Privacy Policy

Introduction

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At Europeanfunds.info (“we”, “us” “our” or “Europeanfunds.info”), we are committed to protecting and preserving the privacy of our visitors when visiting our site or communicating electronically with us and protecting your personal data. This Privacy Policy (the “Policy”) sets out the basis on which your personal data is processed by us, informing you about how Europeanfunds.info uses and protects your personal data. This extends to the use and viewing of our website (regardless of where you visit it from).It is intended to inform you about (i) our obligations in regard to processing your personal data responsibly, (ii) your data protection rights as a data subject and (iii) how the law protects you, and what happens to the personal data that you choose to provide to us, or that we collect from you whilst you visit this site. Our Privacy Policy should be read in conjunction with our Terms and Conditions of website use.

We process your data in an appropriate and lawful manner, in accordance with the Data Protection Act (Chapter 586 of the Laws of Malta) (the “Act”) and the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), following its application on 25th May 2018.

Please read this Privacy Policy carefully, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.

We do occasionally update this Policy so please do return and review this Policy from time to time.

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1. Controller of your personal data

Europeanfunds.info is the controller of, and is responsible for, your personal data.

We have appointed a data protection contact point (“DPCP”) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights as a data subject, please contact the DPCP using the details set out below.

You can address any comments, queries or complaints to the DPCP, using the details indicated below, with the words ‘Data Protection Matter’ in the subject line.

 

Contact details

 

Full name of legal entity: ef.info Ltd (c/o Europeanfunds.info)

Email address: contact@europeanfunds.info

You have the right to lodge a complaint at any time to the competent supervisory authority in your jurisdiction on data protection matters. In the case of Malta, this is the Information and Data Protection Commissioner (“IDPC”) (https://idpc.org.mt/en/Pages/Home.aspx). We would, however, appreciate the opportunity to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

 

Third Party Links

This Privacy Policy is limited to this website. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling such connections may allow third parties to collect or share data about you.

These websites should have their own privacy policies which you should check. We have no control whatsoever over such websites and if you use a link to leave the Site and access a third party website you accept and agree that we cannot be responsible for the protection and privacy of any information which you might provide, make available to or is otherwise collected by such third party website. Accordingly you should use caution and carefully examine such third party’s privacy policy.

 

2. The personal data we collect about you

We may collect, use, store and disclose different kinds of personal data about you which we have grouped together as follows:

• Customer Data includes the services you have acquired from us and customer feedback.

• Identity and Contact Data includes first name, maiden name, last name, billing address, address, email address and telephone or mobile numbers.

• Financial Data includes your bank account and credit card details

• Technical Data includes internet protocol (IP) address and log in data

• Usage Data includes information about how you use the Site

• Marketing and Communications Data includes your preferences in receiving marketing from us and our business partners and your communication preferences.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregate may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect Special Categories of Personal Data about you.

Generally we shall collect this personal data about you by means of the following:

 

A. When visiting our website

It is possible to visit our website and view the products displayed on our website without submitting any personal data. In order to provide you with the best experience when browsing our website we may need to process certain data which can identify you and can therefore be considered to be personal data. In this regard we may collect the following information about you whenever you visit our website.

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• Technical data: including the IP address used to connect your computer to the Internet, your login information, browser type and version, the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time) as well as other information regarding your experience on our Website such as page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.

• Location Information: We may receive information about your location. We may determine your location through your IP address and, when accessing the Website through a mobile device, by using the data that we collect from this device. This includes precise location information from GPS or information about the wireless networks or cell towers near your mobile device at the time of access.

Please refer to our Cookie Policy on this page for further information as to how this website may collect certain information about your visit to our website.

 

B.  When communicating with us over phone or email

Whenever you contact us in order to enquire about our events, we shall require certain basic Identity and Contact Data (in particular, your name, surname and email address).

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C. When using any of our services

In order to be able to provide the services which you request, we shall need to process personal data. Generally, this shall include your contact information, such as your name, surname, address, email, telephone number as well as your financial details.

