pursuant to article 13 of Regulation (UE) 2016/679 of the European Parliament and of the
Council of 27 April 2016 on the protection of natural persons with regard to the processing of
personal data (in brief “GDPR”)
MOVE is an international cooperation project funded by the Erasmus+ programme of the
European Union. It is governed by a consortium of 11 Institutions, which are listed below and
acting as Joint Controllers, according to article 26 of the GDPR. The terms “We”,
“Consortium”, “Partners”, “Joint Controllers” refer all to the MOVE consortium.
In compliance with the European and Italian legislation in force in the sector, we ensure that
the protection of your personal data is guaranteed and that their confidentiality and integrity
are preserved when You browse our website https://www.moveproject-kri-ye.eu/, and use it
to ask for registrations (by using the proper “Google form”), to obtain information on our
activities, to log in the private area devoted to attend courses, to find our contact details and
to contact us. The purpose of the website is dissemination and exchange of information
about the MOVE project. The website falls under the responsibility of the MOVE consortium.
It is not concerned with commercial transactions or with the exchange of data for marketing
purposes. The MOVE website does not work with any third party that serves ads to this site.
We invite You to inspect this policy concerning the modalities, the means and the purposes
of processing of Your personal data.
If you have questions, we invite you to contact us about this policy at: info@moveproject-kri-
ye.eu
- Joint Data Controller and Processors
Pursuant to articles 4, 24 and 26 of GDPR, when two or more data controllers jointly
determine the purposes and means of the processing, they are defined as Joint Data
Controllers. For the purposes of the MOVE project, the data controllers set out a specific
data sharing agreement.
The Joint Data Controllers are 11 organisations, members of the MOVE consortium, and are
listed below:
UNIMED – Unione delle Università del Mediterraneo
Address: Corso Vittorio Emanuele II, 244 – 00186 Rome, Italy
Represented by: Mr. Marcello Scalisi, Director
Università della Calabria
Address: Via P. Bucci. 87036 Rende (CS) Italy
Represented by: Prof. Gianluigi Greco, Rector
Universidad de Murcia
Address: Avenida Teniente Flomesta, 5, 30003, Murcia
Represented by: Prof. J. Samuel Baixauli Soler, Rector
University of Duhok
Address: Zakho Street 38, 1006AJ Duhok, Duhok – Kurdistan Region – Iraq
Represented by: Dr. Dawood Atrushi, President of the University
University of Sulaimani
Address: University of Sulaimani New Campus, Kirkuk Main Road, 46000, Sulaimani,
Kurdistan Region – Iraq
Represented by: Professor Dr Kosar Mohamad Ali Murad, President of University
University of Garmian
Address: Kalar, Barda-sor. Garmian – Kurdistan Region – Iraq
Represented by: Dr. Salar Al-Zangana, Director of International Academic Relations
Salahaddin University – Erbil
Address: Zanko Street, Erbil Kurdistan Region, Iraq Zipcode: 44002
Represented by: Dr. Kamaran Younis M. Amin, President
University of Aden
Address: Al-Shaabi Street, Abyan Coast, Khormaksar, Aden, Yemen
Represented by: Prof. Al-Khadher Laswar, Rector of University of Aden
Hadhramout University
Address: Fuwa Street, Al-Inshaat, Mukalla, Hadhramout, Yemen, P.O. Box: Mukalla
50511/50512
Represented by Prof. Mohammid Khanbash, Rector
Kurdistan Agricultural Engineering Syndicate
Address: Iraq, Kurdistan Region, Duhok Province.
Represented by: Nechirvan Hazim Ramadhan Artoshi, Head of Duhok Province Branch
Selah Foundation for Development
Address: Heya Hospital Street, Next to The Curve Hotel, Mukalla, Hadhramout, Yemen
Represented by: Mr. Ali Ba Shammakh, CEO
The Joint Data Controllers take advantage of third parties that provide some services to the
MOVE project and / or support it in carrying out certain activities: they have been appointed
Data Processors pursuant to article 28 GDPR.
- Categories of data processed and purposes of processing
During browsing through the sections of our Website, which is permitted to any user without
need to register, we obtain and process the following personal data, for the specific
purposes listed below:
1) Browsing data concerning the session. The IT systems responsible for the
functioning of this Website acquire, during their normal functioning, certain personal
data whose transmission is implicit in the use of Internet communication protocols
(e.g. IP addresses, Internet connection and traffic data, domain names of the devices
used by Website visitors).
