1. INTRODUCTION

1.1. General statement – We respect your privacy

Holding Slovenske Elektrarne (“HSE”), as the Coordinator on behalf of the North Adriatic Hydrogen Valley (“NAHV”) project, fully respects your right to privacy and is committed to the protection of personal data, in accordance with the provisions of the General Data Protection Regulation.

This privacy notice will give you information on how the NAHV project (hereafter also: the project) collects, uses, shares and looks after your personal information.

Personal information, or personal data, means any information about an individual from which that person can be identified. Anything we do with your personal information (from the point at which we collect it until we delete it from our systems) is called processing.

This Notice also details the rights available to you in relation to how we hold and use your Personal Data, how to exercise those rights, and what to do if you require more information or wish to make a complaint.

All personal and institutional data provided to the project (e.g. web submission forms, event registrations) will be managed according to the GDPR 2016/679 and national laws (where appropriate). Other types of data will be safely stored using the institutional data safety protocols of the responsible institution, in conformity with the internal rules and regulations concerning the organisation of the project Consortium.

1.2. Who is responsible for your information?

HSE is responsible for your information for the personal data we process. This Notice applies to HSE, as the Coordinator on behalf of the NAHV project. The use of “we”, “us”, “our” and “ours” in this Notice refer to HSE in the capacity of the Coordinator of the NAHV. For more information about us, please see our About webpage: https://www.nahv.eu.

If you want to get in touch and seek to exercise your rights as described below, please contact us at privacy@nahv.eu.

1.3. Layout

This privacy notice is provided in a layered format, so you can click through to the specific areas set out below:
• The NAHV project
• The NAHV Project Partners
• When this privacy notice applies
• Our Legal Bases
• Sharing Your Information
• Consequences of not providing personal information
• NAHV project activities and how we will collect, use and share personal information
• Security
• Informing us of changes to your personal information
• Your rights
• Complaints
• How long we will keep your personal information

This is the current version of our privacy notice. It was last updated in March 2024.

The NAHV project website (https://nahv.eu/) is not intended for children and we do not knowingly collect personal information relating to children.

It is important that you read this privacy notice together with the privacy notices or fair processing notices associated with the other organisations who are NAHV Project Partners (as outlined in the NAHV Project Partners list). This privacy notice supplements the other notices and is not intended to override them.

2. THE NAHV PROJECT

The North Adriatic Hydrogen Valley (NAHV) is the first transnational hydrogen valley under the Horizon Europe programme, supported by the Clean Hydrogen Partnership JU. The NAHV‘s ambition is the creation of a hydrogen-based economic, social and industrial ecosystem based on the capacity of the quadruple helix actors.

The key aim of the initiative is to create a market for green (renewable) hydrogen on both the demand and supply sides, making it a competitive energy source for the future. Key industry players from all three countries will develop pilot projects to produce up to 5,000 tonnes of renewable hydrogen per year from renewable energy sources, destined for energy storage, distribution and use.

Further information on the NAHV project and its Project Partners can be found at https://www.nahv.eu/.

3. THE NAHV PROJECT PARTNERS AND DATA PROTECTION OFFICER

3.1. The NAHV project partners

The list of Project Partners in the NAHV project can be found at https://www.nahv.eu/partners/ with the links to the partners websites. Personal information collected through the NAHV will only be shared as necessary with the other Project Partners.

3.2. Data Protection Officer

For Data Protection Law, each of the NAHV Project Partners and associated organisations, as listed above, are the controllers of personal data they process. However, HSE as the NAHV Coordinator acts as the main point of contact for individuals. Furthermore, according to the project’s governance structure, The IPR and Data Management Board is responsible for overseeing questions in relation to the data management issues of the NAHV project including this privacy notice. If you have any questions about the privacy notice, including any requests to exercise your legal rights in respect of your personal information, please contact the Coordinator or IPR and Data Management Board using the details below.

Email: privacy@nahv.eu

4. WHEN THIS PRIVACY NOTICE APPLIES

This privacy notice applies to any and all NAHV activities, and includes without limitation:
· When you give your personal details through registration systems and / or attend any of our NAHV events
· When you send an enquiry through out website
· When you have asked to receive information and updates in relation to the NAHV project
· When your personal data is included as part of an NAHV case study in a publication or on the website
· To help you better understand how the NAHV Project Partners will process personal data, each of the activities are detailed further below in the section ‘Project activities and how we will collect, use and share personal information’.

5. INFORMATION YOU GIVE US ABOUT OTHER PEOPLE

If you provide information to us about any person other than yourself, you should ensure that you have a legal basis for doing so and that you have complied with your transparency obligations under data protection law.

6. OUR LEGAL BASES

Data protection law says that we must have legal grounds in order to process your personal information. These are known as lawful grounds. There are six lawful grounds. For NAHV Project Partners, the lawful grounds relied upon to process personal data includes:

the performance of task carried out in the public interest or in the exercise of official authority.
necessary for compliance with a legal obligation that applies to us.

iii. Where you have provided consent for the use of your Personal Data. You can withdraw it at any time by informing communication@nahv.eu, however, this will not affect the lawfulness of processing which was carried out based on your consent prior to its withdrawal.

