Privacy policy

1. Introduction

This Privacy Policy describes how the Public Institution Development Agency of Lika-Senj County – LIRA, as lead partner of the ECOFOODCYCLE project, collects, uses, stores, and protects your personal data when you use the website ecofoodcycle.eu (the “Website”), including the login and registration functionality for the Food Exchange feature.

We process personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the General Data Protection Regulation, “GDPR”) and the Croatian Act on the Implementation of the General Data Protection Regulation (Official Gazette 42/18).

The ECOFOODCYCLE project is co-financed under the Interreg VI-A Italy – Croatia cross-border cooperation programme and is implemented by a consortium of partners from Croatia and Italy (the list of partners is available on the “About the Project” page).

2. Data Controller

The controller of the personal data collected through the Website is:

Public Institution Development Agency of Lika-Senj County – LIRA Pazariška ulica 36, 53000 Gospić, Croatia VAT/Tax ID (OIB): 21189792035 Phone: +385 53 560 383 / +385 53 658 010 Email for privacy-related questions: contact@ecofoodcycle.eu

Other ECOFOODCYCLE project partners may, to a limited extent and solely for the purposes of project implementation and reporting (e.g., to the bodies of the Interreg Italy – Croatia programme), have access to aggregated or anonymized data on the use of the Website. The list of partners is available on the “About the Project” page.

3. What personal data we collect
3.1 Data you provide to us – Food Exchange registration and login

To publish surplus food listings, request donations, or otherwise use the food exchange feature, you need to create a user account. In doing so, we collect:

organization / company name,
email address,
phone number,
city,
address,
password (stored in a secure, hashed form and never as plain, readable text).

We use this data to:

create and manage your user account and enable you to log in,
enable you to publish and browse surplus food listings and donation requests,
connect you with other users of the Website to arrange the collection/donation of food (e.g., your organization name, city, and contact details may be visible to the other party with whom you are arranging an exchange),
send account-related notifications (e.g., registration confirmation, password reset notice) — these emails are sent by the Website’s standard system (WordPress/hosting), without the involvement of a third-party email service.
3.2 Data generated through your use of the platform

When you publish a surplus food listing, we also collect the information you enter yourself: item name, category, quantity, description, and location (city) of the item. This information is publicly visible to other visitors and users of the Exchange page.

3.3 Data we collect automatically

When you visit the Website, the following may be collected automatically:

your IP address and basic browser/device information (server log data) — for the purposes of security and the proper functioning of the Website,
data collected through cookies, including statistical data via Google Analytics (number of visits, pages viewed, traffic source, time spent on the site, etc.) — only with your consent given through the cookie banner. Details are described in our Cookie Policy.

The Website is also registered with Google Search Console. This tool allows Google to index the Website and provides us with aggregated statistics on how the Website appears in Google Search (number of impressions, clicks, average position). Google Search Console does not set cookies in your browser and does not allow us to identify individual visitors of the Website.

3.4 Data you send us via contact

If you contact us by email at contact@ecofoodcycle.eu, we process the data you provide at that time (e.g., name, email address, content of your inquiry) solely for the purpose of responding to your inquiry.

3.5 Special categories of data

We do not intentionally collect special categories of personal data (e.g., data on health, religious beliefs, trade union membership, etc.). Please do not submit such data through the forms on the Website.

4. Legal basis for processing

We process your data on the basis of the following legal grounds under Article 6 of the GDPR:

performance of a contract / steps taken prior to entering into a contract (Art. 6(1)(b)) – for data collected during registration and use of the food exchange feature, as processing is necessary to provide you with that service,
consent (Art. 6(1)(a)) – for statistical/analytics cookies (Google Analytics) and in other cases where your explicit consent is requested,
legitimate interest (Art. 6(1)(f)) – to ensure the security of the Website, prevent misuse, and improve our services,
legal obligation / project implementation (Art. 6(1)(c) and (e), as applicable) – for aggregated reporting to the bodies of the Interreg Italy – Croatia programme on the results of the ECOFOODCYCLE project.

