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1.     Controller

The data controller is the Financial Intermediaries Department of the European Investment Bank (the “EIB”).  

2.     Purpose of the processing

This data protection statement provides information regarding the processing of personal data carried out by the EIB in the course of the Green Gateway Advisory programme which comprises the Green Gateway Helpdesk and E-Learning platform. The EIB performs these tasks in the exercise of the authority vested to it in accordance with the Provisions of the Treaties and its Statute.

The EIB processes personal data with a view to manage the Green Gateway Advisory programme, in a reasonable and proper manner, in accordance with applicable laws and regulations. Personal data are processed in accordance with Regulation (EC) 2018/1725 of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies and agencies and on the free movement of such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC (hereafter, the EU DPR).

Specifically, EIB processes the personal data for the below purpose(s) as described in the record: in order to support financial intermediaries increase green financing. The aim of the Helpdesk is to provide EIB Group financial intermediaries with a systematised web-based solution to receive guidance on topics related to Climate Action and Environmental Sustainability eligibility criteria and reporting requirements in the context of EIB Group intermediated finance operations. Financial intermediaries will also have access to a library of Frequently Asked Questions and guidance material related to green financing topics.

The E-Learning programme, which includes, among other activities, access to an E-Learning platform aims to provide self-paced learning solutions to participants made up of selected staff from participating financial institutions (i.e. EIB and EIF financial intermediaries).

In the context of the Green Gateway Advisory programme, the EIB processes the personal data for the below purpose(s) as described in the record:

• hosting and maintaining your profile and the profile of the company or organisation you represent or are associated with;
• keeping you informed of any changes to the information concerning the processing of your personal data;
• collecting, registering, cataloguing and responding in a targeted manner to enquiries you submit through the Helpdesk;
• preparing and disseminating FAQ lists, memos, templates and guidance, developing and delivering training and developing webinars;
• providing E-Learning participants with an individual learning account with access to courses, certificates of completion of courses and record of activity in the platform;
• developing and improving the operation of the programme;
• monitoring and analysing the use of the programme with a view of its further development and improvement.

The processing of personal data in the context of the Green Gateway Advisory programme does not involve the existence of automated decision-making, including profiling. 

3.     Legal Basis of the processing

The legal basis for the processing of personal data in the context of the Green Gateway Advisory programme is, in particular, Article 25 of the Regulation (EU) 2021/523 of the European Parliament and of the Council of 24 March 2021, establishing the InvestEU Programme and amending Regulation (EU) 2015/101 in connection with the advisory agreement concluded in compliance with this Article in March 2022 between the EIB and the European Union represented by the European Commission. This regulation mandated the EIB to provide advisory support for the identification, preparation, development, structuring, procurement and implementation of investment projects and to enhance the capacity of promoters and financial intermediaries to implement financing and investment operations through the InvestEU Advisory Hub (“Mandate”). The establishment and operation of the programme is an expression of this Mandate.

4.     Categories of data subjects

The following categories of data subjects are/may be concerned by the processing under 2: Designated EIB/EIF Staff members, Externals, Clients and Counterparties

5.     What personal data does the EIB process?

The EIB processes the following categories of personal data: 

• basic identification information associated with the Helpdesk or E-Learning account such as full name and email address. For the Helpdesk, the Helpdesk role (i.e.  Agent providing support and participating in the operation of the Helpdesk or User benefiting from Helpdesks), the Helpdesk range of access;
• if the data subjects are using the Helpdesk as the Helpdesk User or the E-Learning platform, employment information about the company or organisation they represent or are associated with, city and country they work in;
• if the data subjects are using the Helpdesk as the Helpdesk Agent, employment information that they have entered in the “About Me” section such as their job title, department or organisation they are employed with, represent or are associated with or their location;
• session cookies in order to identify users, operate and improve the application;
• any personal data contained in the content the data subjects generate.

6.     Where does the EIB obtain the personal data?

Personal data is obtained:

·         directly from the data subject

·         from a legal entity or an organisation that the data subject represents or with which is associated

7.     To whom is the personal data disclosed?

The EIB may disclose personal data to the following recipients:

•               the EIB relevant services (internally), the European Investment Fund relevant services (internally), other EU institutions (including the European Commission, and the European Court of Auditors) and public authorities in the EU member states, the EIB's own governing and controlling bodies, and competent regulatory, prosecuting and tax authorities;

•               our legal advisors,

•               the legal entity, organisation (if any) with which the data subjects are associated and intermediaries and other organisations involved in our transactions, in the ordinary course of communications relating to green and sustainability finance or Mandate

 

 

8.     International Transfers

Personal data are not transferred to entities established outside the EU or the European Economic Area.

