1. PURPOSE AND SCOPE OF THE PROGRAMME

This Information Clause defines the conditions related to participation and data processing for beneficiaries enrolled in the pilot programme implemented by HOPE UKRAINE within the framework of the SIMPLE project, co-funded by the European Union.

2. NATURE AND SCOPE OF PARTICIPATION

Participation in the programme is voluntary and free of charge.
Participation does not create any contractual, employment or financial relationship between the participant and HOPE UKRAINE or the SIMPLE project consortium.
Participants may withdraw from the programme at any time, by providing written notice to Hope World E.T.S. at least 5 working days before the withdrawal date.

3. NATURE OF ACTIVITIES AND SERVICES OFFERED

Participants may be involved in the following activities:

• Learning Community meetings based on dialogue, co-creation and collective reflection;
• access to integration-oriented services (Italian language support, employability services,
  tutoring);
• orientation activities related to entrepreneurship and self-employment;
• optional networking or information sessions with external stakeholders.

The scope and format of activities may be adapted during implementation in order to respond to participants’ needs and operational constraints.
Participation in the programme does not guarantee employment, self-employment, business creation, training placements, financial support or access to public funding schemes. The programme provides orientation, support and facilitation, but outcomes depend on individual circumstances and external
factors.

4. ROLES AND RESPONSIBILITIES HOPE WORLD E.T.S. acts as:

• the implementing organisation of the pilot;
• a facilitator and connector, supporting access to information, services and networks.
  HOPE WORLD E.T.S. does not provide legal, fiscal or professional consultancy and does not replace public institutions or specialised service providers.

PARTICIPANT is expected to:

• engage respectfully in programme activities;
• contribute to Learning Community discussions in good faith;
• respect the diversity, experiences and confidentiality of other participants

5. CODE OF CONDUCT

All activities are conducted in a spirit of mutual respect, inclusion and collaboration. Discriminatory, offensive, aggressive or disruptive behaviour will not be tolerated. HOPE UKRAINE reserves the right to suspend or terminate participation in case of serious or repeated violations of these principles.

The programme is implemented in line with the principles of:

• non-discrimination,
• gender equality,
• safeguarding of vulnerable persons.

Any form of discrimination, harassment or abuse based on gender, nationality, ethnicity, religion, age, disability or legal status is strictly prohibited.

6. DATA COLLECTION AND USE

For the purposes of implementing, monitoring and evaluating the pilot programme, HOPE WORLD E.T.S. may collect and process personal data, including:

• basic identification and contact details;
• information related to education, employability, integration needs and aspirations;
• qualitative inputs and feedback provided during Learning Community meetings and other programme activities.

Personal data will be processed exclusively for the following purposes:

• implementation and coordination of programme activities;
• monitoring and evaluation of outcomes;
• preparation of anonymised reports, thematic compendia and knowledge outputs;
• fulfilment of reporting obligations towards the funding authority.

No data will be processed for commercial purposes.

During the implementation of the programme, audio recordings, photographs and/or video materials may be produced, for example during events, Learning Community meetings or project-related activities.

The processing and use of such materials:

• is not mandatory for participation in the programme;
• is subject to specific and explicit consent, provided through a separate audio–photo–video release form;
• may include use for communication, dissemination and reporting purposes related to the project (e.g. websites, social media, project reports, institutional communication).

Any use of audio-visual materials will:

• fully respect the dignity, honour and reputation of participants;
• avoid the disclosure of sensitive information;
• not generate any form of remuneration or economic entitlement.

Participants may refuse or withdraw consent for the use of audio-visual materials at any time, without affecting their participation in the programme.
Any personal data, qualitative contributions, audio, photographic or video materials collected within the
framework of the pilot programme may be shared, in anonymised or aggregated form, with other partners of the SIMPLE project consortium, exclusively for purposes related to project implementation, monitoring, evaluation, communication and dissemination.

Where audio-visual materials are used for communication or dissemination purposes, this may include publication on:

• the official SIMPLE project website;
• official SIMPLE project communication channels, including social media platforms;
• project reports, publications and dissemination materials addressed to institutional stakeholders and funding authorities.

Such use shall always be subject to prior explicit consent, provided through a dedicated audio–photo–video release form, and shall fully respect the dignity, privacy and rights of participants.

7. CONFIDENTIALITY

All personal data will be processed in compliance with EU Regulation 2016/679 (GDPR) and applicable national legislation.

Data will be:

• stored securely and accessed only by authorised project staff;
• anonymised or aggregated for reporting and dissemination purposes;
• not disclosed to third parties outside the project framework, except where required by law or by the funding authority.

Participants’ names and identifiable information will not be disclosed in public documents unless explicit consent is provided.

8. DATA RETENTION

Personal data will be retained only for the duration necessary to achieve the purposes outlined above and in accordance with project and legal obligations.

Audio, photo and video materials, where consent is provided, may be retained for project communication and archival purposes, unless consent is withdrawn

The Data Controller is: HOPE WORLD E.T.S.
Registered office: Via Montà 29, Padova, Italy
Email: fondazione@hopeukraine.it

9. RIGHTS OF PARTICIPANTS

In accordance with GDPR, participants have the right to:

• access their personal data;
• request rectification or deletion of data;
• request restriction or object to data processing;
• withdraw consent at any time;
• request data portability where applicable.

Requests may be addressed to: direzione@hopeukraine.it

10. LIABILITY AND DISCLAMERS HOPE WORLD E.T.S. shall not be held liable for:

• decisions independently taken by participants;
• outcomes of referrals to external services or institutions;
• indirect or consequential damages arising from participation in the programme.

HOPE WORLD E.T.S. reserves the right to adapt programme activities, formats or timelines where necessary, while maintaining coherence with the programme’s objectives and methodology.

Any significant changes will be communicated to participants.

11. APPLICABLE LAW AND LANGUAGE

This Information Clause is governed by Italian law and applicable EU law.
In case of discrepancies between language versions, the Italian version shall prevail.