PRIVACY POLICY
This Website (irregularmigration.eu) is owned and operated by the University for Continuing Education Krems (Danube University Krems) on behalf of MIrreM (Measuring Irregular Migration and Related Policies), a project funded by the European Commission (Grant Agreement number 101061314).
By using this website, its content and registration forms, you agree to be bound by the following terms and conditions and any future modifications thereof.
The Consortium of the MIrreM Project (“we” or “us”) commit to maintain the accuracy, confidentiality and security of your personally identifiable information (“Personal Information”). As part of this commitment, our privacy policy governs our actions as they relate to the collection, use and sharing of Personal Information. This Privacy Statement sets out the basis on which any information we collect from you, or that is provided to us, will be processed by us.
Our Privacy Statement is based upon the values set by the European General Data Protection Regulation and national legislation.
Information gathering and usage
DATA COLLECTION
In compliance with the applicable EU, international and national law on data protection (in particular, Regulation 2016/679) and specifically in conformity with Art. 85, 89 GDPR and in conjunction with Section 2f(5) Austrian Research Organization Act we will collect personal data (information that can be used to identify you, such as your name, email address, telephone numbers etc.) for scientific and dissemination purposes. Data collected in the course of focus groups, workshops, interviews and surveys shall be understood as scientific purposes. We do neither perform any profiling activities nor sell your personal data to other organizations for commercial purposes. Your personal data will not be processed other than for the purposes for which you shared it with us.
Below, we define the type of personal data we might collect from you and the purposes for which we would use it.
MIrreM Stakeholder platform
Types of information collected through the form for the registration to MIrreM Stakeholders platform accessible via the MIrreM website (www.irregularmigration.eu): first name, last name, affiliation to an organisation, job position in that organisation, work email or other email provided, country/region/city of activity, language, website of the organisation, type of the organization. In addition. Two additional surveys will be conducted asking details about organisations’ scope of activities in relation to irregular migration and professional/organizational networks. These surveys will be linked through the e-mail addresses provided by respondents.
Purpose: Information is collected in a database for scientific purposes accessible to the MIrreM Consortium and Consortia of Horizon Europe Calls A sustainable future for Europe (HORIZON-CL2-2021-TRANSFORMATIONS-01 and HORIZON-CL2-2022-TRANSFORMATIONS -01). The database is managed by the Project Coordinator, University for Continuing Education Krems.
How: The form for collecting the data from the stakeholders has the structure of a questionnaire and for this we used LimeSurvey. The access to the database is granted only for project team of UWK.
Subscription to MIrreM Newsletter
Types of information collected through Newsletter subscription form: email address.
Purpose: The personal data collected through the Newsletter registration form will be accessible only for MIrreM Consortium for dissemination purposes.
How: The subscriptions to MIrreM Newsletter are collected through the popular marketing platform, Mailchimp, that allows us to create and manage the email campaigns (Newsletters).
In addition to scientific purposes, we may collect information on participation in events sponsored by MIrreM for accounting purposes through simple participant lists, including, as a minimum names, institutional affiliation and signatures.
DATA SHARING
Considering the limited number of experts on the research topics touched by MIrreM we intend to share personal data of stakeholders registering with other projects funded under Horizon Europe Calls A sustainable future for Europe (HORIZON-CL2-2021-TRANSFORMATIONS-01 and HORIZON-CL2-2022-TRANSFORMATIONS -01) so that we can respectfully manage your time resources, coordinate our research activities and build synergies. Personal data shared within the Consortium and with other Horizon projects will only include information collected through the registration form. Linked surveys will only be accessible in an anonymised version.
We will not otherwise use, share, disseminate, publish or disclose your personal data (except as may be required in response to litigation, investigations or other legally required disclosures). Data will only be shared if you have consented to it.
Participant lists will be mainly kept for accounting purposes and, upon consent, shared with participants of events. This may also include sharing of e-mail addresses, again providing consent.
YOUR CONSENT
Your consent will be asked at the very beginning of each data collection process, according to art. 6(1) lit. a GDPR. We may request this consent in varying forms, such as, by asking you to tick a box on a form, sign up via the stakeholder registration form through our website, or by asking you to provide a written statement.
RECEIVING NEWSLETTERS
The MIrreM Newsletters can be subscribed when registering via the MIrreM Stakeholder registration form.
We use the so-called double opt-in procedure to send the newsletter, i.e. we will only send you the newsletter if you have previously confirmed your registration via a link contained in a confirmation e-mail sent to you for this purpose. We want to ensure that only you as the owner of the email address provided can register for the newsletter. Your confirmation must be made promptly after receipt of the confirmation e-mail, otherwise your newsletter registration will be automatically deleted from our database.
