Terms and Conditions

TERMS & CONDITIONS OF EDUCATE HUB

EDUCATE HUB interactive online collaborative platform is jointly operated by EDUCATE Eramus+ project partners. We value the trust you have placed in us to create quality educational content and community for actors of the circulat tourism. Sometimes we may need to gather information about our users and their use of our services in order to achieve this goal.

We are committed to creating a safe and secure environment that will maximally support the education and knowledge acquisition of users.

This Privacy Policy (the “Privacy Policy”) describes how we use, share and protect the information we collect from you through the EDUCATE HUB platform. This Privacy Policy applies to the Services only.

Please note that third party services that you use to access our content may be subject to separate privacy policies. We strongly encourage you to familiarize yourself not only with this Privacy Policy, but with any other privacy policies or agreements that may govern your use of the Services.

1. Please read these terms and conditions carefully (the “Terms”). By accessing and using our website and any content and features on it, you agree to these terms and the privacy policy. The privacy policy and other information are available on the website: https://educatehub.eu/
2. If you do not accept these Terms, do not enter and / or use our Services.
3. We may update these Terms at any time. Please check the Terms regularly to make sure you are aware of any changes. Your continued access to and / or use of EDUCATE HUB after changes to the Terms agree that you will be legally bound by the updated and / or amended Terms.

EDUCATE partners

EDUCATE project and EDUCATE HUB is a joint work of partners from 6 countries who have helped to create the project results in their country, implement it and will continue to be involved in supporting in their territory. They are specifically:

Organisation	Kontaktai	Country
Central Transdanubian Regional Innovation Agency Nonprofit Ltd.	kdriu@kdriu.hu	HUNGARY
MB “Efekto grupe”	info@efektasgroup.com	LITHUANIA
European Digital Learning Network	info@dlearn.eu	ITALY
Higher Incubator Giving Growth and Sustainability	info@higgs3.org	GREECE
Yaşar Üniversitesi	bilgi@yasar.edu.tr	TURKEY
Latvian Adult Education Association	sarmite.pilate@laea.lv	LATVIA

Use of EDUCATE HUB Services

1. You agree to use our Services only for lawful purposes and in a manner that does not infringe, restrict or prevent any person from using and enjoying our Services and in all circumstances in accordance with these Terms and all laws and regulations. which apply.
2. The EDUCATE HUB platform could be used exclusively for educational and networking purposes under the conditions when no financial fee will be charged to the learner.
3. By accessing our Services, you agree to access their content only for non-commercial use and not for any commercial or other purposes, including the advertising or sale of any goods or services. You also agree not to adapt, modify or create derivative works from any content of our Services except for your personal non-commercial use. If you wish to use any content of our Services for any other reason, you will need our prior written permission.
4. All our Services only to those users who have registered with us. If you choose or be provided with a user ID, password, or any other information as part of our security procedures, you must treat this information as confidential and you must not disclose it to any third party. Any personal information you provide to us as part of this registration process and / or other interactions with our services will be collected, stored and used in accordance with our privacy policy. We have the right to deactivate any user identification code or password at any time, whether you choose or assign it to us, if in our opinion you have not complied with any of the provisions of these terms and conditions.
5. We do not represent that any content of our Services is appropriate or available for use in your country. You are responsible for ensuring that your use of our Services complies with all applicable local laws and regulations.
6. To use the EDUCATE HUB platform, user needs device with a web-browser with enabled sounds and be connected to Internet. Supported browsers: Google Chrome versions 40-96, Firefox versions 32-95, Microsoft Edge up to version 96, or Internet Explorer 11.

Intellectual property rights

1. All information, data, text, documents, graphics, logos, designs, images, pictures, photographs, videos, weblogs, RSS feeds, widgets, software, interactive features, or other content, services or materials (or any part thereof) accessible on our Services are protected by copyright, trademark, database rights and other intellectual property rights and are owned by us or licensed to us or otherwise used by us in accordance with applicable laws or regulations. Nothing contained herein shall be construed to imply, by implication, impediment or otherwise, any license or right to use the Materials other than as permitted in these Terms.
2. In the event that you would like to use the data for any purpose other than for educational purposes, you agree not to do so without our prior written permission.

