1. Introduction

EUN Partnership aisbl (hereinafter called EUN) takes the protection of your privacy seriously. We exclusively collect, store, and retain the personal data of our platform users to provide the best possible service and treat this data with the utmost care.

This Privacy Policy is subject to EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter called GDPR). EUN is responsible (as the "data controller") for developing and managing the European Schoolnet Academy platform (hereinafter called the platform) and for processing your personal data as explained in this Privacy Policy.

This Privacy Policy outlines the policies by which the platform collects, manages and uses the personal data provided by users, and how users of the platform may exercise their data protection rights.

2. When do we collect and process your personal data?

You directly provide EUN with your personal data through the platform. We collect your personal data when you: 

• Visit the platform.
• Register to the platform and participate in online courses.
• Join or register for live events organised through the platform (e.g. a thematic seminar).
• Facilitate official accreditation procedure for the registered users.
• Sign up for the European Schoolnet Academy mailing list.
• Participate in internal public discussion forums and/or other third-party online tools as part of the online courses.
• Fill in application forms to present in TeachMeets or to nominate your course work to be published.
• Contact us through help desk.

3. What personal data do we process and why?

The processing of personal data through the platform is necessary to:

• Enable registered users to take part in and contribute to the online courses through comments, bookmarks, tagging, completing quizzes and uploading their own resources.
• Track attendance on training courses, progress and completion of modules by registered users.
• Liaise with external organisations offering official accreditation to confirm the course completion of those participants who have requested such official accreditation.
• Send email announcements to the registered users related to the technical developments.
• Enable and improve the user experience within this and similar projects via access control, tracking usage frequency, search behaviours, preferences and settings.
• Detect security incidents, protect against malicious activity and fix system errors.
• Send updates through the European Schoolnet Academy mailing list and manage its subscriptions.
• Enable and facilitate research activities within and across EUN projects and activities.
• Collect, categorise and summarise user contributions in the internal public forums and other online tools, in order to present the course outcomes.
• Manage TeachMeet applications.
• Enable users to join live events.
• Handle helpdesk inquiries.

To achieve the above-mentioned purposes, we process the following personal data in the following circumstances:

a. Platform visits

As a general policy, you are not required to disclose your personal data as a condition of using the platform. No basic identity information, such as your name, postal address, or email address is automatically collected from your visit to the platform. However, we may automatically collect personal data, including technical information and information about your visit, from each of your visits to our platform, as detailed in point 3 (j) below.

b. Registration to the platform and participation in online courses

The platform offers users the opportunity to participate in online courses. For this, it is necessary to create a user account.

The following personal data is required as a part of the registration process:
Name, email address, public name (username) and country/region. 

When you take part in an online course, we may collect certain user-generated content during the course, such as submitted assignments, peer-graded assignments and peer-graded feedback, which may contain your personal data you voluntarily share.

We also collect course data which may contain personal data you voluntarily share through user responses to quizzes, forum entries and comments on the platform (as mentioned above).

We will send e-mail announcements to the registered users from time to time to inform them about the technical developments related to the European Schoolnet Academy platform that directly impact users’ profiles and require action from their side. By consenting to this Privacy Policy, you grant us permission to use your email address for this purpose.

c. Contacting the help desk

When contacting us at academy@eun.org we collect personal data such as your name, email address, username, and any other personal data you choose to share when you communicate with us. If you choose to contact us directly, we will only use the personal data you have provided to us, for the purposes of responding to your message or managing your requests.

d. Participation in internal public discussion forums and third-party online tools

The platform may offer internal public forums or third-party online tools (such as Padlet, X, Tricider, Mentimeter, or Genially) as part of its courses to enhance sharing among participants and deepen the learning experience. These tools can be either on the platform (e.g. platform’s own discussion forum) or they can be embedded or linked to from the platform (third-party online tools). Using such forums and tools, you can share comments, thoughts, ideas, photos, videos and other resources, which may contain your personal data you voluntarily share.

To participate in an internal public forum, you are required to register with us as explained under point 3.b. The use of third-party tools is optional as part of the courses; to use them, you may be required to register at an external site. These tools are managed by third-party websites applying their own privacy policies. By registering to them you accept that your personal data will be processed by these third parties (as data controllers). We advise you to consult the privacy policies of these third-party websites for more detailed information.

