Politika zasebnosti spletnega mesta SWAN

1. Who we are

SWAN is an Erasmus+ Sport project (Project ID: 101185590) coordinated by the ITTF Foundation and project partners.

For the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the ITTF Foundation is the data controller for personal data collected and processed through the SWAN website, unless otherwise stated in a specific notice.

Data Controller:
ITTF Foundation
Richard-Wagner-Straße 10
04109 Leipzig
Germany

Email: SWAN@foundation.ittf.com
Website: https://swan-erasmus.eu

The ITTF Foundation is a not-for-profit foundation established under German law.

For questions concerning the processing of personal data through the SWAN website, you may contact us at SWAN@foundation.ittf.com.

2. What personal data do we collect?

Depending on how you interact with our website, we may collect:

• your name;
• email address;
• organisation and/or professional role, where provided; and
• other information that you voluntarily provide to us.

We do not intentionally collect sensitive personal data through the website unless this is specifically required and an appropriate legal basis exists.

3. How do we collect your personal data?

We collect personal data when you:

• contact us directly by email; or
• otherwise voluntarily provide information to us.

We do not currently use Google Analytics, Matomo or similar analytics services on this website.

We do not currently use advertising trackers or behavioural profiling technologies.

4. Why do we use your personal data?

We may use your personal data to:

• respond to your email enquiries;
• communicate with you about SWAN activities, programmes and developments;
• send newsletters where you have requested or consented to receive them;
• manage and maintain our website and communications;
• meet our legal, regulatory and contractual obligations;
• protect the security and integrity of our website and systems; and
• establish, exercise or defend legal claims where necessary.

We will only process your personal data where we have a lawful basis for doing so under the GDPR.

5. Legal basis for processing

Depending on the circumstances, the ITTF Foundation may rely on one or more of the following legal bases under Article 6 GDPR:

Consent
Where you subscribe to the SWAN newsletter, we will generally rely on your consent to send you communications of this nature. You can withdraw your consent at any time by contacting us or, where available, by using the unsubscribe function included in our communications.

Legitimate interests
Where appropriate, we may process personal data because it is necessary for our legitimate interests, such as responding to enquiries, administering our activities, maintaining the security of our website and communications, or managing our relationship with stakeholders.

Legal obligation
We may process personal data where processing is necessary to comply with a legal obligation to which the ITTF Foundation is subject.

Contract
Where applicable, we may process personal data where this is necessary for the performance of a contract or to take steps at an individual's request before entering into a contract.

6. Who receives your personal data?

Personal data collected through the SWAN website may be accessed by authorised personnel of the ITTF Foundation where necessary for the purposes described in this Privacy Notice.

Where necessary for the implementation and management of the SWAN Erasmus+ project, personal data may also be shared with authorised project partners, including KTG Research & Innovation.

Project partners receiving personal data are required to process that data in accordance with applicable data protection legislation and only for legitimate purposes connected with the SWAN project.

We do not sell your personal data.

7. International transfers

We aim to process personal data within the European Economic Area (EEA).

Where personal data is transferred outside the EEA, we will ensure that an appropriate safeguard recognised under the GDPR is in place, such as an adequacy decision, Standard Contractual Clauses or another lawful transfer mechanism.

8. How long do we keep your personal data?

We retain personal data only for as long as necessary for the purposes for which it was collected and to meet applicable legal, contractual and accountability requirements.

As a general retention period, the ITTF Foundation intends to retain relevant website communications and associated personal data for up to five years, unless a shorter or longer period is required by law or justified by the particular circumstances.

Newsletter subscription information will be retained while you remain subscribed, subject to applicable legal and accountability requirements. Following an unsubscribe request, we may retain limited information necessary to ensure that we respect your request not to receive further communications.

9. How do we protect your personal data?

The ITTF Foundation takes appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

Access to personal data is limited to individuals who require it for legitimate organisational purposes.

However, no transmission or storage system can be guaranteed to be completely secure.

10. Your rights

Under the GDPR, you may have the following rights in relation to your personal data:

• Right of access – request a copy of the personal data we hold about you.
• Right to rectification – ask us to correct inaccurate or incomplete information.
• Right to erasure – in certain circumstances, ask us to delete your personal data.
• Right to restriction – in certain circumstances, ask us to restrict processing.
• Right to data portability – where applicable, request your personal data in a structured, commonly used and machine-readable format.
• Right to object – in certain circumstances, object to our processing of your personal data.
• Right to withdraw consent – where processing is based on consent, withdraw your consent at any time.

To exercise any of these rights, please contact SWAN@foundation.ittf.com.

11. Data Protection Officer

The ITTF Foundation has arrangements in place for data protection oversight in relation to the SWAN project.

For questions concerning data protection, the exercise of your rights, or the processing of your personal data through the SWAN website, please contact:

SWAN@foundation.ittf.com

The organisation remains responsible for ensuring compliance with applicable data protection legislation. The Data Protection Officer provides independent advice and monitoring in accordance with their role under the GDPR.

12. Cookies

The SWAN website does not currently use cookies for analytics, advertising or behavioural tracking.

Where technically necessary cookies are used to operate or secure the website, these may be used without consent where permitted by applicable law.

If our use of cookies changes, this Privacy Notice and, where necessary, our cookie information will be updated accordingly.

13. Third-party websites

The SWAN website may contain links to websites operated by third parties.

The ITTF Foundation is not responsible for the privacy practices or content of third-party websites. We recommend reviewing the privacy notice of any third-party website you visit.

14. Automated decision-making and profiling

The ITTF Foundation does not use personal data collected through this website for automated decision-making that produces legal or similarly significant effects.

We do not carry out behavioural profiling of website visitors.

15. Complaints

If you have concerns about how the ITTF Foundation processes your personal data, we encourage you to contact us first at SWAN@foundation.ittf.com.

You also have the right to lodge a complaint with the competent data protection supervisory authority in the EU Member State where you normally live, work, or where you believe an infringement has occurred.

16. Changes to this Privacy Notice

We may update this Privacy Notice from time to time to reflect changes to our activities, technology, legal requirements or data processing practices.

The latest version will always be published on the SWAN website.