User contributions to our Services

Please read this section carefully before uploading or otherwise transferring any content to the EDUCATE HUB platform. If you do not want to grant us the authorizations set forth in these terms, do not provide your contribution to the system.

1. Whenever you use a feature that allows you to post to users or contact other users of our Services, you must adhere to standards of good conduct.
2. You remain the copyright owner of any original user post you submit. However, we reserve the right to remove inappropriate posts, and it is only up to the founder of the EDUCATE HUB platform whether we consider the post to be inappropriate.
3. The permission you have granted to us is not exclusive, and therefore you may use the User Submission in any way on any medium, including allowing others to do so, provided that such use does not infringe or prejudice the rights you have granted to us.
4. You authorize us to grant, and we hereby grant each user of our Services a non-exclusive license to view, listen, read, upload, download, link and otherwise access your user contributions to our Services through our Services and otherwise use such user contributions as permitted. through the functions of our Services and in accordance with these Terms.
5. You are solely responsible for your User Submissions and the consequences of submitting them to our Services. You promise that:

(a) The User Submission is your own original work and you own all rights, title and interest in the User Submission and / or have all necessary licenses, rights, consents and rights to use and authorize us to use any and all intellectual property rights (including, without limitation, copyright) to such User Submission so that we may use the User Submission in the manner provided for in these Terms;

(b) nothing in the User Submission is derogatory, obscene, indecent, pornographic, sexually explicit, harassing, threatening or offensive, incites racial, cultural or religious hatred, impersonates another person or appears to impersonate another person, is contempt of court, violates any law or regulation, or incites conduct that is tantamount to criminal or civil liability and / or is otherwise defective and / or violates any law of the country in which you use EDUCATE HUB.

(c) the User Submission does not contain any virus, corrupted file, cancelbot, worm program or other malicious code designed to interrupt, destroy or limit the functionality or disruption of any software, hardware, telecommunications, networks, servers or other devices, or any adware, spyware, a Trojan horse or any other material intended to damage, interfere with, misappropriate or expropriate any data or personal information;

Removal of Materials

1. We are entitled at our option, but are not obliged to (a) actively review User Contributions to our Services; and/or (b) remove any User Contributions submitted to our Services by you or any other user if, in our opinion, such User Contributions do not comply with these Terms.
2. We reserve the right in our sole discretion at any time without liability and with or without prior notice (a) not to post any User Contribution on our Services; (b) to remove or suspend or disable access to any User Contributions; (c) to revoke your registration (where applicable) and right to access and/or use our Services or submit any User Contributions; and (d) to use any technological, legal, operational or other means available to enforce these Terms, including without limitation blocking specific IP addresses or deactivating your registration and/or user name and password (where applicable).

Reliability for information about our Services

1. The information published through our Services is intended solely for the purpose of educating and networking young entrepreneurs.
2. We do not warrant that any teaching materials are accurate or error free, and we disclaim all liability and liability arising from any reliance on any content of our services by you or anyone who may be informed of any content of our services.
3. You acknowledge that while using our Services, you may be exposed to materials from a variety of sources and that we are not responsible for the content, truthfulness, accuracy or usefulness of such services.
4. Our goal is to regularly update our Services and we may change the content at any time. We may, at our sole discretion, suspend access to our Services at any time or terminate them indefinitely. Materials may be out of date at any time and we are not required to update them.

Warranties and Disclaimer

1. Our Services are provided “AS IS” and on an “AS AVAILABLE” basis without any representation or endorsement of any kind. To the fullest extent permitted by applicable law, we disclaim all warranties, conditions and other Terms of any kind, express or implied, in connection with our Services and your use of our Services (including, without limitation, as to satisfactory quality, fitness for a particular purpose, non-infringement, compatibility, security and accuracy).
2. We do not warrant that the functions contained in any Materials on our Services will be uninterrupted or error-free, or that our Services or the servers that makes them available are free of bugs.