5. Recipients of personal data

We may share your personal data with the following categories of recipients:

other users of the platform – when you publish or request surplus food, certain data (organization name, city, contact details) becomes visible to the other party in order to arrange collection/donation,
our website hosting provider, which technically stores data on our behalf,
Google LLC – as the provider of Google Analytics and Google Search Console, to the extent described in this Policy and in the Cookie Policy,
project partners and the bodies of the Interreg Italy – Croatia programme – solely in aggregated/anonymized form, for the purpose of monitoring and reporting on project implementation,
competent authorities – where necessary to comply with a legal obligation or to protect our rights.

We do not sell or rent your personal data to third parties for marketing purposes.

6. Transfer of data outside the European Economic Area (EEA)

Through our use of Google’s services (Analytics, Search Console), your data (e.g., IP address, statistical usage data) may be transferred to and processed on servers located outside the EEA, including in the United States. Such transfers are based on mechanisms that the European Commission has recognized as providing an adequate level of protection (e.g., standard contractual clauses and/or participation in the EU–U.S. Data Privacy Framework), in accordance with the transfer solution currently applied by Google. More information is available in Google’s Privacy Policy.

7. Data retention periods

Your user account data (Food Exchange registration) is kept for as long as you maintain an active user account, or until you request its deletion — after which we will delete or anonymize your personal data, unless we are legally required, or have a legitimate interest, to retain certain data for longer (e.g., to resolve a dispute).
Surplus food listings you have published are deleted or anonymized together with the deletion of your user account, or earlier at your request.
Data collected through cookies is retained in accordance with the periods set out in our Cookie Policy.
Inquiries sent by email are kept for as long as necessary to resolve your inquiry, and no longer than a reasonable period thereafter.
8. Data security

We take appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, misuse, or alteration, including:

the use of HTTPS/SSL encryption when transmitting data,
storing passwords exclusively in hashed (non-readable) form,
restricting access to personal data to authorized individuals involved in the implementation of the project and the maintenance of the Website.

Despite the measures taken, no method of transmission over the internet or method of electronic storage is completely secure, and we therefore cannot guarantee the absolute security of your data.

9. Your rights

In accordance with the GDPR, with respect to your personal data you have the right to:

access the data we process about you,
rectify inaccurate or incomplete data,
erasure of your data (“the right to be forgotten”), in the cases provided for by the GDPR,
restrict processing under certain circumstances,
data portability – receiving your data in a structured, commonly used, machine-readable format,
object to processing based on legitimate interest,
withdraw your consent at any time, without affecting the lawfulness of processing before its withdrawal (e.g., disabling statistics cookies via the consent settings),
lodge a complaint with a supervisory authority — in the Republic of Croatia, this is the Croatian Personal Data Protection Agency (AZOP), Selska cesta 136, 10000 Zagreb, www.azop.hr.

To exercise any of the above rights, please contact us by email at contact@ecofoodcycle.eu. We will respond to your request no later than one month from receipt, in accordance with the GDPR.

10. Minors

The Website and the food exchange feature are intended for organizations, companies, and adult individuals. We do not knowingly collect personal data from children under the age of 18. If you believe we have inadvertently collected data from a minor, please contact us so that we can remove it.

11. Cookies

The Website uses cookies for functionality, security, and visitor statistics purposes. Detailed information on the types of cookies used, their purpose, and how to manage your consent can be found in our Cookie Policy.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in the law, technology, or our services. We will notify you of any significant changes by publishing the updated version on this page, with the date of the last update shown at the top of the document.

13. Contact

For any questions regarding this Privacy Policy or the processing of your personal data, you can contact us at:

Public Institution Development Agency of Lika-Senj County – LIRA Pazariška ulica 36, 53000 Gospić, Croatia Email: contact@ecofoodcycle.eu