PROTECTION OF YOUR PERSONAL DATA

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

The Commission and Code4Europe are committed to protecting your personal data and to respecting your privacy. Both parties collect and further process personal data pursuant to Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data (repealing Regulation (EC) n° 45/2001) as well as 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 joint-controllers employ 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:

• To process personal data of visitors in order to operate and administer the EU Code Week website;
• 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;
• 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 5(1)(a) of Regulation (EU) 2018/1725: for the operation and administration of the website, the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Union institution or body. Indeed, informing the broad public is a task resulting from the European Commission's own prerogatives at institutional level, as provided for in Article 58(2) (d) of Regulation (EU, Euratom) 2018/1046 of the European Parliament and of the Council of 18 July 2018 on the financial rules applicable to the general budget of the Union (OJ L 193, 30.7.2018, p. 1) and Article 6(1)(f) of Regulation (EU) 2016/679: the processing is necessary for the purposes of the legitimate interests pursued by the joint controllers or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
• Article 5(1)(d) of Regulation (EU) 2018/1725 and 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(15) of Regulation (EU) 2018/1725, Article 3(11) of Regulation (EU) (2016/679), Article 7 of Regulation (EU) 2018/1725 and 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?

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

• 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 joint controllers only keep 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 joint controllers have 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 Chapters III of Regulation (EU) 2018/1725 and 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) 2018/1725 and Article 6(1)(f) 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 Controllers, or in case of conflict the Data Protection Officers. If necessary, you can also address the European Data Protection Supervisor and the relevant data protection authorities. Their 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 joint controllers

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 joint controllers:

• DG CNECT G.2 European Commission at CNECT-G2@ec.europa.eu;
• JA Europe at privacy@jaeurope.org.

The Data Protection Officer (DPO) of the Commission or JA Europe

You may contact the Data Protection Officer of the Commission (DATA-PROTECTION-OFFICER@ec.europa.eu) with regard to issues related to the processing of your personal data under Regulation (EU) 2018/1725.

You may contact the Data Protection Officer of JA Europe (privacy@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 European Data Protection Supervisor (edps@edps.europa.eu) if you consider that your rights under Regulation (EU) 2018/1725 have been infringed as a result of the processing of your personal data by the Commission.

You also have the right to have recourse (i.e., you can lodge a complaint) to the national data protection authority in Belgium (Autorité de protection des données – Gegevensbeschermingsautoriteit) 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.