Limitation of liability

1. We do not accept any responsibility for any User Submissions submitted by any of our users. Your use of our services, materials and / or any user contributions is entirely at your own risk.
2. To the fullest extent permitted by law, we hereby expressly exclude any liability for any direct, indirect, consequential, special or exemplary loss or damage (whether such losses were foreseen, foreseeable, known or otherwise) arising from, out of or in connection with the use of our Services, including without limitation: (a) personal injury and / or damage to persons or property as a result of any statement, including any actual or alleged defamation statement; (b) losses suffered by any third party, including infringements of any intellectual property or privacy rights; c) data loss; (d) loss of revenue or expected profits; (e) loss of trade or contracts; f) loss of opportunity; (g) loss of expected savings; (h) waste of management or office time; or (i) loss of reputation or damage to reputation.
3. We shall not be liable for any breach of these terms and conditions caused by circumstances beyond our control.

Viruses, hacking and other crimes

1. You may not misuse our services by introducing, transmitting or arranging the sending of any viruses, corrupted files, cancelbots, Trojan horses, worms, time or logic bombs, keyloggers, spyware, adware or other materials intended to adversely affect the operation. any computer software, hardware or telecommunications equipment or interfere with, misappropriate or expropriate any data or personal information. You may not attempt to gain unauthorized access to our Services, the servers on which they are stored, or any server, computer or database connected to our Services. You must not attack our services by denial of service, distributed denial of service or any other type of attack.
2. Any violation of this provision will be reported and we will proceed in accordance with applicable legislative regulations in order to repair and compensate for damages caused to us by the actions.
3. We are not responsible for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other protected material as a result of your use of our services. Services, your downloading of any materials from our Services or any materials on any other website to which it links.

Links to and from our services

Links from our Services

1. We have no control over the content or availability of third party sites that you access through our Services, and such links are provided for your information only. If you visit any linked site, you do so at your own risk and it is your responsibility to take all precautions to protect against viruses or other destructive elements.
2. We do not endorse or be responsible or liable (directly or indirectly) for any content, advertising, products, services, opinions expressed or information on or accessible from third party websites (including, without limitation, payment and delivery of any products or services) or for any damage, loss or misconduct caused by or in connection with your access to and use of these third party sites and any available services. Any conditions, warranties or representations relating to any conduct on the sites of any third parties are solely between you and the relevant provider of those sites and / or any relevant services.

Linking to our Services

1. You may link to the home page of any website within our Services without requesting our further written consent, provided that you fully comply with these Terms.
2. You are not permitted to create a link to any part of our Services other than the Home Page without our prior written consent (and for the avoidance of doubt, such consent will be deemed to be granted with respect to RSS feeds, widgets and embeddable media players, provided we use them in accordance with these Terms and other instructions published through our Services). We reserve the right to revoke the link without notice. The website you link to must comply in all respects with the content standards set out in the Code of Conduct. Our services may not be framed on any other site.
3. Any references to our Services must be made in a manner that is fair and legal and does not damage our reputation or abuse it. You may not create a link in any way that suggests any form of association, representation, approval or support on our part, if any. Links to our services do not imply that we endorse, are associated with or affiliated with any linked site or that any linked site is authorized to use any of our trademarks, trade names, marks, logos or copyright symbols or marks of any of our affiliates or licensors.

Software

1. From time-to-time certain software which is our protected work or the protected work of our suppliers may be made available to download via our Services. You are licensed to use the software on a non-exclusive basis only for the purposes for which it is indicated. You may not use the software for any other purpose and may not redistribute, sell, decompile, reverse engineer, disassemble or otherwise deal with the software.

Privacy

1. Any personal information supplied by you as part of any registration process and/or other interaction with our Services will be collected, stored and used in accordance with our Privacy Policy. By using our Services, you consent to such collection and processing, and you promise that all data provided by you is accurate.

Preferred order

1. In the event of any conflict between these Terms and any specific terms found elsewhere in our Services relating to a particular material, these terms shall prevail.

