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Part A - Privacy Policy

As the coordinating partner of the End FGM E-Campus project and therefore the End FGM E-Campus platform (“the platform”), the Mediterranean Institute of Gender Studies (MIGS) commits to compliance with the provisions of Regulation (EU) 2016/679 as they apply in Cyprus (“the 2018 GDPR Law”).

MIGS seeks to protect your privacy and develop technology that gives you the most powerful and safe online experience. This privacy policy governs data collection and usage related to the platform. By using the platform, you consent to the data practices described herein.

This policy explains when and why we collect personal information from platform visitors and users, how we use it, the conditions under which we may disclose it to others, and how we keep it secure.

The categories of personal data are broadly drawn – personal data may include telephone numbers, addresses, financial information, photographs, ID numbers, email addresses, health records, etc.

Any questions regarding this policy and our privacy practices should be sent by email to the Data Protection Officer, Dr Christina Kaili (MIGS) by emailing dpo@endfgm-ecampus.eu or by calling +357 22 795152.

WHAT INFORMATION DO WE COLLECT?

MIGS collects the personal information you provide on the platform to deliver services such as newsletters and communications on campaigns, training activities, seminars, and other activities related to the platform. The data is collected based on MIGS’ legitimate interest to keep you updated on End FGM E-Campus activities.

Types of information collected:

• Personal information that may include your name, address, email address, IP address, etc. In addition, we collect data on your course participation, including assignment submissions, quiz results, and forum activity, which are necessary to manage and deliver educational services through our platform.

• Web form data, for example, information submitted in a registration form or in a search query on the platform. 

• Web logging, which enables us to collect the standard information your browser sends to every website you visit – such as your IP address, browser type and language, and the site you came from – as well as the pages you visit and the links you click while using our sites and digital services. 

• Course grades and certificates – these will not be made known to third parties. 

• Cookies – The platform may use cookies to identify visitors/users of platform services and pages (e.g. courses, resources etc.). A cookie is a small text file that visited websites save on your computer. Cookies are used to provide visitors access to various functions. The information in the cookie can be used to track your internet usage. We use cookies to manage our platform more efficiently, to enhance your experience as a participant, to facilitate navigation, to display information more effectively, for security purposes, as well as for site administration purposes. You can adjust the settings in your browser to reject cookies or delete individual or all cookies on your computer. 

• IP address: The IP address through which you access the internet and the platform is logged by the Moodle platform. IP addresses are primarily used for security purposes, such as monitoring login activity, detecting suspicious behaviour, and safeguarding the integrity of the platform. Additionally, IP addresses may be used for technical diagnostics, usage analysis, and statistical reporting. However, IP addresses are not linked to any other personal information unless required for security or legal purposes.

HOW IS YOUR INFORMATION USED?

The information we collect is used solely for legitimate interest purposes, such as tracking course participation and platform usage to improve the learning experience. Your data is also used to provide you relevant updates about your enrolled courses, as well as notifications about new course releases or materials that may be of interest based on your area of study. 

Communication is strictly limited to course-related matters and updates, and we do not send promotional materials or unrelated newsletters. All communications are conducted in accordance with confidentiality clauses and only upon the users' consent.

The Moodle platform uses automated systems to grade quizzes and evaluate assessment tasks. This data is processed based on the predefined criteria set by course instructors, and you will be notified of your results through the platform. If you wish to contest a grade, please contact us for manual review.

WHO HAS ACCESS TO YOUR INFORMATION?

The End FGM E-Campus project consortium has access to your information for the purposes outlined above.

• We will not sell or rent your information to third parties.

• We will not share your information with third parties for marketing purposes.

• Please note that your participation in Moodle activities such as forums, wikis, and shared assignments may be visible to other students enrolled in the same course and to course instructors. This is necessary to support collaborative learning and course management.

Third-party service providers: We may need to pass your information to our third-party service providers, agents, subcontractors, and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to send you mailings). In doing so, we disclose only the personal information necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. We do not share information with third parties for their own direct purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime. 

Our Moodle-based platform may utilise third-party plugins or integrations (e.g., plagiarism detection services, video conferencing tools) to enhance the learning experience. These services may collect or process your personal data for functionality purposes, and they adhere to the same privacy and security standards outlined in this policy.

For auditing purposes, we may show attendee lists obtained at events to donors for the sole purpose of verifying that funded events took place.

YOUR CHOICES AND RIGHTS

We will not contact you for marketing purposes by email, phone, or text message unless you have given your prior consent.

HOW CAN YOU ACCESS AND UPDATE YOUR INFORMATION

You have several rights as a data subject: 

• Access: You have the right to obtain confirmation as to whether your personal information is being processed by us and, if it is, to access your information and details of how we process it, as long as this does not adversely affect the rights and freedoms of others. 

• Rectification: We will rectify any errors in your personal information upon request. 

