Thank you for visiting the Strategy website.

Who we are

Strategy is an EU-funded project (Grant Agreement no: 883250) that began September 2020 and ends in August 2023. For further information, we can be contacted at [Info@strategy-project.eu]

Scope of this privacy policy

The Strategy  consortium has prepared this privacy policy to inform website visitors, our partners and other stakeholders about how we process personal data. 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[1].

How we collect your personal data

We collect personal data both directly and indirectly from individuals.

• Directly. We obtain personal data directly from individuals in a variety of ways, when:you subscribe to our newsletter/s
• register to attend meetings and events we host and during your attendance at such events
• visit the offices of our partners
• when we are establishing a research relationship
• when we are performing professional services pursuant to our contract with the European Commission
• you participate in our research activities that we perform either independently or in collaboration with you.
• Indirectly. We obtain personal data indirectly about individuals from sources, including:
• our research partners
• our networks and contacts
• public and open data sources such as public registers, news articles and Internet searches

social and professional networking sites (e.g., LinkedIn).

The personal data types we collect

We collect the following types of personal data about individuals, including:

General personal data types, including: 

• Contact details (e.g., name, job title, organisation and email)

Personal information (e.g., age, gender, country of residence) that is collected for research purposes to understand how these characteristics influence a particular research area

Special categories of personal data, which we collect with explicit consent for project administrative purposes, including: 

• Dietary restrictions and identification documents when registering for in-person events such as project workshops

Expense forms submitted for internal reimbursement from attendance at such events

The lawful bases for processing  personal data 

There are different bases on which the consortium processes personal data.

• Consent – When you provide us with your personal data directly, for example, when you subscribe to our newsletter[3].
• Legal obligations– We may process personal data in order to meet a legal obligation[4], e.g., reporting to the European Commission and promoting project results to multiple audiences, including the media and the public.
• Legitimate interests – We process personal data when it is necessary for us to achieve the following legitimate interests[5]:
• Enhancing our research delivery; and
• Undertaking dissemination activities

What we do with personal data

Strategy partners collect such data from open sources such as adverts on the surface and dark web. The aim of our project is not to monitor an identified individual or to take decision against him or her, but to conduct research to find out if the cross-referencing of publicly available online information might contribute to the strategic and operational fight against organised crime and terrorism.

We process personal data with the purpose of:

• Conducting research (e.g., interviews, surveys)
• Promoting our research to different types of stakeholders
• Sending invitations and providing access to guests attending our events and webinars
• Processing online requests or queries, including responding to communications from individuals
• Complying with legal and regularity obligations.

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. We aim to ensure that access to your personal data are password protected. We encrypt EU classified data and data are 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 a privacy and ethics impact assessment (in line with GDPR Art. 35) 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.

Do we share personal data with third parties?

The Strategy 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 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 services providers
• Marketing services providers (e.g., MailChimp)
• Law enforcement or other government and regulatory agencies (e.g., tax authorities) or to other third parties as required by, and in accordance with applicable law or regulation
• The European Commission when we are required by them to do so in relation to our work with them on EC funded FP7 and H2020 projects.

Do we transfer your personal data outside the EU?

We store personal data on servers located in the EU, however, we  transfer personal data to reputable third-party service providers, notably SharePoint, Dropbox, MailChimp, Google, who may be located outside of the EU. All project partners are  required to safeguard personal data in accordance with our contractual obligations and data protection legislation.

Do we use cookies?

Cookies are small text files that are placed on your computer in order to make websites work better and to provide information to the owners of the website about its use by visitors. We only use third-party cookies on our website.

Where cookies are used, a statement will be sent to your browser explaining the use of cookies. To learn more, please refer to our cookie policy. We give visitors the option of not having cookies from our website.

Your data protection rights 

You have the following rights regarding our processing of your personal data. You can exercise your rights by emailing us (see below) including:

• Right to withdraw consent – You can withdraw consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
• Right of access – You can ask us to verify whether we are processing personal data about you and, if so, to have access to a copy of such data.
• Right to rectification and erasure – You can ask us to correct our records if you believe they contain incorrect or incomplete information about you or ask us to erase your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
• Right to restriction of processing – You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
• Right to data portability – 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 object – You can object to our use of your personal data for direct marketing purposes, including profiling or where processing has taken the form of automated decision-making. However, we may need to keep some minimal information (e.g., e-mail address) to comply with your request to cease marketing to you.
• Right to make a complaint to your local Data Protection Authority (DPA) (see https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm) regarding any concerns you may have about our data handling practices.

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.

How long do we retain personal data?

We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations and professional obligations to which we are subject. Please note that we have an obligation to retain data concerning European Union research projects (H2020, Action Grants, FP7, etc.) for up to five years after the end of the project (unless further retention is requested by auditors).

As the records and documentation containing personal data have been collected within the delivery of an EC project, we expect that the Commission will process it in compliance with Regulation No 2018/1725. 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.

Use of information appearing on this site

The content of this website, including texts, images, photographs, audio, video, graphics, logos, domain names, user interfaces, user “look and feel”, is protected by the provisions of national and international intellectual property laws.

Unless otherwise indicated, you are authorised to view, copy, print and distribute (but not modify) the content of this website, provided that such use is for solely personal and non-commercial purposes. Please acknowledge the source. All logos and trademarks are excluded from the abovementioned general authorisation. In cases of doubt as to the conditions of use or reproduction of a particular item, please contact us at: [Info@strategy -project.eu]

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 high standards and respect for privacy, we are not responsible for the content, security or privacy practices employed by other sites.

Disclaimer and limitations of liability

We aim to keep the information that appears on the Strategy 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 might be used. We cannot be held liable for any direct or indirect damage which 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.

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 the 21 November 2020.

Contact us

If you have any concerns as to how your data is processed or if you have some issues or queries concerning the Strategy website, you can contact us at

[Info@Strategy -project.eu]

[1] Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

[2] Directive (EU) 2016/680 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data by competent authorities for the purposes of the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, and on the free movement of such data

[3] Article 6.1.a of GDPR states that processing is lawful if the data subject has given consent to the processing of his or her personal data, for one or more specific purposes.

[4]  Article 38.1 of the project’s Grant Agreement between the European Commission and the project states that beneficiaries of H2020 projects have an obligation to promote the project and its results.

[5] Article 6.1.f of GDPR states that “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child”.