9.     How long does the EIB keep personal data?

We keep personal data only for as long as is necessary for the purposes described in this data protection statement.

Personal data is kept for 40 months following the closure of the Green Gateway Advisory programme.

10.  What are the rights of data subjects and how can they exercise them?

Data subjects’ rights are set out in sections 3 to 5 of the EU DPR.

§  Data subjects have the right to obtain from the controller confirmation as to whether or not their personal data are being processed, and, if so, to access their personal data by contacting the controller or through the EIB DPO (right of access);

§  Data subjects have the right to request the controller to rectify any inaccurate data and/or have incomplete personal data completed (right to rectification);

§  Data subjects have the right to request the controller to erase their personal data as per Article 19 of the EU DPR (right to be forgotten);

§  Data subjects have the right to request the controller to restrict the processing of their personal data in the following cases (right to restriction of processing):

(i) if they contest the accuracy of their data;

(ii) if the processing of the data is unlawful and they oppose to their erasure;

(iii) if the controller no longer needs the personal data referred to for the purposes of the processing but the data subject concerned needs them for the establishment, exercise or defence of legal claims; or

(iv) if data subjects have objected to the processing of their data and the EIB seeks to establish whether the controller has legitimate grounds overriding data subjects’ right to restriction.

§  Data subjects have the right to object to the processing of personal data, on grounds relating to their particular situation, unless the EIB demonstrates compelling legitimate grounds for the processing or for the establishment, exercise or defence of legal claims;

§  Data subjects have the right to receive their personal data from the EIB in a structured, commonly used and machine-readable format to allow you to transmit your data to another controller without hindrance from the EIB (right to data portability);

§  When the legal basis of the processing is consent, data subjects have the right to withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;

§  Data subjects have the right to lodge a complaint with the European Data Protection Supervisor (www.edps.europa.eu) at any time (right to lodge a complaint).

11.  Contact

Should data subjects have any questions about the processing of their personal data, or wish to exercise any of the aforementioned rights, please contact us at greengateway_helpdesk@eib.org or the EIB's Data Protection Officer, Mr. Pelopidas Donos, by email at p.donos@eib.org or at the following address:

Mr. Pelopidas Donos

European Investment Bank

98-100 Boulevard Konrad Adenauer, L-2950 Luxembourg (Grand Duchy of Luxe

Full policy

The EIB Green Gateway E-Learning System is designed to provide general guidance on green criteria applicable to investments aimed at climate action and environmental sustainability. The content of this E-Learning system is provided for informational purposes only and does not constitute professional, financial, or legal advice. While the EIB strives to ensure that the course materials reflect the latest relevant criteria and guidelines, users should independently verify any information before making investment or business decisions.

The learning materials within the EIB Green Gateway E-Learning System should not be considered a definitive or legally binding interpretation of the EIB’s green eligibility criteria or any related regulatory frameworks, including but not limited to the EU Taxonomy for Sustainable Finance. Compliance with green criteria may require additional assessment, supporting documentation, or legal considerations beyond the scope of this E-Learning system.

Users acknowledge and agree that any decisions or actions taken—or refrained from—based on the information provided in the EIB Green Gateway E-Learning System are made at their sole discretion and responsibility. The EIB does not assume any responsibility for the accuracy, completeness, or timeliness of the information provided and does not guarantee any particular outcome resulting from the application of the knowledge obtained through this system.

To the fullest extent permitted by applicable law, neither the EIB nor the European Commission shall bear any liability (whether in contract, tort—including negligence—breach of statutory duty, or otherwise) for any loss or damage suffered, whether direct or indirect (including, without limitation, financial or economic losses), arising from the use of, reliance on, or inability to use the EIB Green Gateway E-Learning System, including but not limited to any inaccuracies, errors, omissions, or interruptions in the content provided.

By proceeding, you confirm that you have read and accepted the above disclaimer.