Privacy statement

1. Introduction

Welcome to FoodCoP Platform ((“our”, “us” and “we”). FoodCoP project has received funding from the European Research and Executive Agency (REA) under the European Union’s Horizon Europe research and innovation programme under grant agreement No 101182001. The “Platform” has been conceived as a central repository and main online meeting point Startup Villages around Europe, bringing together relevant group of stakeholders and integrating on one single access point, high quality services aiming to unlock the innovation potential of rural economies. FoodCoP platform aims to seek synergies and complement the knowledge and cooperation activities of the European Startup Village Forum, cooperating with “Rural networks”.

This Privacy Policy applies to all users of FoodCoP platform, except for persons working at FoodCoP project.

We will refer to you as “you” and “your”.

We value your privacy and the security of your data and we want to be transparent about the collection, use and sharing of information about you. This Privacy Policy is for your use of the services we make available (“Services”) and our platform (https://www.platform-foodcop.eu). It also applies to your interaction with us through other means such as customer service, discussing or contracting one of our professional services, direct conversations and events.

This Privacy Policy is part of our group of Policies as set out in our Terms of Service which provides information that is likely to be useful to complement this Privacy Policy. Please do not access or use the Services or FoodCoP platform if you do not agree with the terms of this Privacy Policy or any of the other Policies.

We have produced this Privacy Policy to communicate and explain how we process personally identifiable information that we collect about you when you use the Services and interact with us such as:

• how we collect information about you;
• how we use information we collect;
• how we control your information;
• how we store and secure your information;
• how your information is shared;
• how we transfer your information to other countries; and
• additional information we think might be useful to you.

You have choices about the use of personally identifiable information which we hold about you. You can access, update and request the removal of the information we hold about you.

Personal data means any data containing information about persons through which those persons are identifiable.

This Privacy Statement applies to:

• Users of FoodCoP platform
• Recipients of newsletters from FoodCoP Platform
• Registered attendees of the events and webinars organized by FoodCoP consortium
• Potential users of the FoodCoP Platform that established contact with FoodCoP consortium
• Any potential collaborators with whom FoodCoP consortium have made or want to make contact
• Any other person who contacts FoodCoP consortium or whose personal data is processed by FoodCoP partners.

2. Data Controller

FoodCoP Platform – ENCO srl, via Michelangelo Schipa – 115 80122 Napoli (ITALY)

Email: info@platform-foodcop.eu Phone: +39 0817611727

3. Data Protection Officer

We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below:

Dr. Marco de la Feld Email: m.delafeld@enco-consulting.it; info@platform-foodcop.eu Phone: +39 0817611727

4. Information We Collect and Process

We collect information to provide the Services. In order for us to provide the Services to you, we need to collect and use personally identifiable information as described in this Privacy Policy and the Cookie Policy. We may collect, process, store, organise, record, retrieve, use, consult, forward the following data about you:

• Personal Identification Information: contact details, e.g. name, email address, phone number, etc… entered on contact forms, other web forms/sources, registration to FoodCoP events.
• Contact information provided during calls related to FoodCoP project.

• Audio/video recorded during online and in person events.
• Technical Data: IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Platform.
• Usage Data: Information about how you use our Platform, products, and services.
• Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.

The collection and processing of personal data by us is necessary to enable the relationship we have with you, and when that isn’t the case we have a legitimate interest in collecting the information. We collect information about you when you provide it to us through use of the Services as well when it is provided by another source – we talk more about this below. For the purposes of the applicable data legislation, we are the ‘data controller’ in respect of your personal data. In general, we are responsible for the Policies and the handling of your personal data.

Information you give us. This includes personally identifiable information that you provide to us when you use the Service by directly inputting it.

Here are some examples where you may give us personally identifiable information:

Account and Profile Information – This includes the name, email address and password you provided at the time of registering for the Service. It also includes information you input into your profile, any messages you send or receive, any information you provide to us by other means such as e-mail or forms, as well as any data you provide while using the Service;

Information you give us when you receive professional services from us – We collect not confidential  information from you regarding you and your business.

