PROTECTION OF YOUR PERSONAL DATA

PRIVACY POLICY

This privacy statement provides information about the processing and the protection of your personal data.

Processing operation: WeBalkans website

Data Controller: Directorate-General for Enlargement and Eastern Neighbourhood (DG ENEST), ENEST.01 – Strategic Coordination & Communication

Record reference: DPR-EC-05666

TABLE OF CONTENTS

1. Introduction

2. Why and how do we process your personal data?

3. On what legal ground(s) do we process your personal data?

4. Which personal data do we collect and further process?

5. How long do we keep your personal data?

6. How do we protect and safeguard your personal data?

7. Who has access to your personal data and to whom is it disclosed?

8. What are your rights and how can you exercise them?

9. Contact information

10. Where to find more detailed information?

1. Introduction

The European Commission (hereafter ‘the Commission’) is committed to protecting your personal data and to respecting your privacy. The Commission collects and further processes personal data pursuant to   Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data (repealing Regulation (EC) No 45/2001).

This privacy statement explains the reason for the processing of your personal data, the way we collect, handle and ensure protection of all personal data provided, how that information is used and what rights you have in relation to your personal data. It also specifies the contact details of the responsible Data Controller with whom you may exercise your rights, the Data Protection Officer and the European Data Protection Supervisor.

The information in relation to processing operation “WeBalkans website” undertaken by the Directorate-General for Enlargement and Eastern neighbourhood, Unit ENEST 01 Strategic Coordination and Communication, is presented below.

2. WHY AND HOW DO WE PROCESS YOUR PERSONAL DATA?

Purpose of the processing operation: The Directorate-General for Enlargement and Eastern Neighbourhood, Unit ENEST 01 Strategic Coordination and Communication collects and uses your personal information for the purposes of the visibility and promotion of EU-funded projects and programmes in the Western Balkans (Albania, Bosnia and Herzegovina, Montenegro, North Macedonia, Kosovo*, Serbia) – through calls for applications (i.e. Young European Ambassadors contests), invitations and participation to events, and sending of notifications and news alerts about the EU-funded programmes and projects and EU-related opportunities in the Western Balkans region.

Photographs and/or audio-visual recordings of the participants to events may be taken and may be published on DG ENEST and European Commission Intranets, webpages and social media channels for promotion and communication purposes.

All data processing is transparent and abides by the principle of users opting-in/out, and allowing the data they provide to be used for specific purposes.

*This designation is without prejudice to positions on status, and is in line with UNSCR 1244/1999 and the ICJ Opinion on the Kosovo Declaration of Independence.

3. ON WHAT LEGAL GROUND(S) DO WE PROCESS YOUR PERSONAL DATA

We process your personal data because:

• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Union institution or body (Article 5 (a) of Regulation (EU) 2018/1725).

The basis for the processing is laid down by the following Union law:

Article 11 of the consolidated European Treaty on the European Union states: “The institutions shall, by appropriate means, give citizens and representative associations the opportunity to make known and publicly exchange their views in all areas of Union action. The institutions shall maintain an open, transparent and regular dialogue with representative associations and civil society”.

Article 21(1) of the Treaty on European Union (TEU): overall mandate and guiding principles in the field of EU development cooperation; Articles 4(4) and 208 to 211 of the Treaty on the Functioning of the European Union (TFEU).

Informing the broad public is a task resulting from the European Commission’s own prerogatives at institutional level, as provided for in Article 58(2) (d) of Council Regulation (EC, Euratom) No 2018/1046 of 18 July 2018 on the Financial Regulation applicable to the general budget of the European Communities (OJ L 193, 30.7.2018, p. 1)We ensure that adequate and specific safeguards are implemented for the processing of personal data, in line with the applicable data protection legislation.

In addition, Article 32 of the Regulation (EU) 2024/1449 of the European Parliament and of the Council of 14 May 2024 on establishing the Reform and Growth Facility for the Western Balkans stipulates that the Commission shall engage in communication activities to ensure the visibility of the Union funding for the financial support envisaged in the Reform Agendas, including through joint communication activities with the beneficiaries […] Actions financed under the Facility shall be carried out in accordance with communication and visibility requirements in Union-financed external actions and in other relevant guidelines.

