Privacy & Cookies Policy
Your privacy is very important to us.
This Privacy & Cookies Policy statement provides detailed information about the personal data that we collect, the cookies that we make use of, the ways in which we use, process or disclose your personal data, the methods for allowing or denying the activity of cookies, the privacy rights that users and data subjects have, as well as the associated services, procedures and regulations.
The terms “us,” “we” or “our” refer to h-pem. The terms “you”, “your” or “yours” refer to the user reading these Terms. The term “Content” includes, but is not limited to, all or part of any information, data, text, graphics, images, layouts, logos, audio material, films, videos or other moving images, tools, products and/or software published or otherwise available on the Website from time to time (including, without limitation, anything made available for download), and all other materials on the Website. The term “Your Content” includes the complete set of comments, messages, recommendations or links, feedback, and submitted works that you enter or submit to the Website, but not your remunerated contributions.
The term “Contributors” refers to freelance workers who create original content and are remunerated for their contributions. The term “Ambassadors” refers to volunteer workers who serve as representatives for the Website and promote it.
By using the h-pem website (the “Website”) you indicate your acceptance of the Privacy & Cookies Policy described herein. We comply with all applicable privacy laws and regulations. Acceptance of this Privacy & Cookies Policy is in addition to acceptance of the h-pem Terms & Conditions, available here.
Please note that we respect the principles and requirements of European General Data Protection Regulation 2016/679, as well as the EU-US Privacy Shield Principles.
Data Protection Officer
We have appointed a data protection officer (DPO) who is responsible for monitoring our compliance with the GDPR principles and requirements. You may contact our DPO in relation to the collection, use and processing of your personal information. Any comments, concerns and inquiries are welcome, including requests to exercise your data subject rights. You may also inquire from our DPO about the procedure for lodging a complaint with a supervisory authority in relation to our processing of your personal information here.
Personal Data
The following table summarizes the types of personal data that we collect, how and when we collect them, and for what purposes we use them:
Activity |
Type of personal data we collect |
Legitimate interests and purposes of using your personal data |
|
Browsing by all types of users |
Required a) Device IP number b) Aggregate and anonymous Website usage data collected in cooperation with Google Analytics |
Performance and security Monitor activity on the Website to:
Analytical data collection for admin purposes
|
|
Registering as an Active User |
Required a) Name b) E-mail address c) Password d) Device IP number e) Country of residence f) Occupation
Optional g) Display name h) Mobile number i) Date of birth j) Photo k) Countries lived/worked in l) City of residence m) Your social media URLs n) Your website URL o) About you (interests, skills, creative works and style) p) What you are interested in on the Website
|
Contract management
E-mail communications Manage our relationship with you: a) Ask your permission and consent to receive mission-related:
b) Keep a record of e-mail communications to:
c) Send administrative communications related to our services:
d) Receive your requests, complaints, comments, feedback, and inquiries. e) Facilitate participation in a collaboration.
