Privacy Policy

Last updated: February 2026

1. Data Controller

The data controller for this platform is the SAUFEX Consortium (contact: info@saufex.eu). EMOD is the European Master of Countering Disinformation, operated as part of the SAUFEX project.

2. Data We Collect

  • Account data: name, email address, role, and password (hashed)
  • Learning data: course enrollments, lecture progress, quiz attempts and scores, certificates earned
  • Payment data: transaction references, amounts paid (card details are processed solely by Stripe and never stored on our servers)
  • Usage data: page views and interactions collected via Matomo analytics (with cookies disabled and Do Not Track respected)
  • Support data: messages you send through our contact form

3. Legal Basis

  • Contract performance (Art. 6(1)(b) GDPR): processing necessary to provide the learning platform and courses you enrolled in
  • Legitimate interest (Art. 6(1)(f) GDPR): privacy-respecting analytics to improve the platform
  • Consent (Art. 6(1)(a) GDPR): cookie-based analytics, where applicable

4. Data Retention

We retain your personal data for as long as your account is active. If you delete your account, all associated personal data is permanently removed. Anonymised, aggregated statistics may be retained for research purposes.

5. Your Rights

Under the GDPR you have the right to:

  • Access your personal data
  • Rectify inaccurate data
  • Erase your data ("right to be forgotten")
  • Data portability — export your data in a machine-readable format
  • Restrict processing in certain circumstances
  • Object to processing based on legitimate interest

You can exercise your right to data export and account deletion directly from your Account Settings page. For other requests, contact us at info@saufex.eu.

6. Third-Party Services

  • Supabase (EU region) — authentication and database hosting
  • Resend — transactional email delivery
  • Stripe — payment processing (subject to Stripe's Privacy Policy)
  • Matomo (self-hosted) — privacy-focused analytics with cookies disabled

7. Cookies

By default, EMOD uses Matomo analytics without cookies and with Do Not Track respected. If you accept analytics cookies via our consent banner, Matomo may set a tracking cookie. If you decline, no analytics tracking occurs.

You can change your cookie preference at any time by clicking the "Cookie Settings" link in the footer of any page, which will re-display the consent banner.

8. Supervisory Authority

If you believe your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence, place of work, or place of the alleged infringement.

9. Contact

For any privacy-related questions or requests, please contact us at info@saufex.eu.