Information you give us through the Service – You can post, send, access and share information through our Services. For example, you can make a post to a discussion board, send a message asking, send a message to other user(s), reply to a message you receive in your e-mail, write to our connect with an opportunity, provide us with feedback or upload a file;

Information you give when you are asking for support or we are providing it – You may choose to give us information about a problem you are having, or ask us how to use the Service and in doing so you may provide us with information by e-mail.

Information we get automatically when you use the Services. This is personally identifiable information we receive and that is collected by automated systems involved in delivering the Services or when you take specific actions while using the Services.

Cookies – We and third parties use cookies and other tracking methods to deliver you the Service. Please see our Cookie Policy and for more information, and for links that can show you how to control the use of cookies and tracking methods;

Logs and Analysis – We log data about your use of the Service and your response to any communications from us by email or by means of the Platform in order to provide you with the Services, identify issues and understand usage. We do this by means of technology solutions that we have built ourselves and through technologies provided by third parties;

Additionally, some services offer you the choice of what personal data is provided to us and we encourage you to carefully select the information you want to share if that option is available. We also use third party services that help us to provide services like identifying and alerting you if you have duplicate accounts;

Scouting – We may collect information directly from you, use public record sources or create editorial content about you or your start-up/village in order to identify opportunities for you; your start-up; your village. For example, we may engage with you verbally, by e-mail or use other sources to get this information.

Information we get from other partners – We get information about you from third-party partners including those carrying out market research, advertising and lead generation services and who provide us with information about your potential to use our Service and your engagement with us. For example, a third-party may provide us with information because they think you may be interested in one of our professional services that we may use to contact you.

We process personal data that you have provided to us, personal data generated during your visit to the FoodCoP Platform and reading newsletters from FoodCoP project, and personal data that we have derived from other sources, such as social media platforms, business cards, emails.

5. How We Collect Your Data

We use different methods to collect data from and about you including through:

• Direct Interactions: You may provide us with your personal data by filling in forms or by corresponding with us by post, phone, email, or otherwise.
• Automated Technologies or Interactions: As you interact with our Platform, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. Please see our Cookie Policy [https://www.platform-foodcop.eu/platform/cookie-policy] for further details.

6. How We Use Your Data

We only use your personal data when the law allows us to. Most commonly, we use your personal data in the following circumstances:

• To provide and personalise the Services – We use information about you to provide you with the Services. This includes logging you in, authenticating you when you login, operating the Services, responding to your use of the Services, maintaining the Services in line with your requests and providing support to you. As examples: your name and profile picture is used to identify you when you connect with or contact other users of the Service; we use your personally identifiable information to personalise the Services, such as identifying jobs that match with your skills, location, availability and interests; we provide your name, affiliation, e-mail address and other information to other users when you get a benefit from them such as hosting, e-mail infrastructure or travel.
• Deliver FoodCoP services through our partners upon your request, and provide and maintain the FoodCoP Platform services, including monitoring your usage.
• Manage your account and respond to your requests when you register as a user on the FoodCoP Platform. The personal data you supply allows you to access various platform features and services available exclusively to registered users and helps us process your requests effectively.
• Support outreach campaigns by promoting FoodCoP project events, webinars, and other activities, including sharing news, special offers, and general information regarding goods, services, and activities available through the FoodCoP Platform.
• Send you informational communications, such as the FoodCoP project newsletter. You can receive the FoodCoP newsletter in three ways: (1) by subscribing through the sign-up form on the project website; (2) by registering as a user on the FoodCoP Platform, after which you will automatically be added to our mailing list; and/or (3) by registering for a FoodCoP project event, which also automatically adds you to our mailing list. You can unsubscribe at any time. As described in more detail below, we send newsletters via Mailchimp, a third-party service provider, with whom we only share your first name, last name, employer, and email address.

• Send you mailings related to the FoodCoP Platform if you have registered and are using the platform. These mailings include, but are not limited to, confirmations, notifications, updates, and general communications about the platform’s functionalities, services, or your personal account. These messages are essential for managing certain processes, troubleshooting account problems, resolving technical issues, and providing customer support. Additionally, optional mailings, such as polls or surveys aimed at improving our services, may be sent. You can adjust your mailing preferences at any time through your account settings.
• Improve overall service quality, marketing initiatives, and your user experience on the FoodCoP Platform by analyzing anonymized data to identify usage patterns and measure the effectiveness of our processes and campaigns.

