Acting as a consortium partner for communication activities within the 4Growth project (hereinafter, the Project), Evenflow SPRL (“Data Controller”) has set up and is curating the 4Growth website: 4Growth (hereinafter, the Website) and is managing the distribution of project-related news.
This privacy policy (hereinafter, the Policy) concerns both the voluntarily submitted data and the automatically collected data which users have provided while browsing the Website. The Policy outlines the terms of data collection, storage, and processing, answering the following questions:
Part of the data we collect is Personal Data, meaning any information relating to an identified or identifiable natural person. Information is collected in two ways: (I) voluntarily supplied by the user, and (II) automatically collected while browsing the Website or reading the email updates.
Information you supply
Interested visitors may submit, of their own volition, Personal Data through the various “Contact forms” on the Website. You are free to consent to the use of your data for specific purposes which are clearly stated at the point of data collection. When deemed necessary, we may share this information with other consortium partners which are GDPR compliant. Visitors may submit the following data (including Personal Data):
Name
Email address
A description (by a selection of check-boxes) of their desired engagement model (e.g. applicant, investor, etc.)
Information collected while you browse the Website or read the email updates
We use Google Analytics to collect information about how and when the Website is used, although none of this kind of information is personally identifiable, in and of itself.
The information collected includes:
Your device’s IP address, from which an estimation of your geographic location is made (note that we have instructed Google Analytics to mask a portion of the IP address which is stored and processed);
The device and/or browser you used to access the Website;
Which pages you have viewed, in which order, and for how long.
We use cookies (small text files stored on your computer) and other technologies (such as pixel tags) to record information about your browsing, for instance, whether you have visited the Website before.
We collect similar information related to our email updates, including:
How many times the email was opened;
Which links were clicked and how often.
Why do we collect information?
We collect information for one or more of the following reasons:
To respond to questions and requests concerning the project, e.g. for the means of guiding interested parties through the process of becoming applicants;
To send out emails in order to inform subscribers about our project;
To monitor, evaluate and improve our communication activities.
Who holds or processes the data?
We use a range of third-party service providers (“Data Processors”) to assist us in delivering services. Aside from these service providers, and when deemed necessary, certain Project partners, we do not share your information with any other third parties. We never sell your information or use it for advertising purposes.
The Data Processors we use include:
Mailchimp to send out email updates;
FormCraft/Wordpress to collect subscription information from interested visitors;
Google Analytics to processes information about your use of the Website.
Evenflow SRL has signed Privacy Policy Agreements (or equivalent legal documents) with these providers. We share information with them for the purposes of supplying the services mentioned, in a manner compliant with the Policy.
Where and for how long do we keep your information?
We take all reasonable means to make sure that Personal Data is safe with us. Physical and electronic security practices as well as managerial measures are in place. They are regularly reviewed as part of a maintenance and update cycle.
Data are sometimes stored by third parties (as listed above), and as such may be stored anywhere in the world.
Unless you request otherwise, we will keep the information you submit voluntarily with us until 6 months after the end of the project, i.e., the 31st of December 2026.
We have instructed Google Analytics to store data related to user identifiers (including cookies) for 38 months before automatically deleting them. The countdown is reset when a user takes an action such as returning to the Website.
Non-identifiable, aggregate information will be recorded in our project reports (e.g. in the form of charts and diagrams) and as such does not have a “shelf life”.
What are your rights and choices?
You can choose to disable cookies or delete any individual cookie (see here). You can read more about how Google Analytics collects and processes website use data here, and about its use of cookies here.
Across all the platforms we use for subscription, you can choose to unsubscribe at any time. In compliance with applicable law, we can make users’ Personal Data available by their request. Similar requests can be submitted for the purpose of correcting, updating or deleting data. Please send such requests to the email address below.
Which is the applicable law and jurisdiction?
Any dispute arising from, or related to the use of the Website or to the acceptance, interpretation or observance of the Policy shall be submitted to the exclusive jurisdiction of the competent Court of Belgium which shall apply the Belgian law.
How to contact us?
To know more about our Policy, or make a request, please contact us at 4growth@evenflow.eu
