Operated by MoreThanDigital International GmbH · Last updated: May 2026
Controller: MoreThanDigital International GmbH
Address: Zugerstrasse 77, 6340 Baar, Switzerland
Contact: admin@return-ewaste.eu
Applicable law: Swiss nDSG (Federal Act on Data Protection) & EU GDPR (Regulation 2016/679)
Contents
- Who We Are and Who Is Responsible
- Applicable Data Protection Law
- What Personal Data We Collect and Why
- Cookies and Tracking Technologies
- Who We Share Your Data With
- International Data Transfers
- How Long We Keep Your Data
- Your Rights
- Supervisory Authorities
- Data Security
- Links to Third-Party Websites
- Children’s Privacy
- Changes to This Privacy Policy
- Contact
01. Who We Are and Who Is Responsible
The website return-ewaste.eu is the official public website of the RETURN project (Recovering Electronics Parts and Materials for Maximum Resource Efficiency), funded by the European Union under Horizon Europe grant agreement No. 101181128 and co-funded by the Swiss State Secretariat for Education, Research and Innovation (SERI).
The website is operated and managed by:
MoreThanDigital International GmbH
Zugerstrasse 77, 6340 Baar, Switzerland
Email: admin@return-ewaste.eu
Website: return-ewaste.eu
MoreThanDigital International GmbH acts as the data controller for all personal data collected through this website. As the RETURN project’s dedicated dissemination and communication partner, MoreThanDigital is responsible for the website’s operation and all associated data processing activities under Task 7.1 of the project’s Grant Agreement.
02. Applicable Data Protection Law
This Privacy Policy is designed to comply with two legal frameworks simultaneously:
| Framework | Applicability |
|---|---|
| Swiss nDSG | The Swiss Federal Act on Data Protection (nDSG), in force since 1 September 2023. Applies as MoreThanDigital International GmbH is domiciled in Switzerland and processes personal data of persons in Switzerland. |
| EU GDPR | Regulation (EU) 2016/679. Applies to the extent that personal data of individuals located in the European Economic Area (EEA) is processed in connection with services offered or behaviour monitored within the EEA. Given the RETURN project’s EU-wide scope and audiences, GDPR compliance is applied as a standard across all processing activities. |
Where the two frameworks differ, we apply the higher standard of protection. For EEA residents, your rights under the GDPR apply in full.
03. What Personal Data We Collect and Why
We only collect personal data that you provide to us voluntarily or that is technically necessary for the operation of this website. We do not sell, rent, or trade personal data.
3.1 Contact Form
When you use the contact form on return-ewaste.eu, we collect:
- Name
- Email address
- Any information you choose to include in your message
Purpose: To respond to your enquiry and provide the information or assistance you have requested.
Legal basis (GDPR): Article 6(1)(b) — processing necessary for pre-contractual steps, and/or Article 6(1)(f) — legitimate interests in communicating with stakeholders about the project.
Legal basis (nDSG): Processing is necessary for the purpose for which the data was provided and is proportionate to that purpose.
Retention: Contact form data is retained for as long as necessary to respond to your enquiry and for a reasonable follow-up period, and no longer than 3 years unless a longer retention period is required by law.
3.2 Newsletter Subscription
If you subscribe to the RETURN project newsletter, we collect:
- Email address
- Name (optional, if provided at sign-up)
- Date and time of subscription (for consent records)
Purpose: To send you the project newsletter (published biannually), which contains project updates, milestone news, and relevant dissemination activities.
Legal basis (GDPR): Article 6(1)(a) — your freely given, specific, informed, and unambiguous consent. You may withdraw your consent at any time by clicking the unsubscribe link in any newsletter, or by emailing admin@return-ewaste.eu.
Legal basis (nDSG): Your express consent at the point of subscription.
Retention: Your data is retained for as long as you remain subscribed. Upon unsubscription, your data will be deleted or anonymised within 30 days, except where retention is required for legal compliance purposes.
Third-party processor: Newsletter delivery is managed through MailerLite (UAB MailerLite, Gedimino pr. 60, LT-01104 Vilnius, Lithuania). MailerLite processes your email address and subscription data on our behalf as a data processor under a Data Processing Agreement. MailerLite is GDPR-compliant and based in the EEA. For further detail, see MailerLite’s Privacy Policy.
3.3 Website Analytics
This website uses an internal analytics system to collect basic, anonymised statistics about website usage. No third-party analytics services (such as Google Analytics) are used.
The data collected includes:
- Pages visited and navigation paths
- General geographic region (country/region level only — no precise location)
- Type of device and browser used
- Referral source (how you arrived at the site)
- Date and time of visit
This data is aggregated and anonymised. It does not allow us to identify individual users and is not linked to any other personal data.
Purpose: To understand how visitors use the site, improve functionality and user experience, and report website performance metrics as required under the project’s Grant Agreement.
Legal basis (GDPR): Article 6(1)(f) — legitimate interests in understanding and improving website performance, using the least privacy-invasive means available.
3.4 Data We Do Not Collect
We do not collect any of the following unless you explicitly provide it in a contact message:
- Sensitive personal data (health data, biometric data, racial or ethnic origin, political opinions, religious beliefs, etc.)