According to Article 6 (1) lit. a GDPR, the processing of your personal data for sending the newsletter is based on the declaration of consent you gave voluntarily when registering for the newsletter.
The unsubscribe link is available in each Newsletter. Alternately you may remove your address from our mailing lists by sending an email to bellow mentioned email address.
SOCIAL MEDIA NETWORKS
SOCIAL MEDIA NETWORKS
For maximizing the awareness and impact of the produced outputs, we will communicate and connect with the public and stakeholders through social media networks, LinkedIn and Twitter. MIrreM Consortium may communicate and update on project activities and outputs produced (always only anonymised and pseudonymised data) through these social media networks, but will not collect any personal data.
By clicking on the social media icons from this website you will be directed to the MIrreM social media pages. The connection to social media networks is done through social media icons with hyperlinks. No personal data is transmitted in this process. When activating these hyperlinks, you will be redirected from our website directly to the website of the other provider. You will recognise this by the change of URL, among other things. We are not responsible for the confidential handling of your data on these third-party websites, as we have no influence on whether these companies comply with data protection regulations. For more information about the processing of your personal data by these companies, please visit their websites directly.
High quality standards in the dissemination and communication processes and respectively also the usage of social media pages are important for us. For this we commit to following principles, which will help us continuously evaluate the ethical implications of utilising social media pages in the dissemination and communication processes:
- Community safeguarding – Social media pages of the project are public spaces with free access and openly available. We will prevent harm, harassment, bullying, abuse and neglect in the user communities of our social media pages. Nevertheless, statements of members and contributors from our social media pages may be easily searchable and used without consent by other users.
- Anonymity – Research data will not be publicly linked or attributed online to particular users.
- Social media pages will not be used as data source (eighter user data, nor user statements) for the research of MIrreM project.
WHERE WE STORE YOUR PERSONAL DATA
The unanonymized data collected through the registration process to the MIrreM Stakeholders platform will be stored in the cloud storage of LimeSurvey. The registration form offers the possibility to rectify and erase your data.
Email addresses collected through the subscription form for the newsletter will be stored in the cloud storage of Mailchimp.
Backups of your personal data collected through the MIrreM Stakeholder platform and the subscription form for the MIrreM newsletter are stored on a cloud storage (Nextcloud) and local server (NetStorage) of UWK. The cloud storage can only be accessed by MIrreM Consortium for the purposes communicated through this Privacy Policy . For more data security Download and Share options are disabled. The full range of data collected through the stakeholder registration form and subsequent surveys will be accessible via NetStorage to a limited number of UWK employees. Core registration data as set out above will be accessible to other Members of the MIrreM consortium as well as consortium members of related projects funded under Horizon Europe Calls A sustainable future for Europe.
PERIOD FOR WHICH WE STORE YOUR PERSONAL DATA
To comply with the obligation of keeping records and other supporting documentation, as per Grant Agreement (Data Sheet, Art. 6. – Standard time-limits for record keeping) with our funders, the European Commission, we will retain your personal data for 5 years after the final grant payment . Regarding the Newsletter subscription, your personal data will be stored for as long as you have subscribed to the newsletter. After you unsubscribe from the newsletter, this data will be deleted. Further storage can take place in individual cases if this is required by law. Other than this we will store your personal data for no longer than is necessary for the purposes of legitimate interests as the circumstances request.
For further information on how long we will store your personal data in any particular case, please do not hesitate to contact us using the details below.
PROCESSING YOUR DATA FOR OUR LEGITIMATE INTERESTS
In some cases we will process and share your personal data for our legitimate interests, according to art. 6(1) lit. f GDPR, rather than seeking your consent.
Under the following circumstances we are not obliged to request your consent before sharing your personal data:
It is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of this Privacy Statement, or as otherwise required by law.
We transfer information about you if UWK is acquired by or merged with another organisation who then will become the owner of the personal data collected from you. In this event, we will notify you before your information is transferred and becomes subject to a different Privacy Policy. You will have the option to opt out of this agreement at any time by contacting MIrreM at the bellow mentioned email address
For any other legitimate interest cases, we always provide you with information on our data processing activities upon request.
You have the right to object to this processing at any time for reasons that arise from your particular situation. This personal data will then no longer be processed for this purpose, unless compelling grounds for the processing worthy of protection can be demonstrated which overrides your interests, rights and freedoms or the processing serves to establish, exercise or defend legal claims.
