1. Who is the Data Controller?
1.1. The organization with the name “Alma Mater Studiorum – University of Bologna” (“UNIBO”) is the Data Controller for the processing of the User’s personal data (hereinafter referred to as “Data Controller”).
1.2. Data Controller’s Contact details:
By sending an email at the following email address: firstname.lastname@example.org
By sending correspondence to the following address:
Alma Mater Studiorum – University of Bologna
via Zamboni 33
40126 – Bologna
2. What is the purpose and the legal basis for User’s data processing?
2.1. Usage of the AI on-Demand platform
The AI on-Demand platform (AIoD) seeks to act as a resource to facilitate European research and innovation in AI. The objective of the platform is to support all solutions and tools that contribute to the ecosystem of excellence and the ecosystem of trust, which define the European Vision of AI.
AI assets and tools are made accessible through the platform to be used by the broader community to upskill and transfer knowledge to innovation sectors. It supplies new services and a marketplace for non-experts, so that they can experiment and deploy AI solutions in their own workplaces.
For all purposes related to making use of the platform Website (including but not limited to browsing, creating a User account, uploading or downloading assets, etc.), the legal basis is User’s prior consent.
Where the legal basis is User’s prior consent, the User can always withdraw their consent at any time without affecting the legitimacy of the data based on consent prior to its withdrawal.
2.2 Processing of data for reasons related to Data Controller’s compliance with legal obligations
In such cases, the processing of personal data takes place for only the necessary time period in order for the Data Controller to comply with obligations imposed by various legal provisions.
3. Which personal data are processed?
3.1 Personal data
3.1.1 Registration / account creation
In order for a User to voluntarily create an account with the AI on-Demand platform, the User should login with their EU Login account. The User’s account name (EU Login username) and email address are stored in the AI on-Demand platform.
3.1.2. AI on-Demand’s communication for reasons related to User’s permitted use of the AI on-Demand
In order for the AI on-Demand platform to communicate with the User for the above purposes, the Data Controller can process all data relating to a User’s account, uploaded content and data related to the User’s use of the AI on-Demand platform.
3.2 Usage data
We may also collect information on how the webpage is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (IP address), browser type, browser version, the pages of our webpage that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
4. How the AI on-Demand collects personal data
4.1 The information can be collected by the following ways:
4.1.1 During login of a User on the AI on-Demand platform (via the EU Login option at https://www.ai4europe.eu/user/login)
4.1.2 When the User voluntarily submits content via the Contribution Gateway (https://www.ai4europe.eu/contribute), and purposefully includes personal data within that content (e.g. news, events, projects, AI assets, educational materials, etc.).
5. How long is personal data stored and when is it deleted?
5.1. User’s account data
Without prejudice to User’s deletion/erasure right mentioned below, the personal data registered and stored in the User’s account will be stored as long as the User wishes to make use of the AI on-Demand platform Website for the purpose mentioned above. In case Users wish to delete their account, they can do so by emailing email@example.com.
5.2. AI on-Demand’s communication for reasons related to User’s permitted use of the AI on-Demand platform
Data related to such communication will be stored only as long as Users wish to use the AI on-Demand platform Website and maintain their account. In case Users wish to delete their account, they can delete their accounts through account settings or by contacting the Data Controller through the above mentioned contact details.
5.3. Statistical analysis for the optimization of the Website
Regardless of the above mentioned provisions of Section 5, the Data Controller will store and process only necessary data for the period required in order to comply with its obligations imposed by law (compliance with fiscal obligations, etc) and to further optimize the structure and content of the Website.
For more information, please see the section on cookies (Section 11) below.
6. What are the User’s rights in relation to the processing of their personal data and how can these rights be exercised?
6.1 The Data Controller respects the User’s rights in relation to the processing of their personal data.
6.2 Users can exercise their rights by contacting the Data Controller via the contact details provided in Section 1.
For User's facilitation, User’s rights are included in the following list along with a short explanation of each right, as enshrined in the General Data Protection Regulation 2016/679 (GDPR):
- Access (Article 15):The User can ask the Data Controller to:
- confirm whether the Data Controller processes the User’s personal data
- provide the User with a copy of their personal data
- Rectification (Article 16):The User can ask the Data Controller to rectify inaccurate personal data. The Data Controller can seek to verify the accuracy of the data before rectifying them.
