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I. GENERAL PROVISIONS

1. The privacy policy of the istartup.eu website (hereinafter referred to as the “Privacy Policy”) sets out the conditions, legal basis, purposes, retention period, publication and provision, accuracy, safeguards of personal and legal personal data collected and stored via the website and the conditions for the exercise of data subjects’ rights.

2. The website “istartup.eu” (hereinafter – the website) was created during project “Acceleration of the Business Support System” ACCESS (hereinafter – the project), project No. LT-PL-4R-301, implemented under the Interreg V-A Lithuania-Poland Cooperation Program.

3. The intellectual property rights of the training content of the website “istartup.eu” belong to the project partners: Kaunas University of Technology, Kaunas Chamber of Commerce, Industry and Crafts, Białystok University of Technology and Association of Białystok Functional Zone (hereinafter – Project Partners).

4. The solution for the training functionality of the website was developed and the maintenance of the solution during project implementation was taken care of by UAB Kirotech in accordance with the 2020. November 16 concluded service contract No. SV11-1993.>

5. Online training information provided by the website is presented as text or video, tasks can be submitted to training participants in the format of attachment files with tasks. Online training material covering different training topics.

6. This Privacy Notice is to be understood as the general rules that every user of the Website must read when registering. By submitting your form and marking “I have read this Privacy Notice”, the person confirms that he / she is aware of the grounds, purposes and conditions of the processing of his / her personal data.

For more information on personal data protection than provided in this notice, please contact privacy@ktu.lt

7. The target users of the website are:

7.1. Persons seeking to set up or are setting up their own business, seeking opportunities to obtain business creation and development consultations, to acquire the knowledge and skills necessary for business creation and development;

7.2. Business development specialists providing business creation and development consultations.

8.Website content creators are project partners, that are providing business supports services.

9. Data controller – Kaunas University of Technology, legal form: public institution, legal entity code: 111950581, address of registration: K. Donelaičio str. 73, 44249 Kaunas. Responsible for the implementation of the Privacy Policy is the structural unit of the data controller, which administers the following website: KTU National Innovation and Business Center, address: Baršausko str. 59, Kaunas, telephone number: +370 672 65146, e-mail address: nivc@ktu.lt. Neringa Valantinė, Business Development Project Manager of the National Innovation and Business Center of Kaunas University of Technology, Entrepreneurship Education Division, is responsible for data security and confidentiality.

10. General principles for the processing of personal data are set in General Data Protection Regulation (hereinafter – GDPR) – Regulation (EU) 2016/679 of the European Parliament and Council (EU) of 27 April 2016 on the protection of individuals with regards to the processing of personal data and the free movement of such data for the protection of natural persons in the processing of personal data and repealing Directive 95/46/EC.

11. Basic principles of personal data processing:

11.1 Personal data is collected for defined and legitimate purposes.

11.2 Personal data is processed accurately and fairly.

11.3 Data subjects have an unrestricted opportunity to correct inaccurate personal data.

11.4 Personal data shall be kept for no longer than is necessary for the purposes for which they are processed, as specified for each specific purpose of the processing.

11.5 Personal data is processed only by employees who have been granted such a right.

11.6 All information about the processed personal data is confidential insofar as its publication is not necessary for the purposes of organizing and administering the competition.

II. COLLECTION AND PROCESSING OF PERSONAL DATA

12. The collection and processing of personal data is described in the table below:

What personal data is collected?	For what purpose are they collected?	How long will they be stored?	Where will they be stored?
Name Surname	Needed to identify the user of the website	Five years after the end of the project, but no later than 31 November 2026.	The collected data is stored at KTU National Innovation and Business Center, address: Baršausko str. 59, Kaunas, phone number: +370 672 65146, e-mail address: nivc@ktu.lt and in the content management system of the website of Kaunas University of Technology istartup.eu.
Email address, phone number	Needed to identify the user of the website. Remind user-created password.	Five years after the end of the project, but no later than 31 November 2026.	The collected data is stored at KTU National Innovation and Business Center, address: Baršausko str. 59, Kaunas, phone number: +370 672 65146, e-mail address: nivc@ktu.lt and in the content management system of the website of Kaunas University of Technology istartup.eu.

III. PUBLICATION AND SUBMISSION OF DATA

13. No personal data will be made public without the consent of the data subjects.

14. Personal data shall be provided only in cases and in accordance with the procedure established by law.

IV. DATA PROTECTION MEASURES

15. The controller shall implement the following basic data protection measures:

15.1 Access to personal data is granted only to those employees of the data controller who need the data for the performance of their work functions (the “need to know” principle applies). Access shall be terminated when the employment relationship of the controller with the employee to whom access has been granted is terminated or when the nature of the employee’s work functions changes.

15.2 Authorizations to process data are granted to a defined number of employees of the data controller.

15.3 The authorization shall be terminated when the employment relationship of the controller with the employee to whom the authorization has been granted is terminated or when the nature of the employee’s job functions changes.

V. CONDITIONS FOR THE USAGE OF RIGHTS BY DATA SUBJECTS

16. Individuals have the right to access their personal data which are being processed, to request the rectification of inaccurate data, as well as the right to withdraw their consent to the processing of data, as well as other rights established by legal acts.

17. Data processor shall provide information on the processing to the data to the subject in a concise, transparent, comprehensible and easily accessible form, in clear and simple language, in the manner in which the data subject’s request was received, unless the data subject requests otherwise.

18. Information on the processing of personal data shall be provided and other reasonable requests of the data subject shall be executed free of charge.

19. Where the data subject’s requests are manifestly unjustified or disproportionate, in particular because of their repetitive nature, the controller shall have the right to refuse to act on the request.

VI. CONCLUDING PROVISIONS

20. Issues of personal data processing not covered by the Privacy Policy shall be resolved in accordance with the general principles of personal data processing and taking into account the legal basis of data processing and the purposes of data processing.

21. Employees of the Data Controller who are authorized to process personal data or become aware of them in the course of their duties must comply with the general principles of personal data processing and the Privacy Policy. The employees of the data controller shall be liable for the violations in accordance with the procedure established by legal acts.

VII. COOKIES NOTIFICATION

This is to notify you that this website is using the technologies that ensure the proper operation of the website or monitor and analyse the behaviour of the website’s visitors during browsing.

VIII. WHAT ARE COOKIES?

A cookie is a small text file sent by the website to your network browser when you browse and saved in your device. Therefore, the website can “remember” your actions and preferences for some time (for example, your registration name, font size and other view options) so that you would not have to enter them each time you visit the website.

The websites use first-party and/or third-party cookies.

According to their function, the cookies are classified as follows:

• Necessary cookies. These cookies activate the main browsing or access functions of the website. The website cannot function properly without these cookies.
• Functional or technical cookies. The website used these cookies to memorise the information essential for its performance and appearance, for example, the language selected by the visitor or the region of the visitor’s location. The website cannot function without these cookies.
• Statistical or analytical cookies. These cookies collect anonymous information and submit its reports that allow the website owner to learn how the visitors use the website.
• Marketing or advertising cookies. These cookies are used by many websites to track visitors aiming to provide them with customised advertisements. They also limit the number of displayed advertisements and enable to assess the effectiveness of advertising campaigns. Usually, these are the third-party cookies.

According to their validity term, the cookies are classified as session and persistent cookies.

According to the location of their creation, there are two types of cookies:

• First-party cookies – created on the website you are visiting;
• Third-party cookies – created on other websites. These websites own certain content on the website you are visiting, for example, ads or images.

Trackers are a type of cookies that send the report on the website visitor’s browsing and his/her IP address to the third-party database for analysis, usually for marketing purposes.

IX. HOW DO WE USE COOKIES?

We use cookies to:

• the website could recognize you and remember your settings and preferences;
• By analyzing your actions on the website, we could constantly improve its performance.

We do not use cookies to identify you. The cookies on our website are not used for any purpose other than those described here.

X. WHICH COOKIES DO WE USE?

The following cookies are used on our website:

XI. THIRD-PARTY SERVICES

For the optimisation of marketing notifications, we constantly use the analytical software Google Analytics from Google LLC. It enables tracking of behaviour online: the time spent on the website, the geographic location and the usage of the website. This information is collected by using the tracking pixels and/or cookies. The information received via the tracking pixels and/or cookies is anonymous and not linked to personal data. Google processes personal information in servers in various countries of the world. Personal information can be processed in the server located in a country other than the country of the user’s residence. We do not share this information with any third parties that could freely use it. If you disagree with the performance of this analysis, you can submit the refusal of your personal data processing here.

Since this website has an interface with the third-party communication channels Facebook, Instagram, LinkedIn and YouTube in which we upload the information about the University’s activities, the cookies of the data processors of these channels provide us with the aggregated statistics and insights into the manner of the visitors’ interaction with our posts, advertisements, this website, videos and other content in these social media.

To enable the visitors of our website to contact us more efficiently, we have installed the Messenger plugin controlled by Facebook.

More information on the third-party tracking technologies is available here:

XII. HOW TO CONTROL COOKIES?

You do not have to accept all the cookies used here for the website to work, but doing so will make browsing easier for you. You can delete or block all but the required cookies, but in this case, some features of this site may not work as intended, and each time you visit our site, you may need to reset some options.

Most browsers allow you to:

• check which cookies are stored and delete separate cookies;
• block third party cookies;
• block cookies from specific websites;
• block all cookies;
• delete all cookies when you close the browser.

XIII. HOW TO REFUSE COOKIES?

If you do not agree to the storage of cookies on your computer or other device, you can revoke your consent to use them at any time by changing the settings and deleting the stored cookies. If you choose to delete cookies, remember that all the options you set will also be removed. Also, if cookies are completely blocked, many websites (including our website) will not function properly. For these reasons, we do not recommend disabling cookies when you use our website.

XIV. VERSIONS OF COOKIES MESSAGES

We regularly review the cookies used on the Website and update this Cookie Notice as necessary to notify you of material changes to the visitor tracking technology used here.