Introduction
Thank you for visiting the MEMENTOES website.
The website’s Privacy Policy concerns processing of personal data for the operation of the MEMENTOES website. This covers personal data that you provide us with through the website, and the personal data that you see on our website.
We are committed to processing personal data responsibly, securely, and proportionally throughout our activities in compliance with the General Data Protection Regulation (GDPR) 2016/679.
Who we are
MEMENTOES is an EU-funded Horizon Europe project that aims to create video games inspired by real-life experiences throughout monumental historical events, and derive a set of guidelines for the effective design of high-quality, empathy-inducing digital games around sensitive topics. This will be achieved by bringing together experts from museums, the game development industry, and research organizations. The project will take advantage of design approaches implemented in museology with state-of-the-art technologies in the game industry (including VR) for the design and development of three video games that will raise moral consciousness in players and promote reconciliation and healing. Studies will be carried out to explore the extent to which video games can be used as a mechanism for fostering empathy and promoting the concept of transitional justice.
The consortium comprises 8 partners, including museums, game-developing companies and small and medium-sized enterprises (SMEs). The consortium brings together experts with complementary skills, working together toward the creation of video games inspired by real-life experiences.
For the purposes of this website, the data controller is Trilateral Research IE Ltd, registered in Ireland under company number 616396, with a registered office at Marine Point, 2nd Floor, Belview Port, Waterford, X91 W0XW, Ireland. You can contact the data controller by e-mailing: DPO [at] trilateralresearch.com.
Personal data processed through the website
Should you contact us through the website, we are going to collect your contact details and the message you provided us with. We are not going to collect metadata that you did not expressly provide us with (e.g., IP/MAC addresses).
The content we upload or otherwise make available through the website might contain personal data, such as the names of our or affiliated researchers and their work.
Legal bases of processing
For the personal data received through the contact form, we embrace the following lawful bases of our processing are embraced:
- Consent (Art. 6(1)(a) of the GDPR) – When you consent directly to the processing of your personal data, for example, when you subscribe to our newsletter. If you provide us with sensitive personal data, falling within Art. 9 of the GDPR (such as dietary requirements for an event), we will process it under Art. 9(2)(a) of the GDPR.
- Legitimate interests (Art. 6(1)(f) of the GDPR) – We process personal data when it is necessary for us to achieve the following legitimate interests:
- Enhancing our research delivery, by providing information about MEMENTOES to the individuals we deem as likely to be interested in our project. This may include:
- Sending invitations and providing access to guests attending our events and webinars;
- Monitoring the activity on this project website.
- Should the recipient of the information communicate to us that they are not interested in further communications from us, we will cease processing their personal data.
- Enhancing our research delivery, by providing information about MEMENTOES to the individuals we deem as likely to be interested in our project. This may include:
For the personal data we communicate through the website, the following lawful bases of our processing are embraced:
- Consent (Art. 6(1)(a) of the GDPR) – When we have received consent to publish personal data – e.g., a blog post from one of our researchers.
- Legal obligations (Art. 6(1)(c) of the GDPR) – We may process personal data in order to meet a legal obligation, e.g., promoting project results to multiple audiences, including the media and the public.
- Legitimate interests (Art. 6(1)(f) of the GDPR) – We process personal data when it is necessary for us to achieve the following legitimate interests (as long as they are not overridden by the data subject’s interests):
- Enhancing our research delivery, by providing information about MEMENTOES’ activities on the website;
- Undertaking dissemination activities.
How we secure your personal data when we process it
We have put technical and organisational security policies and procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. Wherever possible, we ensure that access to your personal data is password-protected and restricted only to a limited number of individuals who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information. We install and regularly update all security and anti-virus software in use on all of our systems. Nevertheless, the security of data transmitted over the Internet cannot be completely guaranteed. In addition, the consortium is conducting an Ethics and Privacy Impact Assessment Plus over the duration of the project, wherein the consortium will identify and assess any ethical or data protection risks and find solutions to overcome any such risks.
Please be aware that transmissions over the Internet are never completely private or secure.
How long do we retain personal data?
We retain personal data only as long as it is necessary for the purposes described above. Please note that we have an obligation to retain data concerning European Union Horizon Europe research projects for up to five years after the EC’s last payment to the Consortium (unless further retention is requested by the EU auditors).
As the records and documentation containing personal data have been collected within the delivery of an EC project, we expect that the European Commission will process it in compliance with Regulation No 2018/1725 on the protection of natural persons with regard to the processing of personal data by Union institutions, bodies, offices and agencies. After the expiry of the retention period, and unless further legitimate grounds for retention arise, we will dispose of personal data in a secure manner.
Do we share personal data with third parties?
