Privacy
Policy
Privacy Notice
AEROFUSE Programme - Registration and Participation in Training Activities and Aerospace Learning Hubs
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This Privacy Notice explains how IMH Campus processes your personal data in connection with your registration for, and participation in, training activities and Aerospace Learning Hubs organised within the AEROFUSE - An alliance for the Future of the Aeronautics and Upstream segment Skills Evolution project.
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This notice is provided in accordance with Article 13 of Regulation (EU) 2016/679, the General Data Protection Regulation.
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1. Controller
The controller responsible for the processing of your personal data is:
Fundación para la Formación Técnica en Máquina Herramienta (IMH Campus) Azkue Auzoa, 1, 20870, Elgoibar (Guipúzcoa) - Spain imh@imh.eus (+34) 943 744 132
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2. Data Protection Officer or privacy contact
You may contact the Data Protection Officer
or privacy contact of the controller through:
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3. Personal data processed
For registration, participation and management of the activities, we may process the following personal data:
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a) full name;
b) date of birth;
c) email address;
d) nationality;
e) academic background;
f) current occupation or job title;
g) information relating to your registration, attendance, participation, completion of activities and, where applicable, certificates or other participation records;
h) communications exchanged with you in connection with the activity; i) photographs, video recordings or audio-visual materials where image or sound capture takes place during online or in-person activities.
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We do not intend to collect special categories of personal data through the registration form.
Certain additional information may be collected separately and anonymously for project monitoring indicators, including information related to gender, disability, health-related issues or barriers faced by participants. This information is collected only in anonymous form and is not intended to identify you.
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4. Purposes and legal bases
Your personal data will be processed for the following purposes:
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a) Registration and management of participation
Your data are processed to register you for the relevant training activity or Aerospace Learning Hub, manage attendance, communicate practical information, provide access to the activity or platform, and ensure the proper organisation and execution of the AEROFUSE programme.
The legal basis is the controller’s legitimate interest in organising, managing and delivering the AEROFUSE programme and its activities, pursuant to Article 6(1)(f) of the General Data Protection Regulation.
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b) Communication with participants
Your contact details may be used to send you information related to the activity, including confirmations, reminders, logistical information, access instructions, updates and follow-up communications directly related to your participation.
The legal basis is the controller’s legitimate interest in ensuring adequate communication with participants, pursuant to Article 6(1)(f) of the General Data Protection Regulation.
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c) Project management, reporting, audit and accountability
Your data may be processed to document the implementation of the AEROFUSE project, demonstrate participation, comply with project management and reporting requirements, and respond to audits, checks or requests from competent bodies, including the European Commission, the European Education and Culture Executive Agency or other entities legally authorised to verify the implementation of the project.
The legal basis is the controller’s legitimate interest in managing and documenting the implementation of the project, pursuant to Article 6(1)(f) of the General Data Protection Regulation. Where the controller is subject to a specific legal obligation to retain or disclose certain information, the legal basis will be compliance with a legal obligation, pursuant to Article 6(1)(c) of the General Data Protection Regulation.
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d) Dissemination of the project, including photographs and videos
Photographs, videos, screenshots or other audio-visual materials may be captured during online or in-person activities for the purpose of documenting and disseminating the AEROFUSE project, its activities and results.
The legal basis for this processing is the controller’s legitimate interest in documenting, communicating and disseminating the AEROFUSE project and its publicly funded activities, pursuant to Article 6(1)(f) of the General Data Protection Regulation.
These materials may be published on institutional websites, the project website, newsletters, reports, social media pages and other official communication channels of the controller or of the AEROFUSE consortium.
The controller will seek to ensure that the capture and use of photographs and videos is proportionate, limited to the purposes described above and respectful of participants’ rights, freedoms and reasonable expectations. Where feasible, participants may inform the organising team if they do not wish to appear in identifiable photographs or videos.
