PROTECTION OF YOUR PERSONAL DATA

Processing operation: Processing of personal data on the EU Code Week website at codeweek.eu by its visitors and the users of its contact form

Data Controller:

JA Europe, coordinator for the Code4Europe consortium[^1] (hereafter referred to as ‘Code4Europe’).

Data processors:

Amazon Web Services EMEA SARL (AWS) (38 avenue John F. Kennedy, L-1855 Luxembourg, Luxembourg).

European Commission, Directorate General for Communications Networks, Content and Technology, Unit G.2

Record reference: DPR-EC-09706.

Table of Contents

  1. Introduction

  2. Why and how do we process your personal data?

  3. On what legal ground(s) do we process your personal data?

  4. Which personal data do we collect and further process?

  5. How long do we keep your personal data?

  6. How do we protect and safeguard your personal data?

  7. Who has access to your personal data and to whom is it disclosed?

  8. What are your rights and how can you exercise them?

  9. Contact information

  10. Where to find more detailed information?

1. Introduction

Code4Europe is committed to protecting your personal data and to respecting your privacy. Te Consortium collects and further processes personal data pursuant Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

This privacy statement explains the reason for the processing of your personal data, the way we collect, handle and ensure protection of all personal data provided, how that information is used and what rights you have in relation to your personal data. It also specifies the contact details of the responsible joint controllers with whom you may exercise your rights, the relevant Data Protection Officers and the Data Protection Authorities.

2. Why and how do we process your personal data?

Purpose of the processing operation: The-controller employs an external infrastructure to host the website. The technical setup collects and uses your personal information to be able to provide for the website’s proper operation.

The purposes of the processing are the following:

1) To process personal data of visitors in order to operate and administer the EU Code Week website;
2) To process data subjects’ e-mail addresses, passwords or social media authentication to grant them access to their personal accounts on the website. This access allows them to authenticate themselves, access and update their profiles and to access certificates and register activities;
3) To process data subject’s email addresses and other information provided when they use the contact form via the ”Getting in Touch“ button.

Personal data will not be used for an automated decision-making, including profiling.

3. On what legal ground(s) do we process your personal data?

We process your personal data on several grounds:

  • Article 6(1)(f) of Regulation (EU) (2016/679), for the operation and administration of the website, the processing is necessary for the performance of a task carried out in the Legitimate Interest of the Code 4 Europe Consortium. We ensure that adequate and specific safeguards are implemented for the processing of personal data, in line with the applicable data protection legislation.
  • Article 6(1)(a) of Regulation (EU) (2016/679): for the processing activities consisting in cookies, authentication and getting in touch with us, consent is necessary. In compliance with Article 3(11) of Regulation (EU) (2016/679), Article 7 of Regulation (EU) (2016/679), consent must be freely given, specific, informed and unambiguous.

Where we rely on consent, we obtain it directly from the data subject, and it can be expressed by an email, submitted via e-registration form, or in any other electronic or written form.

4. Which personal data do we collect and further process?

In order to operate and administer the website, the controller collects the following categories of personal data:

  • Internet Protocol address (IP address) or device ID of the device used to access the website

Without this processing you will not be able to establish a technical connection between your device and the website server infrastructure and therefore will not be able to access the codeweek.eu.

In order for you to authenticate on the website, the controller collect the following categories of personal data:

  • Either e-mail address and password, or
  • Social media authentication[^2].

In order for you to use the contact form, the controller collects the following categories of personal data:

  • E-mail address
  • Any personal data included in the body of the e-mail you sent.

5. How long do we keep your personal data?

The controller only keeps your personal data for the time necessary to fulfil the purpose of collection or further processing:

  • when you navigate the website, your personal data are only processed for the duration of the browsing session. In addition, IP addresses might be saved for one year in the log files of the services for security reasons. As to the analytics tool, the IP address and the device ID (e.g. IMEI number and WIFI MAC address) are deleted immediately at disconnection;
  • when you authenticate, all personal data will be deleted from the database in December 2029, or until you withdraw from the EU Code Week initiative.
  • When you get in touch with us, your e-mails are deleted two years after the last exchange.

6. How do we protect and safeguard your personal data?

All personal data in electronic format (e-mails, documents, databases, uploaded batches of data, etc.) are stored on servers administered by the Commission. All processing operations are carried out pursuant to the Commission Decision (EU, Euratom) 2017/46, of 10 January 2017, on the security of communication and information systems in the European Commission.

In order to protect your personal data, the controller has put in place a number of technical and organisational measures. Technical measures include appropriate actions to address online security, risk of data loss, alteration of data or unauthorised access, taking into consideration the risk presented by the processing and the nature of the personal data being processed. Organisational measures include restricting access to the personal data solely to authorised persons with a legitimate need to know for the purposes of this processing operation.

7. Who has access to your personal data and to whom is it disclosed?

Access to your personal data for the purposes of administering, monitoring and operating the IT system is only provided to the Commission staff responsible for carrying out this processing operation and to authorised Commission staff according to the “need to know” principle. Such staff abide by statutory, and when required, additional confidentiality agreements. This includes your personal data required for authentication purposes.

Access to personal data provided when using the contact form is provided to joint controllers’ staff responsible for carrying out this processing operation according to the “need to know” principle.

8. What are your rights and how can you exercise them?

You have specific rights as a ‘data subject’ under Chapter III of Regulation (EU) 2016/679, in particular the right to access, rectify or erase your personal data and the right to restrict the processing of your personal data. Where applicable, you also have the right to object to the processing or the right to data portability.

You have the right to object to the processing of your personal data, which is lawfully carried out pursuant to Article 5(1)(a) of Regulation (EU) 2016/679.

For those processing activities which require your consent, you have the right to withdraw your consent at any time by notifying the joint controllers. The withdrawal will not affect the lawfulness of the processing carried out before you withdrew your consent.

You can exercise your rights by contacting the Data Controller, or in case of conflict the Data Protection Officer. If necessary, you can also address the Data Protection Authority of Belgium. The contact information is given under section 9 below.

Where you wish to exercise your rights in the context of one or several specific processing operations, please provide their description (i.e. their Record reference(s) as specified under section 10 below) in your request.

9. Contact information

The controller

If you would like to exercise your rights under Regulation (EU) 2018/1725 or Regulation (EU) 2016/679, or if you have comments, questions or concerns, or if you would like to submit a complaint regarding the collection and use of your personal data, please feel free to contact the controller:

  • JA Europe at privacy@jaeurope.org.

The Data Protection Officer (DPO) of JA Europe

You may contact the Data Protection Officer of JA Europe (dpo@jaeurope.org) with regard to issues related to the processing of your personal data under Regulation (EU) 2016/679.

The Data Protection Authorities

You have the right to have recourse (i.e. you can lodge a complaint) to the national Data Protection Authority in Belgium - GBA (https://www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte) in French or Dutch, if you consider that your rights under Regulation (EU) 2016/679 have been infringed as a result of the processing of your personal data by JA Europe.

10. Where to find more detailed information?

This specific processing operation has been included in the Commission Data Protection Officer public register with the following Record reference: DPR-EC-09706.

[^1]: The Code4Europe consortium is implementing the Code4Europe project funded via a Digital Europe Programme grant 101158834.

[^2]: The personal data includes the name, profile picture and email address for signing in with a Facebook account; the name, email address, language preference and profile picture for signing in with a Google account; the user name and email address for signing in with a X account; the user name or email address for signing in with a GitHub account.