Privacy Policy
1. Introduction
This Privacy Policy explains how personal data are processed through the official website of the SENTRY project – “A Precision Agriculture Solution for Plant Pathogen Surveillance and Risk Assessment”, funded by the European Union under the Horizon Europe programme, Grant Agreement No. 101288591.
The website is used for institutional, communication, dissemination and stakeholder engagement purposes related to the SENTRY project. It provides information on the project, its objectives, partners, activities, public results, news, events and dissemination materials.
The processing of personal data through this website is carried out in accordance with Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”), and other applicable EU and national data protection rules.
2. Website governance and data controller
The SENTRY website is linked to the SENTRY project coordinated by:
STREMBLE VENTURES LTD
Ko 8, Germasogeia
Limassol 4045
Cyprus
STREMBLE VENTURES LTD is the Coordinator of the SENTRY project and the Data Controller for the project website.
For privacy-related requests concerning this website, please contact: info@sentryproject.eu
Where relevant, other SENTRY project partners may contribute to communication, dissemination, stakeholder engagement, event organisation, research or project-related activities. In such cases, personal data may be shared only where necessary for the purposes described in this Privacy Policy or in a specific notice provided to the data subjects.
3. Categories of personal data processed
Depending on how users interact with the website, the following categories of personal data may be processed:
- identification data, such as name and surname;
- contact details, such as email address;
- professional information, such as organisation, role, country and professional affiliation;
- information voluntarily provided through contact forms, email communications, newsletter subscriptions, stakeholder forms or restricted-area registration forms;
- data relating to participation in project activities, where applicable;
- images, photographs, audio or video recordings from project events, where applicable;
- technical and browsing data, such as IP address, browser type, device information, access logs, website usage information and cookie identifiers;
- authentication data, where a restricted area or login functionality is activated.
The website does not intentionally collect special categories of personal data, such as health data, biometric data, political opinions, religious beliefs or other sensitive information. Users are asked not to provide such data through the website unless specifically requested in a dedicated project activity and covered by a separate privacy notice.
4. Purposes and legal bases of processing
4.1 Website operation, maintenance and security
Personal data may be processed to ensure the technical functioning, maintenance, security and availability of the website, including hosting, backup, access logs, troubleshooting and protection against misuse or cyber threats.
The legal basis is the legitimate interest in operating a secure and functional project website.
4.2 Contact requests
When users contact the SENTRY project through a contact form or by email, personal data are processed to respond to the request, provide information, manage the communication and follow up where appropriate.
The legal basis is the user’s consent when submitting the request and, where applicable, the legitimate interest in responding to project-related communications.
4.3 Newsletter and project updates
Where a newsletter or mailing list is activated, personal data may be processed to send project news, updates, event invitations, dissemination materials and information related to SENTRY activities.
The legal basis is the user’s consent. Users may unsubscribe or withdraw consent at any time.
4.4 Stakeholder engagement and research-related contacts
The website may be used to collect information from or about stakeholders, including farmers, advisors, cooperatives, researchers, SMEs, policymakers and other actors relevant to the SENTRY project.
Where personal data are collected for stakeholder engagement, co-design, consultation, surveys, interviews, research activities or project validation activities, additional information may be provided through a specific privacy notice, consent form or participant information sheet.
The legal basis may be consent, legitimate interest, performance of project tasks in the public interest, or another applicable legal basis depending on the specific activity.
4.5 Restricted area
If the website includes a restricted area or login functionality, personal data may be processed to create and manage user accounts, authenticate users, control access to restricted content and ensure the security of the restricted area.
The legal basis is the legitimate interest in managing secure access to project-related materials and, where applicable, the user’s consent or the performance of project-related arrangements.
4.6 Event communication and media content
The website may publish photographs, videos, recordings or other media content from SENTRY events, workshops, meetings or public activities.
Where individuals are recognisable, the relevant privacy information and, where required, consent or other appropriate legal basis will be managed in connection with the specific event or activity.
4.7 Analytics and website improvement
Analytics data may be processed to understand how visitors use the website and to improve its content, accessibility, structure and dissemination effectiveness.
The legal basis is consent where non-essential analytics cookies or tracking technologies are used.
4.8 Compliance with legal obligations and data subject requests
Personal data may be processed to comply with applicable legal obligations, respond to data subject requests, manage complaints, document consent and handle potential data protection or security issues.
The legal basis is compliance with legal obligations and, where applicable, legitimate interest.
5. Cookies and similar technologies
5.1. What are cookies?
Cookies are small text files that a website places on the user’s device when the user visits the website. Cookies allow the website to function properly, improve browsing experience, remember user preferences and, where applicable, collect statistical information on the use of the website.
Similar technologies, such as pixels, local storage or other tracking tools, may also be used for similar purposes.
This Policy explains how cookies and similar technologies are used on the official website of the SENTRY project.
5.2. Types of cookies used
This website may use the following categories of cookies.
5.2.1. Strictly necessary cookies
These cookies are necessary for the website to function correctly and to provide the services requested by the user. They may be used, for example, to ensure website security, enable navigation, remember cookie preferences, manage login sessions or maintain the technical operation of the website.
Strictly necessary cookies do not require the user’s consent.
5.2.2. Preference cookies
Preference cookies allow the website to remember choices made by the user, such as language settings, display preferences or cookie preferences, where such functionalities are available.
These cookies are used only where relevant to the website functionality.
5.2.3. Analytics cookies
Analytics cookies may be used to collect information on how visitors use the website, such as the number of visits, pages viewed, approximate geographic area, device type, browser type and interaction with website content.