The Young European Ambassador network  was one component of the EU Regional Communication Programme for the Western Balkans for which the legal basis was Regulation (EU) N°236/2014 of the European Parliament and of the Council of 11 March 2014 laying down common rules and procedures for the implementation of the Union’s instruments for financing external action and Regulation (EU) No 231/2014 of the European Parliament and of the Council of 11 March 2014 establishing an Instrument for Pre-accession Assistance (IPA II), as well as Article 18 of Regulation (EU) 2021/1529 of the European Parliament and of the Council of 15 September 2021 establishing the Instrument for Pre-Accession assistance (IPA III).

•  Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (Article 5 (c) of Regulation (EU) 2018/1725).

• Your consent is required for the following actions:
  • take your photographs and/or video recordings and publishing them on DG ENEST and European Commission intranets, webpages and social media channels;
  • to invite you to future calls and meetings/events related to the calls for expression of interest;
  • to process your personal data relating to your dietary requirements and/or access requirements for meetings/events;
  • to share the meetings or events participants list containing your name and affiliation with other participants. In addition, further information will be given if there are specific purposes for such sharing (e.g. for the purpose of future collaboration);
  • to share the meetings or events attendee list containing your name and affiliation among participants, in order to create working groups to continue the collaborate work launched during the meeting or event;
  • to process of your personal data for managing your subscription to a newsletter of the data controller.

If you opt-in, you are giving us your explicit consent under Article 5(1)(d) of Regulation (EU) 2018/1725 to process your personal data for those specific purposes. You can give your consent via a clear affirmative act by ticking the box(es) on the online registration form.

Where data are not marked as mandatory, DG ENEST processes your personal data based on your consent (Article 5 (d) of Regulation (EU) 2018/1725). All data processing is transparent and abiding by the principle of users’ opting-in/out, and allowing the data they provide to be used for specific purposes.

We have obtained your consent directly from you. You may have expressed it by an email, submitted via e-registration form, or in any other written form.

We do not process special categories of personal data (Article 10 of the Regulation (EU) 2018/1725).

4. WHICH PERSONAL DATA DO WE COLLECT AND FURTHER PROCESS?

In order to carry out this processing operation the Directorate-General for Directorate-General for Enlargement and Eastern neighbourhood, Unit ENEST 01 Strategic Coordination and Communication may collect the following categories of personal data:

Young European Ambassador applicants

• First name
• Last name
• Gender*
• Age
• E-mail address
• Telephone number
• Country of origin
• Language(s)
• Interests*
• Video upload*
• belonging to a certain minority group or having a specific disability* (The applicants to Young European Ambassador programme may identify themselves in the application form as belonging to a certain minority group or having a specific disability. By providing this information they are  giving the explicit consent to the Data Controller to process their personal data related to health and/or ethnic origin).

* not mandatory fields

Social media influencers

• First Name
• Last Name
• Gender*
• Age
• E-mail address
• Telephone number
• Country of origin
• Country of residence
• Language(s)
• Instagram profile
• Short biography

*  not mandatory fields

Newsletter subscribers 

• First name

• Last name
• E-mail address
• Country
• (Depending on the event, this could also include position/organisation)

Event invitees/participants

• First name
• Last name
• E-mail address
• Country
• (Depending on the event, this could also include position/organisation)
• photographs and/or audio-visual recordings 
• dietary and/or access requirements* 

Website visitors

• IP address

Your data might be collected by means of the news alert registration interface in which the data subjects enter their data directly.

5. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

The Directorate-General for Directorate-General for Enlargement and Eastern Neighbourhood, Unit ENEST 01 Strategic Coordination and Communication only keeps the personal data for the time necessary to fulfil the purpose of collection or further processing:

• Personal data related to the organisation and management of the calls for applications will be kept for 5 years after the last action in relation to the specific call.
• Personal data related to the organisation and management of events (this includes the personal data collected, before, during or after the meeting) will be kept for 5 years after the events. 
• Personal data, including photographs and/or audio-visual recordings, published on intranet page and the external websites of DG ENEST will be kept according to the retention period foreseen in the Commission’s record DPR-EC-01888 – My IntraComm (intranet and collaboration portal) and the retention period foreseen for the specific website. 
• Personal data, including photographs and/or audio-visual recordings, published on social media will be kept according to the retention period foreseen in the Commission’s record DPR-EC-00074 – Audio-visual Services. 
• Sensitive personal data relating to dietary and/or access requirements will be deleted as soon as they are no longer necessary for the purpose for which they have been collected in the framework of the event, but no later than within 1 month after the end of the event.
• Personal data included in the files relating to contracts are  retained until the closure of the contract and in the archives for a period of 10 years following the closure of the contract.
• Personal data related to newsletter subscribers will be retained as long as the data subject is registered and for as long as the website operates as a tool of DG ENEST promotion policy (i.e. until a subscriber erases his/her account or unsubscribes from the mailing list).
• User accounts are deleted after a defined period of six months inactivity
• The IP addresses are kept for the duration of the browsing session (The IP addresses are processed by the processor for technical purposes during the browsing session and are not stored beyond the duration of that session.)

Every six months a recall email is sent to all database users to amend and review their information preferences. It also provides users with the possibility to opt-out, unsubscribe from the services, thus to delete their accountsData will be automatically removed at the end of the respective period or when no longer needed. Information will be anonymised within six months from the date of submission of the unregistration request.

DG ENEST processors use the server e-mailing platform for sending the alerts to the data subjects. The server mailing platform meets the General Data Protection Regulation (‘GDPR’) (EU) 2016/679 requirements and has a retention policy of 30 days on data stored on its servers.

6. HOW DO WE PROTECT AND SAFEGUARD YOUR PERSONAL DATA?

All personal data in electronic format (e-mails, documents, databases, uploaded batches of data, etc.) are stored either on the servers of the European Commission or of its contractors. All processing operations are carried out pursuant to the Commission Decision (EU, Euratom) 2017/46 of 10 January 2017 on the security of communication and information systems in the European Commission.

The Commission’s contractors are bound by a specific contractual clause for any processing operations of your data on behalf of the Commission, and by the confidentiality obligations deriving from the transposition of the General Data Protection Regulation in the EU Member States (‘GDPR’ Regulation (EU) 2016/679.)

In order to protect your personal data, the Commission has put in place a number of technical and organisational measures in place. Technical measures include appropriate actions to address online security, risk of data loss, alteration of data or unauthorised access, taking into consideration the risk presented by the processing and the nature of the personal data being processed. Organisational measures include restricting access to the personal data solely to authorised persons with a legitimate need to know for the purposes of this processing operation.

Personal data in electronic form: access to your personal data, as well as any other information collected in the website is exclusively provided through an identification system with password, accessible to a restricted number of users, without prejudice of a possible future transmission of these data to the bodies charged with the control and inspection of the Commission’s activities in conformity with EU law. These users are DG ENEST staff, as well as contracted external companies.

7. WHO HAS ACCESS TO YOUR PERSONAL DATA AND TO WHOM IS IT DISCLOSED?

Access to your personal data is provided to the Commission staff responsible for carrying out this processing operation and to authorised staff according to the “need to know” principle. Such staff abide by statutory, and when required, additional confidentiality agreements.

Staff of OLAF, IDOC, IAS (Internal Audit Services), the Legal Service of the Commission as well as staff of other DGs (SG, DG BUDG and clearinghouse) upon request necessary in the context of official investigations or for audit purposes.

Pursuant to Article 3(13) of Regulation (EU) 2018/1725, public authorities (e.g. Court of Auditors, EU Court of Justice) which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients. The further processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

Furthermore, access to your personal data is provided to external contractors working on behalf of and under contractual agreement with DG ENEST and engaged in creation, maintenance, management, and archiving of websites according to the “need to know” principle.

The information we collect will not be given to any third party, except to the extent and for the purpose we may be required to do so by law.

