Terms of Use – Privacy Policy - Personal Data Protection

 

I. Definitions

For the purposes of the following Terms of Use-Privacy Policy-Personal Data Protection,

The ASIT Toolbox is the online platform that includes practical tools, research findings, and technological innovations to support the fight against human trafficking in today’s interconnected world and is owned by the ASIT Consortium and managed by the Center for Security Studies (KEMEA), as a Consortium member.

 

The EU co-funded ASIT research project has received funding from ISF program under Grant Agreement No 101101942. ASIT (Adequate Support measures and Improved capacities in countering THB) is a 24-month research project that challenges the new forms of trafficking in human beings and empowers the LEAs, judges, NGOs, businesses, mayors and social workers in identifying the victims. The duration of the EU co-funded ASIT project is 24 months as of November 1st, 2023, i.e. until October 31st, 2025.

 

The ASIT Consortium consists of the following members: (MoISR) MINISTERSTVO VNUTRA SLOVENSKEJ REPUBLIKY, the Coordinator of the ASIT project, (INT) Departament d'Interior - Generalitat de Catalunya, (HELLENIC POLICE) HELLENIC POLICE, (CESIE) CESIE, (KEMEA) KENTRO MELETON ASFALEIAS, (KWP) KOMENDA WOJEWODZKA POLICJI W KRAKOWIE, (MoIBG) ACADEMY OF THE MINISTRY OF INTERIOR.

 

The Center for Security Studies (KEMEA) is a legal person governed by private law, a scientific, consulting and research body established by the provisions of Law 3387/2005 (Government Gazette A’ 224) and is supervised by the Minister of Citizen Protection. KEMEA has its offices in Athens, at P. Kanellopoulou str. 4, Greece.

 

II. Terms of Use

 

The ASIT Toolbox is created and developed in the context of WP5 “Improving digital capacities of LEA” (WP Leader: KEMEA) of the ASIT GA. The ASIT Toolbox is owned by the ASIT Consortium and managed by the Center for Security Studies (KEMEA), as a Consortium member.

 

The ASIT Toolbox has the aim to provide all users/visitors with beneficial ownership information and its use in fighting trafficking in human beings and the training materials and self-learning modules, under the terms of use included herein.

 

The use of the ASIT Toolbox is subject to the Terms set out below. The use of the ASIT Toolbox presupposes and implies that the user/visitor has studied, understood and accepted all the present Terms of Use. In the event that the user/ visitor does not agree to these Terms, they shall refrain from making use of the ASIT Toolbox. Navigating through the ASIT Toolbox, staying on the ASIT Toolbox, creating links to it (URL) or to its files / services, archiving / bookmarking it, constitute acceptance of its terms of use. For any complaint or request for information, the user may contact KEMEA at the email address: asit_support@kemea-research.gr .

 

The present Terms of Use-Privacy Policy- Personal Data Protection apply regardless of whether you use a computer, mobile phone, tablet or any other device.

 

The ASIT Toolbox is the sole responsibility of the ASIT Consortium Members and cannot be considered to reflect the views of the European Commission.

 

The use of the ASIT Toolbox must be conducted solely for legitimate purposes and in a manner that does not restrict or impede its use by third parties. The user / visitor of the ASIT Toolbox is obligated to use it in accordance with the law and the present terms of use. The user/visitor of the ASIT Toolbox shall not commit any acts or omissions that may cause damage or malfunction and may adversely affect or endanger the provision of services provided through the Toolbox to citizens.

 

The ASIT Toolbox and its content, including (indicatively and not exhaustively) texts, graphics, images, videos, sounds, services, logos etc. (hereafter referred to as ‘Content’) is legally protected under Intellectual Property Rights Law. ASIT Consortium reserves all rights of use and ownership of the ASIT Toolbox and its content, all copies created based on it, as well as all intellectual property rights and all other property rights pertaining to it. It is therefore expressly prohibited to reproduce, use, copy, store, transfer, republish, transmit, publish, distribute, sell, download, translate, communicate, disseminate and modify in any way, in whole or in part the ASIT Toolbox and its content without the prior written consent of the ASIT Consortium. The THB tools included in the ASIT Toolbox are legally protected under Intellectual Property Rights Law and their IPRs are and remain the sole and exclusive property of their owners.

All trademarks, trade names and logos displayed on the ASIT Toolbox are the property of their respective owners and protected by copyright and trademark laws. You agree not to defame or disparage the ASIT project and all the trademarks, trade names and/or logos displayed on the ASIT Toolbox. Unauthorised use of these trademarks and logos is strictly prohibited.  