 

We may provide specific privacy notices with our contracts with you or when we request the collection of your personal details which shall list the information which we require as well as other pertinent information relating to how and why we shall process your personal data. These privacy notices should be read in conjunction with this Privacy Policy.

 

The personal data which we request from you shall generally be restricted to the data which is strictly necessary for us to be able to provide the services which you request. In addition, we may also request certain personal data to ensure compliance with our legal obligations.

 

D. Other data

Through our website you may also choose to subscribe to our newsletter. You can unsubscribe to any and all marketing information at any time by emailing us on contact@europeanfunds.info or else choosing the unsubscribe option in any communications sent to you. By subscribing to our newsletter, you shall be included in our mailing list until such time as you choose to unsubscribe to receiving any communications from us. In this regard, we shall process data relating to your preferences in receiving marketing from us to ensure that we adhere to your choices.

 

3. Use of Your Information

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

• Where we need to confirm the booking of an event and/or billing details.

• Where it is necessary for our legitimate interests (or those of a third party, including but not limited to the Malta Further and Higher Education Authority or equivalent authority responsible for the licencing of educational institutions in Malta) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal obligation.

 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the section below.

 

Purpose/Activity: To register you as a new customer

Type of data: Identity and Contact Data  

Lawful basis for processing including basis of legitimate interest: Performance of an agreement with you

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Purpose/Activity: To process  (a) your registration for a course   (b) Manage payments (c) Collect and recover money owed to us

Type of data: (a) Identity (b) Contact (c) Financial (d) Customer (e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest: (a) Performance of an agreement with you (b) Necessary for our legitimate interests (to recover debts due to us)

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Purpose/Activity: To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy and  any changes to our website, including improvements, and service changes that may affect our website.   (b) Asking you to leave a review or provide customer feedback  

Type of data: (a) Identity (b) Contact (c) Marketing and Communications

Lawful basis for processing including basis of legitimate interest: (a) Performance of an agreement with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)  

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Purpose/Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data: (a) Identity (b) Contact (c) Technical  

Lawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation  

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Purpose/Activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical  

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

 

Purpose/Activity: To make suggestions and recommendations to you about services that may be of interest to you  

Type of data: (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications  

Lawful basis for processing including basis of legitimate interest:  Necessary for our legitimate interests (to develop our products/services and grow our business)  

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Purpose/Activity: Sharing of data with the Malta Further and Higher Education Authority (MFHEA).

Type of data: (a) Date of birth (b) Country

Lawful basis for processing including basis of legitimate interest: Necessary for statistical purposes, as part of our licencing obligations as an educational institution registered in Malta. No identity or contact details are shared.

 

Marketing

We may use your Identity and Contact Data, Technical Data as well as your Customer Data to form a view on what we think you may want or need, or what may be of interest to you.

 

If you are an existing customer, we may contact you with information about services similar to those that you have expressed an interest in previously via our website. You will receive marketing communications from us if you have subscribed to our newsletter or engaged us to carry out any services. This is within our legitimate interest to develop our relationship with you and ensure that you receive the best service possible.

 

If you are a new customer, we will only contact you only when you have provided consent and, only by those means you provided consent for.

 

Opting Out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time or emailing us at contact@europeanfunds.info.

 

4. Storage of Your Personal Data

Data that is provided to us is stored on our secure servers. Details relating to any transactions entered into on our site will be encrypted to ensure its safety. We strive to protect the security of any data which you provide to it and which we collect about you, and will update it from time to time in order to ensure that its measures are always up-to-date in accordance with our legal obligations.

 

5. Disclosure of your Information

We may also transfer your personal data to external third parties, namely our service providers which are necessary for us to be able to provide the Services we offer. In particular, we may transfer your personal data to our IT and software support service providers, our insurers and external legal counsel. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

We may also disclose your personal information to third parties:

1. Where we sell any or all of our business and/or our assets to a third party.

2. Where we are legally required to disclose your information.

3. To assist fraud reduction and minimise credit risks.

 

We may also disclose your personal data to regulatory or governmental agencies as well as executive and judicial authorities which may have jurisdiction over our operations. We shall only make such disclosures in accordance with the appropriate authority and to comply with our legal obligations.

