Full policy

Privacy and Cookie policy

1. Privacy Policy

1.1 Introduction

The information below is provided to you to have a faithful image of our activity on the Site regarding the processing of personal data. You will also find identification information, our goals, your rights and the concrete ways to achieve it. Data privacy is one of our main concerns.

EEIRH is the Controller of your personal data when it comes to data privacy:

• East European Institute for Reproductive Health
• Address: 1 Moldovei St., 540493 Tirgu-Mures, Romania
• Authorization: 54/30 March 1997
• E-mail: office@eeirh.org
• Phone: +40 265 255532
• CIF: 9028390
• Mission: The East European Institute for Reproductive Health (EEIRH) promotes the right of women and men to sexual and reproductive health, to a life without gender-based violence and to a healthy and dignified ageing. To fulfill this mission, EEIRH provides policy advisory work, consultancy and technical assistance, develops and implements research, training and communication programmes and projects, and offers services. In all its activities, EEIRH promotes dialogue, partnerships and international cooperation. EEIRH is committed to supporting the achievement of the Sustainable Development Goals, in particular Goals 3 and 5, and of the ICPD Plan of Action, through the combined efforts of governments, civil society organizations and the private sector, in the context of a stronger and more effective partnership for development.
• Data Protection Officer: gdpr@eeirh.org

With this Privacy Policy, we inform you about the processing of personal data in connection with the use of this Site. If you are redirected to other websites via a link, the privacy policy of the respective website operator applies. We recommend that you inform yourself about the handling of personal data on the respective website. We know that the protection of your data is important to you and appreciate the trust placed in us. EEIRH strictly adheres to the legal provisions of the applicable data protection law when collecting, processing, and using your data.

This Privacy Policy tells you how we will collect and use your personal data to provide our service, which allows you to use our Site, content and to be connected with other people for the process of collaborative learning.

1.2 Personal data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

"any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person".

If you have an account at Site, we will process your personal data manually entered by you or with which you agreed in advance, such as:

• Name, Country/Territory of domicile, City, Institution, Profession, Specialty, Age, Gender, Language preferred;
• E-mail address, IP address;
• Data on how you use the Site, Activity on the Site, Activities in the courses, Grades and Certificates obtained in the eLearning courses provided by EEIRH, Feedback provided;
• Other information regarding the access and actions carried out on the Site, as well as any other categories of data you provide directly in the context of user account creation in the context of discussion forums, placement of feedback, comments or requests through the Site or in any other way resulting from the use of the Site.

Some data it is registered just based on you visit. When you visit our Site, the browser on your device automatically sends information to the server on our Site. This information is temporarily stored in a so-called log file. The following information is collected and stored until it is automatically deleted: IP address of the requesting computer; date and time of access; name and URL of the accessed file; website from which access is made (“referrer URL”); if applicable, the search engine you used; the browser used; and, if applicable, the operating system of your computer as well as the name of your access provider.

1.3 For what purpose and on what legal basis do we collect your data?

We collect your personal data in order to deliver the best content, to offer you feedback and to provide you with a great experience with our Site. We value our Site user’s data protection and privacy rights and we have no interest in collecting data beyond what we need to make the Site work for you. We are aware of our obligations as Controller and our Site is 100% in line with GDPR requirements.

The legal basis for processing your personal data is GDPR - Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data – and this scope is falling into:

• Article 6.1(a), Consent
• Article 6.1(b), Contract
• Article 6.1(f), Legitimate Interest

Any legitimate interests pursued by us, or third parties we use, are as follows:

• Information about our activities;
• Providing learning content via eLearning platforms;
• Allowing secured authentication sessions for accessing the eLearning platforms;
• Communicating with other people interested in the same topics;
• Statistics about your online activity in order to evaluate our program and to improve the process and the content.
• Other:
  • Ensuring a functioning connection of the Site;
  • Ensuring comfortable use of the Site;
  • Statistical evaluation using an anonymous marker in order to optimize the Site, as well as the quality and range of our offers;
  • Evaluation of system security and stability; and
  • For other administrative purposes.

1.4 How will we use your personal data?

We will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. We maintain a register of data retention policy for each type of data collected and we reaffirm our commitment to only ever trying to process the minimum amount of data needed. We are required to retain certain information in accordance with the Law, such as information needed for audit purposes of our activity as content providers. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods according to institutional mandate related needs.

1.5 Will we share your personal data with anyone else?

We may pass your personal data on to third-party service providers contracted in the course of offering the Services to you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to deliver the service they provide on our and your behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with our procedures. If we wish to pass your personal data onto a third party, we will only do so once we have obtained your consent, unless we are legally required to do otherwise. If you would like an up-to-date register of all our third-party service providers, please contact gdpr@eeirh.org and we will be happy to provide it.

1.6 How long will my data be stored?

We will process different forms of personal data for as long as is necessary and proportionate for the purpose for which it has been supplied and will store the personal data for the shortest amount of time possible, taking into account legal and service requirements. We will store your data for a period of 2 years since your last activity on the Site. As long as you are active on our Site, you may exercise your rights via usual contact methods from your Profile.

1.7 What data protection rights do I have?

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organization.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that we refuse your request under rights of access, we will provide you with a reason as to why. You have the right to complain.

1.8 Data requests and response procedure

You have the right to see what personal information we hold about you and to make corrections if necessary, or to request restriction of our processing of your personal data.  You have the right to have your data deleted if you would no longer like us to store or process your personal data.

You can address the following requests directly from your Profile page > Privacy and policies > Data request:

• Contact the EEIRH Data Protection Officer.
• Receive an export of all your personal data.
• Delete all your personal data.

Your requests for export, data change or restriction, or deletion, will receive an answer from us in maximum 30 days from your request.  Your request may or may not be aproved, according to this Privacy and Cookie policy and rules and regulations in force, with a detailed motivation of the Data Protection Officer’s decision.

1.9 Consent

By consenting to this Privacy Policy, you are giving us permission to process your personal data specifically for the purposes identified. Agreement with this Privacy and Cookie Policy will be considered to be explicit consent and we will keep a copy of the records of that consent for audit purposes.

You may withdraw your consent at any time by accessing your profile in the Site or by writing to our DPO at gdpr@eeirh.org.

1.10 Complaints

In the event that you wish to make a complaint about how your personal data is being processed by us, or how your complaint has been handled, you have the right to lodge a complaint directly with the EEIRH Data Protection Officer, the national supervisory authority, or Data Compliance Europe Ltd.

2. Cookie policy

2.1 Introduction

Protecting your private sphere while using our Site is an extremely important aspect for us. That is why we are keeping you in touch in detail about the collection of personal data and personal data.

The right to use personal data and anonymous data rests with EEIRH within the limits provided by law, except for the rights of the data subjects described above.

The Site uses software for use analysis. By evaluating these data, useful information on user needs can be obtained. This information contributes to improving the quality of the Site. More specifically, for each visit to the Site, the following set of data is stored unrestricted:

• The anonymous form of the IP address of the requesting computer;
• Date and time of visit or request;
• The name of the page you consulted or the file you visited;
• Refer to the page that this page views;
• The browser used by the user, including the browser version;
• The operating system used by the user.

A cookie is a small text file that saves Internet settings. Almost every web page uses this technology. Your web browser downloads this when you first access a web page. The next time you access this web page with the same device, Cookies and Saved Information are either sent back to the First Party Cookie website or to another Third Party Cookie webpage. Thus, the webpage recognizes that you have visited the page with this browser again and varies in some cases the content displayed.

Some cookies are very useful because they can improve the user experience in the event of the web page being reacted. Provided you use the same terminal and same browser as before, Cookie files remind you, for example, your preferences, communicates how you use a page, and adapts to your personal interests and needs. Most of our cookies are automatically deleted from your hard drive after the session ("Session Cookies"). In addition, we also use cookies that remain on your hard drive after the session is complete. This primarily aims to improve the user experience in case of a new web page access, by subsequently adapting the web page to your personal needs, thus optimizing the loading time.

