1. Introduction

The Federation of Social NGOs in Bulgaria is committed to protecting personal data and respecting the privacy of users of the DigiDementia Learning Platform. Personal data are processed in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and applicable national legislation. This Privacy Policy explains the reasons for processing personal data, the way such data are collected, handled and protected, and the rights of users.

2. Why and How We Process Your Personal Data

Personal data are collected and processed for the purpose of enabling user registration, providing access to educational content, monitoring participation and progress in learning activities, and fulfilling reporting, monitoring, evaluation, and auditing obligations under the Erasmus+ Programme. The processing also supports improvement of the platform and ensures system security. No automated decision-making or profiling is carried out.

3. Legal Basis for Processing

The processing of personal data is based on Article 6(1)(a) GDPR (consent), Article 6(1)(b) GDPR (performance of a service), Article 6(1)(c) GDPR (compliance with legal obligations), and Article 6(1)(f) GDPR (legitimate interests). Processing is necessary for fulfilling obligations related to Erasmus+ programme implementation, including monitoring and reporting requirements.

4. Categories of Personal Data

The platform processes identification and contact data such as name, email address, and country of residence. It also processes account-related information including login credentials and records of course participation and progress. Technical data such as IP address, browser type, and device information may also be collected. The provision of personal data is necessary to register and use the platform.

5. Data Retention

Personal data are retained for the duration of the DigiDementia project and for a period of up to five years after its completion, in order to comply with Erasmus+ reporting and audit requirements. After this period, data will be securely deleted or anonymised.

6. Protection of Personal Data

Appropriate technical and organisational measures are implemented to protect personal data. The platform is hosted on secure servers within the European Union and uses encryption and access control mechanisms. Access to personal data is restricted to authorised persons who require it for project-related purposes.

7. Access to Data and Data Sharing

Access to personal data is granted to authorised staff of the Federation of Social NGOs in Bulgaria and to authorised project partners within the DigiDementia Erasmus+ consortium, strictly on a need-to-know basis. Data may also be shared with the European Commission and National Agencies for reporting and auditing purposes, as well as with IT service providers responsible for hosting and maintaining the platform. Personal data are not transferred outside the European Economic Area unless appropriate safeguards are in place.

8. Rights of Data Subjects

Users have the right to access, rectify, or erase their personal data, as well as the right to restrict or object to processing and to request data portability, in accordance with GDPR. Users may withdraw their consent at any time without affecting the lawfulness of prior processing. Requests to exercise these rights can be submitted to the data controller.

9. Contact Information

The data controller is the Federation of Social NGOs in Bulgaria. For any questions regarding this Privacy Policy or the processing of personal data, users may contact the organisation via its official communication channels. Users also have the right to lodge a complaint with their national data protection authority.

10. Updates to This Policy

This Privacy Policy may be updated to reflect legal, technical, or operational changes. Users will be informed of significant updates through the platform.

CONTACTS of FSSB

Address: Sofia 1612, Tserova Gora Str. 1, Bulgaria

Email: vorstand@fssb.bg

Telephone: +(359) 89 938 2413