Privacy Policy

1. Who We Are

This website is operated as part of the OCTOPUS project (Offering Cross-disciplinary Training for Inclusive Preparation for School Exams), an Erasmus+ KA220-SCH Cooperation Partnership in School Education. Project reference number: KA220-SCH-063BB39C.

The project coordinator and data controller is the Rogers Foundation for Person-Centred Education, based in Budapest, Hungary. The project was submitted through HU01 — Tempus Public Foundation.

The project partnership includes Rogers Foundation (Hungary), Narratologies P.C. (Greece), Üsküdar District National Education (Türkiye), and Centre for Systems Solutions (Poland).

For any privacy-related enquiries, please contact us at: info@rogersalapitvany.hu

2. What Data We Collect

We collect personal data only when you voluntarily provide it through our website forms. This includes:

Newsletter subscription: your email address and the date you subscribed.

Contact form: your name, email address, organisation (optional), subject of enquiry, and message.

Feedback form: your name, email address, professional role (teacher, student, trainer, parent, or other), and feedback text.

Website analytics: we use Google Analytics 4 to collect anonymised usage data such as pages visited, time on site, device type, and approximate geographic location. This data does not identify you personally. See Section 6 for more details.

3. Why We Collect Your Data (Legal Basis)

We process your personal data based on the following legal grounds under Articles 6 and 9 of the EU General Data Protection Regulation (GDPR):

Consent (Art. 6(1)(a) GDPR): when you voluntarily submit a form on our website, you consent to us processing the data you provide for the stated purpose. You may withdraw your consent at any time by contacting us.

Legitimate interest (Art. 6(1)(f) GDPR):we use anonymised analytics data to improve our website and understand how our resources are being used. This serves the project's educational and dissemination objectives under the Erasmus+ programme.

4. How We Use Your Data

We use the data we collect for the following purposes only:

Newsletter emails: to send you project updates, resource announcements, and event invitations related to the OCTOPUS project.

Responding to enquiries: to answer questions submitted through the contact form.

Project evaluation:to collect and analyse feedback from teachers, students, and trainers as part of the project's quality assurance and reporting obligations under the Erasmus+ programme.

Website improvement: to understand how visitors use the website and improve the user experience.

We do not use your data for marketing purposes unrelated to the OCTOPUS project, and we never sell or rent your data to third parties.

5. Who Has Access to Your Data

Your data may be accessed by:

OCTOPUS project partners: Rogers Foundation (Hungary), Narratologies P.C. (Greece), Üsküdar District MEM (Türkiye), and Centre for Systems Solutions (Poland) — only for project-related purposes such as responding to your enquiry or processing feedback for project reports.

Hosting providers: our website is hosted on Vercel (frontend) and Render (CMS backend), both of which process data in accordance with their respective privacy policies and GDPR obligations. Data may be stored on servers in the EU or the United States, with appropriate safeguards in place.

European Commission / Tempus Public Foundation:aggregated, anonymised data may be included in project reports submitted to the Erasmus+ National Agency (Tempus Public Foundation, Hungary) and the European Commission as part of the project's contractual obligations. Individual personal data is not shared with these bodies.

6. Cookies and Analytics

This website uses Google Analytics 4 (GA4) to collect anonymised data about website usage. GA4 uses first-party cookies to distinguish unique users and sessions. The data collected includes pages visited, session duration, referral source, device type, and approximate location (country/city level).

GA4 is configured to anonymise IP addresses, and we do not enable Google Signals or any advertising features. No personally identifiable information is sent to Google Analytics.

You can opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on, or by adjusting your browser's cookie settings.

7. Data Retention

Form submissions (contact, feedback, newsletter) are retained for the duration of the OCTOPUS project (September 2025 – February 2028) and for up to 5 years after the project ends, as required by Erasmus+ programme rules for audit and evaluation purposes.

Analytics data is retained within Google Analytics for 14 months, after which it is automatically deleted.

You may request deletion of your data at any time (see Section 8).

8. Your Rights

Under the GDPR, you have the following rights regarding your personal data:

Right of access: you can request a copy of all personal data we hold about you.

Right to rectification: you can ask us to correct any inaccurate or incomplete data.

Right to erasure: you can ask us to delete your personal data at any time.

Right to restrict processing: you can ask us to temporarily stop processing your data while a complaint is being resolved.

Right to data portability: you can request your data in a structured, machine-readable format.

Right to object: you can object to data processing based on legitimate interest.

Right to withdraw consent: you can withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, contact us at info@rogersalapitvany.hu. We will respond within 30 days.

If you believe your data protection rights have been violated, you have the right to lodge a complaint with your national data protection authority. In Hungary, this is the National Authority for Data Protection and Freedom of Information (NAIH).

9. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encrypted connections (HTTPS/TLS), access controls on our CMS and database systems, and regular review of security practices.

10. Children's Data

This website is intended for educators, trainers, and adult stakeholders. We do not knowingly collect personal data from children under the age of 16. If you believe a child has submitted personal data through our forms, please contact us and we will delete it promptly.

During the piloting phase of the OCTOPUS project, any data collected from students (including minors) will be processed in accordance with separate consent procedures, parental/guardian authorisation where required, and the ethical guidelines of the Erasmus+ programme.

11. International Data Transfers

The OCTOPUS partnership includes organisations in Hungary, Greece, Türkiye, and Poland. Personal data may be transferred between these countries for project-related purposes. For transfers to countries outside the European Economic Area (EEA), including Türkiye, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) adopted by the European Commission, or your explicit consent.

Our hosting providers (Vercel, Render) may process data in the United States under Standard Contractual Clauses and/or the EU-US Data Privacy Framework.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The “Last updated” date at the top of this page indicates when the most recent revision was made. We encourage you to review this page periodically.

13. Contact

For any questions about this Privacy Policy or the processing of your personal data, contact the project coordinator:

Rogers Foundation for Person-Centred Education
Budapest, Hungary
Email: info@rogersalapitvany.hu
Website: www.rogersalapitvany.hu

See also: GDPR Compliance · Accessibility Statement