Analytics, polls, and surveys
Compliance with laws Process and share your personal data to:
|
|
Submitting original work |
Required a) Name b) E-mail address c) Password d) Device IP number e) Country of residence f) Occupation g) Profile data about you (interests, skills, creative works and style) h) Title and description of the work being submitted i) Texts, images, files, audio tracks, video links that are part of your original work
Optional j) Display name k) Mobile number l) City of residence m) Date of birth n) Photo o) Countries lived/worked in p) Your social media URLs q) Your website URL r) What you are interested in on the Website
|
In addition to an Active User’s personal data usage for e-mail communications and compliance with laws:
Contract management
E-mail communications
Manage submissions across our services
|
|
Becoming a contributor |
Required a) Name b) E-mail address c) Password d) Device IP number e) Country of residence f) City of residence g) Occupation h) Profile data about you and a proposal for your first contribution i) Texts, images, files, audio tracks, video links that are part of your contribution j) Receipt
Optional
k) Display name l) Mobile number m) Date of birth n) Photo o) Countries lived/worked in p) City of residence q) Your social media URLs r) Your website URL s) What you are interested in on the Website t) Copyright license
|
In addition to an Active User’s personal data usage:
Contract management
E-mail communications
Manage contributions across our services
|
|
Becoming an Ambassador |
Required a) Name b) E-mail address c) Password d) Device IP number e) Country of residence f) City of residence g) Occupation h) Profile data about you i) A testimonial stating the reason you wish to become an ambassador
Optional j) Display name k) Mobile number l) Photo m) Your social media URLs n) Your Website URL o) Date of birth p) Countries lived/worked in q) What you are interested in on the Website
|
In addition to an Active User’s personal data usage: Contract management
E-mail communications
Manage your Ambassador’s role across our services
|
|
Commenting on the Website |
Required a) Name b) E-mail address c) Password d) Device IP number e) Country of residence f) Occupation
Optional g) Display name h) Mobile number i) Date of birth j) Photo k) Countries lived/worked in l) City of residence m) Your social media URLs n) Your website URL o) About you (interests, skills, creative works, and style) p) What you are interested in on the Website
|
In addition to an Active User’s personal data usage: Comments are stored to:
|
|
Sending feedback |
Required a) Name b) E-mail address c) Password d) Device IP number e) Country of residence f) Occupation g) Message
Optional h) Display name i) Subject j) Mobile number k) Date of birth l) Photo m) Countries lived/worked in n) City of residence o) Your social media URLs p) Your website URL q) About you (interests, skills, creative works and style) r) What you are interested in on the Website s) Texts, images, files, audio tracks, video links that are part of your feedback t) Copyright license
|
In addition to an Active User’s personal data usage for e-mail communications and compliance with laws: Admin management
Feedback is stored to:
|
|
Contacting or submitting an inquiry
|
Required a) Name b) E-mail address c) Device IP number d) Country of residence e) City f) Message
|
In addition to an Active User’s personal data usage for compliance with laws: Admin management
Questions, requests, and suggestions are stored to:
|
|
Sending a message |
Required a) Name b) E-mail address c) Password d) Device IP number e) Country of residence f) Occupation g) Message
Optional h) Display name i) Subject j) Mobile number k) Date of birth l) Photo m) Countries lived/worked in n) City of residence o) Your social media URLs p) Your website URL q) About you (interests, skills, creative works, and style) r) What you are interested in on the Website s) Texts, images, files, audio tracks, video links that are part of your feedback t) Copyright license |
In addition to an Active User’s personal data usage: Messages are stored to:
|
|
Adding a link |
Required a) Name b) E-mail address c) Password d) Device IP number e) Country of residence f) Occupation g) Link title h) Link URL
Optional i) Display name j) Mobile number k) Date of birth l) Photo m) Countries lived/worked in n) City of residence o) Your social media URLs p) Your website URL q) About you (interests, skills, creative works and style) r) What you are interested in on the Website s) Link title t) Description of link u) Your Website URL v) Copyright license
|
In addition to an Active User’s personal data usage: Links are stored to:
|
|
Giving an interview |
Personal information given during an interview. |
We store and post personal information given during interviews to:
|
|
Conducting research by h-pem staff
|
For the Content that we offer to our users on our Website we collect from external sources personal data that is considered manifestly public knowledge.
|
We store and post personal information gathered from indirect sources to:
|
* Submitter and Contributor Note: As specified in our Terms, for every work that you submit to us for publication on the Website (including remunerated contributions), you grant us the right to highlight it on our social media sites as well. You also grant us the right to present and promote your profile on our Website and on our social media sites.
** Ambassador Note: As specified in our Terms, by becoming an Ambassador, you grant us the right to promote your profile and your reason for becoming an Ambassador on our Website, as well as on our social media sites.
How long do we keep your personal data?
We will keep your personal data for as long as necessary in order to continue providing our services and satisfy legal, accounting and reporting requirements. However, we may continue to keep your personal data for a longer period in the event that we cannot delete them for legal, regulatory, technical or other reasons.
