This privacy policy pertains to the processing of personal data carried out by ETRA and its collaborators when you browse the website www.smile-city.eu and to allow your participation in   the private selection process for a supplier to design and produce the logo for the Smile City Project.

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The processing of your personal data will be based on the principles of lawfulness, fairness, transparency, purpose and storage limitation, data minimization, accuracy, integrity, and confidentiality.

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DATA CONTROLLER

The data controller is ASSOC EUROPEENNE RECYCLAGE PNEUS (ETRA), having its registered office in Place Kléber no. F-67000, Strasbourg (France), SIREN 422 988 642.

For more information regarding the processing of your personal data, you can always contact us:

• By email: secretariat@etra-eu.org;

• By post: ETRA, 16 Avenue de Tervueren, 1040 Brussels, Belgium.
   

PERSONAL DATA SUBJECT TO PROCESSING

"Personal Data" means any information relating to an identified or identifiable natural person, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more elements characteristic of their physical, physiological, genetic, mental, economic, cultural, or social identity.

The Personal Data collected by ETRA are as follows:
 

a. Browsing Data

The website’s IT systems collect certain Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with you, but due to its nature, it could, through processing and association with data held by third parties, allow you to be identified. These data may include IP addresses or domain names of devices used to connect to the site and other parameters related to your operating system and IT environment.
These data are used for:
 

• Anonymous statistical analysis,

• Ensuring proper functionality,

• Enabling requested features,

• Security and prevention of cybercrimes.
  
  b. Data Provided Voluntarily
  Through the website, you can voluntarily provide Personal Data while filling out the form “Apply Now”.  ETRA will process the Personal Data provided through the form and in particular: 

• Name and surname

• E-mail address

• Company

• CV.
  
  These data must relate to you or to third parties who have authorized you to provide them under a valid legal basis. In the latter case, you act as the independent data controller.
  
  c. Cookies
  We collect Personal Data through cookies. More information on how the data collected through cookies is processed can be found in the Cookie Policy linked in the footer of this page.
  
  
  PURPOSES AND LEGAL BASES OF PROCESSING
  
  Your Personal Data will be processed for the purposes described below.
  
  a. Purposes Related to the Execution of a Contract or Pre-Contractual Measures
  These purposes include the analysis and evaluation of applications, the management of communications with candidates during the various stages of the selection process and the necessary activities to execute the contract with the selected winner.
  Legal basis: performance of a contract or to take steps at the request of the data subject prior to entering into a contract.
  
  b. Compliance with Legal Obligations
  Your data may be processed to fulfill a legal obligation, a regulatory requirement, or an order from competent authorities.
  Legal basis: compliance with a legal obligation.
  
  c. Statistical Analysis on Aggregated or Anonymous Data
  This includes measuring the website’s functionality, traffic, usability, and user interest. The data collected is anonymous and does not allow for user identification.
  
  d. Legal Defense
  Your data may be processed to ascertain, exercise, or defend a legal right in judicial proceedings or whenever judicial authorities exercise their functions. 
  
  Legal basis: ETRA’s legitimate interest in ensuring judicial or extrajudicial protection whenever necessary.
  
  RECIPIENTS OF PERSONAL DATA
  
  Your Personal Data may be shared with:

• Service providers (email, analytics) acting as data processors. More specifically, ETRA will rely on the services of Google Ireland Limited, Google LLC and Wix.com Ltd.;

• ETRA personnel authorized and bound by confidentiality;

• Judicial authorities, when legally required.
  
  DATA TRANSFERS
  
  When your Personal Data are processed by Google or Wix.com, acting as data processors, they may be transferred outside the European Economic Area (EEA). ETRA ensures that the processing of your Personal Data by these recipients complies with applicable regulations. Transfers are based either on:

• Adequacy decisions,

• Standard Contractual Clauses, or

• The Data Privacy Framework.
  
  DATA RETENTION
  
  ETRA will process your Personal Data for the time strictly necessary to achieve the purposes indicated in the section “Purposes and Legal Basis of Processing.” 
  
  Personal Data processed for purposes related to the execution of a contract or pre-contractual measures will be retained by ETRA for 12 months after the conclusion of the selection procedure, being excepted the Data of data subjects which will consequently sign a contract with ETRA.
  
  More information on data retention periods and the criteria used to determine such periods can be requested by contacting the Data controller.
  
  YOUR RIGHTS
  
  Within the limits of applicable regulations, you have the right to request from ETRA, at any time:

• Access, rectification, deletion of your data

• Restriction or objection to processing

• Data portability
  
  Requests should be sent by email or post to the addresses of the Data controller.
  In any case, you have the right to lodge a complaint with the competent supervisory authority if you believe that the processing of your Personal Data violates applicable regulations.
  
  CHANGES
   

• This Privacy Policy is effective as of March 28, 2025 

• We reserve the right to modify or update this Privacy Policy in consideration of any changes to applicable regulations.