- Erasure/deletion (Article17):The User can ask the Data Controller to erase their personal data:
- when the personal data are no longer needed for the purposes for which they were collected
- when the User withdraws their consent
- when the personal data has been processed unlawfully
The Data Controller is not obliged to comply with a User's request to erase their personal data, if the processing of User's personal data is necessary:
- for compliance with a legal obligation
- for the fulfillment of another legitimate purpose or another legitimate legal basis
- for the establishment, exercise, or defense of legal claims
- Restriction (Article 18): The User can ask the Data Controller to restrict (store but not process) User’s personal data when:
- their accuracy is contested (see rectification), so that the Data Controller can verify the accuracy of the personal data
- the personal data have been unlawfully processed but the User opposes the erasure of the personal data
- they are no longer necessary for the purposes for which they were collected but the User still needs them for the establishment, exercise or defense of legal claims or there is another legitimate purpose of processing or other legal basis
- Data portability (Article 20): When processing is based on consent and the processing is carried out by automated means, the User can ask the Data Controller to receive their personal data in a structured, commonly used and machine readable format or ask the Data Controller to transmit them to another controller directly from the Data Controller. Nevertheless, according to the law, this right refers only to those data that have been given by the User himself and not to those data that are inferred by the Data Controller based on the data that the User has provided.
- Objection (Article 21):The User can object at any time to the processing of personal data concerning them which is based on legitimate interest or performance of a task carried out in the public interest. When the User exercises their right to object, the Data Controller has the right to demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedom of the User or for the establishment, exercise or defense of legal claims.
- Consent withdrawal (opt-out): The User has the right to withdraw their consent where consent is the basis of processing. Withdrawal is valid for the future.
- Supervisory Authority: The User has the right to lodge a complaint with the local supervisory authority related to data protection.In Ireland, the supervisory authority for data protection is the Data Protection Commission https://www.dataprotection.ie/
- Identity: The Data Controller takes the confidentiality of all files that include personal data seriously, and thus is entitled to request the User for proof of their identity if the User submits a request in relation to those files.
- Cost: The User will not have to pay for the exercise of their rights in relation to personal data unless, as provided by law, the request for access to information is unfounded or excessive. In that case, the Data Controller can charge the User with a reasonable fee under specific circumstances. The Data Controller will inform the User for any possible charge before completing the request.
- Timetable: Data Controller aims at answering at User's valid requests the latest within one (1) month from their receipt, unless the request is extremely complicated or the User has submitted multiple requests, in which case the Data Controller aims at answering to them within three months. In case the Data Controller needs more than one month for the reasons above mentioned, the User will be informed. The Data Controller may ask the User if they want to explain what exactly they wish to receive or what is their concern. This will help the Data Controller to act more quickly in relation to the User’s request. In any case, the User should mention specific and true data and/or facts so that the Data Controller can accurately answer and/or satisfy the User's request. Otherwise, the Data Controller reserves their right for any faults that are outside of their control. Additionally, the Data Controller can reject requests that are unfounded, excessive, abusive, made in bad faith, or are illegitimate in the framework of the legal provisions.
7. How is data security safeguarded?
7.1 The Data Controller implements all appropriate security measures to ensure the protection and confidentiality of personal data. This includes the following measures:
- Strong password policies in all servers
- HTTPS protocol for interacting with APIs and Web clients
- SSH protocol for server connection
- Periodical server updates with latest security fixes
7.2 Please note that only specifically authorized employees of the Data Controller, acting under the authority of the Data Controller and only on their instructions where necessary, handle personal data submitted by the User. For processing, the Data Controller selects persons with appropriate qualifications that have sufficient knowledge as to technical safeguards and personal integrity to protect confidentiality. The Data Controller takes all necessary security measures for the protection and safeguard of secrecy, confidentiality, and integrity of personal data also through relevant contractual commitments of their associates. In case the security of the Website may be compromised due to reasons that reside outside the control of the Data Controller as well as due to technical or other problems of the network, force majeure, or accidents, the security of personal data cannot be guaranteed.
