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Privacy Policy

CARDET (“us”, “we”, or “our”) operates the https://platform.spark-project.eu e-learning platform as part of the EU-funded project “SPARK”.

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you register for and use this platform, and the choices you have associated with that data.

Effective date: 20/04/2022

ADDRESSED TO ALL DATA SUBJECTS

  1. About CARDET
  2. Our Privacy Commitment
  3. What Data We Collect and Process
  4. How We Use Data
  5. Use of Cookies and Other Digital Technologies
  6. Accessing Your Personal Information and Your Rights
  7. About Minors (Children)
  8. Sharing Personal Information Outside the European Union
  9. Data Security and Retention

  1. About CARDET

    The Center for the Advancement of Research & Development in Educational Technology Ltd (CARDET) is an independent, non-profit, non-governmental, research and development organization based in Cyprus. This Privacy Policy governs how we collect and process personal data in the context of the SPARK e-learning platform, available at https://platform.spark-project.eu.

    Data Controller. For the purposes of the GDPR, CARDET – Centre for the Advancement of Research and Development in Educational Technology Ltd, 29 Lykavitou Avenue, 1st Floor, Engomi, 2401 Nicosia, Cyprus, is the Data Controller for the personal data processed under this Policy. For any question about this Policy or about your personal data, and to exercise your rights, you can contact us at privacy@cardet.org. This platform is delivered as part of the project SPARK, funded by the European Union under E+ KA3 (European Youth Together), Grant Agreement No. 101186990.

  2. Our Privacy Commitment

    CARDET complies with all applicable privacy laws, including the EU’s General Data Protection Regulation (“GDPR”, Regulation (EU) 2016/679). “Personal Data” means any information relating to an identifiable natural person. “Sensitive Personal Data” (Special Categories) means data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, or data concerning health, sex life or sexual orientation. We process your personal data only as described in this Policy and on the legal bases set out in Section 4.

    We do not collect Sensitive Personal Data, we do not use your data for automated decision-making or profiling, and we do not sell your data.

  3. What Data We Collect and Process

    We apply data minimization and, for this platform, collect only:

    DataSourceUsed for
    Full name You provide it at registration Creating and managing your account, and printing your name on your certificate of completion
    Email address You provide it at registration Account login, account-related messages, and support
    Account credentials (password, stored encrypted) You set it at registration Securing access to your account
    Organization Name Register Project Reporting
    Your Location Register Project Reporting
    Occupation Register Project Reporting
    Course activity (modules opened, progress, completion, and assessment results where the course includes assessment) Generated as you use the platform Tracking your progress and issuing your certificate of completion
    Content you submit, where the course includes a discussion forum or assignment uploads You choose to submit it Delivering that course feature and, where applicable, assessing your work
    Technical and log data (IP address, browser type, and the records of logins and activity kept automatically by the learning platform) Recorded automatically when you use the platform Keeping the platform secure, preventing abuse and diagnosing technical faults
    Website usage statistics (via Google Analytics – see Section 5) Collected with your consent Measuring visits and improving the platform

    Where a course includes a discussion forum, anything you post there is visible to the other registered learners on that course and to CARDET staff. Please do not post personal details you would rather keep private.

    Your certificate of completion is a simple PDF showing your name and the course title. We do not publish it, and we do not maintain any public list of participants or graduates.

    Providing your full name, email address and account password is a necessary requirement to register for and take part in this platform; it is needed to create your account and provide the course to you. If you do not provide this data, we cannot create your account or give you access to the course. Website usage statistics are collected only with your consent, and refusing them does not affect your participation.

  4. How We Use Data

    We use your data for the following purposes, each on a specific legal basis under Article 6(1) GDPR:

    #PurposeLegal basis
    a Creating your account and providing access to the course content Art. 6(1)(b) – performance of a contract (your registration for the course)
    b Recording your course progress and issuing your certificate of completion Art. 6(1)(b) – performance of a contract
    c Sending you service/administrative messages about your account and the course Art. 6(1)(b) – performance of a contract
    d Responding to your enquiries and providing user support Art. 6(1)(b) – performance of a contract
    e Reporting on course participation and completion to the project consortium and to the European Union bodies funding the project Art. 6(1)(c) – legal obligation (grant reporting)
    f Meeting legal, accounting and EU-funding audit obligations Art. 6(1)(c) – legal obligation
    g Keeping the platform secure, preventing abuse and troubleshooting faults Art. 6(1)(f) – legitimate interests (network and information security)
    h Measuring website visits and usage through Google Analytics Art. 6(1)(a) – consent (withdrawable at any time)

  5. Use of Cookies and Other Digital Technologies

    We use strictly necessary cookies required to log you in and keep the platform secure – these do not require consent.

