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Privacy Policy of the PLEIADE Project Privacy policy All users


--- Privacy Policy of the PLEIADE Project ---

Full policy

The following provisions are made in accordance with the EU General Data Protection Regulation 2016/679 and Article 13 of Italian Legislative Decree No. 196/2003.

This statement sets out the provisions governing the processing and use of any personal data you provide to the partners of the PLayful Environment for Inclusive leArning Design in Europe (PLEIADE) project, including to whom and where those data can be transferred. It also specifies your rights with respect to those data.

In accordance with provisions for the protection of personal data of individuals and of other entities set out in Article 13 of Italian Legislative Decree No. 196/2003 (henceforth “Italian Privacy Code”) and in Article 13 of the EU General Data Protection Regulation 2016/679 (henceforth “GDPR 2016/679”), we hereby inform you that any personal data you provide will be processed in accordance with the above mentioned regulations and with the privacy provisions that the PLEIADE partners are required to observe.

The Data Controller and Processor

The PLEIADE Partners have entered an agreement on Joint Control of Personal Data, and each has appointed the following persons to coordinate the Cooperation in connection with the implementation of the Agreement:


a) For National Research Council - Institute for Educational Technology (CNR-ITD), Rome, Italy: Donatella Persico; email

b) For Sofia University St Kliment Ohridski, Bulgaria, Krassen Stefanov; email

c) For OPEN LAB SRL, Florence, Italy, Pietro Polsinelli; email

d) For European Distance and e-learning Network (EDEN), London UK, Ferenc Tatrai; email

e) For 144 Secondary School “Narodni Buditeli”, Sofia, Bulgaria, Tsvetelina Georgieva; email

f) For Scuola secondaria di 1° grado “Rocca Bovio Palumbo”, Trani, Italy, Marilina Lonigro;

g) For “S. Avgoulea-Linardatou” School, Athens, Greece, Kleio Anagnostou;

h) For “Neapolis” Gymnasium, Limassol, Cyprus, Christos Kyriakides;

Data Protection Officers (DPO)

The officially designated DPOs for each Data Controller and their contact details are listed below:

a) National Research Council - Institute for Educational Technology:

b) Sofia University St Kliment Ohridski,


d) European Distance and e-learning Network (EDEN),

e) 144 Secondary School “Narodni Buditeli”,

f) Scuola secondaria di 1° grado “Rocca Bovio Palumbo”,

g) “S. Avgoulea-Linardatou” School,

h) “Neapolis” Gymnasium,

Purposes and obligations of personal data management

The PLEIADE partners will manage your personal data in accordance with the purposes set out in GDPR 2016/679. Specifically, these concern the activities pursuant to the Grant Agreement No. 2020-1-IT02-KA201-080089 and its Annexes, as well as the related partnership agreement of the PLayful Environment for Inclusive leArning Design in Europe (PLEIADE) project and its attachments. This includes archiving, search and analysis of data for statistical purposes.

Your personal data are needed to carry out all the activities of the above project, including training, enactment and dissemination events.

The project will be completed on 31.08.2023. All personal data will be deleted two years after the end of the PLEIADE Project.

Data processing and storage

The PLEIADE partners endeavour to protect all personal data they are provided with, and to process that data in accordance with the principles of fairness, lawfulness and transparency.

Personal data entrusted to the PLEIADE partners will be processed and transmitted for the most part in digital form, in accordance with the provisions of Article 32 of GDPR 2016/679, of Annex B, and of Articles 33-36 of the Italian Privacy Code concerning safety measures carried out by specifically designated persons, as stipulated by Article 29 of GDPR 2016/679.

We inform you that, in accordance with the principles of lawfulness, purpose limitation and data minimization stipulated in Article 5 of GDPR 2016/679, your data will be held only for the period of time necessary to fulfill the purposes for which they have been gathered and processed.

Collected data are processed on the premises of the Data Controllers and in all other places in which those involved in processing the data are located.

All data provided will be processed by authorized personnel of the PLEIADE partners in accordance with current regulations.

Data transfer and transmission

Your personal data will not be transferred or transmitted without your explicit consent, with the sole exception of communications requiring the transfer of data to the project’s funding agency (INDIRE) for the purposes of fulfilling the project grant agreement obligations.

Storage period

All data provided will be stored exclusively within EU Member States and only for the period required for their processing. Some data will continue to be stored thereafter in accordance with Article 18 of GDPR 2016/679. This will be done to allow any verification, exercising or defense of legal rights in a court of law, or for protecting the rights of another individuals or legal entities, or for important public interest of the EU or an EU Member State.

Withdrawal of consent

You have the right to withdraw your consent to processing at any time. Withdrawal of consent shall not affect (a) the lawfulness of processing based on consent before its withdrawal or (b) further processing of the same data on other legal bases (for example, contractual or legal requirements that the Data Controller is subject to).

Your rights

In accordance with Article 7 of the Privacy Code and Articles 15 and 22 of GDPR 2016/679, you have the right at any time to:

  1. Request confirmation regarding the storage and processing of any personal data about you.
  2. Obtain communication regarding the purposes of processing, the category of personal data in question, the recipient or category of recipient to whom the data have been or will be communicated, and, where possible, the period of storage.
  3. Have personal data rectified or deleted.
  4. Impose limits on data processing.
  5. Obtain data portability, namely the right to receive any personal data about you in a structured, commonly used and machine-readable format, and to transmit those data to another controller without hindrance.
  6. Object to automated individual decision-making, including profiling.
  7. Request access to personal data, have personal data rectified or deleted, impose limits on or object to data processing, in addition to data portability.
  8. Withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
  9. Lodge a complaint with a supervisory authority.

You can exercise your rights by making a written request to ITD-CNR, coordinator of the PLEIADE project, at the email address, attaching a scanned copy of your passport, driver’s licence, or similar document as proof of identity.

Your request with be handled with due diligence to ensure your rights are exercised within the limits set by these regulations. You also have the right to lodge a complaint with the Italian privacy authorities (“Garante Privacy”).