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Privacy Policy

This policy describes what personal and sensitive data we collect, how we use it, and your choices.

The ANKAA Project, the organisation, is committed to a policy of protecting the rights and privacy of individuals. The organisation needs to collect and use certain types of data in order to carry on its work. This personal information will be collected and dealt with appropriately. 

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The General Data Protection Regulation (GDPR) governs the use of information about people (personal data). Personal data can be held on computers or in a manual file, and includes email, minutes of meetings, and photographs. The ANKAA Project will remain the data controller for the information held. The ANKAA Project (Committee and Coordinators) will be personally responsible for processing and using personal information in accordance with the GDPR.

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Committee members, coordinators and volunteers running the ANKAA Project who have access to personal information, will be expected to read and comply with this policy. This policy applies to all personal data processed by the ANKAA Project. The Responsible Person (Data Protection Officer) shall take responsibility for the ANKAA Project’s ongoing compliance with this policy. This policy shall be reviewed at least annually. 

Data Protection Principles

The ANKAA Project is committed to processing data in accordance with its responsibilities under the GDPR. Article 5 of the GDPR requires that personal data shall be:

  1. processed lawfully, fairly and in a transparent manner in relation to individuals;

  2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

  4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;

  5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and

  6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

Information we collect

All data processed by the ANKAA Project must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests. ANKAA will rely upon consent as a lawful basis for processing data. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent will be clearly available and systems will be in place to ensure such revocation is reflected accurately in the ANKAA Project’s systems. 

Information collected from Website visitors

As a visitor to our Website, ANKAA Project's servers automatically record certain information, such as your Internet Protocol ("IP") address (so we understand which country you are connecting from when you visit the Website), your operating system, your browser ID, your browsing activity, and other information about how you interacted with our Website, which can be used to identify you. We may collect this information through the use of cookies or other tracking technologies.

 

You may choose to interact with our Website by entering data into form fields and providing personal data to ANKAA Project, such as giving us your name, email address, filling out an application, or making a donation.

We only collect personal data that is reasonable or necessary to accomplish the purpose of your interaction with ANKAA Project as a visitor to our Website. You may choose not to provide this information, but you need to understand that as a result, you may not be able to engage in certain activities on the Website. Any personal data provided by you as a visitor to the Website will be used only as described in this Privacy Policy.

Information collected from centre user’s

We collect information when you register at our centre. When you register, we collect basic information about you – your name and phone number. But we also collect personal and sensitive data, for instance, your arrival date in Greece, your skills and education background, and your nationality. 

During the registration procedure, you will be provided with a consent form, where you have the right to agree or disagree on what information you want to provide.

Information collected from donors

When you make an online donation through our Crowdfunding campaign or through our bank account, we collect personal data such as your name, billing address, and email address. We collect information about your donation, including if it is dedicated for a special aspect for the project and the amount of your donation. We also collect (but do not retain) bank account numbers and credit card numbers which are processed by a third-party payment vendor subject to the Payment Card Industry Data Security Standards. If you use PayPal, or a similar service, their use of your information is based on their terms of service and policies, not ours, so we encourage you to review those policies carefully.

Information collected from volunteers

We collect information when you register to work as a volunteer with the ANKAA Project. When you register, we collect basic information about you – your name, email address and phone number. Besides we collect the skills you have, the timeframe of your stay in Athens, and your arrival and departure date. During the registration procedure, you will be provided with a consent form, where you have the right to agree or disagree on what information you want to provide. 

Informed consent

Informed consent is when a Data Subject (an identified or identifiable person) clearly understands why their information is needed, who it will be shared with, the possible consequences of them agreeing or refusing the proposed use of the data and then gives their consent.

The ANKAA Project will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person, or by completing a form.

Disclosure of Personal Data

As a donor, we will not share your information with any third party. Your personal data is just accessible for committee members in charge of finances and/or fundraising.

As a centre user, your data is available for our registration and assessment team, as well as our personally tailored program developers.

As a volunteer, we will only share your information with committee members and department coordinators to adapt our programs and course plans.

Except for the purposes outlined herein, we will not trade, share, or sell anyone's personal data with anyone else.

If ANKAA Project merges with, or becomes an affiliate of another organisation, we will ensure the confidentiality of any personal data involved in such transactions and provide notice before personal data is transferred and becomes subject to a different privacy policy.