If you request to delete your personal data, we will respond immediately and delete your personal data without undue delay. To put such a request, please contact [email protected].
Personal Data Security
We have implemented appropriate technical and organizational measures to protect your personal data against unlawful security incidents or data breach. We store personal data on secure servers that are managed by our service providers. All data that we transmit in electronic transactions is protected by data encryption.
You should be aware that storing and transmitting information on the internet is never 100% secure. Storage and transmission hardware or software failures or malicious code written by hackers may compromise the security of information. We bear no liability for loss of security in such circumstances. Allowing your personal data to be transmitted and stored in the internet is risky, and by continuing to visit, access and use our Website you are consenting to that risk.
Personal Data-Related Rights and Related Actions
The GDPR rules specify the following rights for all data subjects:
Right to be informed: You have the right to be informed about the collection and use of your personal data.
Our related action: This is why we are informing you in detail about your rights, as well as the personal data that we collect, the purposes for which we collect them, their retention period and who we share them with. In this regard we will always inform you about changes, updates, and novelties. Also, if we collect data about you from other sources we will inform you about it.
Right to withdraw your consent: You have the right to withdraw your consent in relation to how we use your personal data at any time.
Our related action: If the legal basis for the processing involved is the freely given consent that now is being withdrawn, the said processing will be discontinued.
Right of access: You have the right to request a copy of the data that we hold about you.
Our related action: A copy of the personal data that we hold about you will be sent to you, together with the supplementary information that the GDPR regulation requires from us to send.
Right of rectification: You have a right to correct data that we hold about you that is inaccurate or incomplete.
Our related action: The inaccuracy, if there is one, will be corrected. If the data that we hold about you is incomplete and the completion request is reasonable and the effort needed is not disproportionate, the requested addition will be done.
Right of erasure: You can ask for the data we hold about you to be erased from our records.
Our related action: If based on the GDPR rules the request is legitimate, the data we hold about you will be erased.
Right to restriction of processing: You can ask for us to restrict our processing of your data.
Our related action: If based on the GDPR rules the request of restriction of processing is legitimate, it will be applied.
Right for notifications to recipients: When a rectification, erasure or restriction of processing is implemented, such action must be communicated to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. Also, you may request that we inform you about those recipients.
Our related action: Unless if the requested notification is demonstrably uncalled for, impossible to execute, or involves disproportionate effort, it will be executed. Also, you will receive information about the recipients involved, if you have requested it.
Right of portability: You have the right to have the personal data that you have given to us transferred to another organization, or to you.
Our related action: if based on the GDPR rules the request to transfer to you the personal data that you have provided us with, or to transfer it to another organization, is legitimate and you provide us with the proper address information, the transfer will be done.
Right to object: You have the right to object, on grounds relating to your particular situation, to our processing of your data, where we are relying on a legitimate interest of ours in order to process it.
Our related action: We will discontinue the processing involved, except if we have demonstrably compelling legitimate grounds for the processing which override your rights as a data subject.
Right to be notified about a breach of data: You have the right to receive from us a notification about any breach of data involving your personal data when we become aware of it and without undue delay.
Our related action: As soon as we become aware of such a breach, we will notify you about it either directly with an e-mail, or through public communication.
How to go about protecting your rights?
You have the right to lodge a complaint with the local supervisory authority for data protection issues. We would appreciate the opportunity to deal with your concerns before you complain to the supervisory authority, and for that purpose you can contact us at [email protected]
You can also contact our DPO when you have personal data rights related requests. Send a detailed e-mail to the DPO specifying the request that you have and, normally within one month of the receipt of your e-mail your request will be taken care of. Note that we will do our best to respect the one month deadline, but sometimes, if your request is complex or you have made several requests, we might need more time. In this case, we will write to you without delay and notify you. Note also that if the request is manifestly unfounded or excessive, in particular, because of its repetitive character, we will be obliged to refuse to act on the request. If this is the case, we will notify you about it without delay.