 

We may transfer your personal data outside the European Economic Area (EEA) in the following circumstances:

 

a. the transfer is necessary for the performance of a contract between you and Europeanfunds.info or for the implementation of pre-contractual measures taken at your request.

 

b.  the transfer is necessary for the conclusion or performance of an agreement concluded in your interest between us and another natural or legal person;

 

c. the transfer is necessary for important reasons of public interest; or

 

d .the transfer is necessary for the establishment, exercise or defence of legal claims.

 

6. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, 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.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

7. 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.

 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

By law we have to keep basic information about our customers, including contact details and details regarding any contracts which you may have entered into as a result of our Services for 40 years after the conclusion of the contract, taking into account the applicable prescriptive period at law. We may also retain certain personal data to ensure compliance with our legal obligations. In particular, we  may retain certain transactional and financial information for a period not exceeding ten years, in compliance with tax and accounting reporting legal obligations.

 

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Under applicable data protection laws, you are entitled to exercise the following rights:

 

You have the right to:

 

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform an agreement with you.

 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

If you wish to exercise any of the rights set out above, please contact us at contact@europeanfunds.info.  No fee is usually required.

 

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

Google analytics

So as to improve the quality and overall user experience of the Website, we are using Google Analytics Advertising Features, including Google Analytics.

 

If you would like to opt-out of Google Analytics for display advertising, you may do so by using the Ads Preference Manager. In addition, there is also a Google Analytics Opt-Out browser add-on that you can download at https://tools.google.com/dlpage/gaoptout.

 

Variations

We reserve the right to revise and amend this Policy from time to time and any revised version will be deemed to be applicable from the first date of publication on this website. 

 

If there are any changes to this privacy policy, we will replace this page with an updated version. It is therefore in your own interest to check the “Privacy Policy” page any time you access our web site so as to be aware of any changes which may occur from time to time.

 

Contacting Us

If you have any questions or queries relating to this Privacy Policy then please contact us at contact@europeanfunds.info.

 

Any comments or suggestions that you may have and which may contribute to a better quality of service will be welcome and greatly appreciated.

 

IP Address & Cookie Policy

Last Updated: 10/10/2024

1. Introduction

Welcome to Europeanfunds.info IP Address and Cookie Policy.

 

Europeanfunds.info (“we”; “us”; or “our”) collects two types of information about you resulting from your use of our website < https:// https://www.europeanfunds.info/ / > (the “Website” or the “Site”): (i) personal information, including your name and e-mail address and (ii) aggregate information which is generated from the practices that we have in place regarding ‘cookies’ and the Internet Protocol Address (“IP Address”) pertaining to the users of the Website.

 

Our practices regarding the collection and processing of your personal information are set in our Privacy Policy. Correspondingly, the practices which we have in place regarding the generation of aggregate information are described here in our IP and Cookie Policy. In order to be able to access and use the Site, you must expressly agree and consent to the practices set out herein.

 

Please read the following carefully to understand how and why the Site uses your IP Address and cookies. If you do not accept or agree to the practices described in this policy, you must exit the Site immediately.

• IP Address

• What happens when you visit the Site

Every time you connect to the internet or, if you use an always-on connection, such as broadband or ADSL, when you boot up or restart your computer, you are automatically assigned a unique identifying number known as an IP Address. This IP Address, which contains information regarding the location of your computer on the internet (your country of origin) and the name of your internet service provider (“ISP”), is automatically logged by the Site.

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• What is an IP Address?