We may collaterally receive personal data (e.g. text or images available from the third-party website) when you access or log in to a third-party website that displays information on our site, e.g. X or Tricider. We may also receive personal data from a third-party website if you log in using the authorisation mechanism of the third-party site, e.g. Google or Facebook.

EUN reserves the right to reuse and reference posts in public forums and other online tools containing personal data in future versions of the courses offered through the platform to enhance future course offerings. EUN may also archive these posts and/or use them for future communications with course participants.

e. Participation in surveys or questionnaires

As part of the courses, we may run surveys or questionnaires, which are optional. We use Survey Monkey, a third-party service provider (i.e. data processor) to set up and run our surveys and questionnaires – this processing may be subject to Survey Monkey’s own privacy policy. In principle, the surveys are run in anonymous mode, meaning that your IP address will not be collected or stored. The surveys may ask for demographic information (e.g. your country, role, education level, age range, gender), but we do not ask for your name or email.

f. Participation in live events

Some platform courses include online events, or some events are offered outside of courses such as the European Schoolnet Academy Thematic seminar. Participating in such events is optional. Live events (webinars or online seminars) are run using Microsoft Teams (as a ‘data processor’).

Course live events: The course participants don’t have to register for the live events organised as part of courses, but they will have access a page where they have to give their consent in order to see the link for the live event in MS Teams. It is possible and encouraged to join the live event anonymously but by joining a live event the following personal information may be collected if the user is logged in to their MS Teams account: name, email and MS Teams username. Also, the event may be recorded, therefore image and/or sound data of the participants may be collected unless their cameras and/or microphones are disabled. In case the participants contribute to the event through a chat or other available tools, any personal data they may share in such contributions are processed. Processing of participants’ personal data for the purposes of participating in course related online events will be also subject to the privacy statement of Microsoft (as a ‘data processor’).

Other live events offered outside of courses: Users may be asked to register in advance or when joining the event. In that case the following personal data is collected through registration: name, email, and country. Also, certain additional information (e.g. role) may be collected depending on the nature and purpose of the event. We use Microsoft Forms (as the ‘data processor’) to collect and process the personal data you submit for an event registration form. Processing of participants’ personal data for the purpose of participating in these live events will be subject to a separate privacy statement of each event (which we encourage you to read carefully) and the privacy statement of Microsoft (as a ‘data processor’).

g. Filling in TeachMeet application forms

The course participants (i.e. registered users) may present at a TeachMeet as part of the online courses held on the platform. Those who want to present are requested to fill in an online form (an application). The form will include its own privacy statement which we encourage you to read carefully.

We use Microsoft Forms (as the ‘data processor’) to collect and process the personal data you submit for a TeachMeet application form. In addition to the privacy notice for each form, the processing of your personal data will also be subject to the privacy statement of Microsoft.

h. Subscription to European Schoolnet Academy mailing list

When you sign up for the European Schoolnet Academy mailing list, you are asked to submit the following personal data: first name (optional), last name (optional), and email address (mandatory).

We will use this information to send you notifications, e.g. about new courses, blog posts, learning resources, and developments and updates related to the European Schoolnet Academy.

You will also be asked to consent to this Privacy Policy. You will always have the opportunity to unsubscribe from the mailing list by using the unsubscribe link in any of the notification emails you have received, or by contacting us at academy@eun.org.

To manage the European Schoolnet Academy’s mailing list, we use MailerLite, a third-party service provider (as the data processor). The processing of your personal data will be subject to this Privacy Policy as well as to the terms and conditions, including the Data Processing Addendum of MailerLite.

i. Requesting official accreditation

Some of the online courses may be acknowledged by certain national, regional or local entities that provide official accreditation for teachers’ professional development activities. Such entities are listed on each course’s landing page. Certain information may need to be shared between the European Schoolnet Academy and the organisation offering the accreditation. In this situation, the participants expecting for the accreditation would have to contact the European Schoolnet Academy. This implies that their basic identity information (name and email) will be processed by EUN and will be shared with the accreditor to enable them to process the accreditation request.

j. Other forms of collection / Information collected by automated means

When you visit the platform, we collect information about your activity on the platform in order to improve the platform. We use Matomo for this (see also ‘Matomo' and ‘Cookies' sections below).

