1. Definitions
For the purposes of the General Notice on Processing of Personal Data, the terms stated below will have the following meaning:
Agency
means Agency for Mobility and EU Programmes (Agencija za mobilnost i programe Europske unije) Frankopanska 26, Zagreb, Croatian PIN (“OIB): 25385906011;
CLUE Tool Privacy Policy
means this Privacy Policy for CLUE- InCLUsive Erasmus+ tool
CLUE Tool
means a web-based tool designed for schools within the fields of school education (SCH) and vocational education and training (VET) seeking to strengthen their inclusive pedagogical practices through Erasmus+ projects, available at saltoinclusion.eu.
the Union institutions and bodies
means the Union institutions, bodies, offices and agencies set up by, or on the basis of, the TEU, the TFEU or the Euratom Treaty;
Data subject
means a person whose personal data is processed, and whose identity identified or identifiable; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
General Notice on Processing of Personal Data
means the General Notice on Processing of Personal Data dated April 2024, available at https://en.ampeu.hr/files/Notice-on-Processing-of-Personal-Data.pdf
General Regulation
means regulation (EU) 2016/679 of the European Parliament and of the council of 27 April 2016 on the protection of natural persons regarding the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation);
personal data
means any information relating to a data subject, on the basis of which it is possible to directly or indirectly identify an individual;
Regulation 2018/1725
means Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons regarding the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC;
2. Introduction
2.1
This is the CLUE Tool Privacy Policy issued by the Agency and which contains information on processing of personal data of the data subjects in cases in which the Agency has the position of a controller of their personal data, in the context of use of the CLUE Tool.
2.2
The CLUE Tool Privacy Policy in considered as an additional notice on the processing of personal data referred to in Article 2.4 of the General Notice on Processing of Personal Data.
2.3
The General Notice on the Processing of Personal Data also applies to the processing of personal data when using the TCB tool, unless otherwise specified in this Privacy Policy.
3. Agency contact information
3.1
Data subjects may contact the Agency regarding their personal data through the Data Protection Officer whose contact information is listed in the heading of this CLUE Tool Privacy Policy.
4. Users of CLUE Tool
4.1
The Agency is processing personal data of persons using the CLUE Tool only if the entered email address can be considered as personal data due to information contained therein. If you entered a generic email address (e.g. info@XYZ.org), CLUE Tool does not process your personal data.
4.1.1 Data processed by CLUE Tool
email address
country
sector
role in your organization.
4.2
The Agency is processing personal data of the data subjects concerned for the following purposes:
4.2.1 To provide CLUES – recommendations designed to help improve implementation of the Erasmus+ programme, by sending results and recommendations to the email address you entered. In this case, legal basis for the processing of personal data is performance of the contract, i.e. terms of use of the CLUE Tool and providing the requested CLUES – recommendations.
4.2.2 For the purpose of evaluating the efficiency and success of the CLUE Tool. For that purpose, we may send you a follow-up email asking your feedback on the CLUE Tool. In this case, legal basis for the processing of personal data is the legitimate interest of the Agency as a National Agency hosting the SALTO resource center.
4.2.3 For the purpose of fulfilment of the rights of data subject (g. when data subject requests to exercise the rights regarding their personal data). In this case, legal basis for the processing of personal data is compliance with the legal obligations to which the Agency as a controller of data subject personal data is subject;
4.2.4 For the purposes of fulfilment other legal obligations to which the Agency is subject (g. keeping data on activities conducted as national organizer or a coordinator, or a public entity subject to archiving regulations). In this case, legal basis for the processing of personal data is compliance with the legal obligations to which the Agency is subject.
5. Rights of the data subject and other relevant information
5.1
All information related to exercising rights under the General Regulation and all other information which we have to provide you under the General Regulation is available in General Notice on Processing of Personal Data, especially Articles 12 – 17 thereof.