    We also use Google Analytics (Google LLC, United States) to understand how visitors use the platform; as our Analytics property runs on GA4, individual IP addresses are not logged or stored by Google Analytics. Analytics cookies are loaded only after you consent via our cookie banner, where you can accept or reject them and change or withdraw your choice at any time via “Cookie settings”. Rejecting analytics cookies does not affect your use of the platform. See our Cookie Notice, linked in the footer of every page, for the full list of cookies and their duration.

    Some pages may embed content hosted by third parties, such as videos. When such content loads, the provider may set its own cookies and receive your IP address, and its own privacy policy then applies to that processing. We load embedded third-party content only after you consent to non-essential cookies.

  6. Accessing Your Personal Information and Your Rights

    By writing to us at privacy@cardet.org you may exercise your rights to:

    • Information about the personal data we process about you
    • Access to your personal data
    • Rectification of inaccurate or incomplete data
    • Erasure of your personal data
    • Restriction of processing
    • Data portability for data you have provided
    • Object to processing based on legitimate interests
    • Withdraw consent at any time, without affecting the lawfulness of processing carried out before the withdrawal

    You may also close your account at any time by writing to the address above. We will respond as soon as possible and in any event within one month of your request.

    If you believe your data is not handled lawfully, you may lodge a complaint with the Office of the Commissioner for Personal Data Protection (Cyprus) (www.dataprotection.gov.cy), or with the supervisory authority in your own EU country of residence.

  7. About Minors (Children)

    This platform is intended for adults. We do not knowingly collect data from minors under the age of 18. Where participation by a minor is relevant, it is permitted only with the explicit consent of a parent or guardian.

  8. Sharing Personal Information Outside the European Union

    Your data is accessed only by authorized CARDET and project staff and by processors acting on our documented instructions: LeaseWeb USA, Inc. (hosting the platform, United States) and Google LLC (Google Analytics). These providers act solely as data processors, process personal data only on our documented instructions, and do not access, monitor, or use it for their own purposes.

    Recipients of your personal data. Your personal data is disclosed only to: (i) authorized CARDET and project staff; (ii) our processors acting on our documented instructions; (iii) the other organisations in the project consortium, which may be shown course participation and completion information in order to report on the project – they receive this only for project reporting and monitoring, and use it for no other purpose; and (iv) where required to meet our legal and EU-funding audit obligations, the competent European Union institutions and bodies and their authorized auditors (for example, the European Commission and the European Court of Auditors). We do not otherwise disclose your personal data, and we do not sell it.

    These transfers to the United States take place under the EU-U.S. Data Privacy Framework (DPF), in which LeaseWeb USA, Inc. and Google LLC are self-certified and which the European Commission recognized as ensuring an adequate level of protection (adequacy decision of 10 July 2023). Where a provider is not DPF-certified, we rely on EU Commission-approved Standard Contractual Clauses. Our Google Analytics account operates under the Google Ads Data Processing Terms, accepted at account level (accepted 26 March 2019), under which Google acts as a data processor for Analytics data.

  9. Data Security and Retention

    We apply appropriate technical and organizational measures, including HTTPS, encrypted storage of passwords, access controls limiting data to authorized staff, and regular platform updates.

    We keep each category of data only as long as it is needed:

    • Account and registration data, and course activity: for the duration of the project (which ends on 31 October 2026) and for 5 years after that date, i.e. until 31 October 2031, in line with the project’s record-keeping and audit obligations.
    • Technical and log data: 6 months, after which it is automatically deleted.
    • Google Analytics data: 14 months (user-level data) and 2 months (event-level data), in line with our standard Analytics configuration.

    After these periods the data is securely deleted or irreversibly anonymized. You may ask us to delete your data earlier at any time (see Section 6), and we will do so unless we are required to keep it for the legal or audit obligations described above.

    What happens when the project ends. When the project closes on 31 October 2026, we normally close registration and log-in and stop recording any course activity; the course materials may remain publicly available as a read-only resource. Your account data is then kept only until 31 October 2031 for the audit reasons described above, after which it is deleted or irreversibly anonymized. You can contact us at privacy@cardet.org to exercise your rights at any point, including after the project has ended.

Last updated: 23/05/2024