Cookies that do not require your consent. Cookies that are absolutely necessary, also called "strictly necessary", provide functions without which you cannot use the web page correctly. These Cookies are exclusively used by us and are the so-called First Party Cookies. They are only stored for the current browser session on your computer. Cookies that are absolutely necessary. We have a "Session-Cookie" for the sign-in feature. Without this cookie, it is not possible to connect and not go to the functions behind the connection.

In addition, such cookies ensure, for example, changing the http page in https to the functionality of the page and complying with the data transfer security requirements. You do not necessarily require your consent to use the necessary cookies.

Cookies that are absolutely necessary cannot be disabled using the function of this page. However, they can be disabled at any time using the browser you are using. Please refer to the instructions below.

Cookies that, according to the legal definition, is not necessarily necessary to use the web page, but which are performing important tasks. Without these cookies, features that ensure comfortable browsing on our webpage, such as pre-filled forms, would no longer be available. Settings such as language selection cannot be saved and must be reset on each page. In addition, we no longer have the opportunity to offer personalized offers to you.

You can set your browser in such a way that cookies are only created with your consent or are generally denied. Please note, however, that without cookies, certain areas of the web page cannot be used or are only usable.

You can control the use of "Cookies" and prevent it if you configure your browser as follows:

• Microsoft Edge and Internet Explorer: see https://support.microsoft.com/ 
  Extras - Internet Options - Expanded Registration Card - under Security Check "Send" Do Not Track "requests to pages web sites visited with Internet Explorer "Do Not Track" - please confirm
• Google Chrome: see https://support.google.com/chrome/ 
  Menu - Settings - Extensive Settings - under "Data Protection" click "Content Settings" - under "Cookies" desired fields - confirm
• Firefox: see https://support.mozilla.org/ 
  Menu - Settings - Data Protection - under Chronical Check "Create user-defined settings" - in the "Cookies" section make the desired settings - confirm
• Safari: see https://support.apple.com/ 
  Safari - Settings - Data Protection - in the "Cookies and Web Page Data" section, make the desired settings – confirm

2.2 Web analysis cookies (Google Analytics)

If you have given your consent on our Site, we also use cookies to create pseudonymous user profiles for the purpose of web analysis (“web analysis cookies”). These cookies enable us to identify returning users (device owners), analyze their behavior on the Site, optimize the Site and measure its reach. The legal basis for such data processing is Art. 6 (1) (a) GDPR. You give your consent to this tracking on the Site by clicking on “OK” in our cookie banner; no web analysis cookies are set before this happens. We do not combine the data with other personal data and we do not use it for the targeted addressing of individual users for advertising purposes. The web analysis cookies are deleted after 24 months at the latest or if you withdraw your consent beforehand.

For this web analysis we use the service Google Analytics, which is operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses cookies which are stored on your computer and which enable an analysis of your use of the Site. The information generated by the cookie about your use of the Site (browser type/version, operating system used, referrer URL, host name of the accessing computer (IP address), date and time of the server request) are generally transferred to a Google server in the USA and stored there. Google will therefore reduce your IP address by the last octet within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. The transfer of your information to a third country outside the EU is covered by an adequacy decision of the Commission (C/2016/4176 of 12 July 2016 – http://data.europa.eu/eli/dec_impl/2016/1250/oj) within the meaning of Article 45 GDPR, because Google has undertaken to comply with the principles of the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework).

On our behalf, Google uses this information as a processor within the meaning of Art. 28 GDPR to evaluate your use of the Site, to compile reports on Site activities and to provide the Site operator with further services associated with Site use and Internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.

You can prevent the use of cookies by selecting the appropriate settings on your browser (see above); however, please note that if you do this you may not be able to use the full functionality of the Site.

You can also prevent Google from collecting the data generated by the cookie and relating to your use of the Site (including your IP address) and from processing this data by Google for all websites by downloading and installing the browser plug-in available at https://tools.google.com/dlpage/gaoptout?hl=en. You can also – especially with browsers on mobile devices – prevent Google Analytics from collecting and processing your data.

For more information on Google Analytics’ Terms of Use and Privacy Policy, please visit https://www.google.com/analytics/terms/gb.htmland https://support.google.com/analytics/answer/6004245?hl=en

For any additional questions about how personal data is processed and to exercise your rights above, please email us at gdpr@eeirh.org.