In addition, information such as a user's IP address, Internet service provider (ISP), web browser, operating system, approximate times of use, referring site, specific user interactions with the systems functionality and any similar data exchanged between a user's computer and the servers of the platform will be collected. These will not be linked to specific user accounts. We use Matomo for this (see Cookie Policy below). This information is accessible only to the systems administrators of the platform and is used only to ensure the broadest compatibility and connectivity between users and the platform, and to take appropriate action in case of unlawful or inappropriate behaviour.

Finally, aggregated statistics may be collected, including, but not limited to, the number of users during a specific period, professional background information, the preferred courses chosen by users, and account usage.

Some parts of the platform use the video services of YouTube. YouTube may use cookies to collect usage and user-related information about your visit to the platform. No personal data is automatically transmitted to YouTube when you visit the platform.

4. Who can access your personal data?

Apart from the third-party service providers (data processors) referred to by this Privacy Policy and without prejudice to the circumstances explained under points 4(a), 4(b) and 4(c), no third parties will receive your data, unless this is explicitly disclosed to you in advance in a separate privacy policy or unless we are required to do so by law, e.g. in the framework of a judicial enquiry or at the request of the competent legal authorities. 

The third-party service providers listed under this Privacy Policy process your personal data only on behalf of EUN. When we use a third-party service provider, we only disclose to them any personal data that is necessary for them to provide their services.

a. Access to registration data

Access to the full user data is strictly limited to designated EUN staff. EUN can modify and/or delete information as needed to maintain the integrity of the user database or to ensure the proper operation of the platform. Furthermore, course moderators/instructors appointed by EUN have access to the account information of the users in the course that they help organise.

Some data you submitted when registering onto the platform will be displayed in the restricted area of the platform, meaning that it is visible to other participants of the courses you are taking part in. You can choose for the ‘profile visibility’ to be either full profile or limited profile. The following data is then visible:

• Full profile: Username, full name, image (optional), joining date, country, language (optional), description (optional), education level (optional), social media accounts (Facebook, X, LinkedIn), course certificates and accomplishments (course badges).
• Limited profile: Username and image (optional).

b. Access to personal data from internal public forums and other online tools

Any input voluntarily made by a course participant which may contain personal data, in the platform’s internal forums will be publicly visible to other course participants on the platform, and, when using third-party tools, to anyone on the internet.

Furthermore, we may publish the user contributions in the public forums and other online tools, which may contain personal data the course participant chooses to voluntarily share, on the platform itself, in order to present the course outcomes. In this case, the data is accessible by anyone on the internet.

c. Access to personal data for research

We may use general course data (including quizzes or assignment submissions, grades, and forum discussions), information about user activity on the platform, and demographic data from course surveys for research activities. We may also share this data with relevant third-party stakeholders (see below) for the same purpose.

The transfer of specific data to third parties with a legitimate interest to access this data is permitted under the specific authorisation of EUN, taking into account the context and the objectives of the European Schoolnet Academy in general. Such third parties can be for instance educational organisations, governmental bodies, research centres, universities, or partners of the European Schoolnet Academy initiative. Whenever possible, anonymisation is applied to ensure that the data is transferred in an anonymous way to such third parties for research purposes.

d. Access to personal data collected through live events

Access to the personal data collected through live event registration is limited to designated EUN staff and course moderators/instructors. The live event recording may be shared online, e.g. via YouTube, similar video platform, or the project website or the European Schoolnet Academy platform (including its blog), in which case the recording is accessible to anyone on the internet.

e. Access to personal data processed to manage official accreditation requests

If a course participant wants to request official accreditation following a course that s/he has completed, personal data will be shared with the organisation offering the accreditation.

5. International data transfers

Your personal data may be transferred to and stored at a destination outside the European Union (EU)/European Economic Area (EEA) in which our third-party service providers specified in this Privacy Policy or other third parties who are granted access to your data in accordance with the reason explained under 4, are located or have servers.

Your personal data may also be accessible to parties outside the EU/EEA via the platform, European Schoolnet Academy’ social media accounts (Facebook, LinkedIn, YouTube), and EUN’s official website, links to which are embedded in the platform. It may also be the case that you are located outside the EU/EEA, and we need to follow up with you regarding your inquiry. Apart from the above-mentioned circumstances, your personal data is not sent outside the EU/EEA by us.