This information is not collected to be associated with identified data subjects or to
identify users.
Without prejudice to the specific provisions of paragraph 4 below in relation to the
use of cookies on the Website, these data are used for the sole purpose of obtaining
anonymous information on the use of the Website and controlling its correct
functioning.
The data might be used to ascertain responsibilities in case of possible IT crimes
against the Website.
2) Browsing data concerning services provided by third parties and/or obtained by third
parties through the Website. The development of some functionalities of the Website
takes place through services provided by third party entities (WordPress, as
concerns the plugin for detecting, setting up and saving the preferences of users
regarding the language; Google, as concerns monitoring and analysis of traffic data
and of the behaviours of users on the Website, map’s functioning and the
memorisation of user consent to the processing of personal data) through the use of
cookies, as specified in the following paragraph.
The processing of the above-specified data has the purpose of ensuring the correct
functioning and use of our website, through: a) performance evaluations of the
Website during the browsing session, aimed at monitoring and improving the
services we offer; b) analysis of the browsing data, in aggregate form, for statistical
purposes and to keep track of the behaviour of users, without this entailing profiling
activity (we only use Matomo analytics functionalities).
● “Registration forms” webpages (implemented by using Google’s functionalities) are
linked to our Website: by filling the forms in with the requested information – some of
them are compulsory whereas others are not – you can submit your registration’s
request to participate in some of the project activities, and/or to receive information
about the project. The personal data collected in such occasions are processed by
the MOVE partners to issue the services you ask for, to improve the performance
and the efficiency of those services, also differing between several professional
profiles, interest, etc., and for statistical purposes.
● Subject to your consent to receive information from the MOVE consortium, your data
(your name, surname and e-mail address) will be processed to possibly contact you
to share information about the progress of the project and its results, future
opportunities, etc.
● Furthermore, our Website shows an e-mail address: sending, optionally and
voluntarily, electronic mail to such address entails the consequent acquisition of the
address of the sender, necessary to reply to the requests, as well as of any other
personal data that may be included in the letter; by sending the e-mail, you consent
to the data processing for the specified purposes.
We process the personal data concerned, to allow you to contact us, to request information
and/or assistance, and to allow us to reply to your requests. The email provider is Google
Suite.
- Legal ground for the processing
More in detail, the MOVE partners will process the personal data collected from the users to:
● respond to questions and requests to participate in the project activities;
● register and onboard participants in the project activities;
● implement the online activities;
● assure quality control, monitoring and evaluation;
● provide for recognition of the participation in the learning activities.
The processing of personal data, depending on cases, is based on the following legal
grounds:
● the pursuit of a legitimate interest of the Controller to ensure the security of the
Website, control its correct functioning and obtain statistics in relation to its use, as to
the browsing data concerning the session, and to eventually exercise or defend a
legal claim (article 6, paragraph 1, letter f) of the GDPR);
● the performance of the requested services (article 6, paragraph 1, letter b) of the
GDPR), with reference to the personal data that are necessary to create the personal
account to access the Platform (marked as compulsory in the registration form);
● the consent given by the user (as time-to-time above indicated) to the processing of
data referred to in letters B), C) and D) and for what concerns the use of the
browsing data related to services provided by third parties through the Website
and/or obtained from third parties through the Website, (article 6, paragraph 1, letter
a) of the GDPR). Consent may be withdrawn at any time. The withdrawal of consent
shall not affect the lawfulness of processing based on consent before its withdrawal.
Shall the personal data be processed for statistical purposes, the provisions of article 89 of
the GDPR are fulfilled. - Modalities of processing
The processing of personal data will be performed through IT instruments, both automated
and not automated (in such case, through human intervention in the management of IT
systems) and through the use of analogue instruments (paper management), according to
logical processes closely correlated to the purposes of the same processing and, in any
case, with the support of equipment and with modalities that guarantee the security and
confidentiality of the same data, preventing loss of data, illegal or incorrect uses, and
unauthorised accesses.
We use technical (“application”) cookies, both first party and third party, for data processing
on our Website.
