Privacy notice

Policy 1 out of 2

Please read our Privacy notice

How UACEG, as data controller, and DISKORDIA Ltd., as processor, handle your personal data on the Inclusive CloudLearnHub platform under the GDPR. It explains which data we process, why, for how long and how you can exercise your rights.

1. Controller and processor

This notice explains how personal data are processed on the Inclusive CloudLearnHub platform, the learning platform of the Erasmus+ KA220-HED project "Inclusive CloudLearnHub – Sustainable and Inclusive digital skills for Higher education" (2025-1-BG01-KA220-HED-000357134), in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation, GDPR).

The data controller is the University of Architecture, Civil Engineering and Geodesy (UACEG), 1 Hristo Smirnenski Blvd, 1046 Sofia, Bulgaria, coordinator of the project. The platform is operated technically by DISKORDIA Ltd., Sofia, which acts as a processor on behalf of UACEG and only on its documented instructions. The project partners are Palacký University Olomouc (Czech Republic) and the University of Niš (Serbia).

Data protection contact: dpo@uacg.bg – to be confirmed by UACEG.

2. Categories of data

  • Account data: name, e-mail address, institution, preferred language and country.
  • Learning data: activity and progress in courses, submissions, grades and feedback, forum posts, competency ratings and badges.
  • Technical logs: IP address, date and time of access, browser information and actions performed on the platform.
  • Surveys: evaluation surveys are anonymous and are not linked to your account.

3. Purposes and legal bases

  • Providing courses, pilot activities and user support – Art. 6(1)(b) GDPR (performance of the terms of use you accept when registering) and Art. 6(1)(e) GDPR (public task of the partner universities in education and research).
  • Evaluation of the project and reporting to the Erasmus+ programme, in aggregated and anonymised form only – Art. 6(1)(e) GDPR.
  • Optional surveys and other activities for which we ask for your consent – Art. 6(1)(a) GDPR.
  • Security of the platform, prevention of misuse and troubleshooting – Art. 6(1)(b) and (e) GDPR.

4. Recipients

Each partner university has access to the data of its own students and staff, and teachers see the data of participants in their courses. DISKORDIA Ltd. processes data only as a processor. Aggregated, anonymised statistics are shared with the Human Resource Development Centre (HRDC), the Erasmus+ National Agency for Bulgaria. We never sell personal data and do not use them for advertising.

5. Transfers outside the EU/EEA

The platform is hosted in the European Union. Personal data are not transferred outside the EU/EEA, with one exception: the University of Niš (Serbia) may access the data of its own students and staff. As there is no adequacy decision of the European Commission for Serbia, this access is based on the partnership agreement, which includes standard contractual clauses and other appropriate safeguards under Art. 46 GDPR.

6. Retention

  • Account and learning data: until you delete your account, and at the latest 12 months after the end of the project on 14.03.2028.
  • Technical logs: 12 months.
  • Project evaluation data: kept only in anonymised form.

7. Your rights

You have the right of access, rectification, erasure, restriction of processing, data portability and objection, and the right to withdraw your consent at any time without affecting the lawfulness of earlier processing. You can export or delete your data directly in the platform via Profile › Data requests, or write to the data protection contact above. We respond within one month.

You have the right to lodge a complaint with the Commission for Personal Data Protection of Bulgaria (www.cpdp.bg) or with the supervisory authority of the country where you live or work.

8. Cookies

The platform uses only essential session cookies that are necessary for logging in and using the platform. No analytics or advertising cookies are used.

9. Accessibility

The platform aims to meet the WCAG 2.1 AA accessibility guidelines and this notice is available in English, Bulgarian, Czech and Serbian. As this is an alpha/pilot version, some barriers may remain; please report them to the contact above.

10. Changes

This notice may be updated as the platform develops. Significant changes will be announced on the platform.

Next
Back to top