• Erasure: You may ask us to erase your personal information from our systems. 

• Restrict processing: You have the right to restrict our processing on specified grounds. 

• Data portability: You have the right in specific circumstances where processing is based on consent to receive your information in a structured, commonly used and machine-readable format and have the right to transmit the information to another controller without hindrance, provided that our processing is carried out by automated means. 

• Right to object: In certain circumstances, you have the right to object to our processing of your information, including in relation to profiling, direct marketing, or scientific or historical research purposes. 

How to exercise your rights: 

• The accuracy of your information is important to us. We are working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change email address, or if any other information we hold is inaccurate or out of date, please email us at dpo@endfgm-ecampus.eu 

• To exercise any of your data subject rights, please contact dpo@endfgm-ecampus.eu 

• Please note that if you delete or restrict your account or required information, this may prevent you from making full use of our services. 

• If you want to be completely removed from our database or if you want a restriction of your data processing, please send an email to dpo@endfgm-ecampus.eu or use the option “Delete my account”, available under your user profile page.

If you’re a platform participant and ask to be removed from our database or to limit our access to your data, we may not be able to include you in meetings or other activities related to the platform.

You have the right to ask for a copy of the information the platform has gathered on you (there will be no charge for this request).

If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may contact the Office of the Commissioner for Personal Data Protection, the regulator responsible for data protection in Cyprus, where MIGS is located.

PERIOD OF STORAGE

MIGS will store your information as long as you use our services or are a member of our network and until five years after your last use of our services or the termination of the membership.

Grades, course completion records, and other learning outcome data generated during your participation in the courses will be stored for five years following course completion to meet educational audit requirements.

PREVENTION OF LOSS, MISUSE, OR ALTERATION OF YOUR INFORMATION

When you give us personal information, we take steps to ensure that it is treated securely.

Non-sensitive details (your email address etc…) are transmitted normally over the internet and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we ensure as best we can its security on our systems. Where we have given (or where you have chosen) a password that enables you to access certain parts of our platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Personal data stored in the platform, including user profiles and learning records, are protected with encryption and other security protocols to ensure data integrity and privacy. Access to this information is limited to authorised users with appropriate credentials, and security audits are conducted regularly.

Learner data, including personal information such as name and surname provided during registration, will reside securely on our cloud-hosted server. For audit purposes, project partners may export and store participant data, which will be retained for a minimum of five years to meet audit obligations. After this period, or upon request, personal data will be anonymised or securely deleted. For any questions, clarifications, or to request extraction or deletion of your personal data, please contact us at dpo@endfgm-ecampus.eu.

USE OF GOOGLE ANALYTICS WITH ANONYMISATION

The platform uses Google Analytics, a web analysis service from Google Inc. Google Analytics employs cookies to facilitate an analysis of your use of the platform. The information generated by these cookies, such as time, place, and frequency of your visits to our platform, including your IP address, is transmitted to Google’s location in the US and stored there.

We use Google Analytics with an IP anonymisation feature – Google abbreviates and thereby anonymizes your IP address before transferring it from the European Union or signatory states to the Agreement on the European Economic Area.

Google will use this information to evaluate your usage of our platform, to compile reports on platform activity, and to provide other services related to platform and internet usage. Google may also transfer this information to third parties if the law requires this or to the extent third parties on Google’s behalf process this data.

Google states that it will never associate your IP address with other data held by Google. You can prevent cookies from being installed by adjusting the settings on your browser accordingly. You should be aware, however, that by doing so you might not be able to make full use of the functions of the platform.

Most modern browsers offer add-ons or settings that allow users to block Google Analytics and other tracking technologies. By using such options, you can prevent your visit data from being transmitted to Google Analytics or other web analytics services. However, disabling trackers may affect the functionality of certain features on the platform. For more information on how to manage and control the use of cookies and trackers, consult the help section of your browser.

LINKS TO OTHER WEBSITES

Our platform may contain links to other websites run by other organisations. This privacy policy applies only to our platform, so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access those using links from our platform.

In addition, if you arrived on our platform from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third-party site.

CHILDREN’S PRIVACY (AGES 16 OR UNDER)

We prioritise the protection of the privacy of children aged 16 or under. Our services do not address anyone under the age of 16. If we discover that a child under 16 has provided us with personal information, we immediately delete this from our server. If you are aged 16 or under, please get your parent/guardian’s permission beforehand whenever you provide us with personal information.

SECURITY

We take precautions to protect your information both online and offline. Only employees who need the information to perform specific actions are granted access to personally identifiable information.

UPDATE

This policy will be updated from time to time. We advise you to review this page periodically for any changes. These changes are effective immediately once they are posted on this page.