Cookies and third party IT tools: Cookies are pieces of text generated by the web services that a user has visited; these text files can be set on the users’ devices by the website they are currently visiting (“first party persistent cookies”) or by a different website to the one they are currently visiting (“third party cookies”).

To facilitate the functioning of our website we may – subject to visitors’ consent – place small data files called cookies on your device. They enable the website to remember your actions and preferences (such as login, language, and font size and other display preferences) over a period of time, so you do not have to keep re-entering them whenever you come back to the site or browse from one page to another.

Four different types of cookies will be in use:

• First party persistent cookies
• Technical session cookies
• Third party cookies (including the Google Analytics cookies)
• Third party cookies from the Share widget
• Third party advertising cookies (Facebook Pixel)

On this promotional website, the following types of cookies are used: ‘first-party persistent cookies’, and ‘session cookies’.

‘First party persistent cookies‘ enable the tracking of the following information about the visitors to our website:

• IP address (anonymised)
• Location: country, region, city, approximate latitude and longitude (Geolocation)
• Date and time of the request (visit to the site)
• Title of the page being viewed (Page Title)
• URL of the page being viewed (Page URL)
• URL of the page that was viewed prior to the current page (Referrer URL)
• Screen resolution of user’s device
• Time in local visitor’s time-zone
• Files that were clicked and downloaded (Download)
• Links to an outside domain that were clicked (Outlink)
• Pages generation time (the time it takes for webpages to be generated by the webserver and then downloaded by the visitor: Page speed)
• Main language of the browser being used (Accept-Language header)
• Browser version, browser plugins (PDF, Flash, Java, …) operating system version, device identifier (User-Agent header)
• Language of the visited page
• Campaigns
• Site Search
• Events

The collected data will not be shared with any other organisations for marketing, market research or commercial purposes. Moreover, the abovementioned data cannot be used to identify a particular visitor.

‘First party persistent cookies‘ are created by this website and enable:

• proper functioning of the website;
• the collection of statistics to improve website functionalities – for this purpose, the website uses Google Analytics (more information is provided below);
• social media sharing functions.
• monitoring conversions that can be attributed to ads on Facebook and its network. For this purpose, the website uses the Facebook Pixel.

‘First party persistent‘ cookies expire after thirteen months (13), after which they are automatically removed from the users’ device.

‘’Technical Session‘ cookies do not contain any data – they are placed for the duration of a user session (time spent browsing the website). These cookies are necessary to keep the visitor’s choice selection when the website is accessed. Once the visitor leaves the website, the session cookie is deleted.

‘Third party cookies‘ (including the Google Analytics cookies) are detailed below.

‘Third party cookies‘ from the Share widget are placed on the computer – if the user opted-in – in order to allow users to share content on social media.

The website does not set cookies with the display of links to our social media when you are browsing our website

OPTING-IN
When the website is accessed first, the website visitor is provided with a choice to accept (“OK, I agree”) or refuse (“Decline cookies”) the placement of cookies.

Accept cookies: By clicking this option, the visitor gives consent to the placement of all the cookies for the:

• Optimal functioning of the website
• Social media sharing function
• Collection of statistics

Decline cookies: By clicking this option, the visitor does not give consent to the placement of any of the abovementioned cookies. In this case, only a session cookie is placed. This is a technical cookie, the main purpose of which is to remember the visitors’ selection choice. This cookie is placed for the duration of a user session (time spent browsing the website) and will automatically be deleted when said session expires. Choosing not to accept cookies does not hinder your navigation experience on the website.

No selection made: If a visitor neither accepts nor refuses cookies, the website treats this as a refusal to the placement of cookies and all related functions are on hold until a selection is made. No cookies shall be placed on visitors’ devices, unless consent has been given by clicking on the “OK, I agree” option.

OPTING-OUT In case a visitor has opted-in to the placement of cookies, it is always possible to change this decision and opt-out. In order to opt-out, visitors need to delete all the cookies from their browser. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.