6. The legal basis of data processing

In terms of personal data processing activities for the purpose of handling helpdesk inquiries or responding your inquiries received through European Schoolnet Academy social media accounts, we rely on our legitimate interest to be able to respond to requests, questions, or remarks when you contact us via helpdesk or social media.

In terms of personal data processing activities for the purpose of improving the platform’s content and the overall experience, we rely on our legitimate interest in providing an engaging and motivating online learning environment to our visitors.

In terms of personal data processing activities for the purposes of detecting and preventing malware, illegal content, and other types of misuse, we rely on our legitimate interest to keep our online presence safe.

Your consent serves as the legal basis for our processing of your personal data in the following situations when you:

• register to the platform, the European Schoolnet Academy mailing list, or its live events/thematic seminars,
• contribute to the online courses through comments, bookmarks, tagging, completing quizzes, and upload resources,
• contribute to the various internal public forums during the courses,
• participate in surveys/questionnaires, when personal data is collected in rare instances or in TeachMeet applications, or
• request an official accreditation.

If you consent to us processing your personal data, please note that you may withdraw this consent at any time. To do so, please contact us as indicated in point 9 below. Please note that your consent can only be withdrawn with future effect and such a withdrawal does not have any influence on the lawfulness of past processing. In some cases, we may be entitled despite your withdrawal to continue to process your personal data on a different legal basis.

7. How long do we keep your personal data?

Your personal data is only processed for as long as needed to achieve the purposes which are described under point 3 above or, when we asked for your consent, up until such time when you withdraw your consent. As a general rule, we will de-identify your personal data when they are no longer necessary for the purposes outlined above or when the retention period as explained in this section has expired.

All personal data we collect through our interactions with you via the platform and the European Schoolnet Academy social media accounts will be kept for as long as required to communicate with you, but also to keep an historical archive of our communications. This enables us to revert back to earlier communications if you return to us with new questions, requests, or other input.

All personal data collected to send you notifications through the European Schoolnet Academy mailing list will be kept for as long as you remain subscribed, up until such time when you withdraw your consent (unsubscribe). We reserve the right to automatically unsubscribe email addresses that cause delivery errors (i.e. email bounces), which usually mean that the email address is no longer used.

For the live events and surveys/questionnaires, the period of retention will be indicated in the separate privacy policy for the event concerned.

The personal data related to the profile of the user are kept for three years after the user’s last login. User may also ask for the anonymisation of their account anytime by contacting academy@eun.org. In such cases, data will be kept only in an anonymous form that does not allow for personal identification. If users with an anonymised account want to continue using the platform, they will need to register again.

EUN is not in charge of any data submitted on third-party tools which may apply different retention periods for personal data.

The retention periods for certain types of personal data collected by automated means are specified in the Cookies section.

The retention period for personal data collected for TeachMeet applications is specified in its own privacy statement.

Data used for official accreditation requests will be kept for the period necessary to complete the accreditation request but for a maximum of 3 months.

Beyond these periods, your data won’t be retained except in an anonymized form, or insofar as required for research purposes and publication.

8. Data security

We have put in place appropriate technical and security measures to protect our infrastructure, systems, applications, premises, and processes where your personal data is stored, from accidental loss, alteration, disclosure or use or access in an unauthorised way. We process only the personal data required for achieving the purposes we have communicated to you. We have also put in place security incident and data breach response plans and procedures to deal with any security incidents and (confirmed) personal data breaches and will notify you and any applicable regulator of a data breach where we are legally required to do so.

9. What are your data protection rights?

EUN would like to make sure you are fully aware of all your data protection rights. Every platform user is entitled to the following:

• The right to access – You have the right to request EUN for copies of your personal data.
• The right to rectification – You have the right to request that EUN corrects any information you believe is inaccurate or completes the information you believe is incomplete.
• The right to erasure – You have the right to request that EUN erases your personal data, under certain conditions.
• The right to restrict processing – You have the right to request that EUN restricts the processing of your personal data, under certain conditions.
• The right to object to processing – You have the right to object to EUN’s processing of your personal data, under certain conditions.
• The right to data portability – You have the right to request that EUN transfers the data that we have collected to another organisation, or directly to you, under certain conditions.