Separability

1. If any of these terms is found to be illegal, invalid or otherwise unenforceable under the laws of any state or country in which these terms are to be effective, then to the extent and within the jurisdiction in which the term is illegal, invalid or unenforceable, will be segregated and deleted from these Terms and Conditions and the remaining Terms and Conditions will remain in full force and effect and will remain binding and enforceable.

Jurisdiction

1. The Terms are governed by and construed in accordance with the laws of the country where you are using EDUCATE HUB platform (your country).

What information do we collect?

1. Contact information. Users provide us with their email address so that they can access certain services more easily.
2. Username and password to create an account.
3. Usernames are moderated to prevent you or your child from using any personal information to create an account. Additionally, passwords are encrypted.
4. Your content. We collect comments and other information that users post through interactive online features.
5. Some of our services allow users to upload photos. Again, the photographs are for networking and communication purposes only and are no longer used by us or others.
6. The correspondence you send us and correspondence between users within the chat.
7. Information about how our Services are used. We may collect information such as preferences, avatars, links between friends, what’s going on in the platform, what videos are being watched or the pages you view, and links you click on within the Services.
8. Device information. We may collect information about your device, including hardware model, operating system version, and unique identifiers.

What information we don´t collect

1. Biometric or health data;
2. Personal data of the user, unless we seek the consent of a parent or legal guardian or otherwise comply with the law.
3. We erase user accounts and related data no later than 2 years after the last application usage.

How do we protect the information we collect?

1. We assure you that we handle all data with the utmost care for the safety of all parties involved, and we assure you that the data we collect will only be used for educational and networking purposes within the EDUCATE HUB platform.

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Privacy Policy

PRIVACY POLICY OF EDUCATE HUB

effective from January 1^st, 2023

This privacy policy provides an overview about how we process personal data as joint controllers:

HIGGS – Higher Incubator Giving Growth and Sustainability (15 Victoros Ougko St., Metaxourgio – P.C. 10437, Greece)

LAEA – Latvian Adult Education Association (Merķeļa iela 11, Rīga, LV-1050, Latvia);

MB „Efekto grupe“ (Gedimino str. 47, 3000 Kaunas, Lithuania);

DLEARN – European Digital Learning Network (Via Domenico Scarlatti 30 20124, Milano, Italy);

Yaşar Üniversitesi (Üniversite Caddesi, No:37-39, Ağaçlı Yol, Bornova, İzmir, Turkey);

CTRIA – Central Transdanubian Regional Innovation Agency Nonprofit Ltd. (H-8000 Seregélyesi út 113, Székesfehérvár, Hungary);

(hereinafter referred to as “us” or “we”), institutions that developed and maintain the EDUCATE HUB interactive online collaborative platform for persons and organisations participated in circular tourism.

We value the great effort that has been provided by the EDUCATE Erasmus+ project partnership (https://www.educatehub.eu/contact/) when developing a unique online hub. Even more, we value all the persons & organisations, tourism hots and providers, stakeholders who will join our still growing EDUCATE family and who start creating amazing business ideas in circular tourism with us! Nevertheless, sometimes, we may need to collect information about our users and their use of our service to help us achieve that goal. Our users are usually students and young entrepreneurs but for this Privacy Policy, we use the term “users” only.

If you have any questions concerning how we process your personal data, you can contact our Joint Contact Point. All privacy enquiries sent to us are received and reviewed by our Joint Contact Point, which serve as a contact point for you and supervisory authorities. Contact to Joint Contact Point:

Country	Organisation	Kontaktai
HUNGARY	Central Transdanubian Regional Innovation Agency Nonprofit Ltd.	kdriu@kdriu.hu
LITHUANIA	MB “Efekto grupe”	info@efektasgroup.com
ITALY	European Digital Learning Network	info@dlearn.eu
GREECE	Higher Incubator Giving Growth and Sustainability	info@higgs3.org
TURKEY	Yaşar Üniversitesi	bilgi@yasar.edu.tr
LATVIA	Latvian Adult Education Association	sarmite.pilate@laea.lv

This Privacy Policy is primarily designed to ensure compliance with our informational obligations pursuant to Articles 13 and 14 GDPR towards data subjects about whom we process personal data as a controller. Typical data subjects are users of the EDUCATE HUB. Being an EU-based subjects, we must comply with the EU general data protection regulation (the “GDPR“) provisioning your individual rights^[1]  when processing the personal data, applicable sections of the national data protection legislation (the “Data Protection Act”) and other legislation. In case that you do not understand any information provide in this Privacy Policy, do not hesitate to contact our Joint Contact Point.