Please note that in order for us to be able to process your request and to complete the processing of your request in one month the following additional requirements apply:
- if your request applies to the entirety of your data, you must say so; otherwise, you must specify precisely what part of your data it applies to
- in case you withdraw consent, you must indicate clearly the data and the processing for which you are withdrawing consent
- in case you request a rectification, you have to be precise about the inaccuracy to be corrected or missing data to be added
- in case you request a restriction of processing, you have to be very precise about the data involved, the specific processing to be restricted and the restriction to be applied
- in case you request a transfer of your data to another organization, you must give our DPO the correct name and contact details (e-mail, phone numbers, etc.) of the organization.
Note that we will execute your request free of charge, except when it is manifestly unfounded or excessive, in particular because of its repetitive character. If this is the case, we will either charge a reasonable fee taking into account the administrative costs of executing the request, or we will be obliged to refuse to act on the request. In either case we will reply without delay and notify you.
When and how we will contact you?
We might send you occasional e-mails as follows:
A. Updates, notifications, invitations
a) notify you about changes in our policies and guidelines;
b) send you information and links for new content and services on our website ;
c) send you invitations for taking part in activities, collaborations and surveys.
Note: each of the above three types of e-mails will be sent to you only if you have given your consent for receiving such communications.
B. Practical communications
a) respond to your queries, requests, complaints and e-mailed comments
b) check with you about activities and services you have signed up for
c) communicate with you about your submissions and occasional applications
d) request information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that we are dealing with the correct owner of the personal data involved.
Note that in case you have provided us with your mobile number, and only if communicating with you on an important matter by e-mail has failed multiple times, we may contact you by calling you. This will be very rare. In the case of group (A) communications above, you can avoid being contacted by phone by not giving your consent.
Third Party Service Providers
Our website is cooperating with certain third parties, making use of their technologies in providing secure and exciting services to our users. These third parties are:
- Leaseweb, for hosting
- Google Analytics, for analytics
- Google Maps, for maps
- OneTrust, for privacy and consent management
- Youtube, for video sharing
- Facebook, Instagram, and Twitter, for social network services and associated web technology
-
Cloudflare, for CDN services
-
ShareThis, for social sharing tools
The privacy rights related mechanism in place with all our third-party partners conforms to the European General Data Protection Regulation 2016/679.
Cookies and Cookie Management
What are cookies and web beacons?
A "cookie" is a small data file that is sent from a web server to your browser and stored in the memory or the hard drive of your device. It helps the website that created it remember some information about you (such as your approximate location, your e-mail address), as well as your device (such as the device’s IP address), the browser you are using (such as browser type), and your browsing activity (such as pages you are visiting). Both we and some third party websites may put cookies in your browser. Some third parties may also use a similar technology called web beacon. A Web beacon (also called web bug) is an often transparent, tiny graphic image that is placed on a website and is used to monitor the behavior of the user visiting the website. The information it collects is similar to what a cookie collects. Web beacons often work in combination with cookies.
What are the different types of cookies?
- Session cookies are created when you start visiting a website and are deleted from your device when you close your browser.
- Persistent cookies are saved on your device for a fixed period of time after the browser has closed.
- First party cookies are cookies that are set by the website you are visiting.
- Third party cookies are cookies created by third parties with whom we cooperate to obtain useful services.
What types of service do cookies provide?
You may encounter five categories of cookies on our website:
- Necessary cookies: Required to navigate the website and use its functions successfully. They do not collect any personal data.
- Functional Cookies: Used to authenticate your identity and to remember your preferences. For instance, they help us remember if you have visited our site before so that messages intended for first-time users are not displayed to you.
- Performance cookies: Used to monitor the performance of our website. They collect analytical-statistical information on the way the website and its pages are used (for instance, which pages users visit the most, what is the number of visitors to the website, how do visitors move around the website). Google Analytics, with whom we are cooperating to obtain analytical services creates and stores such cookies.
