PRIVACY POLICY AND COOKIE POLICY

1. PRIVACY POLICY

Data Controller

EDUCATION EXPERT FOR YOU d.o.o. For course organization and services

Registered Office: Novigradska ulica – Via Cittanova 35, 52470 Umag – Umago, Croatia

OIB / VAT ID: HR02316806472 | MBS: 130160776

Email: info@courses-erasmus.eu

Website: https://courses-erasmus.eu/ - https://courses-erasmus.com – https://education-expert.eu

1. Purposes and Legal Bases for Data Processing

The Company collects and processes personal data solely for lawful, predetermined purposes pursuant to Article 6 and Article 9 of the General Data Protection Regulation (GDPR):

1.Course Organization and Execution of Educational Mobilities:

    • Categories of Data Processed: First name, last name, email address, telephone/mobile number, name and address of the employing institution, job title/role, billing details.

    • Legal Basis: Performance of a contract or taking steps at the request of the data subject prior to entering into a contract (Article 6(1)(b) GDPR).

2. Special Categories of Data (Dietary, Health Requirements, and Accessibility):

    • Categories of Data Processed: Information regarding food allergies, specific dietary requirements, disabilities, or special accommodation arrangements.

    • Legal Basis: Explicit consent of the data subject (Article 9(2)(a) GDPR). Consent is collected via a dedicated field in the registration form and may be withdrawn at any time.

3. Minor Participants (Participants Under 18 Years of Age):

    • Categories of Data Processed: Necessary student identification details required to execute pupil Erasmus+ mobility programmes.

    • Legal Basis: Data processing is primarily carried out through the sending school or educational institution (Article 6(1)(b) GDPR). For direct collection of personal data from minors under 16 years of age via information society services, authorization from the holder of parental responsibility is secured (Article 6(1)(a) in conjunction with Article 8 GDPR).

4. Direct Marketing and Newsletters (Mautic Automation):

    • B2B Marketing (Educational Institutions and Legal Entities): Sending notices and professional offers for Erasmus+ courses to publicly available official institutional email addresses is conducted based on the Company's legitimate interest in promoting educational services (Article 6(1)(f) GDPR and Article 107(2) of the Croatian Electronic Communications Act. Data subjects retain the right to object to such processing at any time free of charge.

    • B2C Marketing (Private Individuals / Consumers): Marketing communications and newsletters are sent to private individuals exclusively based on prior explicit consent (Article 6(1)(a) GDPR).

5. Interactive System (Botpress AI Assistant):

    • Categories of Data Processed: Content of chat inquiries. Collection of identification or contact details for follow-up and issuing tailored course offers is based on explicit consent provided directly within the chat interface (Article 6(1)(a) GDPR).

2. Independence and Relationship with JUTAKI Kft.

Education Expert for you d.o.o. and the Hungarian company JUTAKI Kft. operate as completely independent and separate Data Controllers. Any referral of inquiries, recommendations, or contact intermediation between these entities constitutes an intermediary business activity. Personal data is never shared automatically, but strictly under an appropriate legal basis (explicit consent or contractual necessity).

3. Data Recipients and Transfers to Third Parties (Data Processors)

Personal data is never sold or unauthorizedly disclosed to third parties. Data is shared exclusively with necessary, contractually bound Data Processors who guarantee appropriate technical and organizational security measures:

  • IT Infrastructure and Service Providers:

    • Fehér Rendszerház Informatikai Kft. (Website hosting and servers – EU)

    • Google Ireland Ltd. / Google LLC (Google Forms & Workspace – governed by EU Standard Contractual Clauses (SCCs) for international transfers)

    • Botpress Inc. (AI chat platform provider – governed by SCCs)

    • Mautic Inc. (Marketing automation system)

  • Accounting Agency: BREVIS UMAG d.o.o. (Umag, Croatia) – for compliance with statutory tax and accounting obligations.

  • Local Logistics Partners: Accommodation providers, catering services, and transport companies (strictly minimized dietary or accessibility data necessary for safe stay execution).