 

ASIT Consortium uses all endeavours to ensure that the information and content that appears on the ASIT Toolbox is as accurate, true and up to date as possible. It also provides the content (e.g., information, names, pictures, images, data, etc.) and the services made available through the Toolbox ‘AS IS’. Under no circumstances can ASIT Consortium be held liable for any legal claims, civil or criminal or damages of any kind (direct loss, special damage or indirect loss) to the user/visitor of the ASIT Toolbox.

 

The ASIT Toolbox contains links to third party websites for the sole purpose of providing information to the user/visitor. The referral to links belonging to third-party websites does not constitute an endorsement of their views and actions or the acceptance of the content they express, publish or post. Third-parties -owners of the websites/responsible under the law- are solely responsible for the content of their websites or for any damage that may result from their use when the user / visitor of the ASIT Toolbox gains access to them. ASIT Consortium makes all efforts to ensure the proper function of its network but does not guarantee that its server operations will be uninterrupted or error-free, free from viruses, malicious software or other similar elements.

 

The terms and conditions of use of this ASIT Toolbox, as well as any amendment thereof, are governed by and supplemented by national and European law and the applicable international treaties. Any provision of these terms which is found to be against the above legal framework or is rendered invalid ceases to be valid and enforceable and shall be withdrawn from the present terms, without in any way undermining the validity of the remaining terms.

 

The terms and conditions of use of this ASIT Toolbox constitute the overall agreement between the ASIT Consortium and the users/visitors of the ASIT Toolbox and bind solely them. No modification of the terms of use is taken into account and is part of this agreement, unless it is expressed in writing and is incorporated in the present Terms of Use. Unless otherwise stated on the ASIT Toolbox, the above terms of use are immediately applicable in their entirety. ASIT Consortium unilaterally reserves the right to modify, add, alter the content or services of the ASIT Toolbox and its terms of use, whenever it deems necessary, without prior notice, through this Toolbox, always within the legal framework in force.

 

 

III. Privacy Policy- Protection of Personal Data

 

The present Privacy Policy – Protection of Personal Data clarifies in a layered manner the processing of personal information of users/visitors of the ASIT Toolbox. The data processing on the ASIT Toolbox is pursuant to Regulation (EU) 2016/679 (General Data Protection Regulation) and in accordance with Greek Law 4624/2019 for the protection of personal data, applicable to Center for Security Studies (KEMEA). 

Personal data, as defined in Article 4(1) General Data Protection Regulation (GDPR) include any information relating to an identified or identifiable living natural person. Personal data can be your first name, last name, e-mail address and IP address. Hereinafter, by using the terms “we” and “our”; we refer to the data controller, namely KEMEA. Hereinafter, by using the terms “you” and “your”, we refer to the ASIT Toolbox user/visitor.

The ASIT Toolbox is owned by the ASIT Consortium and managed by the Center for Security Studies (KEMEA) and is committed to protecting your privacy. This Section explains the procedure through which KEMEA acting as Data Controller collects, processes, transfers, uses and discloses users’ data as well as provides information regarding the actions which a user/visitor of the ASIT Toolbox must take if they do not wish their personal information to be further collected or processed while using the ASIT Toolbox. Users/visitors can use the ASIT Toolbox without disclosing their personal data. Users/visitors are not required to provide their personal data as a condition of access to and use of the ASIT Toolbox, except when users/visitors send e-mail directly to the KEMEA’s email address (asit_support@kemea-research.gr) and the statistical browsing information, as analysed below.

Data Controller

KEMEA is the Data Controller. For any further information you may contact KEMEA as follows:

Center for Security Studies (KEMEA) established in P. Kanellopoulou str. 4, Athens 10177, Greece. For any inquiry, please send an email to the following email address: asit_support@kemea-research.gr .

 

Data Protection Officer (DPO)

In case you have any question about the processing of your data, or you wish to exercise your rights related to data protection, you may contact the Data Protection Officer (DPO) of KEMEA at the following email address: dpo@kemea-research.gr.

Types of Personal Data

When the user/ visitor uses the ASIT Toolbox, KEMEA collects the following information sent by the user/visitor themselves:

v  (i) Information, messages and files sent directly to KEMEA’s e-mail address (asit_support@kemea-research.gr)

The information provided on an optional and voluntary basis by the user / visitor may include their name, e-mail address and / or other contact details, expertise or title, area residence, etc.

ΚΕΜΕΑ shall contain such data in hardcopy and electronic files and / or databases in full compliance with data protection legislation, including security and confidentiality requirements based on the principles of good practice, proportionality and transparency regarding processing.

 

v  (ii) Statistical browsing information

In some cases, technical information may be automatically (e.g. not through registration) aggregated when the user / visitor visits or makes use of the ASIT Toolbox. Examples of this kind of information that can be collected are the type of Internet Browser used by the user / visitor, the type of operating system of the computer used by the user / visitor to visit the ASIT Toolbox, the IP used for this access and the URL used by the user / visitor to connect to the ASIT Toolbox.

