This Privacy Policy explains how the PRIMARY Consortium (the “Consortium”, “we”, “us” and “our”) collects, uses, and protects your personal information when you interact with our project activities and website (www.primary-project.eu) (the “Service”).

The PRIMARY project focuses on developing new business opportunities for farmers and cooperatives in rural areas through innovative upcycling solutions for underutilised agricultural feedstocks. We are committed to protecting your privacy and complying with the General Data Protection Regulation (GDPR) and all applicable data protection laws.

By using or accessing the Service, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree with these terms, please refrain from using the Service.

Data Controller: 
Please note that when you click through from the PRIMARY website to register on the ERBN Stakeholder Platform, the data controller for your personal information changes:

• On the PRIMARY website: The PRIMARY Consortium, coordinated by VTT Technical Research Centre of Finland Ltd, is the data controller for any information you provide directly to us (such as newsletter subscriptions or contact form submissions). Contact: dorothee.barth@vtt.fi
• On the ERBN Stakeholder Platform: The Institute of Soil Science and Plant Cultivation – State Research Institute (IUNG-PIB) in Puławy, Poland, becomes the data controller for your platform registration data and activities. Contact: iod@iung.pulawy.pl

By registering on the ERBN platform through PRIMARY’s links, you are consenting to IUNG-PIB processing your personal data in accordance with their privacy policy. We strongly recommend reviewing the ERBN platform Privacy Policy before completing your registration. Both the PRIMARY Consortium and IUNG-PIB are committed to full GDPR compliance and protecting your personal information.

Information we collect:

When we collect your information

We collect personal information when you:

• Contact us directly through our website, email, or social media
• Subscribe to our newsletter
• Register for workshops, webinars, or events
• Join our Stakeholder Platform
• Participate in stakeholder surveys or provide feedback
• Attend project events (with your consent for photography/audio/video)

 

Types of information we collect

Contact information:

• Name and surname
• Organisation/institution details
• Professional position and sector of activity
• Email address and (in some cases) telephone number

Professional information:

• Occupation and expertise area relevant to bioeconomy and agriculture
• Organisation type and sector of activity
• Technical expertise and experience

Event participation data:

• Registration details and attendance records
• Dietary requirements and accessibility needs
• Feedback responses and evaluation forms

Survey data:

• Responses to stakeholder surveys
• Business model development questionnaires

Website usage data:

• Pages visited and files downloaded
• Newsletter subscription preferences
• Comments and feedback submitted

Visual content:

• Photographs or videos from events
• Images uploaded to social media or website

 

How we use your information

Primary purposes

We use your personal information to communicate project updates, milestones, and results, facilitate participation in workshops, events, and Open Calls, enable networking and collaboration through our Stakeholder Platform, conduct stakeholder engagement activities, evaluate project impact and effectiveness, and comply with project reporting requirements to the European Commission.

 

Legal basis for processing

We process your personal data based on different legal grounds depending on the specific activity. Under GDPR, we must have a lawful basis for processing your personal information.

Consent: We rely on your explicit consent when you use or access the Service, subscribe to our newsletter or agree to photography, video, or audio recording at events, participate in optional surveys or feedback activities, or provide optional information during registration such as dietary requirements. You can withdraw your consent at any time by contacting us or using the unsubscribe options provided.

Legitimate interest: We process data based on our legitimate interest in conducting the PRIMARY project when we analyse website usage through Google Analytics to improve user experience, conduct stakeholder engagement activities, share project results and publications with the scientific and policy community, and evaluate project impact and effectiveness for reporting purposes. We have assessed that these activities are necessary for our legitimate interests and that your rights and freedoms are not overridden by these interests.

Legal obligation We process data to fulfil our legal obligations, including reporting project progress and results to the European Commission as required under our grant agreement, maintaining financial and administrative records as required by EU project regulations, complying with audit and evaluation requirements for EU-funded projects, and meeting data retention requirements for public funding accountability.

Contract performance We may process data when necessary to fulfil contractual obligations and coordinating with consortium partners to deliver project activities.

If we intend to use your information for any purpose other than those stated, we will first seek your consent and will use it only after receiving your approval, and solely for the purposes you have consented to, unless otherwise required by law.

 

Website and technical information

Website hosting

Our project website is hosted on the WordPress platform with secure data storage behind firewalls. Your data may be stored through WordPress data storage systems and databases.

 

Analytics

We use Google Analytics to understand how visitors use our website and improve user experience. Google Analytics collects information such as which pages you visit, how long you spend on the site, and your general location. We have configured Google Analytics to anonymise IP addresses. You can opt out by installing Google’s browser add-on or through your browser’s privacy settings.

 

Cookies

Cookies are small text files that websites place on your device to help the site remember information about your visit and preferences.

 

Types of cookies we use:

Essential cookies: These are necessary for our website to function properly and cannot be switched off. They enable basic functions like page navigation and access to secure areas of the website.

