Last updated: 27th October 2026
This Privacy Policy explains how the THRIVE project collects, uses and protects your personal data when you visit thrive.mh4hrm.eu (the “Website”). We process personal data in line with the EU General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”) and applicable national data protection law.
1. Who we are (Data Controller)
THRIVE is a research project funded by the European Union under the Horizon Europe programme, Grant Agreement No. 101286779. The controller responsible for the processing of personal data on this Website is:
- Organisation: IDEC SA
- Address: 96, Iroon Polytechniou Avenue, 18536 Piraeus, Greece
- Email: info@idec.gr
- Phone: (+30) 210 428 6227
Data Protection Officer (if appointed): dataprotection@idec.gr
For any question about this policy or your personal data, please contact us at info@learn2thrive.eu.
2. What data we collect and why
We collect only the data we need. We do not sell your data or use it for advertising.
|
Purpose |
Data processed |
Legal basis (GDPR) |
|
Delivering the Website securely (server logs) |
IP address, date and time of access, pages requested, browser and operating system, referring URL |
Legitimate interest in running a secure, working website (Art. 6(1)(f)) |
|
Website statistics (Google Analytics) |
Pseudonymous usage data: pages visited, time on page, approximate location (country/city), device and browser type, a random cookie identifier |
Your consent (Art. 6(1)(a)), given via the cookie banner |
|
Newsletter |
Email address; date and time of sign-up and confirmation; IP address at sign-up and confirmation (as proof of consent); newsletter interaction data (opens, clicks) if tracking is enabled |
Your consent (Art. 6(1)(a)); proof of consent under Art. 7(1) |
|
Answering your enquiries |
Name, email address and message content you send us |
Legitimate interest in responding (Art. 6(1)(f)) |
Newsletter and double opt-in. We only ask for your email address. After you sign up, you receive a confirmation email. You are only added to the list once you click the confirmation link. You can unsubscribe at any time via the link in every newsletter or by writing to info@learn2thrive.eu.
Sending the newsletter with Brevo. We send our newsletter through Brevo, an email marketing service based in France that stores data on servers in the EU. Brevo can record whether a newsletter was opened and which links were clicked. We use this only in aggregate to improve our content. After you unsubscribe, your email address may be kept on a suppression list solely to ensure you receive no further emails.
Google Analytics. Google Analytics only runs if you accept statistics cookies. Google Analytics 4 does not log or store full IP addresses for users in the EU. We have set data retention to 12 months and have disabled Google Signals and advertising features.
We do not use your data for automated decision-making or profiling within the meaning of Art. 22 GDPR.
3. Cookies and consent
We use strictly necessary cookies to run the Website and, only with your consent, Google Analytics statistics cookies. We do not use advertising or social media tracking cookies. You can change your choice at any time via “Cookie settings”.
Full details, including the list of cookies we use and how long they last, are in our Cookie Policy https://learn2thrive.eu/cookie-policy.
4. Hosting, service providers and data transfers
We use trusted service providers (processors) who act only on our instructions under a data processing agreement (Art. 28 GDPR).
|
Provider |
Service |
Data location |
Transfer safeguard |
|
Infomaniak Network SA, Rue Eugène-Marziano 25, 1227 Les Acacias (Geneva), Switzerland |
Website hosting and server logs |
Data centres in Switzerland |
EU adequacy decision for Switzerland (Art. 45 GDPR) |
|
Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland |
Google Analytics |
EU, with possible transfer to Google LLC in the USA |
EU-US Data Privacy Framework adequacy decision (Art. 45 GDPR) and Standard Contractual Clauses (Art. 46 GDPR) |
|
Brevo (Sendinblue SAS), France |
Sending the newsletter and managing subscriptions |
Servers in the EU (France, Germany and Belgium) |
Processing within the EU; any transfer by Brevo’s sub-processors outside the EU/EEA is covered by Standard Contractual Clauses or the EU-US Data Privacy Framework |
Why Switzerland is safe for your data. Switzerland is not an EU member, but the European Commission has formally recognised that it ensures an adequate level of data protection. Data can therefore flow to Switzerland as it would within the EU.
We do not otherwise transfer your data outside the EU/EEA. We only share data with public authorities where required by law.
5. How long we keep your data
We keep personal data only as long as needed for the purpose it was collected for.
|
Data |
Retention period |
|
Server logs |
30 days, unless needed to investigate a security incident |
|
Google Analytics data |
12 months, then automatically deleted by Google |
|
Newsletter email address |
Until you unsubscribe; deleted within 30 days after unsubscribing |
|
Unconfirmed newsletter sign-ups |
Deleted after 7 days if the link is not clicked |
|
Proof of consent (sign-up and confirmation records) |
For as long as you are subscribed and up to 3 years after, to demonstrate compliance |
|
Enquiries sent to us |
Until the matter is closed, at the latest 12 months after |
|
All Website data |
No longer than the end of the project ([PROJECT END DATE]) plus [X] years, unless required by EU funding rules |
6. Your rights
Under the GDPR you have the right to:
- Access the personal data we hold about you (Art. 15)
- Rectify inaccurate data (Art. 16)
- Erase your data (Art. 17)
- Restrict processing (Art. 18)
- Data portability (Art. 20)
- Object to processing based on legitimate interest (Art. 21)
- Withdraw consent at any time, without affecting the lawfulness of processing before withdrawal (Art. 7(3))
To exercise your rights, email info@learn2thrive.eu. We will reply within one month. We may ask you to confirm your identity.
7. Right to lodge a complaint
You have the right to complain to a data protection supervisory authority, in particular in the EU Member State where you live or work. Our lead supervisory authority is: Αρχή Προστασίας Δεδομένων, dpa.gr
8. Security
We use appropriate technical and organisational measures to protect your data. These include encrypted connections (HTTPS/TLS), access restrictions and regular software updates.
9. Children
This Website is aimed at adults, such as educators, researchers and policymakers. The newsletter is not intended for people under the age of 16 years old. If you believe a child has given us personal data, please contact us and we will delete it.
10. Links to other websites
Our Website may link to external websites, such as partner or EU websites. We are not responsible for their privacy practices. Please read their own privacy policies.
11. Changes to this policy
We may update this policy to reflect legal or technical changes. The current version is always published on this page, with the date of the last update at the top.
12. EU funding disclaimer
Funded by the European Union under Grant Agreement No. 101286779. Views and opinions expressed are however those of the author(s) only and do not necessarily reflect those of the European Union or European Research Executive Agency (REA). Neither the European Union nor the granting authority can be held responsible for them.