The MEMENTOES consortium will generally not share personal information with anyone except the European Commission if it so requests. All partners will treat information received from other partners as confidential and will not disclose it to third parties, unless it is obvious that the information is already publicly available or there is a legal obligation to do so. The partners will impose the same obligations on their employees and suppliers.
We may occasionally share personal data with trusted third parties, such as those listed below, to help us deliver efficient and quality services. When we do so, we will ensure that recipients are contractually bound to safeguard the data we entrust to them before we actually share the data. We may engage with several or all of the following categories of recipients:
- Parties that support us as we provide our services (e.g., cloud-based software services such as Dropbox, Microsoft SharePoint, Google Analytics);
- Our professional advisers, including lawyers, auditors and insurers;
- Payment service providers;
- E-mail management services;
- Law enforcement or other government and regulatory agencies (e.g., tax authorities) or other third parties as required by, and in accordance with, applicable law or regulation;
- The European Commission when we are required to do so in relation to our work on EC Horizon Europe projects.
Do we transfer your personal data outside the EU?
By default, we store personal data on servers located in the EU. However, we may also transfer personal data to reputable third-party service providers, notably SharePoint, who may be located outside of the EU.
Your rights under data protection legislation
As a data subject, you can exercise the rights outlined in this section of the privacy policy. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make an initial request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.
Right to access (Art. 15 of the GDPR)
The data subject has the right to obtain confirmation as to whether processing of personal data concerning them takes place in the MEMENTOES project. If this is the case, the data subject can request access to their data. Granting the right to access only occurs where the identification of the data subject is possible.
Right to rectification (Art. 16 of the GDPR)
The data subject has the right to obtain the rectification of inaccurate personal data concerning them. The exercise of this right is only possible where the data subject can be identified and the inaccuracy of data is verified.
Restriction of processing (Art. 18 of the GDPR)
The data subject has the right to obtain the restriction of processing, where:
- the accuracy of the personal data is contested;
- the processing is unlawful, the data subject opposes the erasure of personal data and requests the restriction of processing instead;
- the controller no longer needs the personal data, but they are required by the data subject for the establishment, exercise or defence of legal claims;
- the data subject has objected to processing pursuant to Art. 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
The exertion of this right may require provision of further information to allow identification of the data subject.
Right to object (Art. 21 of the GDPR)
A legal basis for the processing of personal data in the MEMENTOES project is Art. 6(1)(f) of the GDPR. The data subject has the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them unless the MEMENTOES consortium demonstrates compelling legitimate grounds for the processing that override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
The exertion of this right may require provision of further information to allow identification of the data subject.
Right to erasure (’Right to be forgotten’) (Art. 17 of the GDPR)
The data subject has the right to obtain erasure of personal data concerning them, if:
- the data subject objects to the processing pursuant to Art. 21(1) of the GDPR and there are no overriding legitimate grounds;
- the personal data have been unlawfully processed;
- the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
Right to data portability (Art. 20 of the GDPR)
In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used and machine-readable format) directly to another company.
Right to lodge a complaint with a supervisory authority (Art. 77 of the GDPR)
The data subject has the right to lodge a complaint with a data protection supervisory authority in the Member State of their habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to them infringes the GDPR.
Disclaimer and limitations of liability
We aim to keep the information that appears on the MEMENTOES website as complete and up to date as possible. If errors are brought to our attention, we will take all reasonable steps to make any necessary corrections within a reasonable time. Please be aware that the information published on our website is for informational purposes only. None of the information contained on the website constitutes legal or professional advice, nor can we accept responsibility for how it might be used, and we are not responsible or liable for any errors or omissions in any of the information provided on the website. We cannot be held liable for any direct or indirect damage that may result from use of this site. Links to other websites are provided in good faith and for information only. A link to another website does not mean that we endorse or accept any responsibility for the content or use of such website.
While we take all possible steps to minimise disruption caused by technical errors, we cannot guarantee that our website will not be interrupted or otherwise affected by such problems. Please note that access may be suspended temporarily and without notice in the case of system failure, website maintenance or repair or for reasons beyond our control.
The use of our website is governed by the law of Ireland. Any dispute arising from or related to the use of this website shall be subject to the non-exclusive jurisdiction of the Irish courts.
Do we link to other websites?
Our websites may contain links to other sites, including the sites of the consortium partners, which are not governed by this privacy policy. Please review the destination websites’ privacy policies before submitting personal data on those sites. Whilst we try to link only to sites that share our standards and respect for privacy, we are not responsible for the content, security or privacy practices employed by other sites.
Do we change this privacy policy?
We regularly review this privacy policy and will post any updates to it on this webpage. This privacy policy was last updated on 14 April 2023.
