Privacy Policy

1. Joint Controllers

The Read.For Real project is implemented by a consortium of partner organisations which jointly determine the purposes and means of processing personal data in connection with the implementation, coordination, communication, promotion, dissemination and reporting of the project.

For these processing activities, the following organisations act as Joint Controllers within the meaning of Article 26 of the General Data Protection Regulation (GDPR):

• Fundacja Powszechnego Czytania (Universal Reading Foundation), Poland;
• Biblioteka Narodowa (National Library of Poland), Poland;
• Ciclic Centre-Val de Loire – EPCC, France;
• Stiftung Lesen, Germany;
• Chetene (Reading) Foundation / Reading Foundation, Bulgaria;
• Federation of European Publishers (FEP), Belgium;
• EURead, Belgium.

The Joint Controllers cooperate in the implementation of the Read.For Real project and may process and share personal data with one another where necessary for the purposes described in this Privacy Policy.

The Joint Controllers have established arrangements concerning their respective responsibilities under the GDPR, including the handling of requests and the exercise of data subject rights.

For questions concerning the processing of personal data in connection with Read.For Real, or to exercise your rights, you may contact:

Fundacja Powszechnego Czytania (Universal Reading Foundation)
Przyokopowa 33
01-208 Warsaw
Poland
E-mail: [email protected]

Requests may be handled in cooperation with the relevant Joint Controller(s).

2. Scope and Purposes of Data Processing

The Read.For Real website provides information about the project and allows users and organisations to participate in project activities through various online forms.

Depending on the form used, personal data may be collected for the following purposes:

• registration of Read.For Real events and reading activities;
• registration for workshops, conferences, meetings and other project events;
• communication with participants, organisers, educators, institutions, authors and other persons involved in the project;
• coordination of project activities at European and national level;
• cooperation with National Hubs;
• distribution of Welcome Packs and other project materials;
• promotion and dissemination of Read.For Real;
• documentation, evaluation and reporting of project activities;
• operation of the Read.For Real newsletter;
• responding to enquiries;
• providing information about Read.For Real activities, events, materials and resources.

Depending on the relevant form, personal data may include:

• first and last name;
• e-mail address;
• telephone number;
• organisation or institution;
• professional role;
• country;
• city;
• information concerning the event or activity;
• website or social media links;
• other information voluntarily provided by the user.

Sharing with Consortium Partners

Where the user has provided the relevant consent through the applicable form, personal data may be shared with all Read.For Real consortium partners listed in Section 1.

This enables the partners to jointly implement, coordinate, communicate, promote, disseminate, document and report on the Read.For Real project.

The consortium partners may process the data only for purposes connected with the Read.For Real project and other directly related activities described in this Privacy Policy.

Sharing with National Hubs

Read.For Real operates through a network of national and regional National Hubs.

Where relevant to the user’s country or the activity concerned, personal data may also be shared with the appropriate National Hub.

National Hubs may use the data to:

• communicate with users in the relevant national language;
• provide information and support concerning Read.For Real;
• organise and coordinate local events;
• communicate with event organisers and participants;
• distribute Welcome Packs and other project materials;
• support schools, libraries, cultural institutions and other local organisations;
• promote and disseminate Read.For Real locally.

The current list of National Hubs is available in the “Find Your Hub & Event” section of the Read.For Real website.

3. Legal Basis for Processing

Personal data are processed in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and applicable national data protection legislation.

Depending on the specific processing activity, the legal basis may include:

• Article 6(1)(a) GDPR – consent, where the user has provided explicit consent to the processing of their personal data for one or more specific purposes;
• Article 6(1)(b) GDPR – performance of a contract or taking steps at the request of the data subject, where processing is necessary to manage participation in an activity or provide a requested service;
• Article 6(1)(c) GDPR – compliance with a legal obligation, where processing is necessary to comply with a legal obligation;
• Article 6(1)(f) GDPR – legitimate interests, where processing is necessary for the legitimate interests pursued by the Joint Controllers, provided that such interests are not overridden by the rights and freedoms of the data subject.

Where consent is requested through an online form, it will be obtained through a clear affirmative action, such as ticking a checkbox. Pre-ticked boxes or inactivity do not constitute valid consent.

Consent may be withdrawn at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

The legal basis applicable to a particular processing activity will be indicated in the relevant form or information provided at the time the personal data are collected.

4. Data Recipients

Personal data collected through Read.For Real forms may be shared with:

Read.For Real Consortium Partners

The seven organisations forming the Read.For Real consortium:

• Fundacja Powszechnego Czytania (Universal Reading Foundation);
• Biblioteka Narodowa (National Library of Poland);
• Ciclic Centre-Val de Loire – EPCC;
• Stiftung Lesen;
• Chetene (Reading) Foundation / Reading Foundation;
• Federation of European Publishers (FEP);
• EURead.

The purpose of sharing is to enable the consortium partners to implement, coordinate, organise, communicate, promote, disseminate, document and report on the Read.For Real project.

Read.For Real National Hubs

Personal data may also be shared with the relevant National Hub responsible for the user’s country or the activity concerned.

National Hubs may use the data for communication, local coordination, organisation of activities, distribution of project materials and local promotion of Read.For Real.

The current list of National Hubs is available in the “Find Your Hub & Event” section of the website.

Technical and Service Providers

Personal data may also be processed by service providers supporting the website and project activities, including:

• GetResponse – newsletter and e-mail communication;
• MyDevil.net – website hosting and technical services;
• Google Analytics or other analytics providers, where applicable;
• other technical providers necessary for the operation of the website and project services.

