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Data Protection Policy

We are committed to safeguarding the privacy of the users of The Manifold Files. This Data Protection Policy statement explains our data processing practices.

1. The Controller

The controller responsible for the processing of personal data performed within the framework of the present website is The Manifold Non-Profit Civil Partnership, seated in Athens. The controller can be contacted at: themanifold@themanifold.media

2. Legal Basis of the Processing

The processing of personal data shall be performed only when permitted by the relevant provisions, in the following circumstances:

  1. Processing may be permitted where necessary for the performance of a contract to which the data subject is a party or to take action at the request of the data subject prior to the conclusion of the contract.
  2. Processing may be permitted where necessary for the compliance of the legal entity with its legal obligations. Primarily, the legal entity only processes the data that it is required to process in order to exercise the requirements of its by-laws.
  3. Where appropriate, processing is permitted subject to the consent of the data subjects to send newsletters and other updates.
  4. The processing operation is allowed for the purpose of informing the public and promoting journalistic research.

3. Transparency and Information to be Given to the Data Subject

3.1. By announcing this policy, the controller informs the data subjects that their data are being processed (Article 12 GDPR).

3.2. Τhe controller collects solely on the basis of the consent of the parties concerned the following information by the persons interested in registering as “members”, with regard to the newsletter(s) list(s):

a – Name, b – Username, c – Password, d – Password Confirmation, e – Email Address, f – Email Address Confirmation, and g – Captcha Automation Blocking (“I’m Not a Robot”).

3.3. The controller collects solely on the basis of the consent of the parties concerned the following information from several sources for the purposes of notification to the Data Subjects with regard to events organised by the website, and for statistical purposes:

a – Name, b – Email Address, c – Age, d – Gender Identification, e – Country of Residence, f – Language, g – Education Level, and h – Profession. 

3.4. The controller collects public information, such as biographical information, on persons whose activities are related to the journalistic purposes of the website (Article 6(1f) GDPR).

4. Right to Access

4.1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

  1. the purposes of the processing;
  2. the categories of personal data concerned;
  3. the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  5. the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
  6. the right to lodge a complaint with a supervisory authority;
  7. where the personal data are not collected from the data subject, any available information as to their source;
  8. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

4.2. Where personal data is transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer.

4.3. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

4.4. The right to obtain a copy referred to in paragraph 4.3 shall not adversely affect the rights and freedoms of others.

5. Right to Rectification

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

6. Right to Erasure (“Right to be Forgotten”)

6.1. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

  1. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  2. the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) GDPR, or point (a) of Article 9(2) GDPR, and where there is no other legal ground for the processing;
  3. the data subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR;
  4. the personal data have been unlawfully processed;
  5. the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
  6. the personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

6.2. Where the controller has made the personal data public and is obliged pursuant to paragraph 6.1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

6.3. Paragraphs 6.1 and 6.2 shall not apply to the extent that processing is necessary:

  1. for exercising the right of freedom of expression and information;
  2. for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  3. for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3) GDPR;
  4. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) GDPR in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
  5. the establishment, exercise or defence of legal claims.

7. Right to Restriction of Processing

7.1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

  1. the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
  2. the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
  3. the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
  4. the data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

7.2. Where processing has been restricted under paragraph 7.1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

7.3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.

8. Right to Data Portability

8.1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

  1. the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1) GDPR; and
  2. the processing is carried out by automated means.

8.2. In exercising his or her right to data portability pursuant to paragraph 8.1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

8.3. The exercise of the right referred to in paragraph 8.1 of this Article shall be without prejudice to Article 17 GDPR. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

8.4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

9. Right to Object

9.1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

9.2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

9.3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

9.4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.

9.5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.

9.6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) GDPR, the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

10. Automated Individual Decision-Making, Including Profiling

10.1. The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

10.2. Paragraph 10.1 shall not apply if the decision:

  1. is necessary for entering into, or performance of, a contract between the data subject and a data controller;
  2. is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
  3. is based on the data subject’s explicit consent.

10.3. In the cases referred to in points (a) and (c) of paragraph 10.2, the data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

10.4. Decisions referred to in paragraph 10.2 shall not be based on special categories of personal data referred to in Article 9(1), unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests are in place.

11. Records of processing activities

The controller maintains a record of processing activities under its responsibility, according to Article 30 GDPR

12. Security of processing

12.1.   Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the controller and the processor shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:

  1. the pseudonymisation and encryption of personal data;
  2. the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
  3. the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
  4. a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.

12.2.   In assessing the appropriate level of security account shall be taken in particular of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.

12.3.   Adherence to an approved code of conduct as referred to in Article 40 GDPR or an approved certification mechanism as referred to in Article 42 GDPR may be used as an element by which to demonstrate compliance with the requirements set out in paragraph 12.1 of this Article.

12.4.   The controller and processor shall take steps to ensure that any natural person acting under the authority of the controller or the processor who has access to personal data does not process them except on instructions from the controller, unless he or she is required to do so by Union or Member State law.