7. SHARING YOUR INFORMATION

Personal information will be shared by the NAHV Project Partners who are involved in the NAHV project (as detailed above in the Project Partners section).

The information may be shared with the funding organisation, European Commission, the European Court of Auditors and any national audit authorities for the purposes of reporting on the NAHV project, audit and compliance. Where required to do so by law, we may also share your information with law enforcement agencies. In the course of administering the NAHV project, we may share information with various other third parties, as set out below. We do this based upon the legal bases and exceptions mentioned in section 6 of this Notice.

Service Providers: We may share your Personal Data to help us administer the Project and communicate with you. Categories of service providers include companies who provide IT software and hosting providers and records-storage companies. Where such third parties are processors, these third parties are contractually required to use it only to provide their servi/ce to us and are contractually barred from using it for their own purposes.
Experts, advisors, lawyers and others connected to the administration of the NAHV Project: We share your information with a variety of third parties, so we can administer the NAHV project. This may include sharing your information with advisers, solicitors and law firms, and other experts.
Legal and safety reasons: We may retain, preserve, or share your information if we have a good-faith belief that it is reasonably necessary to (a) respond, based on applicable law, to a legal request (e.g., a subpoena, search warrant, court order, or other request from government or law enforcement agency); (b) detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues; (c) protect our rights, property, or safety; (d) enforce the Grant Agreement or any other contracts we have with you or a third party which relates to you; (e) prevent physical injury or other harm to any person or entity, including you and members of the public.
Research: We may include your Personal Data in research studies to assess the impact and benefits of the NAHV project. The outcome of these studies may be published, or we may publish individual case studies. However, we will ensure that you will not be identifiable in any such studies, without your consent, which will be separately obtained.

8. CONSEQUENCES OF NOT PROVIDING PERSONAL INFORMATION

NAHV Project Partners require personal information to deliver, manage and monitor all activities of the NAHV project. If you do not provide the NAHV Project Partners with personal information, you will be unable to participate in the NAHV project. You will still be able to access the NAHV website and the information contained within it.

9. NAHV ACTIVITIES AND HOW PERSONAL INFORMATION IS USED

The NAHV project delivers the following main activities:

Setting up a project structure to facilitate the coordination and support of the set project implementation.
Coordination of project activities and monitoring of the project progress, including contractual and project reporting procedures with the Grant Authority – European Commission (EC) and the Clean Hydrogen Partnership JU.
Ensuring effective and efficient internal project communications with partners, and regular communication with the Grant Authority on project activities and results.
Providing regular reports to the Grant Authority with updates on the status of the planned activities.
To ensure partners operating in accordance with EU rules on ethics and data collection.

9.1. Personal information we collect

The NAHV Project Partners will collect, use, store and share different kinds of personal information about you. To help you identify these, they have been grouped together as follows:

Identity data: title, forename, surname, job title, work experience relevant to participation in a NAHV activity
· Contact data: email address, telephone number, employer’s name, address
· Enquiry data: enquiries related to the NAHV project
· Marketing data: your preferences in receiving information and updates related to the NAHV project
· Requirements data: dietary requirements, accessibility needs for events

There is also other information that we collect, use, store and share that is not personal information, including:
Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information, which will be used in accordance with this privacy notice.
· Anonymised Data is the process of turning personal information into a form which does not identify individuals and where identification is not likely to take place.
· Company Data is any information relating to a company, such as the company’s address, financial information, business plans (although these may contain elements of personal information), methodologies, project briefs etc.

Further details on the activities we deliver, and personal information we collect in relation to each activity is set out below.

9.1.1. Enquiries, Events

9.1.1.1. ENQUIRIES

Personal information we collect

The following types of personal data may be collected if you submit an enquiry or register for an event:
· Contact data
· Enquiry data
· Marketing data

How we collect personal information

Personal information will be collected:
· Directly from you when you submit an enquiry to NAHV
· From your employer if they:
o submit an enquiry in which you are copied / mentioned
o nominate you as a contact person for the organisation

How we will use personal information

To process any enquiries which you may submit to NAHV
To provide you with updates / information you have asked for
To invite you to participate in any events or activities delivered by NAHV
For monitoring and evaluating the activities delivered by NAHV

9.1.1.2 EVENTS

NAHV events include, but are not limited to, conferences, workshops, and meetings.