When you first started your internet session (i.e. your computer connected to the internet), your computer was automatically assigned a unique number (normally in the region of 9 or 10 decimal numbers), known as an IP Address. This is your computer’s unique address on the internet. Without an IP Address, websites would not be able to deliver their content to you given that they would not be able find your computer on the internet. Since each time you disconnect and reconnect to the internet a new IP Address is automatically assigned to your computer, IP Addresses are not inherently capable of identifying you as an individual (at least, by themselves and not combined with other identifiers). An IP Address does, however, contain information regarding the location of your computer on the internet (your country), and the name of your ISP.

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• How do we collect your IP Address

Each time you visit a page on the Site, your computer sends out a message to the Site asking for the content to be delivered. This message sent by your computer also encloses your IP Address as a form of “return address”, so that the Site may find your computer in order to send it the requested content. Our web-server automatically logs all these messages.

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• What do we do with your IP Address?

When we log your IP Address, the data collected is grouped up with the other logged IP Addresses in order to provide us with the statistics on the geographic location of visitors to the Site, how long they stay on the Site, which are the most viewed pages and for other statistical reasons.

 

We gather your IP address automatically and store it in log files. These files also contain information relating to your browser type, ISP, operating system, date/time stamp, clickstream data and the files viewed on the Site. Collecting this type of information allows us to generate aggregate information for the purposes of the Site, including in terms of overall user trends and activities online (such as the number of unique visitors, pages access most frequently or the search terms entered). Furthermore, it also allows us to administer the Site, diagnose any potential server problems, analyse visitor trends and statistics, and generally helps us to provide you with a better internet experience.

 

IP Addresses are not stored for longer than necessary for the above stated purposes.

• Cookies

• Information about our use of Cookies

The Site uses cookies to distinguish you from other users. They allow us to analyse trends and administer the Site, to help us to provide you with a good experience when you browse the Site and to improve it at the same time.

 

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. A cookie enables the website to remember users that have already visited. Without a cookie, every time you open a new web page, the server where that page is stored will treat you like a completely new visitor. Cookies allow us to remember your custom preferences such as your language preference and allow you to complete tasks without having to re-enter your information when browsing.

 

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of the Site. Namely, by way of illustration, they include cookies that enable you to log into secure areas of the Site and make use of its check-out functionality.

• Analytical and Performance cookies. They allow us to recognise and count the number of visitors and see how visitors move around the Site when using it. This helps us to improve the way the Site works, such as by ensuring that users are finding what they are looking for easily.

• Functionality cookies. These are used to recognise you when your return to the Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

• Targeting cookies. These cookies record your visit to the Site, the pages you have visited and the links you have followed. We will use this information to make the Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

• Session cookies. These cookies contain encrypted information to allow our system to uniquely identify you while you are logged in. Session cookies exist only during an online session. They disappear from your computer when you close your browser software. These allow us to process your requests and help us make sure you are who you say you are after you have logged in.

• Third party cookies. These cookies allow the Site to interact with different websites. As explained, the Site uses social media widgets such as {●} to facilitate setting up your account.

 

Please note that third parties (including advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical and performance cookies or targeting cookies.

 

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of the Site.

 

Furthermore, some parts of the Site, or the services that you connect to through it, may not function properly if you choose not to accept cookies.

 

Except for essential cookies, all cookies will expire after a maximum of 2 years.

 

You can control the use of cookies at the individual browser level. If you reject cookies, you may still use the Site, but your ability to use some features or areas of the Site, as well as the services that you connect to through it, may be limited.

 

Many browsers allow you to browse privately, whereby cookies are automatically erased after you visit a site. The following is a list of the most common browsers and the way in which you can activate private browsing:

• Internet Explorer 8 and later versions: In Private

• Safari 2 and later versions: Private Navigation/Browsing

• Firefox 3.5 and later versions: Private Navigation/Browsing

• Google Chrome 10 and later versions: Incognito

Further information on cookies can be found on various sites such as www.allaboutcookies.com

 

The Site includes social media features such as Facebook, Instagram and LinkedIn Widgets. These features may collect your IP address, which pages you are visiting on the Site, and may set a cookie to enable this feature to function properly.

 

Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

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