- Social media cookies: These cookies are created and stored by social network servers. We cooperate with social networks and include in our pages their plug-ins (such as “Like”, “Share”, “Follow” buttons). Even if you do not click on such buttons, the code associated with these plug-ins may make use of cookies to collect information about you, such as the pages that you view and your IP address.
- Advertising cookies: Used to record your interests, to remember what sites and pages you have visited and allowing the website and third parties to show personalized advertisements tailored to your interests. Also used to measure the effectiveness of advertising campaigns. In its current phase of operation our Website will not do any advertising. When there is a change in this regard, we will inform you. Advertising done on our website in future may include personalized advertising, but only if beforehand you give us your consent for such personalization.
How can you manage cookie activity by giving/denying consent?
- Necessary cookies: You will not be allowed to opt-out from the use of this type of cookies, as without them the basic services of our website will not be available to you.
- Functional Cookies: Upon your first visit to our website, and every time after deleting cookies from your device, you will be asked to give your explicit consent for the activity of this type of cookies. Also, anytime you feel like it, you may withdraw your consent and opt-out, but you will then be disabling some services and your use of our website will be less smooth and pleasant.
- Performance cookies: Upon your first visit to our website, and every time after deleting cookies from your device, you will be asked to give your explicit consent for the activity of this type of cookies. Also, anytime you feel like it, you may withdraw your consent and opt-out, but then you will be denying us the possibility of obtaining very useful aggregated information that will help us improve our website’s services and performance.
- Social media cookies: Upon your first visit to our website, and every time after deleting cookies from your device, you will be asked to give your explicit consent for the activity of this type of cookies. Also, anytime you feel like it, you may withdraw your consent and opt-out.
Note that we do not recommend turning cookies off, because preferences and some functionality will be lost and your experience on our website will be more tasking and less pleasant.
Other ways of deactivating cookies
If you think that cookies are denying you privacy and wish to deactivate them, you can change the preferences/settings in your web browser to control cookies. In general, you can delete cookies or prevent automatic acceptance of cookies by the browser. You can also block all cookies. To learn about these possibilities please refer to the help menu within the browser that you are using. The following links may also be of help:
Managing cookies in Internet Explorer
Managing third party cookies
We do not control the use and management of third party cookies. Please visit the relevant third party's website to find directions about the cookies they set and how to manage them. Here are links that may provide you information useful in managing cookies set by third parties:
- To opt out of Google Analytics data collection you can use the browser add-on developed by Google. You can find information about this option at https://tools.google.com/dlpage/gaoptout/?hl=en
- To find help in managing cookies set by Facebook you can find useful information at https://www.facebook.com/policy/cookies
- To find help in managing cookies set by Instagram you can find useful information at https://help.instagram.com/1896641480634370
- To find help in managing cookies set by Twitter you can find useful information at https://help.twitter.com/en/rules-and-policies/twitter-cookies
- To manage Youtube cookies and Google Map cookies, the Google Privacy & Terms page may provide you with useful information. You can find the page at https://policies.google.com/?hl=en&gl=ZZ
- You can access the terms of use and cookie policy page of our hosting company Leaseweb at https://www.leaseweb.com/legal/website-terms-of-use-and-cookie-statement
- You can access the cookies policy of One Trust, the third party providing privacy and consent management services to us, at https://www.onetrust.com/cookie-policy/
How to render web beacons ineffective
You can normally prevent web beacons from tracking your activity and collecting personally identifiable information by switching off cookies in your browser. There are also browser add-ons and extensions that block web beacons.
Do Not Track signals
h-pem does not respond to Do Not Track (DNT) signals. Do Not Track (DNT) is a preference you can set in your web browser to let the websites you visit know that you do not want to be tracked.