We may also be required to disclose your personal data in the following circumstances: (1) we need to respond to a subpoena, court order or legal process, including to meet national security or law enforcement requirements; (2) an emergency situation requires disclosure before your permission can be obtained (e.g., situations involving potential threats to personal safety), or; (3) we determine that disclosure is needed to protect our rights or property, or the rights or property of another person, in which case we will implement appropriate safeguards to ensure that your personal data continues to be protected.

Your Rights

Right to access

You can access your information or make changes or updates at any time by contacting us in the centre, through our website or by email. We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes (for example, if you have a new email address), then you are responsible for notifying us of those changes.

Upon request, we will provide you with a copy of the information that we have.

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Right to erasure

If you wish to delete your account or have your information removed from our system, you can do so by sending an email to info@ankaaproject.org

For privacy and security, requests must come from the email address tied to your account.

 

Right to rectification

If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we have shared your personal data with others, we will inform them about the corrections where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.

 

Right to restrict processing

You may ask us to restrict or 'block' the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restrictions on processing. If we have shared your personal data with others, we will inform them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.

 

Right to data portability

You have the right to obtain your personal data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your personal data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.

Upon request, we will provide you with a copy of the information that we have. Users can submit their request to access a copy of their information by writing an e-mail to info@ankaaproject.org.


 

Right to object

You may ask us at any time to stop processing your personal data, and we will do so:

If we are relying on a legitimate interest (described in this Privacy Policy) to process your personal data, unless we demonstrate compelling legitimate grounds for the processing or;

If we are processing your personal data for direct marketing.

 

Right to withdraw consent

If we rely on your consent to process your personal data you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.

 

Data Retention

To ensure its processing of data is lawful, fair and transparent, the ANKAA Project will maintain a Register of Systems that will be reviewed at least annually. Individuals have the right to access their personal data and any such requests made to the Data Protection Officer will be dealt with in a timely manner. 

 

Centre Users

If you are a centre user, we will retain your information as long as you are participating in ANKAA’s activities (classes, trainings, workshops etc). We may also retain and use your personal data in order to comply with our contractual or legal obligations, audit requirements, resolve disputes, and prevent abuse.

 

Volunteers

If you are a volunteer, we will retain your information for as long as you are active in the centre. Even after  your volunteering is completed, we may retain data in case you return to volunteer at the ANKAA Project. We may also retain and use personal data in order to comply with our contractual or legal obligations, audit requirements, resolve disputes, and prevent abuse.

 

Donors

If you are a donor, we will retain your information for as long as your donor account is active or as long as needed to provide our services. We may also retain and use your personal data in order to comply with our contractual or legal obligations, audit requirements, resolve disputes, and prevent abuse.

 

Our Data Protection Officer makes sure that personal data is retained as long as is needed for the purpose or purposes for which it was obtained. 

A schedule listing all records featuring personal data is drawn up by the ANKAA Project containing maximum retention periods for each type of document, file set or database featuring personal data. Non-active donor details will be removed from databases. 


All access to personal data on donor databases will be restricted and could be subject to monitoring

 

Safeguarding Your Information

ANKAA Project understands the importance of keeping your information secure and confidential. We take reasonable and appropriate measures to protect personal data from loss, misuse and unauthorised access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal data.

 

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The ANKAA Project ensures that personal data is stored securely using modern software that is kept-up-to-date.  Access to personal data is limited to personnel who need access and appropriate security will be in place to avoid unauthorised sharing of information. When personal data is deleted this will be done safely such that the data is irrecoverable. Appropriate back-up and disaster recovery solutions will be in place.

 

Centre User

Your data will be stored on the servers of our registration software. We will take all reasonable steps necessary to ensure your data is treated securely and in accordance with this Data Protection Policy and the GDPR.

 

Volunteers

Your data will be stored in our database in the cloud in a password-protected format, accessible only by committee members and coordinators of the ANKAA Project. We will take all reasonable steps necessary to ensure your data is treated securely and in accordance with this Data Protection Policy and the GDPR.

 

Donors

Your data will be stored in our database in the cloud in a password-protected document, accessible only by committee members in charge of finances and fundraising. We will take all reasonable steps necessary to ensure your data is treated securely and in accordance with this Data Protection Policy and the GDPR.

Data Storage

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