Functionality cookies: These remember your preferences and choices (such as language settings) to provide you with a more personalised experience.

Analytics cookies: These enable us to measure website performance and understand user behviour as described in our Analytics section above.

 

Cookie retention periods:

• Essential cookies: Session cookies that are deleted when you close your browser
• Functionality cookies: Up to 12 months to remember your preferences
• Analytics cookies: Up to 26 months (Google Analytics default setting)

 

Managing cookies:

You can control cookies through our consent banner or your browser settings. Please note that disabling certain cookies may affect website functionality.

 

Newsletter and communications

Newsletter subscription

When you subscribe to our newsletter, we collect your email address (required) and name, organisation, and areas of interest (optional) You can unsubscribe at any time, and we will immediately delete your subscription data.

 

Communication content

Our newsletters and communications include:

• Project milestones and updates
• Open Call announcements and opportunities
• Workshop and event invitations
• Key results and publications
• Learning stories and best practices

 

Stakeholder platform

Stakeholder Platform registration is conducted through the ERBN (European Rural Bioeconomy Network) platform, which is technically facilitated by IUNG (subcontractor) and co-owned in design by IUNG and CERTH. The platform operates collaboratively between PRIMARY and its sister projects (BioRural, thERBN). PRIMARY retains ownership of stakeholder data and materials specifically related to PRIMARY project activities and contributions. IUNG acts as the technical facilitator of the platform but does not own the project-specific content.

The PRIMARY website does not directly collect personal registration data. However, when you register through our platform links, PRIMARY will have access to stakeholder information and materials uploaded under the PRIMARY project hub. All personal data processing follows GDPR requirements and the platform’s privacy policy. By using platform links on our website, you will be directed to the ERBN platform where you must review their privacy policy. Data ownership and access rights will be governed by the inter-project collaboration arrangements, with content ownership clearly attributed through the platform’s tagging system.

 

Data sharing and transfers

Within the consortium

Your personal data may be shared among PRIMARY project partners solely for legitimate project activities, including:

• Event organisation and stakeholder engagement
• Surveys and impact assessment
• Communication and dissemination activities

 

Third-Party sharing

We do not sell or rent your personal information to third parties. Limited sharing may occur:

• With service providers supporting project activities
• When required by law or legal obligations

In this case, we require such third parties to use the personal information we share with them solely for the purpose for which it was provided and to retain it only for as long as necessary to fulfill that purpose.

All third-party sharing complies with GDPR requirements and includes appropriate safeguards.

 

International transfers

Some of the services we use to run our website and project activities are provided by companies based outside Europe. This means your personal information may be transferred to and processed in other countries.

When this happens, we make sure your data is still protected by using approved legal agreements and security measures. For example, Google Analytics may process data in the United States, but Google has agreed to follow European data protection standards.

We only work with service providers who can demonstrate they will protect your personal information to the same standard required in Europe.

 

Data security and retention

Security measures

We implement appropriate technical and organisational measures to protect your personal data, including secure servers protected by firewalls, access controls and authentication procedures.

 

Retention periods

We retain your personal data only as long as necessary for project purposes:

• Project duration plus one year for most project-related data
• Until withdrawal of consent for newsletter subscriptions and optional activities
• Anonymised data may be retained indefinitely for statistical analysis

Certain data may need to be kept for longer periods to comply with legal obligations, maintain records, enforce legal rights, prevent fraud, or for other legitimate business reasons.

 

Your rights

Under the General Data Protection Regulation (GDPR) and applicable data protection legislation, you have several important rights regarding your personal information. These rights are designed to give you control over how your data is processed and used.

Under data protection law, you have the right to:

Access: Request a copy of the personal information we hold about you

Rectification: Request correction of inaccurate or incomplete information

Erasure: Request deletion of your personal information in certain circumstances

Restriction: Request limitation of processing in certain situations

Portability: Request transfer of your data to another organisation

Objection: Object to processing based on legitimate interests

Withdraw consent: Withdraw consent for processing at any time (where consent is the legal basis)

To exercise these rights, please contact us using the details provided below.

 

External links

Our website contains links to external websites. We are not responsible for the privacy practices or content of these third-party sites. We encourage you to review their privacy policies before providing any personal information.

 

Updates to this policy

We may update this Privacy Policy at any time without prior notice. Any changes will be posted on our website and will take effect 30 days after the posting date. By continuing to access or use the Service after that period, you agree to the updated Privacy Policy. We encourage you to review this page periodically for any updates.

 

Contact information

For questions, comments, or requests regarding this Privacy Policy your personal data, please contact:

PRIMARY’s data protection contact:
VTT Technical Research Centre of Finland Ltd
Dorothee Barth, email: dorothee.barth@vtt.fi

 

This Privacy Notice was last updated on 15.12.2025 and is effective from that date.