PHIRE – Photonics Healthcare Infrastructure for Resilient Europe
Last updated: 3 November 2026
1. Introduction
The PHIRE project is committed to protecting the privacy and personal data of individuals visiting its website, contacting the project team, or participating in project activities.
This Privacy Policy explains how personal data are collected, processed, stored, and protected in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and applicable Polish data protection legislation.
2. Data Controller
The controller responsible for the processing of personal data through the PHIRE project website is:
Łukasiewicz Research Network – Institute of Microelectronics and Photonics (Łukasiewicz–IMiF)
al. Lotników 32/46
02-668 Warsaw, Poland
Email: sekretariat@imif.lukasiewicz.gov.pl
Data Protection Officer (DPO):
Email: iod@imif.lukasiewicz.gov.pl
3. Personal Data Collected
Depending on how individuals interact with the website and the PHIRE project, the following categories of personal data may be processed:
- Contact information, such as name, surname, email address and telephone number.
- Professional information, such as organisation, position, professional role and area of expertise.
- Information voluntarily provided through contact forms, correspondence, registration forms or project surveys.
- Technical information necessary for website operation and security, such as IP addresses, access timestamps and server logs.
The project aims to collect only personal data necessary for clearly defined and legitimate purposes.
4. Purposes and Legal Bases of Processing
Personal data may be processed for the following purposes:
a) Communication and enquiries
To respond to enquiries, provide requested information and maintain correspondence concerning PHIRE activities.
Legal basis: Article 6(1)(f) GDPR – the legitimate interest of Łukasiewicz–IMiF in responding to enquiries and maintaining correspondence concerning PHIRE activities.
b) Surveys and stakeholder engagement
To conduct surveys, identify barriers to accessing technology infrastructures, assess stakeholder needs and support research and analysis related to photonics technologies for healthcare.
Legal basis: Article 6(1)(a) GDPR – consent of the data subject to the processing of personal data for the purposes of the survey.
c) Project participation and networking
To coordinate participation in project meetings, workshops and stakeholder engagement activities, where applicable.
Legal basis: Article 6(1)(a), 6(1)(b), 6(1)(e) or 6(1)(f) GDPR – depending on the nature and purpose of the specific processing activity. The applicable legal basis will be specified in the relevant information notice provided at the time of data collection.
d) Website operation and security
To maintain website functionality, ensure technical security, prevent misuse and diagnose technical problems.
Legal basis: Article 6(1)(f) GDPR – the legitimate interest of Łukasiewicz–IMiF in ensuring the proper functioning and security of the website.
e) Project communication and updates
To send project-related news, invitations or updates to individuals who have requested such communications.
Legal basis: Article 6(1)(a) GDPR – consent of the data subject to receive project-related news, invitations and updates.
5. Data Sharing and Recipients
Personal data may be disclosed, where necessary and legally justified, to:
- Authorised personnel of Łukasiewicz–IMiF involved in PHIRE activities.
- PHIRE consortium partners, where data sharing is necessary for defined project purposes and is covered by an appropriate legal basis and information notice.
- IT service providers, website hosting providers and survey platform providers acting under appropriate contractual arrangements.
- Public authorities or other authorised entities where disclosure is required by law.
Personal data will not be sold or shared with third parties for unrelated commercial marketing purposes.
Where survey respondents are asked whether their contact information may be shared with PHIRE consortium partners for future collaboration or follow-up activities, such sharing will occur only where an appropriate legal basis has been established, and respondents have received the relevant information.
6. International Data Transfers
Where personal data are transferred outside the European Economic Area (EEA), Łukasiewicz–IMiF will ensure that the transfer complies with Chapter V of the GDPR, including the use of an applicable adequacy decision or appropriate safeguards, where required.
Information about relevant international transfers and safeguards will be made available to data subjects in accordance with applicable law.
7. Data Retention
Personal data will be retained only for as long as necessary to fulfil the purposes for which they were collected.
Retention period will be in accordance with the Act on the National Archival Holdings and Archives, as well as the regulations in force at Sieć Badawcza Łukasiewicz – Instytut Mikroelektroniki i Fotoniki.
Where processing is based on consent, withdrawal of consent will be respected, subject to any other applicable legal basis requiring continued retention.
Data will subsequently be deleted or anonymised unless further retention is legally required.
8. Rights of Data Subjects
Under the GDPR, individuals have the following rights, subject to the conditions and limitations established by law:
- The right to access their personal data.
- The right to rectify inaccurate or incomplete personal data.
- The right to request erasure of personal data.
- The right to request restriction of processing.
- The right to data portability, where applicable.
- The right to object to processing based on Article 6(1)(e) or 6(1)(f) GDPR.
- The right to withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.
- The right not to be subject to certain decisions based solely on automated processing, where applicable.
Requests concerning personal data may be addressed to the Data Protection Officer at:
Individuals also have the right to lodge a complaint with the Polish supervisory authority:
President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych – UODO)
Website: https://uodo.gov.pl
9. Cookies and Website Analytics
The PHIRE website may use cookies or similar technologies necessary for its proper functioning and security.
Where optional analytics or third-party technologies are implemented, visitors will be informed about their purposes, providers and storage periods, and consent will be obtained where required by applicable law.
Visitors will be able to manage their preferences concerning non-essential cookies where such cookies are used.
Detailed information about the cookies and technologies actually used on the website, including their purposes and storage periods, is available through the website’s cookie information or settings.
10. External Websites and Survey Platforms
The PHIRE website may contain links to external websites, online questionnaires and services operated by third parties.
Personal data submitted through external platforms may be subject to additional privacy information describing the respective processing activities, the roles of the organisations involved and any applicable international data transfers.
Visitors are encouraged to review the relevant privacy information before submitting personal data through external services.
11. Data Security
Łukasiewicz–IMiF applies appropriate technical and organisational measures designed to protect personal data against unauthorised access, accidental loss, alteration, disclosure or destruction.
Access to personal data is restricted to authorised persons who require such access for legitimate purposes.
12. Voluntary Provision of Data
Providing personal data through contact forms, surveys or other voluntary interactions is generally optional.
However, certain information may be necessary to respond to an enquiry, register participation in an activity or process a specific request.
Where information is required, the consequences of not providing it will be indicated at the point of collection.
13. Changes to this Privacy Policy
This Privacy Policy may be updated to reflect changes in project activities, website functionality, data processing practices or applicable legislation.
The most recent version will be published on the PHIRE website, together with the date of its latest update.
14. Contact
For questions concerning this Privacy Policy or the processing of personal data, please contact:
Łukasiewicz Research Network – Institute of Microelectronics and Photonics
Email: sekretariat@imif.lukasiewicz.gov.pl
Data Protection Officer: iod@imif.lukasiewicz.gov.pl
