Privacy Policy

Effective Date: November 2, 2026

This Privacy Policy explains how Comparative Research Network e.V. (“we”, “us”, “our”) processes personal data when you use https://circularmuseum.eu (the “Website”), the platform of the EU-COM-E – European Circular Online Museum project, co-funded by the European Union (Creative Europe, project ID CREA-CULT-2025-COOP-1-101255314). We process personal data in accordance with the EU General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG) and the German Telecommunications Digital Services Data Protection Act (TDDDG).

1. Controller

Comparative Research Network e.V.
Office: Müllerstr. 70 B, 13349 Berlin, Germany
Postal address: Belziger Str. 60, 10823 Berlin, Germany
Email: central@comparative-research.net
Phone: +49 171 7791386
Represented by the Board: James W. Scott (Chair), Martin Barthel (Deputy Chair)
Register: Amtsgericht Berlin-Charlottenburg, VR 27819 B

Data Protection Officer: we are not legally required to appoint a Data Protection Officer. For any data protection matter, please contact us at central@comparative-research.net.

Joint controllers: for activities run jointly by the project partners – in particular the Open Call / Art Contest – Comparative Research Network e.V. (Germany), COTA – Art for Society (France) and Il Salone dei Rifiutati (Italy) act as joint controllers under Art. 26 GDPR. You may exercise your rights with any of them; the central contact point is Comparative Research Network e.V.

2. What Data We Process, Why, and on What Legal Basis

2.1 Visiting the Website

Our hosting provider automatically processes technical data: IP address, date and time of access, page requested, referrer, browser and operating system. This is necessary to deliver the Website and protect it (firewall, brute-force protection).

  • Legal basis: Art. 6(1)(f) GDPR – legitimate interest in a secure and functioning website.
  • Retention: log files are deleted after 30 days, unless needed to investigate a security incident.

2.2 Statistics

We use WP Statistics, a plugin hosted on our own server, to produce anonymous visitor statistics. IP addresses are anonymised and no data is shared with third parties.

  • Legal basis: Art. 6(1)(f) GDPR.

2.3 Community accounts and published content

If you register as a community member, we process the data you provide: name, username, email address, password, profile information, profile photo, biography, links, and the works and texts you submit. We use it to create and manage your account and to publish the content you choose to make public in the Community and Showroom. Public profile content is visible to everyone.

  • Legal basis: Art. 6(1)(b) GDPR – performance of the user agreement.
  • Retention: until you delete your account or ask us to delete it; data is then erased within 30 days, unless longer retention is required by law.

2.4 Open Call / Art Contest applications

When you apply via the registration form, we process: name (and collective name), date of birth, email address, phone number, city and country of residence, preferred language, website and social media profiles, biography, personal photo, information on the artwork (title, dimensions, technique, materials, year, description), photos and video links, and the declarations you make.

  • Purposes: checking eligibility (e.g. minimum age of 18), evaluation by the international jury, communication with applicants, organisation of residencies and exhibitions, and reporting to the European Commission / EACEA as required by the grant agreement.
  • Legal bases:
    • Art. 6(1)(b) GDPR – participation in the contest under the Contest Regulations;
    • Art. 6(1)(c) GDPR – EU grant reporting and audit obligations;
    • Art. 6(1)(a) GDPR – your consent to publish your name, images and works on the Website, social media, catalogues and exhibitions.
  • Providing this data is necessary to take part; without it we cannot process your application.
  • Retention: application data of non-selected participants is deleted 12 months after the results are announced. Data required for grant documentation is kept for 5 years after the final payment of the grant, as required by the grant agreement.

2.5 Contact by email

If you contact us, we process your message and contact details to reply to you.

  • Legal basis: Art. 6(1)(b) or (f) GDPR.
  • Retention: data is deleted when it is no longer needed.

We do not collect special categories of personal data (Art. 9 GDPR), we do not buy data from third parties, and we do not use automated decision-making or profiling.

3. Cookies and Similar Technologies

We use technically necessary cookies (e.g. login session, security, storing your consent choice) on the basis of § 25(2) TDDDG and Art. 6(1)(f) GDPR. Non-essential cookies and embedded third-party content (e.g. maps, videos) are only activated after your consent via our cookie banner (§ 25(1) TDDDG, Art. 6(1)(a) GDPR). You can change or withdraw your consent at any time via “Cookie settings”. For details, see our Cookie Policy: https://circularmuseum.eu/cookie-policy/

4. Do Not Track

Our Website does not respond to Do Not Track (DNT) browser signals, as there is no common industry standard for them. We do not track users across third-party websites. Non-essential cookies are only set with your consent, which you can manage or withdraw at any time via “Cookie settings”.

5. Recipients and Service Providers

We do not sell or rent your personal data. We share it only as follows:

  • Hosting and email delivery: Netsons S.r.l. (Italy, EU) hosts the Website and its mail server, which sends form notifications and confirmations – data processing agreement under Art. 28 GDPR.
  • Cookie consent: CookieYes Limited (United Kingdom – covered by an EU adequacy decision) – storing your consent choice.
  • Fonts: hosted locally on our server; no data is sent to Google.
  • Maps and embedded videos (Google Maps, YouTube): loaded only after your consent. Google may process data in the USA; transfers are based on the EU-U.S. Data Privacy Framework and/or Standard Contractual Clauses.
  • Project partners and jury members (within the EU), for the purposes described in section 2.4.
  • The European Commission / EACEA or their auditors, where required by the grant agreement.
  • Public authorities, where we are legally required to disclose data.

Our social media pages (Facebook, Instagram, YouTube) are linked only; no data is transferred until you click on them, after which the respective platform’s privacy policy applies.

6. Your Rights

Under Articles 15–21 GDPR you have the right to:

  • access the personal data we hold about you and receive a copy;
  • rectify inaccurate or incomplete data;
  • request erasure (“right to be forgotten”);
  • restrict processing;
  • data portability;
  • object to processing based on our legitimate interests (Art. 21 GDPR);
  • withdraw any consent at any time, with effect for the future (Art. 7(3) GDPR); this does not affect the lawfulness of processing before withdrawal.

To exercise your rights, write to central@comparative-research.net.

You also have the right to lodge a complaint with a supervisory authority, in particular in your country of residence, or with the authority competent for us:
Berliner Beauftragte für Datenschutz und Informationsfreiheit, Alt-Moabit 59–61, 10555 Berlin, Germany – https://www.datenschutz-berlin.de

7. Minors

Community accounts and contest participation are reserved for persons aged 18 or over. If you are a parent or legal guardian and believe that a minor has provided us with personal data, please contact us and we will delete it.

8. Security

We take appropriate technical and organisational measures (Art. 32 GDPR), including encrypted HTTPS connections, a firewall and access controls, to protect your data. However, no method of internet transmission or digital storage is completely secure.

9. Links to Other Websites

Our Website contains links to external websites that we do not operate. This Privacy Policy does not apply to them; please review their privacy policies.

10. Changes to This Privacy Policy

We may update this Privacy Policy when our services or the law change. The current version is always available on this page and is effective from the date it is published.

11. Contact

Comparative Research Network e.V.
Office: Müllerstr. 70 B, 13349 Berlin, Germany
Postal address: Belziger Str. 60, 10823 Berlin, Germany
Email: central@comparative-research.net / info@crnonline.de
Project email: circularmuseum@gmail.com