ProBleu is a project funded by the European Union (EU). The ProBleu Resource Catalogue Website (website) is provided by Plymouth Marine Laboratory (PML) on behalf of the ProBleu Consortium (‘we’, ‘our’ or ‘us’). PML is the controller of personal data obtained via the website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to the service provided by ProBleu in the European Economic Area (EEA).
Given the nature of our website, we do not expect to collect the personal data of anyone under 18 years old. If you are aware that any personal data of anyone under 18 years old has been shared with our website, please let us know so that we can delete that data.
This privacy policy is divided into the following sections:
What this policy applies to
Personal data we collect about you
How your personal data is collected
How and why we use your personal data
ProBleu Marketing
Who we share your personal data with
How long your personal data will be kept
Transferring your personal data out of the UK and EEA
Cookies
Your rights
Keeping your personal data secure
How to complain
Changes to this privacy policy
How to contact us
This privacy policy relates to your use of our website only.
Throughout our website we may link to other websites owned and operated by certain trusted third parties to make additional material and services available to you. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.
The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:
your full name, country of residence and contact information, including email address and employer details.
details of any information, feedback or other matters you give to us by email
your account details, such as username and login details
your activities on, and use of, our website
your professional interests
information about the materials and services you access or we provide to you or you upload / provide to us
your saved items
information about how you use our website and technology systems
your responses to surveys
You must provide this personal data in order to have an account with ProBleu unless we tell you that you have a choice.
Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
We collect personal data from you:
directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, download from or post material to our website and complete surveys via our website, and
indirectly, such as your actions on the website
We may also collect personal data about you from other ProBleu consortium organisations
Under data protection law, we can only use your personal data if we have a proper reason, eg:
where you have given consent
or the performance of a contract with you or to take steps at your request before entering into a contract, or
for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
| Creating and managing your account with us | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you |
| Providing materials and services to you | To perform our contract with you or to take steps at your request before entering into a contract |
| Conducting checks to identify you and verify your identity | For our legitimate interests, to minimise inappropriate use of the website and protect other users. |
| Enforcing legal rights or defend or undertake legal proceedings |
Depending on the circumstances:
|
| Necessary cookies, required for the secure operation of certain site features including uploading and downloading materials are always active. These do not store any personally identifiable data | We do not obtain your consent for our legitimate interests in order to minimise inappropriate use of the website and protect other users. |
| Communications with you not related to marketing, including about changes to our terms or policies or changes to the Website or other important notices |
Depending on the circumstances:
|
| Protecting the security of systems and data used to provide the services | To comply with our legal and regulatory obligations. We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
| Statistical analysis to help us understand our user base | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service |
| Updating and enhancing user records |
Depending on the circumstances:
|
| Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant | To comply with our legal and regulatory obligations |
| Marketing our services to existing and former users | For our legitimate interests, ie to promote our materials to existing and former users. See ‘ProBleu Marketing’ below for further information. |
| The audit of the ProBleu funding authority (the EU) (to the extent not covered by ‘activities necessary to comply with legal and regulatory obligations’ above) | For our legitimate interests, ie to comply with the ProBleu funders obligations so we can demonstrate we operate at the highest standards. |
| To share your personal data with members of the ProBleu consortium and third parties that will or may take control of the ProBleu website and activities. In such cases information will be anonymised where possible and only shared where necessary Updating and enhancing user records |
Depending on the circumstances:
|
More details about how we use your personal data and why are set out in the table below
| Purpose | Processing operation | Lawful basis relied on under UK GDPR and EU GDPR | Relevant categories of personal data |
| Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices | Addressing and sending communications to you as required by data protection laws, ie: the UK GDPR or Data Protection Act 2018 | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) |
Your full name, country of residence and contact information, including email address and employer details. Your account details (username) |
| Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices | Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices (other than those addressed above) | Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you |
Your full name, country of residence and contact information, including email address and employer details. Your account details (username) |
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
ProBleu consortium members may use your personal data to send you updates (by email, text message, telephone or post) about our materials and services.
We have a legitimate interest in using your personal data for the above purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by contacting us at probleu-support@pml.ac.uk
We may ask you to confirm or update your marketing preferences if you ask us to provide further materials and services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations outside the ProBleu consortium for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
We routinely share personal data with
other ProBleu consortium members we work with use to help deliver the ProBleu materials and services
Consejo Superior de Investigaciones Científicas, Spain
Kaunas University of Technology, Lithuania
Innovation Services, SA, Portugal
Earthwatch, UK
Ocean Conservation Trust, UK
other third parties we use to help us run our website including SMTP email forwarding
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also ensure contractual obligations are imposed on them to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above occasionally also share personal data with:
the ProBleu project funding authority (EU) and or its external auditors, eg in relation to the audit of the ProBleu operations, in which case the recipient of the information will be bound by confidentiality obligations
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not keep your personal data for longer than we need it for the purpose for which it is used.
If you stop using your account we will delete or anonymise your account data after seven years.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
We will transfer your personal data to our service providers located outside of the UK:
Consejo Superior de Investigaciones Científicas, Spain
Kaunas University of Technology, Lithuania
Innovation Services, SA, Portugal
other third parties we use to help us run our website including SMTP email forwarding
As we are based in the UK we will also transfer your personal data from the EEA to the UK.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR.
in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR.
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
a specific exception applies under relevant data protection law
Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation . In the event we cannot or choose not to continue to rely on this mechanism at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision. In the event we cannot or choose not to continue to rely on this mechanism at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.
If you would like further information about data transferred outside the UK/EEA, please contact us or our Data Protection Officer (see ‘How to contact us’ below).
A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We only use necessary cookies on our website, which we define as cookies that are essential to the secure operation of the website. These are required for the secure operation of certain site features including uploading and downloading materials.
The cookies we use do not contain personally identifiable information. You may choose to disable these cookies by adjusting your browser settings but this will impact certain site functionalities
You generally have the following rights, which you can usually exercise free of charge:
| Access to a copy of your personal data | The right to be provided with a copy of your personal data |
| Correction (also known as rectification) | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
| Restriction of use | The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object to use |
The right to object:
|
| Not to be subject to decisions without human involvement |
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by our website |
| The right to withdraw consents |
If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by contacting us using the email address probleu-support@pml.ac.uk Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below).
If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:
provide enough information to identify yourself and any additional identity information we may reasonably request from you, and
let us know which right(s) you want to exercise and the information to which your request relates
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
the Information Commissioner in the UK
a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA
We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example via email.
You can contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
| Our contact details | Our Data Protection Officer's contact details |
|
Plymouth Marine Laboratory, Prospect Place, Plymouth, PL1 3DH probleu-support@pml.ac.uk +44 (0)1752 633 100 |
Plymouth Marine Laboratory, Prospect Place, Plymouth, PL1 3DH legal@pml.ac.uk +44 (0)1752 633 100 |