Central Entry Point - Privacy Statement

1. Introduction

The European Commission (hereafter ‘the Commission’) is committed to protect your personal data and to respect your privacy. The Commission collects and further processes personal data pursuant to Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data (repealing Regulation (EC) No 45/2001).

This privacy statement explains the reason for the processing of your personal data, the way we collect, handle and ensure protection of all personal data provided, how that information is used and what rights you have in relation to your personal data. It also specifies the contact details of the responsible Data Controller with whom you may exercise your rights, the Data Protection Officer and the European Data Protection Supervisor.

The information in relation to processing operation “InvestEU Advisory Hub (Central Entry Point)” for advisory support requests undertaken by GROW C.3 is presented below.

2. Why and how do we process your data?

Purpose of the processing operation:

The InvestEU Advisory Hub forms an integral part of the InvestEU Programme, together with the InvestEU Fund and the InvestEU Portal. The InvestEU Advisory Hub central entry point (CEP) allocates requests for advisory support to be dealt under the appropriate advisory initiative. Following the initial assessment, the InvestEU Advisory Hub will link the promoters’ and intermediaries’ requests with advisory partners who shall continue to work directly with the promoters and intermediaries on the advisory support of their projects.

The personal data is collected on the basis of the InvestEU Regulation* Article 25 for the purposes of providing advisory support for the identification, preparation, development, structuring, procuring and implementation of investment projects, and for enhancing the capacity of project promoters and financial intermediaries to implement financing and investment operations. Such support may cover any stage of the life cycle of a project or financing of a supported entity. The personal data will not be further processed in a manner that is incompatible with this purpose.

Potential final beneficiaries of advisory support performed under the InvestEU Advisory Hub will provide information about the project/proposal they would like the InvestEU Advisory Hub to support. This information will be collected via a Wizard (set of interactive questions – The InvestEU Central entry point) leading to the submission of an advisory support request to the InvestEU Advisory Hub. The InvestEU Advisory Hub is not providing advisory support as such but is relying on Advisory Partners (AP) that will perform, on the behalf of the InvestEU Advisory Hub, the advisory support assignments.

The Commission evaluates the advisory request and allocates the request to one or more advisory partners. The data collected by the Wizard, including identification data of contact persons (name, email address) received from the requestors, will be made available to one or several advisory partners so that they can follow up the request directly with the final beneficiaries to identify if the advisory request can be served and if so to translate the advisory request into a detailed assignment. This information will be sent and stored in an internal tool, the InvestEU MIS (Management Information System - see DPR-EC-32310 InvestEU Management Information System). This system is hosted by the Commission and the user (i.e. requestor of advisory support).

The InvestEU Advisory Hub is implemented by the Commission. Its implementation mechanism is indirect management mode as the Advisory Partners selected by the Commission are pillar assessed entities (International Financial Institutions and National Promotional Banks), the personal data of requestors received from the InvestEU Advisory Hub, which are bound to comply with protection of personal data equivalent to that referred to in Article 5 of the Financial Regulation (EU, Euratom) 2018/1046. The advisory support is performed by the APs. The APs can source themselves advisory requests or receive them from the Central Entry Point. Advisory partners are performing the advisory support and reporting to the Commission via the InvestEU Management Information System.

The Advisory Partners (National Promotional Banks or Institutions and International Financial Institutions) under the InvestEU Advisory Hub as set out in the Regulation (EU) 2021/523, act as processors on behalf of the Commission whenever a request is filed by a natural person.

Advisory Partners can share the request received from the InvestEU Advisory Hub with their contractors, provided that they assume full responsibility for ensuring that the contractors adhere to the applicable national laws and regulations concerning the safeguarding of personal data. Contribution agreements' (signed with APs) General conditions point 2.7 provides that: 'In addition, the Organisation also undertakes to require Contractors and Grant Beneficiaries to: (i) comply with the relevant national laws and regulations as regards protection of personal data.' All the advisory partners according to the signed contribution agreements can transfer requests to contractors.

*Regulation (EU) 2021/523 of the European Parliament and of the Council of 24 March 2021 establishing the InvestEU Programme and amending Regulation (EU) 2015/1017, OJ L 107, p. 30–89.

3. On what legal ground(s) do we process your personal data

We process your personal data, because:

(a) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Union institution or body;

The basis for the processing referred to in points (a) and (b) of the paragraph 1 has been laid down in the Regulation (EU) 2021/523 of the European Parliament and of the Council of 24 March 2021 establishing the InvestEU Programme, more specifically its Article 25. The processing of data is necessary for the proper functioning of the InvestEU Advisory Hub Central Entry Point for advisory support requests.

4. Which personal data do we collect and further process?

In order to carry out this processing operation GROW C.3 collects the following categories of personal data:

• Name,
• Surname,
• Contact details (e-mail address, telephone number, mobile telephone number, national ID number of a natural person, etc.).

The provision of personal data is mandatory to meet a statutory requirement to provide with advisory services. If you do not provide your personal data, possible consequences are that the Advisory request is not treated.

5. How long do we keep your personal data?

GROW C.3 only keeps your personal data for the time necessary to fulfil the purpose of collection or further processing, namely for completing an Advisory request assignment. The administrative retention period starts to run from the acceptance of an advisory request and lasts for 2 years after the completion of the assignment as specified in the relevant Record.

