This Help Desk notice is a sub-notice of the institutional EUROPEUM-EDIC Privacy Notice and inherits its definitions, controller, and legal bases. Where this document is silent, the institutional notice applies.

EUROPEUM-EDIC Help Desk — Privacy Notice

Data Controller: EUROPEUM-EDIC
Registered office: 30 Simon Bolivar, boîte 1, 1000 Brussels, Belgium
Contact: info@europeum.eu
Processing operation: Technical Help Desk for the EBSI network
Record reference: EE-DPR-2026-001
Effective date: 2026-05-08

1. Data Controller

The data controller is EUROPEUM-EDIC, 30 Simon Bolivar, boîte 1, 1000 Brussels, Belgium. For any question related to personal data processing, contact info@europeum.eu.

2. Purpose of the Help Desk

The EUROPEUM-EDIC Help Desk is provided to support node operators, wallet providers, application service providers, and other authorised users of the EBSI network. The service is used to:

• Receive and resolve technical support requests
• Coordinate Node Operator Onboarding (NOOB) procedures
• Coordinate Wallet and Application conformance testing
• Communicate with operators on maintenance, incidents, and governance
• Improve and secure the support service itself

3. Personal Data Collected

EUROPEUM-EDIC only collects personal data that is strictly necessary for the purposes above.

3.1 Support requests. When you log a request or reply on a ticket, we may collect: first name, last name, email address, phone number (voluntary), job title (voluntary), organisation (voluntary), and any further information you choose to include in the message body, subject, or attachments.

3.2 Authentication. When you sign in to the Help Center, your account identifier and session metadata are recorded.

3.3 Access logs. For security purposes (incident response and abuse prevention) we log: IP address (if not masked), user agent, timestamp, and the requested resource.

4. Legal Basis for Processing

Processing relies on the same legal grounds as the institutional notice, in accordance with Article 6 GDPR:

• Article 6(1)(e) GDPR — performance of a task carried out in the public interest, in relation to EUROPEUM-EDIC's institutional mission and activities.
• Article 6(1)(a) GDPR — your consent, where applicable, when you voluntarily submit information through a support request or form. You may withdraw your consent at any time by contacting info@europeum.eu.

5. Cookies on the Help Center

Consistent with the institutional notice, EUROPEUM-EDIC does not use analytics cookies, tracking technologies, third-party advertising, or profiling tools.

The Help Center (hosted on Zendesk) sets only strictly-necessary session cookies required to keep you signed in and to maintain ticket session continuity. These cookies are operational and are deleted when you sign out.

6. Data Recipients and Processors

Personal data submitted to the Help Desk may be processed by authorised EUROPEUM-EDIC staff members in accordance with the GDPR. We engage the following categories of processors under written data-processing agreements:

• Zendesk Inc. — Help Center and ticket management platform (data hosted in the EEA).
• Sub-processors necessary for sending transactional email, all within the EEA.

Your ticket contributions are visible only to authorised EUROPEUM-EDIC staff and to anyone you explicitly share a ticket link with.

7. International Data Transfers

EUROPEUM-EDIC does not transfer your personal data outside the European Union or the European Economic Area (EEA).

8. Data Retention

Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected, and in accordance with applicable legal and administrative requirements.

• Help Desk tickets and contributions: retained while the support service is provided and for up to 5 years after your last request, then deleted or anonymised.
• Access logs: retained for 1 year from the date you accessed the platform.

You may request earlier deletion of your account; in that case, your contributions are anonymised and you lose access to the history of your interactions without authentication.

9. Data Subject Rights

In accordance with the GDPR you have the right to:

• Access your personal data;
• Request rectification of inaccurate or incomplete data;
• Request erasure of your personal data;
• Request restriction of processing;
• Object to processing carried out under Article 6(1)(e);
• Withdraw consent at any time where processing is based on Article 6(1)(a);
• Lodge a complaint with the competent supervisory authority.

To exercise any of these rights, contact info@europeum.eu. Reference EE-DPR-2026-001 in your request so we can route it quickly.

10. Security Measures

EUROPEUM-EDIC implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration, or disclosure. Measures include encryption in transit and at rest, multi-factor authentication for administrators, role-based access on a need-to-know basis, access logging, regular staff training, and a documented incident-response procedure.

11. Competent Supervisory Authority

You have the right to lodge a complaint with the competent supervisory authority. As EUROPEUM-EDIC is established in Belgium, the competent authority is the:

Autorité de protection des données / Gegevensbeschermingsautoriteit
Rue de la Presse 35 / Drukpersstraat 35, 1000 Brussels
www.autoriteprotectiondonnees.be · www.gegevensbeschermingsautoriteit.be

12. Updates to this Notice

This Privacy Notice may be updated to reflect changes in legal requirements or EUROPEUM-EDIC's activities. The latest version is published in the Help Center and the effective date above is updated accordingly.

Issued by EUROPEUM-EDIC — Data Protection. This document is a sub-notice of the institutional EUROPEUM-EDIC Privacy Notice and supersedes any prior privacy statement covering the Help Desk.