Disclosure of your personal data and international transfers
We may disclose personal data in the following cases:
a) As noted previously, in providing our services we will sometimes cooperate with third party service providers. We will always work with reliable providers who have adequate privacy and security policies. We will always inform you about the service providers with whom we cooperate. In the current phase of operation of our website, some or all of your personal data will be accessible to the third party service providers Leaseweb, Google Analytics, Facebook Instagram, Twitter, and Youtube.
b) In its current phase of operation, our Website will not do any advertising. When there is a change in this regard, we will inform you. Advertising done on our website in the future may include personalized advertising, but only if beforehand you give us your consent for such personalization.
c) While implementing our website’s Collaboration service, if the given collaboration project involves disclosing your personal data we will disclose only a subset of your personal data that is necessary for the successful execution of the specific collaboration, and only after obtaining your explicit consent for that disclosure.
d) We may disclose your personal data in responding to requests from law enforcement agencies, judicial courts, regulating agencies or authorities, government authorities or other organizations, only if the requests are legal.
e) If necessary, we may disclose a minimized subset of your personal data to our lawyers and in court so as to:
- defend our rights and property during court actions in general, including for enforcing the requirements of our Terms & Conditions;
- protect the rights, property or personal safety of our users, directors, personnel, contributors, sponsors, and the public;
- protect us against fraud, illegal or criminal activities, claims, and other liabilities.
f) We may disclose your personal data to our agents or sub-contractors. In such cases, the agent or sub-contractor in question will be obligated to use that personal data in accordance with the terms of this privacy statement.
g) If we are involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different privacy policy.
In relation to disclosures and our liabilities, please note that:
a) Our website will have links to other websites. If you click on these links and visit the corresponding third party websites, they may collect personal data from you and disclose them to other parties cooperating with them. We cannot control their operations and we cannot be held responsible for them. It is up to you to be careful in this regard.
b) Transmissions to and from this site may be read or intercepted by others. This is not something we can stop or control, and we will not be deemed to have any liability for unsolicited or intercepted messages.
c) You should be aware that any personal data that you might disclose in the chat areas can be collected and used by others and could result in unsolicited messages from other parties.
d) While any personal data transmitted with an e-mail, such as the sender's name, e-mail or home addresse, will be protected in accordance with the policies set forth in this policy, any non-personal information you provide to us by e-mail, including, but not limited to, feedback, data, answers, questions, comments, suggestions, plans, ideas or the like, shall be deemed to be non-confidential and we assume no obligation to protect any such non-personal information from disclosure.
International transfer of data
Third parties mentioned in the disclosure points above may be based outside your country. The servers on which our data is stored as well. Also, your data may be processed by our staff residing outside your country. This implies that your personal data may be subject to international transfer. We do this on the basis of your consent to this policy. We will always require from such third parties as well as our staff to guarantee the security of your data and to respect your privacy rights as stipulated in the European General Data Protection Regulation 2016/679 and the US-EU Privacy Shield Principles.
Children’s Privacy
Our website does not address anyone under the age of 13 (“Children”). We do not knowingly collect personally identifiable information from children under 16. We do not knowingly allow children under 16 to register as Active User.
If you are under 16 please do not give us any personal data.
Parents/guardians who wish to provide parental consent should kindly contact [email protected].
If you are a parent or guardian and are aware that your child has provided us with personal information, please contact [email protected]. If we discover that a child under 16 has provided us with personal information, without your parental consent, we will delete such information from our servers, before we process any personal data or other information.
If you believe that we might have any information from or about a child under the age of 16, please contact [email protected].
Updating our Privacy & Cookies Policy
We may update our privacy and cookies policy from time to time. Any revised policy will apply to the use of the Website from the date of its publication on the Website. The date of publication will be indicated in the Website footer, next to “Privacy and Cookies Policy”. Please check the website footer regularly to ensure you are familiar with the current version of the policy. If you have given us consent for receiving notifications, we will notify you by e-mail about each and every new version of our Privacy and Cookies Policy.
Privacy policies of other websites
This website contains links to other websites. We are not responsible for the privacy policies or practices of other websites.
Contact us
If you have any questions about this privacy policy, please write by e-mail to [email protected].