Data subjects’ requests delivered at the Joint Contact Point shall be handled individually and on behalf of us by the controller from the country from which data subject request was sent.

Why we process personal data?

Generally, we need to process personal data to:

• provide our services and for that purpose process personal data of users of the EDUCATE HUB;
• meet our legal and contractual obligations; and
• pursue our own legitimate interests.

For what purposes and under which legal bases do we process personal data?

We process personal data for the following purposes and legal grounds:

	Purpose of the processing personal data	Legal ground
	Establishment, exercise, or defence of legal claims (legal agenda)	Legitimate interest
	Management of data subject requests	Compliance with legal obligation
	Provide our services – operating the EDUCATE contract	Contract
	Protection of property and security	Legitimate interest

What are our legitimate interests that we pursue?

We rely on a legal ground of legitimate interest pursuant to Article 6 (1) f) of GDPR for the following purposes. We provide description of these purposes and legitimate interests below:

Establishment, exercise or defense of legal claims (legal agenda)	From time to time, we might need to pursue a legal claim, ask for compensation or off-court settlement, or report certain facts to public authorities and aforementioned processing operations shall be considered as our legitimate interest.
Protection of property and security	We consider our legitimate interest protecting the property and security of us including our employees or users of EDUCATE HUB. We rely on this legal ground to ensure the security of our information assets and IT systems.

What personal data we process?

We process personal data for two types of users. Firstly, in most cases we process standard contact and identification types of personal data such as name, surname, country, and email for the persons. Secondly, we process standard identification types of personal data such as name, country, and email for organisations.

Who are recipients of your personal data?

We take the confidentiality of your personal data very seriously and have internal policies in place to ensure that your data is only shared with authorized personnel or a verified third party. Our staff might have access to your personal data on a strictly need-to-know basis typically governed and limited by function, role and department of the particular employee. Personal data of users or other natural persons are provided to the extent necessary to following categories of recipients:

• our verified and properly mandated processors;
• our professional advisors (e.g., attorneys or auditors);
• providers of standard software and cloud services;
• providers of technical (IT) and organizational (events agency) support of us;

We also use sub-contractors to support us in providing services who might process personal data for us. We ensure that selection of our sub-contractors and any processing of personal data by them is compliant with the GDPR in terms of technical and organizational security of processing operations. If we use our own recipients to process personal data (our internal staff), your personal data are always processed based on authorizations and instructions that inform our recipients about not only our internal privacy policies but also about their legal responsibility for their violations. If we are requested by the public authorities to provide your personal data, we examine the conditions laid down in the legislation to accept the request and to ensure that if conditions are not met, we do not adhere to the request. In case that you have a question about our current processors, do not hesitate to contact our Joint Contact Point for further information.

What countries do we transfer your personal data to?

By default, we seek not to transfer your personal data outside the EU and/or European Economic Area where not necessary.

How long do we store your personal data?

We must not and we do not want to store your personal data for longer than necessary for the given purpose of processing. Due to this legal requirement but also due to technical and financial aspects of data storage we actively delete data where no longer necessary. Retention periods are either provisioned in respective laws or are set out by us in our internal policies. When processing of your personal data is based on consent and you decide to withdraw your consent, we do further not process your personal data for the specific purpose. However, it does not exclude the possibility that we process your personal data on different legal grounds especially due to our legal obligations.

General retention periods for our purposes are as follows:

Purpose	General retention period
Establishment, exercise, or defence of legal claims (legal agenda)	Based on limitation period according to the law.
Management of data subject requests	Based on limitation period according to the law.
Provide our services – operating the EDUCATE HUB	During the contractual relationship with users and 2 years after termination of the contract
Protection of property and security	1 year

The above retention periods only specify the general periods during which personal data are processed for the specific purposes. However, we proceed to erasure or anonymization of personal data before the expiry of these general periods if we consider the personal data to be unnecessary in view of the above-mentioned processing purposes. Conversely, in some specific situations, we may keep your personal data longer than stated above if it is required by law or our legitimate interest.

How we collect your personal data?

Generally, we collect your personal data directly from you. You can provide your personal data to us by different means e.g.:

• by registration on our website;
• communication with you;
• completing and submitting a contact form with your comments, queries, or questions.

What rights do you have?

If we process your personal data based on consent to the processing of personal data, you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. You have the right to effectively object to the processing of personal data for direct marketing purposes, including profiling.

You also have the right to object to the processing of your personal data based on the legitimate interests we follow, as explained above. You are also entitled to the processing of personal data on the legal basis of a public interest.

If you exercise your right to object, we will gladly demonstrate to you the way how we evaluated these legitimate interests as overriding the interests, rights and freedoms of the data subjects.

The GDPR lays down general conditions for the exercise of your individual rights. However, their existence does not automatically mean that they will be accepted by us because in a particular case exception may apply. Some rights are linked to specific conditions that do not have to be met in every case. Your request for an enforcing specific right will always be dealt with and examined in terms of legal regulations and applicable exemptions.

Among others, you have:

• Right to request access to your personal data according to Article 15 of the GDPR. This right includes the right to confirm whether we process personal data about you, the right to access to personal data and the right to obtain a copy of the personal data we process about you if it is technically feasible.
• Right to rectification according to Article 16 of the GDPR, if we process incomplete or inaccurate personal data about you.
• Right to erasure of personal data according to Article of the 17 GDPR;
• Right to restriction of processing according to Article 18 GDPR
• Right to data portability according to Article 20 GDPR;
• Right to object against the processing including profiling based on legitimate or public interest according to Article 21 (1) of the GDPR;
• Right to object against processing for direct marketing purposes including profiling according to Article 21 (2) of the GDPR;
• Right to not be subject to the automated individual decision making according to the Article 22 of the GDPR.

If you feel that we are processing incorrect personal data about you given the purpose and circumstances, you can request rectification of incorrect or incomplete personal data.

You have a right to lodge a complaint related to personal data to the relevant data protection supervisory authority or apply for judicial remedy. Please note that because of leading controller, Central Transdanubian Regional Innovation Agency Nonprofit Ltd. is from Hungary our competent data protection authority is the Hungarian National Authority for Data Protection and Freedom of Information (https://www.naih.hu/). In any case we advise to primarily consult us with your questions or requests.

Do we process your personal data via automated means which produces legal effects concerning you?

We do not currently conduct processing operations that would lead to the decision which produces legal effects or similarly significantly affects concerning you based solely on automated processing of your personal data in light of Article 22 GDPR.

How we protect your personal data

It is our obligation to protect your personal data in an appropriate manner and for this reason we focus on the questions related to protection of personal data. We have implemented generally accepted technical and organizational standards to preserve the security of the processed personal data, especially considering the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or otherwise processed. In situations where special categories of data are processed, we use encryption technologies e.g., during communication with the payment gateway. Your personal data are stored on our secure servers or servers of our web site providers located in data centers in Hungary. If third-party analytics tools are used data are stored on third-party servers (see cookies).

Cookies

Cookies are small text files that improve website usage e.g., by allowing us to recognize previous visitors when logging in to a user environment, remembering a user’s choice when opening a new window, measuring website traffic, or how evaluation of usage of the website for the improvement. Our website uses cookies in particular to measure its traffic. You can always stop storing these files on your device by changing your web browser to a different setting.

Changes to this privacy policy

The information we give you with regard processing of personal data may change or cease to be up to date. From these reasons we may change this privacy policy from time to time by posting the most current privacy policy and its effective date on our website. In case we change this privacy policy substantially, we may bring such changes to your attention by explicit notice, on our websites or by email.

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[1] See Articles. 12 – 22 GDPR: https://eur-lex.europa.eu/legal-content/SK/TXT/HTML/?uri=CELEX:32016R0679&from=EN

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