LINKS TO THIRD-PARTY WEBSITES
Our website may contain links to other websites of interest or sister projects. If you activate these links, you will be forwarded from our website directly to the website of the other provider. You can recognize this among other things by the change in the URL. However, once you have used these links to leave our website, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and such websites are not governed by this Privacy Statement.
Your rights
ACCESS
ou may contact us at any time in order to request access to the personal data we hold about you. We will confirm whether we are processing your personal data, provide details of the categories of personal data concerned, the reasons for our processing and how your data is processed. We will also provide you with a copy of your personal information.
RESTRICTION
In certain circumstances, it may be possible to require us to limit the way in which we process your personal data (i.e. require us to continue to store your personal data, but not otherwise process it without your consent). Such circumstances include:
- where you think the data we hold about you is inaccurate, processing can be restricted while it is being rectified;
- where you object to our processing, (which is being carried out on the grounds that it is necessary for our legitimate interests) processing can be restricted while we determine whether such grounds override your interests;
- where processing is unlawful but you oppose the erasure and request restriction of your data instead;
- where we no longer need the personal data but you require the data in order to establish, exercise or defend a legal claim, our processing can be restricted.
REMOVAL OF YOUR DATA / WITHDRAWAL OF YOUR CONSENT
You may ask to have your personal data deleted or removed. We will do so within the time frame specified in this Privacy Policy, and to the extent possible, we will inform anyone who has received your personal data.
You can request the immediate correction of incorrect or the completion of your personal data stored by us.
You may withdraw your consent at any time, by unsubscribing from the information you receive or by using the contact details below.
You will always have the option to unsubscribe from receiving information or to request to be deleted from our database which we will do accordingly.
However, we must keep track of certain transaction information, such as past event registrations and similar information, for legal compliance purposes of our funders and accountants, so we may not be able to fully delete your information in certain circumstances.
COMPLAINTS
f you are located in the EEA and you believe that our processing of your personal data is in breach of data protection law, you have the right to lodge a complaint with the relevant data protection supervisory authority in the country where you are based or any place in the EEA where you believe the infringement has occurred. You may also contact us at any time if you wish to complain about our processing of your personal data.
For any of the requests listed above, please use the contact details below. We will make reasonable efforts to respond promptly and at the latest within one (1) month. Our response to such requests may be limited to information under our direct control.
Security
SECURITY MEASURES
We limit access to personal data collected about you to via the MIrreM stakeholder registration form to the MIrreM Consortium and the coordinators of projects funded under Horizon Europe Calls A sustainable future for Europe. Full, personalized data collected through the surveys will only be accessible to UWK as the coordinating institution, but anonymized files of surveys linked to the stakeholder database will be shared with the MIrreM consortium. Events related data will remain with the respective organizing entity.
We have security measures in place to help protect against the loss, misuse and alteration of the information under our control. While we cannot guarantee that loss, misuse or alteration to data will not occur, we ensure that our systems adhere to market security standards so as to help safeguard against such occurrences. In case you have any questions about these measures, please use the contact details provided below.
CHILDREN’S PRIVACY PROTECTION
MIrreM does not target and its website is not intended for children under the age of 16. MIrreM will not knowingly collect personal data from children and will delete such data upon discovery.
Opting out process
If you do not wish to receive certain communications from us you may opt out by:
- following the opt out instructions that we include in each of our communications with you or
- informing us at mirrem@donau-uni.ac.atthat you no longer wish to receive such communications.
We will comply with your requests unless such communications from us are required by law or do not require your consent under applicable laws.
Your opting out may restrict our ability to provide you with the full extent of our services.
Contact details
The Data Protection Officers (“DPO”) responsible for data protection on behalf of UWK are RA Dr. Daniel Stanonik LL.M. and Dr. Karsten Kinast LL.M., representing the law firm KINAST Rechtsanwaltsgesellschaft mbH. If you have any questions regarding how we process your data, please don’t hesitate to contact the DPO at:
+43 2732 893-5506
If you would like to get in touch with us with regards to rectification and withdrawal of your personal data, please contact UWK at:
Dr.-Karl-Dorrek-Straße 30
3500 Krems an der Donau
Changes in this privacy statement
MIrreM reserves the right to update and change the terms of the Privacy Statement from anytime without notice. Continued use of www.irregularmigration.eu after any such changes shall constitute your consent to such changes. We encourage you to frequently review the Policy Statement. For your review changes of this Privacy Statement will be protocolled in a version history.
Copyright
The content of www.irregularmigration.eu is the property of MIrreM Consortium. Any form of reproduction is prohibited without the express consent of the owner.