SINFT Project

Cookie Policy

Document type: Third-Party Policy (tool_policy)

Version: 1.1  |  Effective date: August 2026

Platform: sinft.net  |  Erasmus+ Project

1. What Are Cookies?

Cookies are small text files stored in your web browser by websites you visit. They are used to make websites function correctly, remember your preferences, and in some cases to track usage. Alongside cookies, websites may also use browser Local Storage — a similar mechanism that stores data in your browser but persists beyond the current session.

This policy explains exactly which cookies and storage items the SINFT platform places in your browser, why they are placed, and how long they last.

2. Who Operates This Platform?

This platform is operated under joint controllership by two SINFT Consortium partners, as required by GDPR Art. 26:

A copy of the Joint Controllership Agreement governing the allocation of responsibilities between the joint controllers is available on request from contact@porakanova.org.

3. Who This Policy Applies To

Access to all course materials, including embedded video and document content, is restricted to registered and enrolled users only. Unauthenticated visitors (guests) cannot access any course content, embedded videos, or embedded documents.

This means that all third-party content described in this policy is encountered exclusively by users who have completed registration, have been enrolled in a course, and have actively accepted this Cookie Policy as part of the mandatory onboarding consent process. Acceptance of this policy at login constitutes prior informed consent to the data processing activities described below.

4. Cookies Set by This Platform (Moodle)

This platform is built on Moodle, an open-source learning management system. Moodle sets the following cookies in the course of normal operation:

5. Third-Party Content: Embedded YouTube Videos

Some course materials on this platform include videos embedded from YouTube (a service operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). When a page containing an embedded video loads, your browser establishes a connection to YouTube's servers, which involves the transmission of your IP address and browser information to Google, regardless of whether you press Play.

Technical mitigation: All YouTube videos embedded on this platform use the privacy-enhanced embed domain (youtube-nocookie.com) instead of the standard youtube.com embed. This reduces — but does not eliminate — tracking activity prior to Play. It prevents DoubleClick advertising cookies and prevents embedded views from influencing the user's YouTube recommendations.

International data transfer: YouTube/Google is a US-based service. When your browser connects to YouTube's servers, your personal data (IP address, device identifiers) is transferred to the United States. Google LLC participates in the EU-US Data Privacy Framework (adequacy decision by the European Commission, 10 July 2023), which provides an adequate level of data protection for these transfers.

Google's Privacy Policy is available at: https://policies.google.com/privacy

6. Third-Party Content: Embedded Google Documents

Some course materials include documents embedded from Google Docs (also operated by Google LLC). When a page containing an embedded Google Doc loads, your browser connects to Google's servers, transmitting your IP address and browser information to Google.

The same international transfer framework described in Section 5 (EU-US Data Privacy Framework adequacy decision) applies to Google Docs embeds.

7. Analytics and Tracking — Our Position

The SINFT platform does not use any third-party analytics services (such as Google Analytics, Matomo, or similar). The only usage data collected is Moodle's built-in server-side access logs, which record page visits, login/logout events, and course activity. This data is stored on the platform's own server infrastructure and is not shared with third parties except as required by law or described in this policy.

No advertising networks, social media pixels, or marketing tracking technologies are deployed on this platform.

8. Legal Basis for Processing

Processing activity    →    Legal basis

→  Moodle session cookies (MoodleSession, MoodleSessionTest)   →   Legitimate interest / strictly necessary (ePrivacy Directive Art. 5(3))

→  MOODLEID convenience cookie   →   Legitimate interest; disclosed and revocable

→  YouTube and Google Docs embed connections (IP transmission, Local Storage)   →   Consent, given through acceptance of this policy at account registration and enrolment (GDPR Art. 6(1)(a))

→  Moodle server-side access logs   →   Legitimate interest (GDPR Art. 6(1)(f)) — platform security and correct operation

9. Your Rights

Under the General Data Protection Regulation (EU) 2016/679, you have the following rights in relation to your personal data:

•  Right of access — request a copy of the personal data held about you

•  Right to rectification — request correction of inaccurate data

•  Right to erasure — request deletion of your personal data, subject to legal retention obligations

•  Right to restriction of processing — request that processing be limited in certain circumstances

•  Right to data portability — receive your data in a structured, machine-readable format

•  Right to object — object to processing based on legitimate interest

•  Right to withdraw consent — withdraw consent at any time for processing based on consent, without affecting prior lawful processing

You may also lodge a complaint with the supervisory authority in your country of residence. The lead supervisory authority for this platform is determined by the location of the Lead Controller (Poraka Nova Organisation — North Macedonia).

To exercise any of these rights, contact: contact@porakanova.org, stating the right you wish to exercise and a return email address. Within Moodle, you may submit a data request directly from your profile page under Privacy and Policies → Data Requests.

10. How to Manage or Delete Cookies

You can manage, restrict, or delete cookies through your browser settings. Note that deleting the MoodleSession cookie will log you out of the platform. Guidance for major browsers:

•  Google Chrome: Settings → Privacy and security → Cookies and other site data

•  Mozilla Firefox: Settings → Privacy & Security → Cookies and Site Data

•  Microsoft Edge: Settings → Cookies and site permissions → Cookies and site data

•  Safari: Preferences → Privacy → Manage Website Data

For YouTube and Google cookies specifically, you may also use Google's My Ad Center (myaccount.google.com) to review and manage how Google uses data associated with your account.

11. Changes to This Cookie Policy

We may update this Cookie Policy when the platform's technology stack changes, new third-party content is introduced, or regulatory requirements change. When a material update occurs, this policy will be re-versioned in Moodle's policy management system and you will be required to re-accept it before continuing to access the platform. The effective date at the top of this document will be updated accordingly.

Minor changes (corrections, clarifications that do not affect data processing) may be made without re-consent.

Joint Controllers: Poraka Nova Organisation + Angor AG  |  contact@porakanova.org  |  sinft.net

Data Protection Contact: Aleksandar Karadimche (UIST)  |  Erasmus+ co-funded project  |  Cookie Policy v1.1 — August 2026