Effective Date: [Insert Date]
This Privacy Policy describes how the [SPARK-COIL website] (“we”, “our”, or “us”) collects, uses, and protects your personal data in connection with our mission to promote collaborative online international learning (COIL) through the consortium of five Jesuit universities in the Philippines and our European partners, WSB University (Poland) and the University of Alicante (Spain), under the auspices of an EU Erasmus+ CBHE-funded project.
This Policy is in accordance with the Philippine Data Privacy Act of 2012 and the European Union General Data Protection Regulation (GDPR).
1. Scope and Purpose
This website serves as a platform for:
- Information dissemination about the SPARK-COIL project
- Directory and matchmaking for COIL course offerings
- Sharing of resources and best practices
- Registration and participation in project activities, events, and training
We collect and process personal data only for these legitimate educational and collaborative purposes.
2. Personal Data We Collect
Depending on your interaction with the website, we may collect:
- Identification Information: Full name, affiliation, job title, email address, country
- Course Participation Data: Areas of interest, courses offered/attended, institutional role
- Communication Data: Messages sent through contact forms, inquiries, or feedback
- Technical Data: IP address, browser type, access time, and activity logs via cookies
3. Legal Bases for Processing
We process your personal data based on:
- Consent: When you voluntarily submit information or register for activities
- Legitimate Interest: For the operational management of the website and project outcomes
- Legal Obligation: For compliance with grant requirements under EU Erasmus+ regulations
- Public Interest/Educational Purpose: As part of our mandate to support international academic collaboration
4. Use of Personal Data
We use your personal data to:
- Administer and maintain the website and platform services
- Facilitate COIL course matchmaking and collaboration
- Contact you about events, updates, or related academic opportunities
- Report to project funders (aggregated, non-personally identifiable data unless consented)
- Comply with legal or regulatory obligations
5. Data Sharing and Transfers
We may share your data only with:
- Consortium partner universities involved in the project
- Authorized project staff and administrators
- Third-party service providers (e.g., website hosting, cloud storage) under strict confidentiality
- European Commission/EACEA for project monitoring and compliance reporting
Some data may be transferred across borders (e.g., between the EU and the Philippines). In such cases, we ensure:
- Compliance with GDPR rules on international transfers
- Use of Standard Contractual Clauses or equivalent safeguards
6. Cookies and Analytics
Our website uses cookies to:
- Improve functionality and user experience
- Analyze site traffic through tools like Google Analytics
Visitors from the EU will be presented with a cookie consent banner to accept or decline non-essential cookies.
7. Data Retention
We will retain your personal data only for as long as necessary to:
- Fulfill the purposes outlined above
- Comply with Erasmus+ project documentation requirements
- Respect applicable retention laws in the EU and the Philippines
8. Your Rights
You have the right to:
- Access, correct, or update your personal data
- Object to processing or request data erasure (where applicable)
- Withdraw consent at any time
- File a complaint with the National Privacy Commission (Philippines) or an EU Data Protection Authority
To exercise your rights, contact us at: [Insert Contact Email]
9. Security Measures
We take appropriate technical and organizational measures to protect your data from unauthorized access, disclosure, alteration, or destruction. These include encryption, access controls, and secure servers.
10. Third-Party Links
Our website may contain links to external sites (e.g., other COIL platforms, educational resources). We are not responsible for the privacy practices or content of these third-party sites.
11. Changes to This Policy
We may update this Privacy Policy from time to time. Any changes will be posted on this page and, where appropriate, notified via email or website banner.
12. Contact Information
For any questions or concerns related to this Privacy Policy or your personal data, you may contact our project’s Data Protection Representative:
Data Protection Contact – SPARK-COIL Project
[Insert Name or Role]
[Insert Email Address]
[Insert Address of Coordinating University]
[Insert Phone Number (if applicable)]