6. How do we protect and safeguard your personal data?

All personal data in electronic format (e-mails, documents, databases, uploaded batches of data, etc.) are stored either on the servers of the European Commission or of its contractors. All processing operations are carried out pursuant to the Commission Decision (EU, Euratom) 2017/46 of 10 January 2017 on the security of communication and information systems in the European Commission.

The Commission’s contractors are bound by a specific contractual clause for any processing operations of your data on behalf of the Commission, and by the confidentiality obligations deriving from the transposition of the General Data Protection Regulation in the EU Member States (‘GDPR’ Regulation (EU) 2016/679).

In order to protect your personal data, the Commission has put in place a number of technical and organisational measures in place. Technical measures include appropriate actions to address online security, risk of data loss, alteration of data or unauthorised access, taking into consideration the risk presented by the processing and the nature of the personal data being processed. Organisational measures include restricting access to the personal data solely to authorised persons with a legitimate need to know for the purposes of this processing operation.

7. Who has access to your personal data and to whom is it disclosed?

Access to your personal data is provided to the Commission staff responsible for carrying out this processing operation and to authorised staff according to the “need to know” principle. Such staff abide by statutory, and when required, additional confidentiality agreements.

In addition, relevant departments in National Promotional Banks or Institutions and International Financial Institutions acting as InvestEU Advisory Partners will have access to your personal data as processors. Advisory partners are International Financial Institutions (IFI) or National Promotional Banks or Institutions (NPBI) where a contribution agreement is signed between the Commission and the Advisory Partners. The Advisory Partners are implementing some of the InvestEU Advisory Hub tasks. Advisory Partners are processing the advisory requests coming from the Central Entry Point, but they are free to accept or reject the incoming advisory request.

The controller may transfer your personal data to the following recipients in a third country or to an international organisation in accordance with Regulation (EU) 2018/1725:

• Advisory partners (International financial institutions) that have concluded an advisory agreement with the Commission as set out in Regulation (EU) 2021/523.

The controller will transfer your personal data based on:

• the European Commission's adequacy decision (Article 47 of Regulation (EU) 2018/1725).

The following Advisory Partners have access:

• Bpifrance, 27 Avenue du Général Leclerc, Paris, France
• European Investment Bank, 98-100 boulevard K. Adenauer L-2950, Luxembourg, Grand Duchy of Luxembourg
• Cassa depositi e prestiti S.p.A., Via Goito, 4, Rome 00185, Italy
• The European Bank for Reconstruction and Development, 5 Bank Street, London, E14 4BG United Kingdom
• Caisse des Dépôts et Consignations, 56 rue de Lille, Paris, 75007, France
• The Council of Europe Development Bank, 55 avenue Kléber, 75116 Paris, France
• InvestNL, Kingsfordweg 43-117, Amsterdam 1043 GP, The Netherlands
• NRB, Přemyslovská 2845/43, Žižkov, 130 00 Praha 3, Czech Republic

The information we collect will not be given to any third party, except to the extent and for the purpose we may be required to do so by law.

8. What are your rights and how can you exercise them?

You have specific rights as a ‘data subject’ under Chapter III (Articles 14-25) of Regulation (EU) 2018/1725, in particular the right to access, your personal data and to rectify them in case your personal data are inaccurate or incomplete. Where applicable, you have the right to erase your personal data, to restrict the processing of your personal data, to object to the processing, and the right to data portability.

You have the right to object to the processing of your personal data, which is lawfully carried out pursuant to Article 5(1)(a) on grounds relating to your particular situation. The processing relates to automated decision-making, including profiling (Article 24(2)(b) of the Regulation).

You have consented to provide your personal data to the Commission for the present processing operation. You can withdraw your consent at any time by notifying the Data Controller. The withdrawal will not affect the lawfulness of the processing carried out before you have withdrawn the consent.

You can exercise your rights by contacting the Data Controller, or in case of conflict the Data Protection Officer. If necessary, you can also address the European Data Protection Supervisor. Their contact information is given under Heading 9 below.

Where you wish to exercise your rights in the context of one or several specific processing operations, please provide their description (i.e. their Record reference(s) as specified under Heading 10 below) in your request.

9. Contact information

The Data Controller

If you would like to exercise your rights under Regulation (EU) 2018/1725, or if you have comments, questions or concerns, or if you would like to submit a complaint regarding the collection and use of your personal data, please feel free to contact the European Commission, Directorate-General for Internal Market, Industry (DG GROW) - EC-InvestEU-Advisory-Hubec [dot] europa [dot] eu (EC-InvestEU-Advisory-Hub[at]ec[dot]europa[dot]eu).

The Data Protection Officer (DPO) of the Commission

You may contact the Data Protection Officer (DATA-PROTECTION-OFFICERec [dot] europa [dot] eu (DATA-PROTECTION-OFFICER[at]ec[dot]europa[dot]eu)) with regard to issues related to the processing of your personal data under Regulation (EU) 2018/1725.

The European Data Protection Supervisor (EDPS)

You have the right to have recourse (i.e. you can lodge a complaint) to the European Data Protection Supervisor (edpsedps [dot] europa [dot] eu (edps[at]edps[dot]europa[dot]eu)) if you consider that your rights under Regulation (EU) 2018/1725 have been infringed as a result of the processing of your personal data by the Data Controller.

10. Where to find more detailed information

The Commission Data Protection Officer (DPO) publishes the register of all processing operations on personal data by the Commission, which have been documented and notified to him. You may access the register via the following link: http://ec.europa.eu/dpo-register.

This specific processing operation has been included in the DPO’s public register with the following Record reference: DPR-EC-32308