SUSTAIN-HTA

Purpose of Data Collection

To provide you with access to our e-learning platform, we process certain personal data relating to you. This allows us to create your user account, track your learning progress, and monitor platform usage.

Types of Personal Data Collected

• Name
• Email address
• Country
• Background
• Affiliation (optional)

Legal Basis for Processing (GDPR)

We process your personal data under the following legal bases, depending on the purpose of processing:

• Performance of a contract (Article 6(1)(b)): Processing is necessary to provide you with access to and use of the e-learning platform, including account creation, course participation, and progress tracking.
• Legitimate interests (Article 6(1)(f)): Processing is necessary for ensuring the security, stability, and improvement of the platform, including basic usage analytics and system monitoring. We ensure that such processing does not override your fundamental rights and freedoms.
• Consent (Article 6(1)(a)): Where you choose to provide additional, non-essential personal data (such as a profile picture, biography, or other optional profile information) processing of such optional data is based on your consent. Providing such data is entirely voluntary and is not required for using the core functionality of the platform. You may modify or delete this information at any time via your account settings, or request its removal.

How Your Data Will Be Used

• To create and manage your e-learning account
• To track your progress and activity within the platform
• To generate usage reports for internal monitoring and improvement

Your personal data is not used for marketing purposes and is only shared with parties necessary for the operation of the e-learning platform. This includes the following parties:

• Syreon Research Institute Ltd., acting as the data controller
• Klippe Learning Educational and Provider Ltd., acting as data processor

Personal data may also be disclosed where required by applicable law.

Data Storage

Your personal information will be stored by the following entities:

Data Controller: Syreon Research Institute Ltd. (Syreon Kutató Intézet Kft.)
Headquarters: Mexikói út 65/A, 1142 Budapest, Hungary
EU-tax identification number: HU14463589
Represented by: Dr. Tamás Zelei, managing director
Contact: info@sustain-hta.org

Data Processor: Klippe Learning Educational and Provider Ltd.
Headquarters: Hungary, H-1123 Budapest, Győri út 20. 3. em. 7.
Commercial registry number: 01-09-164126
Tax identification number: HU10703546
Represented by: Dr. Péter Tamás Balkányi, managing director

Further information about data processing arrangements can be provided upon request.

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it
was collected:

• Account-related data (e.g., name, email address) is retained for the duration of your account. Upon account deletion, such data is deleted or anonymized within 60 days.
• Learning and activity data is retained for the duration of your account and deleted or anonymized within 60 days after account termination.
• Optional profile data is retained until you remove it or delete your account.
• System-generated data (such as logs and technical records) may be retained for a limited period for security, auditing, and system monitoring purposes and is handled in accordance with applicable retention settings.

In certain cases, where complete deletion is not possible (for example, where data is part of shared content or required for system integrity), identifying information will be removed or anonymized so that it can no longer be linked to you.

Certain data may be retained for longer where required by applicable law or where necessary to establish, exercise, or defend legal claims.

International Data Transfers

Your personal data is stored and processed exclusively within the European Economic Area (EEA). We do not transfer your personal data to countries outside the EEA. You may request further information about these safeguards by contacting us using the contact details provided below.

Your Rights Under the GDPR

You have the right to:

• Access your personal data, including obtaining confirmation of whether your data is
  being processed and receiving a copy of it
• Request correction of inaccurate or incomplete data
• Request deletion of your personal data under certain conditions
• Request restriction of processing in specific cases
• Object to processing where it is based on legitimate interests
• Receive your data structured, commonly used, and machine-readable format and,
  where technically feasible, transmit it to another controller
• Withdraw your consent at any time where processing is based on consent
• Lodge a complaint with a supervisory authority

You may request deletion of your account at any time. Upon such request, your personal data will be deleted or anonymized in accordance with the retention periods outlined above, unless retention is required by law or justified by legitimate interests (e.g., legal claims or security purposes).

Contact Information

For any questions or to exercise your rights, please contact: info@sustain-hta.org