Personal information we collect

The following types of personal data may be collected if you register for an event:
· Contact data
· Identity data
· Requirements data
· Marketing data

How we collect personal information

Personal information will be collected:
· Directly from you when you register for and / or attend a meeting or event
· From your employer if they sign you up for an event on your behalf

How we will use personal information

To register you to attend NAHV events
To ask if you have any specific requirements (e.g. dietary, access) so that we can try to ensure these are addressed
To manage bookings, including notifying you of changes or cancellations
For monitoring and evaluating the activities delivered by NAHV
To maintaining our records and audit trail for verification of NAHV activity and expenditure, in relation to the European Research and Development Funding of the project, European and national regulations and the audit and reporting obligations of the NAHV Project Partners

9.1.2. Questionnaires, Surveys & Feedback

Personal information we collect
· Identity data
· Contact data

How we collect personal information
· Directly from you when you:
o complete a questionnaire
o complete a survey
o provide feedback

How we will use personal information
· To request and collect your input to any questionnaire or research which will be carried out by NAHV
· To send you feedback forms and collect your comments about NAHV activities
· To request and collect your input to any surveys or research which may be carried out by NAHV to evaluate our activities or plan for future activities
· To analyse questionnaire responses, feedback and survey responses and produce reports. Note: The data included in reports will be aggregated and anonymised, unless you give us specific written consent to publish a comment
· For monitoring and evaluating the activities delivered by NAHV
· To maintain our records and audit trail for verification of NAHV activity and expenditure, in relation to the European Research and Develop Funding of the project, European and national regulations and the audit and reporting obligations of the NAHV Project Partners

10. SECURITY

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Where we use third party providers such as Survey Monkey, we have ensured that they too have such appropriate security measures. In addition, our employees, agents, secondees and suppliers will only process personal information on our instructions and in accordance with this privacy statement. They are also subject to a duty of confidentiality.

11. INFORMING US OF CHANGES TO YOUR PERSONAL INFORMATION

It is important that the personal information that we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us, by contacting us using the details below:

NAHV project, e-mail: privacy@nahv.eu

12. YOUR RIGHTS

You have a number of rights in relation to your information that we process. These rights are subject to a number of exceptions under law. To exercise these rights, please contact us at: privacy@nahv.eu.

12.1. Access to your information

You have the right to request a copy of the personal information about you that the NAHV Project Partners hold, in relation to NAHV activities and interactions. You can do so by contacting HSE or the relevant partner.

12.2. Correcting your information

The NAHV Project Partners want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards.

12.3. Deletion of your information

You have the right to ask the NAHV Project Partners to delete personal information about you where:
· You consider that the NAHV Project Partners no longer require the information for the purposes for which it was obtained
· NAHV Project Partners are using the information with your consent and you have withdrawn your consent – see Withdrawing consent to use your information below
· You have validly objected to the use of your personal information by the NAHV Project Partners – see Objecting to how we may use your information below
· The use of your personal information by the NAHV Project Partners is contrary to law or their other legal obligations.

12.4. Restricting how we may use your information

In some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to the use of your information by the NAHV Project Partners.

The right might also apply where NAHV Project Partners no longer have a basis for using your personal information, but you don’t want them to delete the data. Where this right to restrict is validly exercised, the NAHV Project Partners may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.

12.5. Objecting to how we may use your information

You have the right at any time to require the NAHV Project Partners to stop using your personal information to keep you informed about NAHV activities. In addition, where the NAHV Project Partners use your personal information to perform tasks carried out in the public interest or in exercising official authority vested in it then, if you ask them to, they will stop using that personal information, unless there are overriding legitimate grounds to continue.

12.6. Withdrawing consent to use your information

Where NAHV Project Partners use your personal information with your consent you may withdraw that consent at any time and the NAHV Project Partners will stop using your personal information for the purpose(s) for which consent was given.

Please contact HSE or the NAHV Project Partner by any of the ways set out in the Contact information and further advice section if you wish to exercise any of these rights.

12.7. Automated processing

NAHV Project Partners use your personal information in relation to NAHV on an automated basis to make decisions which significantly affect you, you have the right to ask that the decision be reviewed by an individual within the NAHV Project Partners to whom you may make representations and contest the decision. This right only applies where NAHV Project Partners uses your information with your consent or as part of a contractual relationship with you.

13. COMPLAINTS

NAHV Project Partners seek to resolve directly all complaints about how they handle personal information, but you also have the right to lodge a complaint with the Belgian Data Protection Authority, whose contact details are as follows, or equivalent organisations in any of the NAHV project partner countries.

Belgian Data Protection Authority

Rue de la Presse 35
1000 Brussels
Belgium

Phone: +32 2 274 48 00

Email: contact@apd-gba.be

HOW LONG WE WILL KEEP YOUR PERSONAL INFORMATION

We may retain your information for as long as necessary in light of the purposes set out in this Notice, including for the purposes of satisfying any legal, accounting, or reporting requirements and, where required for HSE to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. We also consider regulatory guidance, as appropriate.

The NAHV project is supported by the Clean Hydrogen Partnership JU and is funded by the European Union’s Horizon Europe Research and Innovation Programme under thre Grant Agreement No.: 101111927. European regulations and the Grant Agreement require that the NAHV Project Partners retain information to verify the eligibility of activity and expenditure carried out by the project. All relevant information must be retained for verification and audit purposes until 3 years after the final payment of EU funding.

15. AMENDING THIS PRIVACY NOTICE

From time to time, we may amend this Notice. This might happen, for example, where we make changes to the project activities. If we make material changes to the Notice, we will take steps to notify you, such as by posting a notice on our website.

16. CONTACT INFORMATION AND FURTHER ADVICE

If you want to exercise your rights (described above), or if you have any questions about this Notice, please contact us as follows: