Privacy Policy

1. Who We Are

This Privacy Policy applies to the European Digital Inclusion Fund ("EDIF", "we", "us", "our"), operating in partnership with the EU Tech Renewal Programme (EUTRP). We are committed to protecting your personal data in accordance with the General Data Protection Regulation (GDPR) and applicable EU law.

2. What Data We Collect

We collect the following personal data when you participate in our program:

• Email address
• Full name
• Phone number
• Delivery address (street, city, postal code, country)
• Age group and country of residence
• Device usage preference
• IP address and browser/device information (for security purposes)

3. Why We Collect Your Data

We use your personal data for the following purposes:

• To verify your eligibility for the program
• To process your device selection and delivery
• To process the symbolic delivery fee payment
• To communicate important program updates
• To prevent fraud and abuse of the program
• To comply with legal obligations

4. Legal Basis for Processing

We process your data on the following legal bases under GDPR Article 6:

• Contractual necessity — to fulfill your participation in the program
• Legitimate interest — to prevent fraud and ensure program integrity
• Legal obligation — to comply with EU and national laws

5. Data Retention

We retain your personal data for a maximum of 24 months from the date of collection, or until the delivery of your device and settlement of all related obligations, whichever is later. After this period, your data is permanently deleted.

6. Data Sharing

We do not sell your personal data. We may share your data with:

• Logistics and shipping partners for device delivery
• Payment processors for fee collection (data encrypted in transit)
• EU regulatory bodies when legally required

7. Your Rights

Under GDPR, you have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate data
• Request deletion of your data ("right to be forgotten")
• Object to processing of your data
• Request data portability
• Lodge a complaint with your national data protection authority

To exercise any of these rights, contact us at: privacy@eudigitalfund.eu

8. Security

We implement industry-standard security measures including 256-bit SSL encryption, secure database access with row-level security, and regular security audits to protect your personal data from unauthorized access, disclosure, or loss.

9. Contact

For any privacy-related questions, contact our Data Protection Officer at: privacy@eudigitalfund.eu