A “cookie” is a small quantity of data that is sent to the browser of the user by a Web server
and that is subsequently stored on the hard drive of his or her computer.
Third party cookies are cookies sent by third party domains / partner websites that offer their
functionalities inside the pages of the Website and/or in the context of the operation of the
Website (e.g., icons to express preferences expressed on social networks). The use of the
data collected by these external operators through cookies is subject to the respective
privacy policies. For detailed information on the preceding, we suggest referring to the
privacy policy of the services listed as third-party cookies available on the respective
websites.
Our Website does not use cookies for the transmission of information of a personal nature
(e.g. first and last name, e-mail address or telephone number), nor so-called persistent
cookies of any kind, or system to track users.
The use of so-called session cookies is strictly limited to the transmission of session
identifiers (represented by random numbers generated by the server), necessary to enable
the secure and efficient exploration of the website, and to the acquisition of data to save the
browsing preferences of the user (e.g., setting the language, managing statistics), in order to
optimise the experience on the Website. Session cookies used in this Website avoid
recourse to other IT techniques potentially prejudicial to the confidentiality of users’ browsing
and do not allow acquisition of personal data identifying the user. Cookies may be
deactivated but, should this choice be made, users would not be able to use the related
functionalities and services. If You accept the use of cookies you consent to the processing
of your data for the above-specified purposes (see paragraph 2).
- Disclosure and dissemination of data
The entities that may become aware of the personal data are our employees and
collaborators, who take care of the administrative management of the Web page and of
relations with users / customers. The entity taking care of the management of the Website
may, possibly, become aware of the personal data, on the occasion of assistance /
maintenance interventions.
Personal data will be processed within any MOVE Consortium Partners according to the
tasks assigned to it, within and outside the European Economic Area (EEA).
As far as Google services are concerned, Google, LLC will comply with the Data Privacy
Framework requirements, thus, we guarantee an appropriate level of protection; furthermore,
some Google services are provided by Google Ireland Limited in favour of subjects based
and / or operating within the European Union.
Where needed, should we have an obligation to report a crime or in any case the need to
pursue a legitimate interest to exercise or defend a legal claim on our part, the data of users
might be disclosed to the judicial Authority or to police forces.
Apart from the cases just specified, personal data will not be disclosed to third parties and/or
in any way disseminated outside the context of the European Union. - Data retention periods
Browsing data are deleted immediately after the processing, at the end of the browsing
session (closure of the browser).
Data provided voluntarily by users (by sending emails), will be stored for the 12 months
following delivery to users of the requested information, unless further storage of the data is
necessary to comply with legal obligations, or the parties enter into another relationship.
Data processed through third party cookies (including sharing cookies) are stored for the
period of time provided by the operators, according to the respective privacy policies.
The data collected for the purpose of sending the newsletter will be processed and stored
exclusively for the period during which the service will be active: therefore, up to a possible
request to no longer receive the newsletter messages.
The other personal data collected through the registration forms will be retained by the
project partners until the end of the project (31/01/2028) to comply with the regulatory
obligations. Moreover, the Joint Controllers will retain the data until five years after the
termination of the Project in order for the competent Authorities to verify the compliance with
the relevant regulations.
Once the retention period has passed, the MOVE consortium and potential subcontractors /
external providers will take adequate measures to delete all personal data collected within
the project.
- Rights of the data subject concerning the processing of personal data (Articles 15-
22 and 77 of the GDPR)
It is possible to submit requests to exercise the rights afforded by the GDPR (access,
rectification, erasure, objection, restriction and portability, if the conditions are present) by
sending an email to info@moveproject-kri-ye.eu.
To enable us to respond quickly, we kindly ask you – thanking you in advance for your
cooperation – to specify your first and last name, as well as e-mail address. Certain requests
(for example concerning exercise of the right to access) must be accompanied by a
photocopy of an identity document with your signature to verify your identity; you also need
to specify the address at which you wish to receive the answer. The answer will be sent
within one month of receipt of the request.
The data subject also has the right, if they believe the processing of their data to be
performed in infringement of the provisions of the GDPR, without prejudice to the right to
complain to the competent civil or administrative judicial authorities, to lodge a complaint
with the Supervisory Authority for the protection of personal data, within the limits of its
jurisdiction.