Contents
- Introduction
- The personal data that we collect
- Purposes of processing and legal bases
- Providing your personal data to others
- International transfers of your personal data
- Retaining and deleting personal data
- Your rights
- About cookies
- Cookies that we use
- Cookies used by our service providers
- How to control or delete cookies
- Integration of Services and Content by Third Parties
- Links to other websites
- Amendments
- Data protection officer
- Introduction
This website is dedicated to the dissemination of the BrightSpace project funded by the European Union under Horizon Europe Grant Agreement No 101060075 and receives funding from UKRI under Project Code: 10047415.
The BrightSpace consortium is committed to the protection of your personal data and respects your privacy on its website on the brightspace-project.eu and www.brightspace-horizon.eu domains). Our website complies with the General Data Protection Regulation (EU) 2016/679.
This Privacy and Cookie Policy applies to all BrightSpace website users and outlines how our website collects, uses, discloses, and manages the personal information of individuals. This serves as a transparency mechanism, informing users about the ways in which their personal data is handled and protected by our project, and what choices you have as a visitor to this website.
By visiting our site, you are accepting the practices described in our Privacy and Cookie Policy. If you do not agree to the terms of this Privacy and Cookie Policy, please do not use the site.
As a data subject, you must be aware that some of your personal data is collected and maintained by our website for a certain period and for specified, explicit and legitimate purposes. Personal data shall be treated fairly and in a transparent manner in accordance with the applicable legal framework and in such a way as to guarantee the key data protection principles, namely:
- Lawfulness, fairness and transparency
- Processing within the legitimate purpose limits
- Data minimization
- Accuracy
- Storage Limitation
- Integrity and confidentiality (security)
- Accountability
- The personal data that we collect
There are several ways in which we can collect information about you:
- We collect your first name, last name and e-mail address when you subscribe to our newsletter.
- We may also collect your personal data (your name, your organization name, country, your contact details and the message itself) if you contact us via the contact form in our website, via social media, e-mail, phone, or any other digital communication channel. We will use this data only to reply to your initial message, unless you agree to receive further information related to the BrightSpace Project.
- We collect certain information about you when you use this webpage via cookies. Further details on this are provided in our Cookie Policy in Sections 8 to11.
The BrightSpace website does not collect, process or gain access in any way to specific categories of personal data, as set forth in the provisions of the legislation in force (in particular data relating to racial or ethnic origin, religion, health data, etc.).
- Purposes of processing and legal bases
We process your personal data for the following purposes:
- If you subscribed to the newsletter: to regularly send you the INCISIVE newsletter, including invitations to events and webinars about the project. You may also receive email from us with questions and information about your subscription to our newsletter. You always have the opportunity to unsubscribe from our newsletter by clicking on the link provided in the newsletter or by contacting us at brightspace.wecr@wur.nl.
- When you contact us through the contact form or via phone, e-mail or other digital communication channel: to answer the questions received via the contact form.
- Keep the website secure and prevent fraud.
- Improve the website content and experience by analysing the user’s performance.
- Verify compliance with the terms and conditions governing the use of the Website.
The legal bases for collecting and using your data:
- If you subscribe to our newsletter, you are providing your consent which is the legal basis on which we process your personal data. Your consent is voluntary but necessary to receive the newsletter. You may withdraw your consent at any time by clicking on the link provided in the newsletter or by contacting us at brightspace.wecr@wur.nl.
- If you contact us via our contract form or via phone, e-mail or other digital communication channel and for web analytics purposes we rely on our legitimate interest to be able to respond to your message, request or a question or improve the performance of our website.
The purposes for which we use data obtained by our cookies are described in our Cookie Policy in Sections 8 to11.
We may also process your personal data to comply with legal obligations or to comply, insofar we are legally allowed, with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities.
- Providing your personal data to others
We will only share your personal data when necessary. Where possible, data will be anonymized and/or aggregated.
The information collected from the website may, when necessary, be shared with:
- the BrightSpace consortium partners (i.e. if you ask a question relating to the role of a particular partner). The list of the partners is available here [https://brightspace-project.eu/about/partners/];
- potentially also with the European Commission when reporting BrightSpace results, or governmental or judicial authorities insofar we are required by law to send them your personal data (e.g. police or law enforcement).