To learn about how to clear cookies in different browsers, visit: https://www.aboutcookies.org/

DO NOT TRACK OPTION

Do Not Track is a technology that enables visitors to opt out from being tracked by websites for whatever purpose, including the use of analytics services, advertising networks and social platforms. You can enable the ‘Do Not Track’ option directly in your web browser. Google Analytics and Facebook Pixel will not track users who have enabled this option in their web browsers.

GOOGLE ANALYTICS

The website uses Google Analytics in order to track the information of visitors described above. For this purpose, the abovementioned collected data are transmitted to Google Inc. The IP addresses of visitors are anonymised by the website prior to their transmission to Google Inc. This protects the anonymity of the visitors that have opted for the full website functionalities.

Google Analytics has implemented a data retention control feature. This feature provides website owners with the flexibility to define a retention period for the data stored within the Google Analytics account. The defined retention period is 26 months; any data beyond this period is deleted from Google servers.

FACEBOOK PIXEL

The website uses the Facebook Pixel in order to monitor the conversions that can be attributed to our advertising activity on Facebook and his network. All information on Facebook’s data policy can be found here: https://www.facebook.com/about/privacy

Processing of personal data by the contractor and the communication companies may involves international transfer of data when the contractors are non EU/EEA companies or use local offices in the country where the project/programme is implemented. These transfers are based on  derogations, namely for important reason of public interest (Article 50(1)(d))

8. HOW DO WE PROTECT AND SAFEGUARD YOUR PERSONAL DATA?

You have specific rights as a ‘data subject’ under Chapter III (Articles 14-25) of Regulation (EU) 2018/1725, in particular the right to access your personal data and to rectify in case your personal data are inaccurate or incomplete. Where applicable, you have the right to erase your personal data, to restrict the processing of your personal data, to object to the processing, and the right to data portability.

You have the right to object to the processing of your personal data, which is lawfully carried out pursuant to Article 5(1)(a) on grounds relating to your particular situation.

You have consented to provide your personal data to the Directorate-General for Directorate-General for Enlargement and Eastern Neighbourhood, Unit ENEST 01 Strategic Coordination and Communication for the present processing operation. You can withdraw your consent at any time by notifying the Data Controller. The withdrawal will not affect the lawfulness of the processing carried out before you have withdrawn the consent.

You can exercise your rights by contacting the Data Controller, or in case of conflict the Data Protection Officer. If necessary, you can also address the European Data Protection Supervisor. Their contact information is given under Heading 9 below.

Where you wish to exercise your rights in the context of one or several specific processing operations, please provide their description (i.e. their Record reference(s) as specified under Heading 10 below) in your request.

9. CONTACT INFORMATION

The Data Controller

If you would like to exercise your rights under Regulation (EU) 2018/1725, or if you have comments, questions or concerns, or if you would like to submit a complaint regarding the collection and use of your personal data, please feel free to contact the Data Controller, Directorate-General for Enlargement and Eastern Neighbourhood, Unit ENEST 01 Strategic Coordination and Communication, using the functional mailbox ENEST-01@ec.europa.eu.

The Data Protection Officer (DPO) of the Commission

You have the right to have recourse (i.e. you can lodge a complaint) to the European Data Protection Supervisor (edps@edps.europa.eu) if you consider that your rights under Regulation (EU) 2018/1725 have been infringed as a result of the processing of your personal data by the Data Controller.

10. WHERE TO FIND MORE DETAILED INFORMATION?

The Commission Data Protection Officer (DPO) publishes the register of all processing operations on personal data by the Commission, which have been documented and notified to him. You may access the register via the following link: http://ec.europa.eu/dpo-register.

This specific processing operation has been included in the DPO’s public register with the following Record reference: DPR-EC-05666.

Who we are

Suggested text: Our website address is: http://webalkans.a3ia.com.

Comments

Suggested text: When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

Suggested text: If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies

Suggested text: If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Suggested text: Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Who we share your data with

Suggested text: If you request a password reset, your IP address will be included in the reset email.

How long we retain your data

Suggested text: If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

Suggested text: If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where your data is sent

Suggested text: Visitor comments may be checked through an automated spam detection service.