Privacy Policy
1. Introduction
Citizens in Power (CIP), with Organisation Identification Number (OID) registered in the Registry of Public and Private Entities, is committed to protecting your personal data and respecting your privacy.
This Privacy Policy explains how we collect, use, store, and protect your personal data on the GrandFriend e-learning platform (https://training.grandfriend.eu/), in accordance with Regulation (EU) 2016/679 on Data Protection (GDPR).
2. Who is the Data Controller?
The data controller responsible for processing your personal data is:
Citizens in Power (CIP) Cyprus Email: info@citizensinpower.org
For any requests concerning your personal data, please contact us using the contact details provided above.
3. What Data Do We Collect?
When you register and use the GrandFriend platform, we collect the following categories of personal data:
Registration data: Full name, email address, password (encrypted), date of birth
Learning data: Course progress, grades, assessments, time spent on the platform
Connection data: IP address, device type, operating system and browser information
Communication data: Messages and support requests you send us
4. Why Do We Collect Your Data?
The collection and processing of your data is based on the following legal grounds under GDPR:
Contract performance (Article 6(1)(b)): To provide you with access to the learning platform and monitor your progress
Legitimate interest (Article 6(1)(f)): To improve the platform, system security, and fraud prevention
Legal obligation (Article 6(1)(c)): Where required by Cypriot or European legislation
Consent (Article 6(1)(a)): For any additional use beyond the above cases
5. How Long Do We Retain Your Data?
Your personal data is retained according to the following schedule:
Active user accounts: Retained while you remain a registered user
Learning and assessment data: Retained for 3 years after the end of the Erasmus+ project, then deleted
Connection logs and IP addresses: Retained for 6 months for security purposes, then deleted
Support requests: Retained for 2 years
6. Who Do We Share Your Data With?
Your personal data is not shared with third parties for commercial purposes. However, it may be shared with:
Audit authorities: Erasmus+ authorities or local authorities if there is a legitimate legal requirement
Service providers: Hosting and software providers who act as data processors
7. Your Rights
Under GDPR, you have the following rights:
Right of access: You can request access to your personal data
Right to rectification: You can request correction of inaccurate or incomplete data
Right to erasure: You can request deletion of your data under certain conditions
Right to restrict processing: You can request restriction of data processing
Right to data portability: You can request your data in a structured, widely-used format
Right to object: You can object to certain processing activities
To exercise any of these rights, please contact us at info@citizensinpower.org
8. Data Security
We implement appropriate technical and organisational measures to protect your personal data from unauthorised access, alteration, disclosure, or destruction, including:
Encryption of data in transit (SSL/TLS)
Encryption of passwords
Regular security testing and updates
Restricted access to authorised personnel only
9. International Data Transfers
Your data is primarily stored in Cyprus (EU). If transferred to third countries, appropriate protective measures will be implemented in accordance with GDPR (e.g., standard data protection clauses).
10. Complaints and Reports
If you have concerns about how your data is being used, please contact us first:
Citizens in Power (CIP)
Email: info@citizensinpower.org
We will investigate the matter and respond within 30 days.
If you are not satisfied with our response, or if you wish to lodge a formal complaint about a data protection rights violation, you have the right to contact the Cyprus Data Protection Authority:
Email: commissioner@dataprotection.gov.cy
Address: 1 Iasonos Street, 1082 Nicosia, Cyprus
11. Contact Us
For any questions or concerns about this Privacy Policy, please contact us:
Citizens in Power (CIP)
Email: info@citizensinpower.org
Cyprus
12. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of any significant changes via the platform or email. Your continued use of the platform following such changes constitutes your acceptance of the updated policy.