8. Who are the recipients of personal data?
8.1 The recipients of the User’s personal data are associate organizations that provide technical infrastructure for the operation of the AI on-Demand Website, hosting provider as well as the organization that undertakes to send electronic communications related to the operation of the AI on-Demand platform to Users. Where necessary, as per applicable laws, the Data Controller will sign agreements with such organizations, which refer to the implementation and regular monitoring of security measures. In case personal data is transferred outside the ΕU, all necessary guarantees are in place.
8.2. If the Data Controller receives a valid request to notify or transfer data following a request by the appropriate administrative authority, attorney, court or other authority, the Data Controller may notify / transfer such data in order to fulfill their duty executed in favor of the public interest towards these authorities (with or without User’s previous notification) in accordance with the appropriate legal provisions. If the User should be previously notified in accordance with the relevant legal provisions, then the User has the right to object to this processing as provided in Section 7 above.
8.3. Αs to the professional details made available by each User, they are available to all registered Users of the AI on-Demand platform for the purposes mentioned above.
9. Connection to other websites/social media
This Website connects with other websites through hyperlinks. These websites are not related to the Data Controller’s Website and their content is neither checked nor recommended by the Data Controller. Thus, the accuracy, legitimacy, completeness or quality of their content and legitimacy of the processing of User’s personal data cannot be checked and no guarantee is provided for them. The Data Controller cannot be held liable for them or any damage that may be caused to the User due to or following their use. The Data Controller cannot check the processing of the User’s personal data by those linked websites and thus does not bear any liability for the use of them. When the User accesses such websites they should take into consideration that the terms and conditions of each website apply. For any issue that may occur as to the content or the use of the linked website, the User should directly contact the operator or administrator of each website. The Data Controller does not approve or embrace the content or services of the linked websites, which the User accesses through the AI on-Demand Website.
The Website gives Users the possibility to connect and interact with social media following their own initiative and will. In that case, the Data Controller is not liable for the processing of a User’s data taking place through or by social media platforms. Users should directly address each specific social media platform in order to exercise their legitimate rights.
10.2. Cookies are small text files stored on the Users’ computer when they visit the AI on-Demand Website, which can be used as a means of identifying their computer.
10.3. Cookies, apart from absolutely necessary cookies, are only installed if the User accepts their installation when they visit the AI on-Demand Website. By accepting cookies when entering the AI on-Demand Website, the User expressly states that they have read and understood the specific terms and conditions regarding the installation, function, and purpose of the cookies and that they provide their consent for their use.
10.4. Alternatively, the User may not accept cookies. In this case, only cookies that are technically and functionally necessary for the operation of the AI on-Demand will be installed.
10.5. The User can manage the use and installation of cookies at any time through a panel, where they can choose which categories of cookies they want to accept.
10.6. In particular, the cookies used by the AI on-Demand Website are the following:
10.6.1 Absolutely necessary Cookies:
The absolutely necessary cookies are essential for the proper operation of the AI on-Demand Website. These cookies allow the User to browse and use AI on-Demand features such as access to secure areas. These cookies do not recognize the User’s individual identity and without them, the smooth operation of the AI on-Demand Website is not possible.
Example of this cookie:
1) SSESS5f14077676e7784cad49646a1157d45c. It is created after the User is logged in and deleted automatically when the User logs out.
It is associated with the login session of the user.
Duration of this cookie: Session (24 days or until logout).
This cookie does not transfer data to third parties
10.6.2 Statistics/Analytics Cookies
These are cookies that evaluate the way visitors use the AI-on-Demand Website (for example, which pages are visited more often and whether they receive error messages from webpages). These cookies are used for statistical purposes and to improve the performance of AI-on-Demand.
With the User’s consent for Statistics/Analytics Cookies, the following cookies are placed by Matomo analytics in order to begin logging usage statistics:
1) _pk_id: Used by Matomo analytics to store a few details about the user such as the unique visitor ID.
Duration of this cookie: Session (24 days or until logout)
This cookie does not transfer data to third parties
2) _pk_ref: Used by Matomo analytics to store the attribution information, the referrer initially used to visit the website.
Duration of this cookie: 06 months
This cookie does not transfer data to third parties
3) _pk_ses: Used by Matomo analytics. Short-lived cookies used to temporarily store data for the visit.
Duration of this cookie: 30 minutes
This cookie does not transfer data to third parties
11. Children’s Privacy
Our project is not directed towards anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we will take steps to remove that information from our servers.