Whenever we process your personal data based on your consent, you also have the right to withdraw your consent at any time.

If you would like to exercise any of these rights, we ask that you send us an e-mail at privacy@eun.org. Your request should be dated and signed and should clearly state and specify which right you wish to exercise. We will notify you as soon as reasonably possible and at the latest thirty (30) days after having received the request. Please note that whenever you wish to exercise a right, we may ask you to provide proof of identity. We do this to avoid a possible data breach, e.g. if an unauthorised person pretends to be you and exercises a right in your name.

10. Privacy policies of other websites

The platform contains links to other websites. This Privacy Policy applies only to this platform, so if you click on a link to another website, you should read their privacy policy.

The platform includes links to third-party websites, including European Schoolnet Academy’s social media accounts, among others. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their use of your data. We recommend that you read any privacy notices on their websites carefully.

In addition, if you linked to our platform from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party website and recommend that you check the privacy notice of that third-party website.

11. Changes within this Privacy Policy

This Privacy Policy will be updated periodically to reflect changes in our personal data processing practices through the platform. All changes to this Privacy Policy will be posted here. Your further use of this platform and our services after a change to our Privacy Policy will be subject to the updated Privacy Policy. This Privacy Policy was last updated in January 2025.

12. Contacting EUN

If you have any questions about this Privacy Policy, the processing of your personal data, if you would like to exercise one of your data protection rights, or if you have any complaint regarding the processing of your personal data by EUN, you can contact us:

13. Making an official complaint

If you feel that we have infringed your data protection rights, you may make an official complaint to the Data Protection Authority in the country where you reside or the Belgian Data Protection Authority at the following address:

Belgian Data Protection Authority
Rue de la Presse 35
B-1000 Bruxelles

COOKIE POLICY

To make this site work properly, we sometimes place small data files called cookies on your device. Most big websites do this, too.

What are cookies?

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don't have to keep re-entering them whenever you come back to the site or browse from one page to another.

How do we use cookies?

On our site, we only use a very limited number of cookies, namely user preferences. These cookies help to improve a user's experience of a website by providing a more personalised service, without having to ask you again every time; more specifically, our Open edX platform stores a limited number of user preferences, such as language and session id.

The platform applies among others the following cookies (list not exhaustive):

• csrftoken: a client-side token used to sign in the client browser to the platform
• edx-user-info: set when the user has logged in. Has information like username, version, enrolment status, urls, etc.
• edxloggedin: a “is logged in” status tracker
• openedx-language-preference: language of the user (UI)
• sessionid: edx generated session ID (can persist across browser sessions)
• welcome-message-timer: if the welcome message needs to be displayed
• welcome-message-viewed: if the welcome message has been viewed by the user
• Other specific cookies for specific actions (e.g. instructor dashboard)

The platform also uses Matomo and YouTube which may install cookies on your device:

• Matomo: Matomo is an open-source web analytics platform. It is used by EUN to measure, collect, analyse and report visitors’ data for purposes of understanding and optimising the European Schoolnet Academy platform. If you would like to see what Matomo looks like, you can access a demo version at: https://demo.matomo.cloud. Matomo is used to analyse the behaviour of the platform visitors to identify usage patterns or issues: ‘not found’ pages, search engine indexing issues, most visited pages, etc. Once the data is processed (number of visitors reaching a ‘not found’ page, viewing only one page, etc.), Matomo generates reports so that EUN can take action to improve user experience. Matomo collects information without identifying you directly.
• YouTube: The platform uses YouTube (owned by Google) as its video platform. YouTube hosts/stores videos on its servers for the platform. YouTube cookies are placed on users’ devices when a user arrives on a page where there is an embedded YouTube video. YouTube cookies are e.g. used to track viewing statistics and assign a unique identifier to the device on which the video is viewed, enabling YouTube to recognise the device. This data is sent to Google, and EUN is not in control of the data. Google can use this data to show relevant advertising in other YouTube videos.

How to control cookies?

You can control and/or delete cookies as you wish – for details, see aboutcookies.org. You can delete all cookies that are already on your device and you can set most browsers to prevent them from being placed. 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.