Such providers process personal data only to the extent necessary to provide their services and in accordance with applicable data protection requirements.

GetResponse

The Read.For Real project uses GetResponse to manage and distribute newsletters and electronic communications.

Personal data submitted when subscribing to the newsletter, including the user’s e-mail address and first name, may be processed by GetResponse on behalf of the relevant Joint Controller(s).

GetResponse acts as a data processor for the relevant processing activities and processes personal data in accordance with applicable data processing arrangements.

5. Cookies and Analytical Tools

The website www.readforreal.com uses cookies and similar technologies.

Cookies may be used for:

• proper functioning of the website;
• website security;
• maintaining user preferences;
• improving website performance;
• analysing website traffic and user behaviour;
• improving website content and functionality.

The website may use Google Analytics or other analytical tools.

Where required by applicable law, non-essential cookies and analytical technologies will only be activated after the user’s consent has been obtained.

Users may manage or withdraw their cookie preferences through the cookie settings available on the website or through their browser settings.

6. Data Retention Period

Personal data are retained only for as long as necessary to fulfil the purposes for which they were collected or for as long as required by applicable law, contractual obligations or project reporting requirements.

In particular:

• newsletter data are retained until the user unsubscribes or withdraws consent, unless another lawful basis permits continued retention;
• event registration data may be retained for the period necessary to organise, document, evaluate and report on Read.For Real activities;
• workshop and conference registration data may be retained for organisational, administrative and reporting purposes;
• contact correspondence may be retained for as long as reasonably necessary to handle the enquiry;
• data processed through GetResponse are retained in accordance with the applicable service and data processing arrangements;
• analytical data are retained in accordance with the relevant analytics service settings and applicable legal requirements.

After the applicable retention period has expired, personal data will be deleted, anonymised or securely disposed of unless further retention is required by law.

7. Data Subject Rights

Under the GDPR, data subjects may have the following rights, subject to applicable legal conditions:

• the right to access their personal data;
• the right to rectify inaccurate or incomplete personal data;
• the right to request erasure of personal data;
• the right to request restriction of processing;
• the right to data portability;
• the right to object to processing based on legitimate interests;
• the right to withdraw consent at any time where processing is based on consent.

To exercise your rights, please contact:

[email protected]

Requests may be handled in cooperation with the relevant Joint Controller(s).

You also have the right to lodge a complaint with a competent data protection supervisory authority.

In Poland, the competent supervisory authority is:

President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych – UODO).

8. Data Security

The Joint Controllers and their service providers apply appropriate technical and organisational measures to protect personal data against:

• unauthorised access;
• accidental or unlawful destruction;
• accidental loss;
• alteration;
• unauthorised disclosure;
• other unlawful forms of processing.

Access to personal data is limited to persons and entities that require access for legitimate project, organisational, administrative or technical purposes.

Appropriate security measures may include access controls, authentication procedures, confidentiality obligations, secure data transmission, backups and other safeguards appropriate to the nature and risks of processing.

Nevertheless, no method of transmitting or storing information electronically can guarantee absolute security.

9. Social Media, Photographs and Project Communication

Read.For Real and its consortium partners may communicate and promote the project through websites, newsletters, social media, publications, reports and other communication channels.

Where photographs, videos, quotations, names or other information identifying individuals are published, the relevant legal requirements will be observed and, where necessary, appropriate consent will be obtained.

The Read.For Real website may also publish information about registered events through its interactive event map. Personal information will only be published where there is an appropriate legal basis for such publication.

The social media profiles operated by Read.For Real and its consortium partners are also subject to the terms and privacy policies of the respective social media providers.

Personal data shared directly by users with social media providers are processed by those providers in accordance with their own policies.

10. Changes to the Privacy Policy

This Privacy Policy may be updated from time to time to reflect:

• changes in the Read.For Real project;
• changes to the website or its functionalities;
• changes in the organisations participating in the consortium;
• changes in data processing activities or service providers;
• changes in applicable data protection legislation.

The current version of this Privacy Policy will always be available on www.readforreal.com.

Where required by applicable law, users will be informed about material changes to this Privacy Policy.

11. Use of Read.For Real Materials

Materials made available through the Read.For Real website, including educational scenarios, templates, visual materials, logos, promotional materials and other project resources, are intended to support the objectives and activities of the Read.For Real / European Authors Day project.

Unless otherwise stated, such materials may be used, copied and distributed by individuals and organisations participating in or supporting Read.For Real for non-commercial purposes connected with:

• reading promotion;
• educational activities;
• cultural activities;
• literary activities;
• implementation of Read.For Real events;
• promotion and dissemination of the Read.For Real project.

The use of Read.For Real materials, logos or visual identity for purposes unrelated to the project is not permitted without prior authorisation.

In particular, the materials may not be used for:

• commercial sale or resale;
• promotion of unrelated products or services;
• misleading representation of an affiliation with Read.For Real;
• political campaigning or political communication;
• religious campaigning or religious communication;
• activities that could damage the reputation, integrity or objectives of the Read.For Real project.

The Read.For Real consortium and Fundacja Powszechnego Czytania (Universal Reading Foundation), as the coordinating organisation of the project, are not responsible for unauthorised, misleading or otherwise improper use of Read.For Real materials, branding or visual identity by third parties.

For questions concerning the permitted use of Read.For Real materials or branding, please contact:

[email protected]

Read.For Real / European Authors Day
11 November – 12 December
www.readforreal.com