  • Third-Party Course Providers: Where the Company acts strictly as an intermediary (pursuant to Section 1.2 of the General Terms and Conditions), participant details are forwarded to the direct course organizer for training execution.

4. Photography, Video Recordings, and Erasmus+ Dissemination

During training courses and mobility activities, the Company may take photographs and video recordings to document, disseminate, and promote Erasmus+ project results (publication on websites, social media, and official reports for the Agency for Mobility and EU Programmes).

Processing and public display of identifiable photographs or videos of participants is carried out exclusively based on prior signed written or electronic consent. Providing consent is voluntary and may be withdrawn at any time without adverse consequences on course participation.

5. Data Retention Periods

Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected or to comply with statutory retention requirements:

  • Accounting and Contractual Documentation: Retained for 11 years pursuant to the Croatian Accounting Act.

  • Dietary and Special Health Data: Permanently deleted or anonymized within 30 days following course completion.

  • Marketing Data (Consents and Mautic Records): Retained until consent is withdrawn, an objection is lodged, or the user unsubscribes via the "Unsubscribe" link.

  • Botpress AI Chat Data: Deleted within 6 months of creation, unless a contractual relationship is established.

6. Data Subject Rights

Pursuant to the GDPR, every data subject is guaranteed the following rights regarding their personal data:

  1. Right of Access: Right to obtain confirmation as to whether personal data concerning them is being processed and to access that data.

  2. Right to Rectification: Right to obtain without undue delay the rectification of inaccurate or incomplete personal data.

  3. Right to Erasure ("Right to be Forgotten"): Right to request the erasure of personal data when it is no longer necessary or when consent has been withdrawn (unless statutory retention obligations apply).

  4. Right to Restriction of Processing: Right to request restriction of processing in cases specified under Article 18 GDPR.

  5. Right to Data Portability: Right to receive personal data in a structured, commonly used, and machine-readable format.

  6. Right to Object: Right to object at any time to processing based on legitimate interests, including profiling and direct marketing.

  7. Right to Withdraw Consent: Consent may be withdrawn at any time without affecting the lawfulness of processing based on consent before its withdrawal.

Data Subject Rights Request Form (PDF – Click here to download)

To exercise any of your rights, contact us at: info@courses-erasmus.eu.

You also have the right to lodge a complaint with the supervisory authority:

Croatian Personal Data Protection Agency (AZOP)

Metela Ožegovića 16, 10000 Zagreb, Croatia

Email: azop@azop.hr | Website: www.azop.hr

 

2. COOKIE POLICY

The websites courses-erasmus.eu - courses-erasmus.com - education-expert.eu use cookies and similar technologies to ensure proper website functionality, enable the AI course search assistant, and analyse web traffic.

The collection of cookies complies with Article 134 of the Croatian Electronic Communications Act (CEC) and the EU ePrivacy Directive.

Cookie Classifications

1.Strictly Necessary Cookies – Always Active:

    • Description: Essential for technical website functionality, security, and navigation (e.g., maintaining your session or recording your cookie preferences).

    • Consent: Not required. CEC and ePrivacy exempt strictly technical cookies from consent requirements.

2. Functional Cookies:

    • Description: Enable enhanced functionality and personalization, such as the interactive Botpress AI course search assistant and language preference memory.

    • Consent: Activated based on your explicit prior consent (Opt-in).

3. Analytics & Marketing Cookies:

    • Description: Help us understand how visitors interact with the website (Google Analytics), measure marketing campaign effectiveness (Meta Pixel), and enable automated Mautic scripts.

    • Consent: Activated exclusively following your explicit consent (Opt-in) via the Cookie Banner. You retain the right to modify or withdraw your consent at any time in the footer under "Cookie Settings".

To exercise any of your GDPR data protection rights (access, rectification, erasure, or withdrawal of consent), please download and complete the form below and send it via email to info@courses-erasmus.eu:

Data Subject Rights Request Form (PDF – Click here to download

Report document