7. Processors
   We may engage service providers (processors) to process your personal data on our behalf. These processors only handle personal data according to our instructions. We enter into data processing agreements with these processors, ensuring compliance with the requirements of the General Data Protection Regulation (GDPR).

For instance, we collaborate with service providers offering Software as a Service (SaaS) solutions or providing hosting services. Additionally, we rely on ICT service providers to support the security and stability of our systems. We also use third-party services to manage the distribution of newsletters and commercial emails. These service providers may be considered (sub)processors under the General Data Protection Regulation (GDPR).

8. Sharing Your Data

We provide a Service that is a community where users share and collaborate together. This means that information is shared throughout the Services and with third-parties. Our business is not to sell personally identifiable information, rather our goal is to offer you the best collaborative community possible.

In some circumstances, we may share your personal data with third parties. Your data could be shared with FoodCoP partners for some of the activities of the project, such as but not limited to connecting stakeholders, inviting you to events/webinar, etc…

Furthermore, your data could be shared with external Service Providers: External third parties who provide IT and system administration services.

• Professional Advisers: Including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
• Regulatory Authorities: regulators, and other authorities who obliges us to provide your personal data in certain circumstances.

Your personal data will not be shared with third parties for commercial purposes. We never sell your personal data to third parties, nor do we use automated decision-making processes that could significantly affect you.

9. Sharing and Collaborating with other users in the Services’ community

When you connect with other users of the Platform – You connect with other users of the Services by a variety of means. When you connect with another Service user, you give them permission to see, share, edit, copy and download information you add to the Services. Examples of connections include sending a message to another user, starting a discussion on FoodCoP Platform Forum, following another Service user, completing a survey, attending an event. Some community and collaboration features of the Services show all or some of your profile information when you share or interact with content or other users through the Services. You can provide information that is freely visible to other users, such as the information on your personal profile.

Survey Registration Pages – You may be asked to complete a registration or survey. For example, if you choose to complete the registration for an event that you are attending you can provide information on your Entity which will result in your information being shared with the Service user that corresponds to the registration.

10. Legal basis of our processing of your personal data

We will only collect and process your personally identifiable information where we have a valid legal basis for doing so. The legal basis for processing your personally identifiable information depends on the Services you use and how you use them.

In general, we collect and use your personally identifiable information where:

• We have a legitimate interest. This is applicable when the interest is not overridden by your data protection interests.
• We need to do so in order to deliver you the Services.
• You give us your consent to collect and use your personally identifiable information; or we need to process your personally identifiable information to be in compliance with our legal obligations.

As set out above, in some cases, the legal basis for the processing of your personal data is your consent. This is the case, for example, if you agree to us emailing you with relevant information. In other cases, the processing will be necessary for the purposes of our providing you with the Services as referred to in this Privacy Policy and the other Policies. An example of processing personal data in accordance with our legitimate interest is protecting our legal rights, engaging in research and development or offering products and services of value to you, other users of the Services and our business partners. As mentioned above, processing of personal data by us based on our legitimate interests will only take place provided that those interests do not outweigh your rights and interests.

You have the right to withdraw your consent to use your personally identifiable information for a specific purpose at any time. Removing your consent will not change any processing that has already occurred. If you do withdraw your consent, and if we do not have another legal basis for processing your personally identifiable information, then we will stop processing your personal data. If we do have another legal basis for processing your personally identifiable information, then we may continue to do so subject to your legal rights. If we are processing your personally identifiable information because we or a third-party have a legitimate interest you have the right to remove consent, but this may mean that it is no longer possible for you to use the Services.

11. Access and Control of your Information

You have rights with respect to your personally identifiable information. We have compiled a list of choices below that you may make with additional information on how to make them happen.

You have the right to:

request access to personally identifiable information we hold about you;

deactivate your account;

update your personally identifiable information;

stop receiving communications from us; and ask us to provide you with a copy of personally identifiable information we hold about you in a structured, electronic format.