Where the intended use involves interviews, testimonials, close-up images, individual promotional materials or other materials focused specifically on an identifiable participant, the controller may request separate consent before using those materials.
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5. Recipients of personal data
Your personal data may be shared with:
a) other AEROFUSE consortium partners, where access is necessary to organise, manage, execute, monitor or report on the programme and its activities;
b) service providers supporting the organisation of the activities, including providers of IT, registration, communication, learning management, hosting or collaboration tools;
c) the European Commission, the European Education and Culture Executive Agency, auditors or other competent bodies, where necessary for project reporting, audit, monitoring or legal compliance;
d) social media platforms, website providers, communication channels or the general public, where photographs, videos or other dissemination materials are published in accordance with this notice and, where required, on the basis of your consent.
Access by consortium partners must be limited to what is necessary for the organisation, execution, coordination, monitoring and reporting of the AEROFUSE
programme. Those partners may process the data only for the purposes described in this notice or for purposes that are compatible with them.
6. International transfers
As a rule, personal data will be processed within the European Economic Area.
However, some IT providers, online platforms, social media platforms or website services used for the purposes described in this notice may involve the processing of personal data in, or access to personal data from, countries outside the European Economic Area.
Where such transfers occur under the controller’s responsibility, they will be carried out in accordance with Chapter V of the General Data Protection Regulation, including, where applicable, on the basis of an adequacy decision adopted by the European Commission, standard contractual clauses approved by the European Commission, or other appropriate safeguards provided for by the General Data Protection Regulation.
7. Retention periods
Personal data processed for registration, participation and activity management will be retained for the period necessary to organise, deliver and close the relevant activity.
Personal data necessary for project documentation, reporting, audit, accountability or legal compliance may be retained until the end of the applicable project, audit, limitation or statutory retention periods.
Photographs, videos and dissemination materials may be retained for as long as necessary for project dissemination, institutional communication, accountability and archival purposes, unless your rights override the controller’s grounds for continued processing or you object to the processing of said personal data.
Anonymous KPI information is not retained as personal data, provided it remains genuinely anonymous and cannot reasonably be linked to an identifiable person.
8. Whether providing data is mandatory
The personal data requested in the registration form are necessary for registration and participation in the relevant activity. If you do not provide the required data, it may not be possible to register you, provide access to the activity, communicate with you or issue participation records.
Participation in photographs, videos, testimonials or promotional materials based on consent is voluntary. Refusing or withdrawing consent will not affect your ability to participate in the activity.
9. Your rights
Under the conditions set out in the General Data Protection Regulation, you have the right to:
a) Right of access — to obtain confirmation as to whether your personal data are being processed and to access those data and related information;
b) Right to rectification — to request the correction of inaccurate personal data or the completion of incomplete personal data;
c) Right to erasure — to request the deletion of your personal data, where the legal requirements for erasure are met;
d) Right to restriction of processing — to request that the processing of your personal data be restricted in certain circumstances;
e) Right to object — to object, on grounds relating to your particular situation, to processing based on the controller’s legitimate interests, including the processing of photographs, videos or other audio-visual materials where the legal basis is Article 6(1)(f) of the General Data Protection Regulation;
f) Right to data portability — to receive the personal data you have provided to the controller in a structured, commonly used and machine-readable format, and to transmit those data to another controller, where the legal requirements for portability are met;
g) Right to withdraw consent — where processing is based on consent, to withdraw that consent at any time, without affecting the lawfulness of processing carried out before withdrawal;
h) Right to lodge a complaint — to lodge a complaint with a competent supervisory authority.
In Spain, the competent supervisory authority is the Spanish Data Protection Agency (Agencia Española de Protección de Datos — AEPD). Further information is available on the AEPD website: www.aepd.es.”
10. Automated decision-making
Your personal data will not be used for automated decision-making, including profiling, producing legal effects concerning you or similarly significantly affecting you.
11. Contact
For any questions regarding this Privacy Notice or the processing of your personal data, please contact: