1. Scope

This Privacy Policy explains how personal data may be processed when users visit or use the Empowered by Empathy Digital Education Platform, including its public pages, Moodle courses, online Books, PDF publications and support resources.

2. Responsibility for the processing

Project coordinator and data controller for the project purposes described in this notice:
Kırıkkale Sosyal Hizmetler Derneği (KISODER)
Ovacık Mah. Zafer Cad. 9/31, Kırıkkale, Türkiye.

KISODER coordinates the Empowered by Empathy project and is responsible for the project purposes, educational content and overall use of the Digital Education Platform.

Technical platform operator:
REDEFINE - Associação para a Investigação, Educação e Desenvolvimento
Av. São Francisco Xavier, Lote 1, 7G, 2900-616 Setúbal, Portugal.

REDEFINE operates and maintains the Moodle platform on behalf of the project, including technical administration, maintenance, security and support.

Privacy and technical contact: info@redefine.pt

No Data Protection Officer has been formally designated for this platform.

3. Public Guest access

The public learning resources are designed to be accessed without creating a user account. Moodle may automatically create a Guest session in order to provide navigation and access to public courses and resources.

4. Personal data that may be processed

• Technical and security data: IP address, date and time, requested page, browser/device information, server logs, error logs and session identifiers.
• Session and interface information: information required to maintain the Moodle session and selected interface language.
• Account data: name, username, email address and related profile information, only where an account is specifically created or administered.
• Support and communications: information supplied when a user contacts the project or requests technical support.

5. Purposes of processing

• to provide access to project information, educational resources and publications;
• to maintain essential Moodle sessions and Guest access;
• to operate, secure, maintain and troubleshoot the platform;
• to administer accounts where account access is specifically used;
• to answer support, privacy or administrative requests;
• to comply with applicable project, legal, security and record-keeping obligations.

6. Legal bases

Necessary technical, security and session processing is carried out on the basis of the legitimate interests in providing and protecting the educational platform. Other processing may be necessary to comply with legal or project-management obligations, or to respond to requests made by users. Consent will be requested where processing requires consent under applicable law.

7. Recipients and service providers

Access to personal data is limited to authorised project and technical personnel who require it for project administration, platform operation, security or support. Personal data is not sold.

Hosting provider: SuperHosting.BG Ltd., Bulgaria, European Economic Area. The hosting provider processes data stored on its infrastructure in connection with the provision of hosting services.

The platform does not currently use advertising, behavioural tracking or analytics services.

8. International data access and transfers

The platform is technically operated from Portugal and hosted in Bulgaria, both within the European Economic Area. KISODER, the project coordinator, is established in Türkiye. The platform is designed to minimise personal data and routine technical administration is performed within the EEA. Where project administration requires personal data to be accessed or disclosed in Türkiye, that access is treated as an international data transfer and must be handled in accordance with the applicable safeguards required by data-protection law.

9. Retention

Personal data is retained only for as long as necessary for the purposes described above, platform security, project administration, legal obligations and legitimate record-keeping requirements. Where an exact retention period cannot be stated in advance, the period is determined according to the type of data, the purpose for which it is processed, security needs and applicable project or legal requirements.

10. Security

Appropriate technical and organisational measures are used to protect personal data against unauthorised access, alteration, loss or disclosure. Access to administrative functions is restricted to authorised personnel.

11. Your rights

Subject to the applicable legal conditions, individuals may request access to their personal data, rectification, erasure, restriction of processing, objection to processing and data portability where applicable. Where processing is based on consent, consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

Requests may be sent to info@redefine.pt. Reasonable identity verification may be required before a request is completed.

12. Children and sensitive information

The platform is primarily intended for adult caregivers, trainers and professionals. Users should not upload identifiable information about children, case files, health information or other sensitive personal data unless a specific authorised process and lawful basis have been established.

13. Complaints

Individuals have the right to lodge a complaint with a competent data-protection supervisory authority, including the supervisory authority in the EU/EEA country of their habitual residence, place of work or the place of the alleged infringement, where applicable.

14. Cookies

The public platform currently uses only the technically necessary Moodle session cookie identified in the platform's Cookie Notice.

15. Updates

This policy may be updated if the platform configuration, project arrangements, service providers or applicable legal requirements change. The date of the latest revision will be shown at the top of this page.