 

Cookies

The ASIT Toolbox does not use any kind of cookies.  

 

 

Purposes of Processing

KEMEA may use the user / visitor’s personal data for communication purposes in order to respond to any requests/questions submitted by the user/visitor, unless the latter does not wish so and expresses such wish during their communication with KEMEA.

In addition, the personal data are processed by KEMEA for scientific research purposes related to the EU co-funded project ASIT (Grant Agreement No101101942).

Personal data may be processed for compliance with legal or administrative obligations.

 

Personal data may be processed for accountability purposes towards the granting authority (European Commission).

 

KEMEA does not sell any personal information of third parties or users / visitors of the ASIT Toolbox. KEMEA does not transfer or disclose personal information of the users / visitors of the ASIT Toolbox to third parties, unless otherwise specified by law or if it is a contractual obligation necessary for the proper functioning of the ASIT Toolbox and the realisation of its functions. KEMEA may process part, or all of the data sent by users / visitors for statistical purposes and to improve its information services. The user / visitor should be aware that when they voluntarily disclose their personal information (such as name, e-mail address) to an interaction site, such information, along with the actual information disclosed in their contact, may be collected, correlated, and used by third parties and may result in ‘unsolicited’ sending of messages from third parties. Such actions are not controlled by KEMEA, which does not guarantee that the user / visitor’s identity will not be disclosed if methods that are impossible to control are used.

 

Legal Basis

The personal data that the ASIT Toolbox processes are provided by the user/visitor when they decide to access the ASIT Toolbox and to communicate by email with the Data Controller. The Data Controller uses the personal data based on the consent of the user/visitor when they submit an email.

Personal data may be processed based on article 6 (1)(c) GDPR, when the processing is necessary for compliance with a legal obligation.

Data Storage and Data Security

Your personal data will be securely stored and accessed only by authorised personnel of the Data Controller.

We utilise state-of-the-art technology to store your data. The following safeguards are used to protect your personal data from misuse or any form of unauthorised processing:

-          Access to personal data is restricted to a limited number of authorised for the stated purposes.

-          The IT systems used for processing data are technically isolated from other systems to prevent unauthorised access and hacking.

-          Access to these IT systems is constantly monitored to detect and prevent misuse in the early stages.

 

Data Retention

The Data Controller will keep your personal information only for as long as it is necessary for the above purposes for which it was originally collected, and no more than 5 years after the termination of the ASIT research project (31 October 2030 or later if the project is officially extended) or for as long it may be required by a legal obligation.

If this reasonable period of time expires, personal data will be securely deleted.

 

Data Recipients

Your personal data will be accessible only by the Data Controller and may be shared with the ASIT Consortium and/or with the European Commission.

ASIT Consortium does not transfer or disclose personal information of the users/ visitors to third parties, unless otherwise specified by law or if it is a contractual obligation necessary for the proper functioning of the ASIT Toolbox and the realisation of its functions.

 

Data transfer

No transfer to non-EU countries/ international organisations is foreseen.

 

Data Breaches

The Data Controller will report any unlawful data breach of your personal data within 72 hours after having become aware of the breach to the Supervisory Authority.

 

Data Subject’s Rights

Under the circumstances of law, you have the following rights:

You have the right to:

  • Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding it.
  • Request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request rectification of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you.
  • Request transfer of your personal information in an electronic and structured form to you or to another party (right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
  • Lodge a complaint with a supervisory authority. You have the right to contact the competent supervisory authority of your habitual residence or of KEMEA’s headquarters. In the latter case, you can file a complaint with the Hellenic Data Protection Authority https://www.dpa.gr/en .
  • Withdraw your consent at any time. Please note that the withdrawal does not affect the processing of your data which is based on the consent you have given before the withdrawal. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose/purposes you originally agreed to (Article 7 par. 3 GDPR).

 

In order to exercise your rights, you may contact the Data Protection Officer (DPO) at the following email address: dpo@kemea-research.gr.

Children’s Privacy

ASIT Toolbox is not intended for use by children under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from children. If you are a parent or guardian and you are aware that your child/ren has/have provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information.

Time Limits for Compliance with your Rights

We make every effort to comply with all requests within thirty (30) days. However, this period may be extended for reasons relating to the specific right or complexity of your request.

 

Amendments to our Terms of Use and Privacy Policy – Personal Data Protection

The present Terms of Use – Privacy Policy – Personal Data Protection is effective as of May 2025.

The present Terms of Use- Privacy Policy- Protection of Personal Data may be reviewed and updated in order to comply with the legislation and new developments at any time and without further notice. We recommend that you check the present Terms of Use - Privacy Policy – Protection of Personal Data regularly in order to keep track of any changes, as the continuous use of the ASIT Toolbox implies full acceptance of any possible modifications. 

 

Last Update: 21/05/2025