INFORMATION / CANCELLATION / DELETION

The 2018 GDPR Law allows you to contact us at no cost if you have questions relating to the collection, processing, or use of your personal information, if you wish to request the correction, blocking or deletion of the same, or if you wish to cancel explicitly granted consent. Please note that you have the right to have incorrect data corrected or to have personal data deleted, where such a claim is not barred by any obligation to retain this data.

CONTACT THE DATA PROTECTION OFFICER 

For the reasons above, or if you feel that your personal data has been misused, or data processing is otherwise not compliant with the 2018 GDPR Law, contact Dr Christina Kaili (the Data Protection Officer at MIGS) at dpo@endfgm-ecampus.eu or by calling +357 22 795152.

Part B - Terms of Use

The platform comprises various web pages operated by MIGS. The platform is offered to you conditioned on your acceptance without modification of the terms, conditions, and notices contained herein. Your use of the platform constitutes your agreement to all such terms, conditions, and notices.

MODIFICATION OF THESE TERMS OF USE

MIGS reserves the right to change the terms, conditions, and notices under which the platform is offered, including but not limited to the charges associated with the use of the platform.

LINKS TO THIRD PARTY SITES

The platform may contain links to other websites (“linked sites”). The linked sites are not under the control of MIGS and MIGS is not responsible for the contents of any linked site, including without limitation any link contained in a linked site, or any changes or updates to a linked site. MIGS is not responsible for webcasting or any other form of transmission received from any linked site. MIGS is providing these links to you only as a convenience, and the inclusion of any link does not imply endorsement by MIGS of the site or any association with its operators.

NO UNLAWFUL OR PROHIBITED USE

As a condition of your use of the platform, you warrant to MIGS that you will not use the platform for any purpose that is unlawful or prohibited by these terms, conditions, and notices. You may not use the platform in any manner that could damage, disable, overburden, or impair the platform or interfere with any other party’s use and enjoyment of the platform. You may not obtain or attempt to obtain any materials or information through any means not intentionally made available or provided for through the platform.

USE OF COMMUNICATION SERVICES

The platform may contain bulletin board services, chat areas, news groups, forums, communities, personal web pages, calendars, and/or other message or communication facilities designed to enable you to communicate with the public at large or with a group (collectively, “communication services”), you agree to use the communication services only to post, send and receive messages and material that are proper and related to the particular communication service. By way of example, and not as a limitation, you agree that when using a communication service, you will not:

• Defame, abuse, harass, stalk, threaten, or otherwise violate the legal rights (such as rights of privacy and publicity) of others.

• Publish, post, upload, distribute, or disseminate any inappropriate, profane, defamatory, infringing, obscene, indecent, or unlawful topic, name, material, or information.

• Upload files that contain software or other material protected by intellectual property laws (or by rights of privacy of publicity) unless you own or control the rights thereto or have received all necessary consent.

• Upload files that contain viruses, corrupted files, or any other similar software or programmes that may damage the operation of another’s computer.

• Advertise or offer to sell or buy any goods or services for any business purpose, unless such communication service specifically allows such messages.

• Conduct or forward surveys, contests, pyramid schemes, or chain letters.

• Download any file posted by another user of a communication service that you know, or reasonably should know, cannot be legally distributed in such a manner.

• Falsify or delete any author attributions, legal or other proper notices or proprietary designations or labels of the origin or source of software or other material contained in a file that is uploaded.

• Restrict or inhibit any other user from using and enjoying the communication services.

• Violate any code of conduct or other guidelines which may be applicable to any particular communication service.

• Harvest or otherwise collect information about others, including e-mail addresses, without their consent.

• Violate any applicable laws or regulations.

MIGS has no obligation to monitor the communication services. However, MIGS reserves the right to review materials posted to a communication service and to remove any materials at its sole discretion. MIGS reserves the right to terminate your access to any or all of the communication services at any time without notice for any reason whatsoever.

MIGS reserves the right at all times to disclose any information as necessary to satisfy any applicable law, regulation, legal process, or governmental request, or to edit, refuse to post, or to remove any information or materials, in whole or in part.

Always use caution when giving out any personally identifying information about yourself or your children in any communication service. MIGS specifically disclaims any liability with regard to the communication services and any actions resulting from your participation in any communication service. Managers and hosts are not authorised MIGS spokespersons, and their views do not necessarily reflect those of MIGS.

Materials uploaded to a communication service may be subject to limitations on usage, reproduction, and/or dissemination. You are responsible for adhering to such limitations if you download the materials.

MATERIALS PROVIDED TO MIGS OR POSTED ON ANY MIGS WEBSITE

MIGS does not claim ownership of the materials you provide to MIGS (including feedback and suggestions) or post, upload, input, or submit to the platform or its associated services (collectively “submissions”). However, by posting, uploading, inputting, providing, or submitting your submission you are granting MIGS, its affiliated companies, and necessary sublicensees permission to use your submission in connection with the operation of their internet businesses, including, without limitation, the rights to: copy, distribute, transmit, publicly display, publicly perform, reproduce, edit, translate and reformat your submission; and to publish your name in connection with your submission.

