keep your personal data for a longer time, e...g. to defend ourselves against legal claims. 

6 - Your rights
6.1. Right of access and inspection: 

Via the Platform you dispose of the possibility to get at any time and for free information about your personal data and the use that EUPATI makes of them. 

6.2. Right of correction, elimination and limitation:
You are free to communicate or not your personal data to EUPATI, except for a number of mandatory legal data in case of registration and use of the Platform. Besides, you always have the possibility to correct, complete or eliminate your personal data. You acknowledge that, if you do not fill in some data, or eliminate them later, some services and products may be not (no longer) available. You may also request to limit the processing of your personal data. 

6.3. Right to object: 

You also have a right to object to the processing of your personal data for serious and legitimate reasons.

In addition, you are always entitled to oppose to the use of personal data for direct marketing purposes; in such case, you do not have to give any reason. 

6.4. Right of free data transfer
You have the right to obtain your personal data processed by us in a structured, commonly used and machine-readable form and/or transfer these to other controllers. 

6.5. Right of withdrawal of consent:
In as far as the processing is based on your prior consent, you dispose of the right to withdraw this consent. 

6.6. Exercise of your rights:
See articles 9.4 and 11 on the procedure and who to contact to exercise your rights.

6.7. Automatic decisions and profiling:
The processing of your personal data does not include profiling, and neither will you be subject to automatized decisions.

6.8. Right to file a complaint.
You dispose of the right to file a complaint with a controlling authority. For the Netherlands this is:

Data Protection Authority / Autoriteit Persoonsgegevens
Bezuidenhoutseweg 30
2594 AV Den Haag
Phone +31(0)88-1805250
https://autoriteitpersoonsgegevens.nl/

Postal address:

Data Protection Authority / Autoriteit Persoonsgegevens
Postbus 93374
2509 AJ Den Haag

This leaves intact the possibility of seeking relief before a civil court. 

If you suffer damage as a consequence of the processing of your personal data, you can file a claim for compensation.

7 - Security and confidentiality
7.1. We have developed security measures fitted on technical and organisational level to avoid the destruction, loss, falsification, modification, unauthorized access or communication by accident to third parties of collected personal data, and any other unauthorized processing of these data. 


7.2. Under no circumstances, EUPATI can be held liable for any direct or indirect damage derived from an incorrect or unlawful use of the personal data by a third-party. EUPATI has ensured that, when it calls on third parties for the processing of personal data, these third parties will be bound by the same rules. 

7.3. You must at all times comply with the security rules, amongst others by preventing any unauthorized access to your login and code. You are therefore the only responsible for the use made from the Platform of your computer, IP-address and of your identification data, as well as for the confidentiality thereof. 

8 - Access by third parties
8.1. To be able to process your personal data, we give access to your personal data to our employees or agents. 


8.2. We guarantee an identical level of protection by making contractual obligations that are opposable to these employees and agents and which are identical to this Privacy Policy.

9 - Cookies
9.1. What are cookies? 

 A “cookie” is a small file sent by the server of EUPATI and placed on the hard disk of your computer / smart phone. The information registered on these cookies can only be read by us and only during the duration of the visit to the Platform (hosted by Moodle Workplace).

9.2. Why do we use cookies?
Our Platform uses cookies and similar technologies to differentiate your user’s preferences from those of other users of the Platform. This helps us to offer a better user’s experience when you use the Platform and allows us to optimize our Platform.

As a consequence of recent law amendments, all platforms oriented towards certain parts of the European Union, are obliged to ask consent for the use or storage of cookies and similar technologies on your computers or mobile devices. This Cookie Policy gives you clear and complete information about the cookies we use, and their purpose. 

9.3. The Platform only uses the following cookies:
Functional cookies

Authentication cookies: ‘Remember me’ Identification of the user when he/she is logged in.

Non-functional cookies 
For cookies placed by third parties (e.g. Google Analytics) we wish to refer to the declarations of these parties on their respective websites. Please note we do not have any influence on the contents of these declarations, neither on the contents of the cookies of these third parties: Google Analytics cookies.

9.4. Your consent:
You can refuse cookies or block them by changing configuration parameters of your navigation system. The elimination of cookies can mean that you cannot make use of some functionalities of the Platform.

If you have further questions or remarks in relation with the processing of your personal data or the use of cookies on the Platform, do not hesitate to contact us, either via the following contact sheet or by post to:

The European Patients’ Academy on Therapeutic Innovation (EUPATI)

STICHTING EUPATI FOUNDATION
Daltonlaan 600
3584BK Utrecht
The Netherlands

More information about cookies can also be found on: http://www.allaboutcookies.org/

More information concerning on-line behavioural advertising and on-line privacy can be found here: http://www.youronlinechoices.eu/ .

10 - Applicable law and competent court 
This Privacy & Cookie Policy is ruled, explained and executed according to Dutch law, the only applicable. 


The courts of the juridical district Utrecht have exclusive jurisdiction to take note of any dispute that might arise from the interpretation or execution of this Privacy & Cookie Policy. 

11 – Contact us
Do you have questions as a company or private person concerning how EUPATI deals with your data, do not hesitate to contact us by post to the address:


The European Patients’ Academy on Therapeutic Innovation (EUPATI)
STICHTING EUPATI FOUNDATION
Daltonlaan 600
3584BK Utrecht
The Netherlands

Or via e-mail on info@eupati.eu

As we keep or process your personal data, you do have certain rights (see Article 6). If you want to make use of these rights, send us a registered letter to the above-mentioned address. In order to protect your privacy, we hereby ask to add a copy of the front side of your ID-card.