Privacy Policy
Last updated:
This policy explains what personal data we collect through this website, why we collect it, how long we keep it, and the rights you have over it. We have tried to write it in plain language. If anything here is unclear, ask us — the address is at the bottom.
Who is responsible for your data
Two organisations are involved, with different roles.
This website — including the contact form, the newsletter and any account you hold on it — is operated by ABARKA ONGD, which acts as data controller for everything described in this policy.
ABARKA ONGD
Registered address: Agerrealde Etxadia 7bajo, 20180 Oiartzun - Guipuzcoa
Tax identifier (CIF): G95836847
Email: info@ongabarka.org
The wider SereniSleep project is coordinated by MOGA ZNAM TVORIA (Varna, Bulgaria). For questions about the project itself, its Erasmus+ funding, or data processed in project activities outside this website, contact the coordinator at mogaznamtvorya@gmail.com.
We have not appointed a Data Protection Officer, as we are not required to. All data protection enquiries go to info@ongabarka.org.
What we collect, and why
When you use the contact form
We collect your name, your email address, the enquiry type you select, your subject line and your message. We use them only to read and answer your message, and to route it to the right team.
Legal basis: our legitimate interest in responding to people who contact us (GDPR Article 6(1)(f)). You choose what to put in the message — please do not send us health information or other sensitive details through this form.
When you subscribe to updates
We collect your email address and the language you selected. We use them only to send you SereniSleep project updates.
Legal basis: your consent (Article 6(1)(a)). You can withdraw it at any time using the unsubscribe link in any email, or by writing to info@ongabarka.org. Withdrawing consent does not affect anything we sent before you withdrew it.
When you hold an account on this site
Accounts exist only for project partner staff who publish content. We store your name, email address, organisation and the role assigned to you, plus a log of the content changes you make.
Legal basis: performance of our working relationship with you and our legitimate interest in keeping an accurate record of who changed what (Article 6(1)(b) and 6(1)(f)). The change log is a requirement of running a publicly funded project accountably.
When you simply browse
We use privacy-friendly, aggregated website analytics. We do not use them to identify you, we do not build a profile of you, and we do not share the data with advertisers. See our Cookie Policy for exactly what is stored on your device.
Analytics provider: Google
Legal basis: our legitimate interest in understanding whether the site is useful (Article 6(1)(f)), or your consent where the tool requires it.
What we never do
We do not sell your data. We do not share it with advertisers. We do not use it to train AI models. We do not track you across other websites.
How long we keep it
| What we keep | How long we keep it |
|---|---|
| Contact form messages | 24 months from your last message, then deleted |
| Newsletter subscribers | Until you unsubscribe, then deleted within 30 days |
| Account and role records | For as long as you work on the project, then deleted within 6 months |
| Content change log | For the project's record-keeping period, then deleted |
| Website analytics | Aggregated only; no individual record is retained |
The project's record-keeping period is set by our Erasmus+ grant agreement: 3 years after the final payment.
Who else can see it
We use a small number of service providers who process data on our instructions, under contract, and only for the purposes above:
| Service | Provider |
|---|---|
| Website hosting and database | AXARNET |
| Email delivery | info@ongabarka.org |
| Website analytics |
Beyond these, we share personal data only where the law requires it, or where an audit of our Erasmus+ funding requires it — the European Commission, the Bulgarian National Agency (HRDC) and the European Court of Auditors have audit rights over this project.
Transfers outside the European Economic Area
Whether any of the providers above store data outside the EEA: None
If they do, the transfer is protected by the European Commission's Standard Contractual Clauses or an adequacy decision. We will name the mechanism here once confirmed.
Your rights
Under the GDPR you can ask us to:
- give you a copy of the personal data we hold about you
- correct anything that is wrong
- delete your data
- restrict how we use it
- give you your data in a portable format
- stop processing based on legitimate interest, by objecting
- withdraw consent you previously gave
Write to info@ongabarka.org. We will answer within one month. There is no charge.
If you think we have handled your data badly, please tell us first so we can fix it. You also have the right to complain to the Spanish Data Protection Agency (Agencia Española de Protección de Datos), www.aepd.es, or to the supervisory authority in your own country.
Security
Access to personal data is restricted to named project staff with an assigned role. Data is transmitted over encrypted connections, database access is governed by row-level security rules, and every content change is logged. No system is perfect; if a breach affects your rights we will notify you and the supervisory authority as the GDPR requires.
Children
This website and course are intended for adults. We do not knowingly collect data from anyone under 16. If you believe we have, write to us and we will delete it.
Changes to this policy
If we change how we handle personal data we will update this page and change the "Last updated" date at the top. Material changes will be announced on the site.