No compensation will be paid with respect to the use of your submission, as provided herein. MIGS is under no obligation to post or use any submission you may provide and may remove any submission at any time in MIGS’s sole discretion.

By posting, uploading, inputting, providing, or submitting your submission you warrant and represent that you own or otherwise control all of the rights to your submission as described in this section including, without limitation, all the rights necessary for you to provide, post, upload, input or submit the submissions.

LIABILITY DISCLAIMER

The information, software, products, and services included in or available through the platform may include inaccuracies or typographical errors. Changes are periodically added to the information herein.

MIGS and/or its suppliers may make improvements and/or changes in the platform at any time. Advice received via the platform should not be relied upon for personal, medical, legal, or financial decisions, and you should consult an appropriate professional for specific advice tailored to your situation.

MIGS and/or its suppliers make no representations about the suitability, reliability, availability, timeliness, and accuracy of the information, software, products, services, and related graphics contained on the platform for any purpose. To the maximum extent permitted by applicable law, all such information, software, products, services, and related graphics are provided “as is” without warranty or condition of any kind.

MIGS and/or its suppliers hereby disclaim all warranties and conditions with regard to this information, software, products, services, and related graphics, including all implied warranties or conditions of merchantability, fitness for a particular purpose, title, and non-infringement.

To the maximum extent permitted by applicable law, in no event shall MIGS and/or its suppliers be liable for any direct, indirect, punitive, incidental, special, consequential damages or any damages whatsoever, including, without limitation, damages for loss of use, data or profits, arising out of or in any way connected with the use or performance of the platform, the delay or inability to use the platform or related services, the provision of or failure to provide services, or for any information, software, products, services, and related graphics obtained through the platform, or otherwise arising out of the use of the platform, whether based on contract, tort, negligence, strict liability or otherwise, even if MIGS or any of its suppliers has been advised of the possibility of damages.

Because some states/jurisdictions do not allow the exclusion or limitation of liability for consequential or incidental damages, the above limitation may not apply to you. If you’re dissatisfied with any portion of the platform or with any of these terms of use, your sole and exclusive remedy is to discontinue using the platform.

Contact: dpo@endfgm-ecampus.eu

TERMINATION/ACCESS RESTRICTION

MIGS reserves the right, in its sole discretion, to terminate your access to the platform and the related services or any portion thereof at any time, without notice. 

ENTIRE AGREEMENT

Unless otherwise specified herein, this agreement constitutes the entire agreement between the user and MIGS with respect to the platform and it supersedes all prior or contemporaneous communications and proposals, whether electronic, oral or written, between the user and MIGS with respect to the platform. 

GOVERNING LAW

To the maximum extent permitted by law, this agreement is governed by the laws of the Republic of Cyprus and you hereby consent to the exclusive jurisdiction and venue of courts in the Republic of Cyprus in all disputes arising out of or relating to the use of the platform. Use of the platform is unauthorised in any jurisdiction that does not give effect to all provisions of these terms and conditions, including without limitation this paragraph. 

NO JOINT VENTURE

You agree that no joint venture, partnership, employment, or agency relationship exists between you and MIGS as a result of this agreement or use of platform. MIGS’s performance of this agreement is subject to existing laws and legal processes, and nothing contained in this agreement is in derogation of MIGS’s right to comply with governmental, court and law enforcement requests or requirements relating to your use of the platform or information provided to or gathered by MIGS with respect to such use. 

GENERAL

If any part of this agreement is determined to be invalid or unenforceable pursuant to applicable law including, but not limited to, the warranty disclaimers and liability limitations set forth above, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision and the remainder of the agreement shall continue in effect.

A printed version of this agreement and of any notice given in electronic form shall be admissible in judicial or administrative proceedings based upon or relating to this agreement to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form. It is the express wish of the parties that this agreement and all related documents be drawn up in Greek language.

COPYRIGHT AND TRADEMARK NOTICES

This platform material is copyrighted. No part of these materials may be copied, photocopied or reproduced in any form or by any means, without the written permission of MIGS, unless for the personal use of the registered User. Violations will lead to prosecution.

All trademarks, service marks, products, or services are trademarks or registered trademarks of their respective holders and are acknowledged by the authors.

The example companies, organisations, products, people, and events depicted herein are fictitious. No association with any real company, organisation, product, person, or event is intended or should be inferred.

Any rights not expressly granted herein are reserved.

NOTICES AND PROCEDURE FOR MAKING CLAIMS OF COPYRIGHT INFRINGEMENT

Pursuant to the Copyright Laws of 1976 to 1993, notices of claimed copyright infringement under the copyright laws of the Republic of Cyprus should be sent to the Copyright Authority Ownership and Related Rights.