We will not share your personal data with anyone but our suppliers who help us process your personal data.
Our use of analytical and statistical cookies may imply that the third party provider of those cookies, namely Google, may obtain certain information about you, including about your surfing behaviour. You may find more information on Google’s processing activities here: https://support.google.com/analytics/answer/6004245?hl=en.
Anyone who has access to your personal data will always be bound by strict legal or contractual obligations to keep your personal data safe and confidential. BrightSpace will not, without your express consent, supply your personal data to any third party for marketing purposes, whether directly or indirectly.
Anonymised and aggregated statistics about the use of the website, may be shared within the BrightSpace consortium and with the European Commission, but this will not contain any information that can be traced back to you as a user.
- International transfers of your personal data
We do not intend to send your personal data outside of EEA. However, we have consortium partners based in the UK. We may need to share your data with them if – for example – your request pertains to their organizations. In case any transfer of personal data outside the European Economic Area (the European Economic Area consists of the EU, Liechtenstein, Norway and Iceland) would occur, we assure you that we will only do so in accordance with either Art. 45 GDPR (on the basis of an adequacy decision) or Art 46 GDPR (appropriate safeguards in place).
- Retaining and deleting personal data
We process and store personal data as long as it necessary for the fulfilment of our contractual obligations under the Grant Agreement of the project. When this data is no longer necessary for the above purposes, it will be regularly deleted.
All personal data we collect to send you our newsletter we will keep for as long as you remain subscribed to our mailing list.
Regarding data collected through cookies your personal data are only processed at the first moment of collection. Afterwards we immediately use the anonymization features of Google Analytics to ensure that any information collected via cookies is anonymized.
We may keep reports and aggregated statistical data for up to 5 years after the project’s duration.
- Your rights
You enjoy a number of rights which you can exercise in the manner described below. You have the right:
- To ask us whether we process personal data on you, and if so, to obtain access to your personal data processed by us. You can also obtain a copy of your data.
- To correct/ update your personal data. If possible, please specify the context in which we use your personal data (e.g. to send you newsletters or to respond to a request), so that we may assess your request swiftly and accurately.
- To request deletion of your data, where applicable. For example, this right could be exercised in cases where the personal data is no longer necessary, the personal data processing in unlawful, or you withdraw your consent.
- To request restriction of the processing of your personal data, where applicable. This could for example be a temporary measure in the case where you contest the accuracy of the personal data of you object to the processing, pending our review of your request.
- To receive the personal data, which you have provided on the website, in a structured, commonly used and machine-readable format and to transmit those data to another controller without hindrance from the us (data portability). However, this right only applies to personal data you have provided to us and if they were provided on the basis of your consent or because they were necessary for the execution or the performance of an agreement with you>
- To object to processing of your data. You can exercise this right when we process your personal data on the basis of our legitimate interests, i.e. you have not given us your consent and we do not need them for the execution or performance of an agreement nor to comply with legal obligations. When our interest relates to direct marketing, we will grant you your request immediately. For other interests, e.g. our security interests, we will ask you to describe your specific circumstances giving rise to request. We then need to balance our interests against your circumstances. If this balancing exercise results in your circumstances outweighing our interests, we will cease processing your personal data.
- To withdraw your consent for the processing of personal data when we have collected your personal data on the basis of your consent. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
You can exercise these rights by sending an email to brightspace.wecr@wur.nl. When doing so, please make sure to provide any information needed to confirm your identify.
Organisations have an obligation to respond to any request to consult, modify or delete your personal data within 30 days. However, this period may be renewed if the request concerns a large amount of data. In any case, you will be informed as soon as possible of the time required for processing the request.
In case you remain unsatisfied with our response you have the right to contact the competent supervisory authority of the Member State. In the Netherlands, the supervisory authority is the Dutch Data Protection Agency: https://autoriteitpersoonsgegevens.nl/en The list of the European data protection authorities is available on the website of European Data Protection Board (https://edpb.europa.eu/about-edpb/board/members_en ).
- About cookies
During users’ navigation on this website, we may collect identification data of users, by using cookies.
Cookies are short software code texts, which are sent from our website hosting server and are stored at your terminal (“browser”). Their basic function is to communicate to us data from your browser.
First party cookies are cookies set by the website you are visiting. Only that website can read them. In addition, a website might potentially use external services, which also set their own cookies, known as third-party cookies.
Persistent cookies are cookies saved on your computer and that are not deleted automatically when you quit your browser, unlike a session cookie, which is deleted when you quit your browser.
Every time you visit the BrightSpace website, you will be prompted to accept or refuse cookies.
The purpose is to enable the site to remember your preferences (such as user name, language, etc.) for a certain period of time.
That way, you do not have to re-enter them when browsing around the site during the same visit.
Cookies can also be used to establish anonymised statistics about the browsing experience on our sites.
Cookies do not have access to data on your hard disk or cookies created by other sites and do not damage your system.
You may control and/or delete all cookies from your computer and, in most browsers, select settings that do not allow installation of cookies. However, in that case, you may have to adjust certain preferences every time you visit a website.
Users may make use of the website without problems even without use of cookies, but, potentially, to the detriment of its user-friendliness and of the functioning of certain of its services. Any personal data collected via cookies that can be correlated to a specific visitor/user shall be processed exclusively for the purposes cited above.
For more information about cookies, please visit http://www.allaboutcookies.org/
- Cookies that we use
The types of cookies used by us and our partners in connection with the BrightSpace website can be classified into one of four categories, namely ‘functionality cookies’ necessary for essential Website purposes, , performance and analytics cookies’, ‘ tracking cookies’, and ‘social media cookies’. We have set out some further information about each category, and the purposes of the cookies we and third-parties set as follows.
Functionality Cookies
Functionality cookies record information about choices you have made and allow us to tailor the website to you. These cookies mean that when you continue to use or come back to the Platform, we can provide you with our services as you have asked for them to be provided. For example, these cookies allow us to:
- Save your location preference if you have set your location on your homepage, if applicable.
- Remember settings you have applied, such as layout, text size, preferences, and colours;
- Show you when you are logged in; and
- Store accessibility options. Please see the instructions set out in ‘How to control or delete cookies’ below.
Performance and Analytics Cookies
We use Google Analytics as web analytics tool that helps us understand how users engage with our website. Like many services, these web analytics services use first party cookies to track user interactions as in our case, where they are used to collect information about how users use our site and how they use it. This information is used to compile reports and create services to help us improve our website and the services associated with it.
The reports disclose website trends without identifying individual visitors. Some services will allow you to opt out of tracking with their services directly. For instance, while you cannot opt out of use of cookies with our site, you can opt out of Google Analytics without affecting how you visit our site. For more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page. https://support.google.com/analytics/answer/6004245?hl=en
Social Media Cookies
On some pages of our website, third parties that provide applications through our website may set their own cookies in order to track the success of their applications or customise applications for you. For example, when you share a content using a social media sharing button on our Platform (e.g., Facebook, Twitter, or Google Plus), the social network that has created the button will record that you have done this. Because of how cookies work, we cannot access these cookies, nor can the third parties access the data in cookies used by us. Some pages of our website may also contain embedded content, such as video content from YouTube, and these third-party sites may set their own cookies. Please see the instructions set out in ‘How to control or delete cookies’ below.
The cookies we use collect the following data:
- Time of visit, pages visited, and time spent on each page of the webpages
- Referring site details (such as the URI a user came through to arrive at this site)
- Type of web browser
- Type of operating system (OS)
- Flash version, JavaScript support, screen resolution, and screen color processing ability
- Network location and IP address.
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- Cookies used by our service providers
These third-party services are outside of the control of the BrightSpace consortium. Providers may, at any time, change their terms of service, purpose and use of cookies, etc.
- How to Control or Delete Cookies
You have the right to accept or stop cookies from being stored on your device at any time by modifying the settings in your web browser to reflect your cookie preferences.
Please be aware that you may not be able to use all the interactive features of our services, the website and its content once cookies are disabled.
Most browsers offer instructions on how to change your cookie settings. These settings will typically be found in the options or preferences menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the ‘Help’ option in your browser for more details.
- Integration of Services and Content by Third Parties
It may happen that content or third-party services such as city maps or fonts from other websites are integrated into our Online Services. Integration of third-party content always requires that they know the User’s IP address, since they will not be able to send the content to the User’s browser without the IP address . The IP address is therefore required in order to display this content. In addition, providers of third-party content may set their own cookies and process the Users’ data for their own purposes. User profiles may be created from the processed data. We will use this kind of content as sparingly as possible to prevent unwanted transfer of data and will select reliable Third-Party Providers in terms of data security.
The following list provides an overview of Third-Party Providers and their contents as well as links to their privacy policies, which contain further information on the processing of data and, as in some cases already mentioned here, the possibility to object (called “opt-out”):
– External fonts from Google, Inc. https://www.google.com/fonts (“Google Fonts”). The integration of Google Fonts is done by a server call on Google (usually in the US). Privacy: https://policies.google.com/privacy?hl=en, Opt-Out: https://www.google.com/settings/ads/.
– Maps from the “Google Maps” service of the Third-Party Provider Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy: https://policies.google.com/privacy?hl=en, Opt-Out: https://www.google.com/settings/ads/.
— Videos from the “YouTube” platform of the Third-Party Provider Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy: https://policies.google.com/privacy?hl=en, Opt-Out: https://www.google.com/settings/ads/.
Google Analytics
We use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google uses cookies. The information generated by the cookie about the use of the website by the User is usually transferred to a Google server in the United States of America and stored there.
Google will use this information on our behalf to evaluate the use of our website by Users, to compile reports on the activities on this website, and to provide us with other services related to the use of this website and the internet. The processed data may be used to create pseudonymized user profiles.
We only use Google Analytics with IP anonymization enabled. This means that the IP address of the User is shortened by Google within EU Member States or other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the United States and shortened there.
The IP address transmitted by the User’s browser is not merged with other Google data. Users can prevent the storage of cookies by adjusting their browser software accordingly; Users can also prevent the collection of data which is generated by the cookie and transmitted to Google for processing in connection with their use of the Online Services by downloading and installing the browser plugin which is available at: http://tools.google.com/dlpage/gaoptout.
For more information on the use of Google data for advertising purposes, setting options and opt-out options, please visit Google’s websites: https://www.google.com/intl/en/policies/privacy/partners (How Google uses information from sites or apps that use our services), https://policies.google.com/technologies/ads?hl=en (How Google uses cookies in advertising), http://www.google.de/settings/ads (Control the information Google uses to show you ads) and https://adssettings.google.com/authenticated?hl=en (Ad personalization).
Social Media Tools
Our website uses Social Plugins (Plugins) of different social networks like Twitter, LinkedIn and Youtube, which are marked by their logos. When you open a site with these plugins, browser data is transferred to the owners of those social networks. Thus, they are informed that you have opened the respective site. If you are logged in to one or several of these social networks, this data can be linked to your account. Your IP address may be logged without you being a member of a social network or logging into a network.
In that case, please note that the processing of data takes place outside of the European Union. We have no influence on and take no responsibility for the volume of data that is transferred through social plugins.
For more information, please look up the data security policies of the respective network:
twitter.com/privacy
https://www.linkedin.com/legal/privacy-policy
https://www.youtube.com/static?template=privacy_guidelines
Newsletter Services
We use MailerLite to manage our email marketing subscriber list and to send emails to our subscribers. MailerLite is a third-party provider, which may process your data (when you subscribe) using industry-standard technologies to help us monitor and improve our newsletter. MailerLite’s privacy policy is available at https://www.mailerlite.com/legal/privacy-policy
You can always unsubscribe from our newsletter by clicking on the unsubscribe link provided at the end of each newsletter. You may also contact us using the information below to request a complete deletion of your data from our Newsletter Service.
- Links to other websites
The website contains links to other websites. The BrightSpace consortium are not responsible for data privacy policies and/or practices on other websites and have no influence as to whether the operators of other websites act in compliance with data protection provisions. The BrightSpace Privacy and Cookie Policy is solely applicable to data collected by BrightSpace project website itself.
- Amendments
The terms and conditions of this Privacy and Cookie Policy can be adjusted without prior notice. Changes are effective as soon as they are published on the website. Your continued use of our site following the posting of changes to these terms will mean you accept those changes.
- Data protection officer
The data protection laws require that we provide you with information on the processing of your personal data. Should you have further questions regarding the processing of your personal data, the BrightSpace Data Protection Officer can be contacted via email at brightspace.wecr@wur.nl.
Last updated: 20/02/2024