This information helps the SENTRY project understand how the website is used and improve its structure, content, accessibility and dissemination effectiveness.
The website may use Google Analytics or similar analytics tools. Analytics cookies will only be activated where required after the user has given consent through the cookie banner or cookie settings panel.
5.2.4. Third-party cookies
Some content or functionalities on this website may be provided by third-party services, such as embedded videos, maps, social media widgets, analytics tools, newsletter tools, event tools, repositories or other external services.
These third parties may place cookies or similar technologies on the user’s device when the user interacts with their content or services. The use of such cookies is governed by the cookie and privacy policies of the relevant third parties.
The SENTRY project does not control third-party cookies and recommends that users read the policies of the relevant third-party providers.
5.4. Cookie consent
When accessing this website, users may be shown a cookie banner allowing them to:
- accept all non-essential cookies;
- reject all non-essential cookies;
- manage cookie preferences by category.
Strictly necessary cookies are always active because they are required for the website to function.
Non-essential cookies, such as analytics or third-party cookies, will only be activated where required after the user has given consent.
Users may withdraw or modify their consent at any time through the cookie settings available on the website.
5.5. Managing cookies through the browser
Users can also manage, block or delete cookies through their browser settings. Most browsers allow users to:
- view cookies stored on their device;
- delete all or selected cookies;
- block cookies from specific websites;
- block third-party cookies;
- block all cookies;
- receive a warning before cookies are stored.
Please note that blocking or deleting some cookies may affect the proper functioning of the website or limit access to certain features, including restricted-area access where applicable.
Information on how to manage cookies is available through the support pages of the main browsers, including:
- Google Chrome;
- Mozilla Firefox;
- Microsoft Edge;
- Safari;
- Opera.
5.6. Cookie list
The specific cookies used on this website are listed below. This table must be completed and updated once the website configuration, WordPress plugins, analytics tools and third-party integrations are finalised.
| Cookie name | Provider | Type | Purpose | Duration |
| wordpress_test_cookie | WordPress | Strictly necessary | Checks whether the browser accepts cookies | Session |
| wp-settings-{user} | WordPress | Strictly necessary / preference | Stores UI preferences for logged-in users | 1 anno |
| wp-settings-time-{user} | WordPress | Strictly necessary / preference | Stores the timestamp of logged-in user preferences | 1 anno |
| wordpress_logged_in_* | WordPress | Strictly necessary / preference | Maintains the session of the logged-in user | Session |
6. Recipients of personal data
Personal data may be accessed or processed by:
- STREMBLE VENTURES LTD, as SENTRY Project Coordinator and Data Controller, where necessary for project coordination and website governance;
- Onoblo s.r.l. Società Benefit, as technical website operator for website-related processing, including web development and website administration;
- authorised members of the SENTRY consortium, where necessary for communication, dissemination, stakeholder engagement, research or project-related purposes;
- hosting, cloud, backup, security, maintenance and technical service providers, including Serverplan, where applicable;
- WordPress plugin providers, analytics providers, newsletter providers or other technical providers used by the website;
- public authorities, courts or competent bodies, where disclosure is required by law.
Service providers will process personal data only on the basis of appropriate contractual arrangements and instructions, where required by GDPR.
Personal data will not be sold to third parties.
7. International transfers
Personal data will primarily be processed within the European Economic Area.
Where third-party tools or service providers involve transfers of personal data outside the European Economic Area, such transfers will take place only where appropriate safeguards are in place in accordance with GDPR, such as adequacy decisions, standard contractual clauses or other lawful transfer mechanisms.
8. Data retention
Personal data will be kept only for as long as necessary for the purposes for which they were collected, unless a longer retention period is required by law or necessary to protect legitimate interests.
Indicatively:
- contact request data will be kept for the time necessary to respond to the request and manage any follow-up;
- newsletter subscription data will be kept until the user unsubscribes or withdraws consent;
- restricted-area account data will be kept for as long as the account remains active or access is required;
- stakeholder engagement and research-related data will be retained according to the relevant project documentation, data management plan or specific privacy notice;
- technical logs will be kept for the period necessary to ensure website security and functionality;
- consent records and data protection request records may be kept for the time necessary to demonstrate compliance with legal obligations.
Specific retention periods may be defined in internal project procedures, the SENTRY Data Management Plan or the tools used for the website.
9. Data subject rights
Under GDPR, users may have the following rights in relation to their personal data:
- right of access;
- right to rectification;
- right to erasure;
- right to restriction of processing;
- right to object to processing;
- right to data portability, where applicable;
- right to withdraw consent at any time, where processing is based on consent;
- right to lodge a complaint with a competent supervisory authority.
Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.
To exercise these rights, users may contact: info@sentryproject.eu
Users may be asked to provide information necessary to verify their identity and process the request.
10. Data security
Appropriate technical and organisational measures are applied to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.
However, no website or online transmission can be guaranteed to be completely secure. Users are encouraged to use appropriate precautions when communicating information online.
11. Third-party websites and services
This website may contain links to third-party websites, platforms, repositories, social media pages or external resources.
The SENTRY consortium and Onoblo are not responsible for the privacy practices, content or security of third-party websites. Users should read the privacy policies of those third parties before providing personal data through them.
12. Children
This website is not intended for children and does not knowingly collect personal data from children.
If personal data of a child are collected through a specific project activity, appropriate information and safeguards will be provided in accordance with applicable law.
13. Updates to this Privacy Policy
This Privacy Policy may be updated from time to time to reflect changes in the website, project activities, applicable laws, technical tools or internal procedures.
The updated version will be published on this page.