You can accomplish most of these directly using the tools we provide to you as part of the Service. If you are unable to do so using the tools we provide, please contact our support through the help section of our website, or e-mail us at info@ platform-foodcop.eu. Depending on the choices you make, it may not be possible for us to continue to provide you with the Services after we implement your choices. This may result in us closing your account or your use of the Services being limited or not possible.

Your rights are subject to any exemptions provided by law and we rely on our legitimate interests to process your information. Our response to your requests may be limited in some cases, such as when providing your requested information would reveal another person’s personal information or if you ask us to delete information we are permitted to retain by law or have a compelling legitimate interest to retain. You may also need to contact third-parties directly that you have asked us to share information with to have your information deleted.

We may also process information that contains your personally identifiable information for marketing purposes, and you also have a right to object to our use of this information for that purpose.

12. Questions and potential complaints.

Under applicable law, each individual has certain rights regarding their personal data. You have the right to access, correct, or delete your personal data. Additionally, you may object to or request restrictions on the processing of your data. In some cases, you can request to receive your data to transfer it to another organization. For any inquiries or to exercise these rights, please contact us. If you have any concerns about how we handle your personal data, please reach out via email. We will gladly assist you in finding a suitable solution within four weeks of receiving your request. Subject to applicable law, you have the rights above as well as the right to take any unresolved concerns to a data protection authority.

13. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

14. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Data Retention – We apply data retention policies in line with the type of personally identifiable information retained. We retain personally identifiable information for no longer than is required for our legitimate processing purposes. After a data retention period has expired, we either delete or anonymise your personally identifiable information. The retention policies we apply to different types of personally identifiable information are:

• Your Account Information – This personally identifiable information is retained as long as your account is active and you have not requested its deletion, and nor has it been deleted under the Policies. We may keep some of your personally identifiable information to the extent needed to be in compliance with our legal obligations, to resolve disputes and enforce any agreements we have with you.
• Information you have shared on the Services – We retain personally identifiable information from deleted and deactivated accounts as required to allow other users of the Services to continue to make use of the Services. For example, (i) your name will continue to appear on any messages you have sent to other users of the Services after account deletion and any posts you have made will continue to appear, or (ii) where your name or other personally identifiable information has been added to the Service by you or another user other than in association with your account (such as where your name has been added, with authority, as the founder of a startup and such record is not specifically linked to your account). You acknowledge and confirm that this may result in certain personally identifiable information remaining on the Service in these circumstances.

Apart from what we’ve described above, we’ll archive and stop processing any personally identifiable information about you in accordance with our data retention policy when you delete your account (and we’ll continue to act in line with the other parts of the Policies) or when it’s no longer necessary or required for us to process your personal information to provide our Services, whichever comes first. The decision about what’s necessary or required to provide our Services depends upon factors such as actions you take, the type of data held by us, archive provisions, legal and regulatory requirements for data retention and the data required for our operations. By way of examples, we will delete back-ups containing your personal identifiable information within one year of first storage and web logs are deleted within six months. As another example, if we are providing you with professional services the period of data retention can be up to ten years from your last use of the Services due to legal and other regulatory requirements.

15. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at [Contact Email].

16. Transfer outside EEA (European Economic Area)

We do not transfer your personal data outside the European Economic Area (EEA) unless it is necessary for the execution of project activities. If personal data is transferred to parties outside the EEA, those parties will ensure that an adequate level of protection for personal data is provided, in compliance with applicable data protection laws.

17. More about using our Service

Giving us information about other people – You confirm that you have the right to authorise us to process information you give us about other people on your behalf in accordance with this Privacy Policy.

Sensitive Data – We will not collect any “Special Category Data” about you except where you provide it to us, or where it is necessary to do so to comply with the law. For these purposes that means data regarding your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning your sex life or sexual orientation and offences or alleged offences committed by you.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes.

19. Contact Us

If you have any questions about this Privacy Policy, please contact us:

Email: m.delafeld@enco-consulting.it; info@platform-foodcop.eu