PHAROS Erasmus+ Learning Platform (pharoserasmus.eu)

Last updated: [21/11/2025]

The PHAROS Erasmus+ Consortium (“PHAROS Consortium”, “we”, “us”, or “our”) is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, and safeguard your information when you visit https://pharoserasmus.eu, register for online courses, or interact with our learning platform (“Website”).

This Privacy Policy complies with the General Data Protection Regulation (GDPR) (Regulation EU 2016/679).

1. Who We Are

The PHAROS Erasmus+ Learning Platform is operated by the PHAROS Consortium, a partnership of organisations implementing the Erasmus+ project “PHAROS”.

Website address: https://pharoserasmus.eu
Project contact point: DOREA Educational Institute
Email: info@dorea.org

2. What Personal Data We Collect

We only collect personal data when it is voluntarily provided or automatically generated through your use of the Website.

2.1 Data you provide directly

You may provide personal data when you:

register for an online course,
create a user account,
submit a contact form,
subscribe to updates,
leave a comment on the Website.

This data may include:

first and last name
email address
country of residence
username
profile information
communication preferences

For contact forms, we may also collect the content of your message.

2.2 Comments

When visitors leave comments, we collect:

data shown in the comments form,
visitor’s IP address,
browser user agent string (for spam detection).

If you use Gravatar, an anonymised hash based on your email may be sent to the Gravatar service.
Gravatar Privacy Policy: https://automattic.com/privacy/

After comment approval, your profile picture (if any) becomes publicly visible next to your comment.

2.3 Media Uploads

If you upload images, you should avoid uploading images containing embedded location data (EXIF GPS). Visitors may download and extract such data.

2.4 Cookies and Usage Data

The Website uses cookies to ensure proper functionality. Cookies may store:

your login status,
screen display settings,
comment form details (name, email, website),
session security information.

Examples:

“Remember Me” login cookies last for two weeks.
Comment form cookies last for one year.
A temporary cookie checks if your browser accepts cookies; it is deleted when you close your browser.
If you edit or publish content, a cookie storing the post ID may be saved for one day.

2.5 Embedded third-party content

Articles may include embedded content (e.g., YouTube videos, documents, social media).
Such content behaves as if you visited the originating site and may collect data, including:

cookies,
tracking data,
interaction analytics,
If logged in to those external platforms.

2.6 Automatically collected technical data

The Website may automatically collect:

IP address
browser type/version
device type
pages visited
date and time of access
referring URLs

This helps ensure website security and performance.

3. How We Collect Your Data

Personal data is collected only in the following situations:

when you register for an online course,
when you fill out forms on the Website,
when you submit a contact request,
when you subscribe to email notifications (if applicable),
when you leave a comment,
when cookies are stored in your browser during normal use of the platform.

We do not collect personal data from visitors who simply browse the Website unless essential for technical or security purposes.

4. Purposes for Processing Personal Data

Your personal data is collected and processed for:

providing access to online courses and learning materials,
creating and managing your user account,
responding to your enquiries,
maintaining website security,
generating anonymised statistics for reporting to the European Commission and/or relevant Erasmus+ National Agencies,
sharing project updates only if you explicitly consent.

We do not use your data for commercial or marketing purposes beyond the project scope.

5. Legal Basis for Processing

Under the GDPR, personal data must be processed under at least one lawful basis. We process your data on the basis of:

Your consent (for registration, communication, forms, cookies)
Performance of a task carried out in the public interest (Erasmus+ project reporting)
Compliance with legal obligations (EU project documentation requirements)
Legitimate interests such as website security and spam prevention

You may withdraw your consent at any time by contacting info@dorea.org.

6. How Long We Retain Your Data

Comments and their metadata: retained indefinitely to support follow-up comment approval.
Registered user accounts: data stored as long as the account remains active or until deleted.
Course registration data: retained for the duration of the PHAROS project and reporting obligations.
Technical logs: retained for security purposes for a limited period (usually weeks to months).

Once data is no longer needed, it will be securely deleted or anonymised.

7. Who We Share Your Data With

Your data may be shared only with:

PHAROS Consortium partners (for course delivery and reporting),
approved service providers managing website hosting or security,
automated spam detection services (e.g., Akismet),
EU funding authorities, if required, for Erasmus+ reporting.

We do not sell or transfer personal data to unrelated third parties.

If you request a password reset, your IP address will be included in the reset email.

8. Where Your Data Is Sent

Visitor comments may be checked by automated spam detection tools.
Data is stored on secure servers within the EU (unless the hosting provider states otherwise).
If technical support is provided outside the EU, GDPR-compliant safeguards (e.g., Standard Contractual Clauses) are applied.

9. How We Protect Your Data

We use several technical and organisational measures to protect your data, including:

encrypted data transmission (HTTPS),
firewalls and anti-intrusion tools,
secure user authentication,
limited administrative access,
regular website security checks,
GDPR-compliant hosting environment.

However, no online system is entirely immune from security vulnerabilities. We take all reasonable steps to minimise risks.

10. Your Data Protection Rights

Under GDPR, you have the right to:

request a copy of your personal data,
request correction of inaccurate data,
request deletion of your data (“right to be forgotten”),
request restriction of processing,
object to processing under certain grounds,
request data portability,
withdraw consent at any time.

To exercise these rights, contact info@dorea.org.
We will respond within one (1) month as required by GDPR.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Commissioner for Personal Data Protection (Cyprus) or your national Data Protection Authority.

11. Links to External Websites

Our Website may contain links to external websites for your convenience.
Please note that we have no control over the content or privacy practices of those sites.

We recommend reviewing their respective privacy policies.

12. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in legislation, project requirements, or platform functionality. Updates will be posted on this page with an amended “Last Updated” date.

13. Contact Information

For questions regarding this Privacy Policy or your personal data rights, contact:

DOREA Educational Institute
Project Partner – PHAROS Erasmus+
Email: info@dorea.org