- Financial data
- Data from minors — this website is not directed at persons under 16 years of age
04. Cookies and Tracking Technologies
Cookies are small text files stored on your device when you visit a website. This website uses only technically necessary cookies required for the website to function properly.
| Cookie Type | Description |
|---|---|
| Session cookies | Temporary cookies that expire when you close your browser. Used for basic website functionality such as maintaining your session while navigating between pages. |
| Preference cookies | Used to remember your cookie consent choice. Expire after 12 months. |
We do not use advertising cookies, tracking cookies, or any cookies that monitor your behaviour across other websites. We do not use third-party analytics cookies.
Where your consent is required for any non-essential cookies, you will be presented with a consent banner. You may also manage or delete cookies through your browser settings at any time.
05. Who We Share Your Data With
We do not sell or share your personal data with third parties for their own commercial purposes. Data may be shared only in the following limited circumstances.
5.1 Service Providers (Data Processors)
| Provider | Purpose and Basis |
|---|---|
| MailerLite (UAB MailerLite, Lithuania) | Newsletter delivery and subscription management. Data Processing Agreement in place. GDPR-compliant. EEA-based. |
| Website hosting provider [Insert provider name] | Hosting and serving of the website. Data Processing Agreement in place. |
5.2 RETURN Project Consortium
As part of the RETURN project, anonymised or aggregated website and communication statistics may be reported to the project Coordinator (Argo Natural Resources Limited) and to the European Research Executive Agency (REA) as part of mandatory project reporting under the Horizon Europe Grant Agreement. No personal data identifying individual visitors is shared in these reports.
5.3 Legal Obligations
We may disclose personal data where required to do so by applicable law, court order, or instruction from a competent authority, including Swiss and EU data protection authorities.
06. International Data Transfers
MoreThanDigital International GmbH is based in Switzerland. Switzerland has been recognised by the European Commission as providing an adequate level of data protection under GDPR. Transfers of personal data between Switzerland and the EEA are therefore permitted without additional safeguards.
MailerLite, our newsletter processor, is based in the EEA (Lithuania) and is fully GDPR-compliant. Where any future service provider processes data outside Switzerland or the EEA, we will implement appropriate safeguards such as Standard Contractual Clauses (SCCs) as required by GDPR Article 46 and the equivalent provisions of the Swiss nDSG.
07. How Long We Keep Your Data
| Data Type | Retention Period |
|---|---|
| Contact form enquiries | Up to 3 years from the date of the enquiry, or until the purpose is fulfilled, whichever is sooner. |
| Newsletter subscriber data | For the duration of your subscription. Deleted or anonymised within 30 days of unsubscription. |
| Anonymised analytics data | Aggregated statistics may be retained for the duration of the project (until May 2028) and for reporting purposes thereafter. |
| Consent records | Records of newsletter consent retained for up to 5 years to demonstrate compliance. |
Data is deleted or anonymised as soon as the retention period expires, unless a longer period is required by applicable law.
08. Your Rights
Depending on your location, you have the following rights regarding your personal data. We will respond to all legitimate requests within one month (extendable by two months for complex requests).
EU GDPR — EEA Residents
- Access (Art. 15): Request a copy of your data
- Rectification (Art. 16): Correct inaccurate data
- Erasure (Art. 17): Request deletion of your data
- Restriction (Art. 18): Limit how we use your data
- Portability (Art. 20): Receive data in machine-readable format
- Object (Art. 21): Object to legitimate interest processing
- Withdraw consent: At any time, without retroactive effect
- Lodge a complaint: With your national supervisory authority
Swiss nDSG — Swiss Residents
- Access: Information about data we process about you
- Rectification: Correction of inaccurate data
- Erasure: Deletion where no overriding legal basis exists
- Restriction: Restriction of processing in certain circumstances
- Object: Object to certain types of processing
- Lodge a complaint: With the Swiss FDPIC at fdpic.ch
How to Exercise Your Rights
Email: admin@return-ewaste.eu
Post: MoreThanDigital International GmbH, Zugerstrasse 77, 6340 Baar, Switzerland
Please include sufficient information to identify yourself and specify which right you wish to exercise. We will respond within one month of receiving your request.
09. Supervisory Authorities
If you believe your data protection rights have been violated and are not satisfied with our response, you have the right to contact the relevant supervisory authority:
| Location | Supervisory Authority |
|---|---|
| Switzerland | Federal Data Protection and Information Commissioner (FDPIC) Feldeggweg 1, CH-3003 Berne fdpic.ch · info@edoeb.admin.ch |
| European Union / EEA | The data protection supervisory authority in your EU member state of residence or place of work. Full list at edpb.europa.eu. |
10. Data Security
We implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures are reviewed and updated regularly.
All data transmitted via this website is protected using HTTPS encryption. Access to personal data is restricted to personnel with a genuine need to process it for the purposes described in this policy.
No transmission method over the internet is completely secure. While we take all reasonable steps to protect your data, we cannot guarantee absolute security.
11. Links to Third-Party Websites
This website may contain links to third-party websites, including partner organisation websites and social media platforms. This Privacy Policy applies only to return-ewaste.eu. We are not responsible for the privacy practices of third-party sites and encourage you to review their privacy policies before providing any personal data.
Social media channels operated under the RETURN project (LinkedIn, YouTube, X/Twitter, Instagram, Facebook, Threads) are subject to each platform’s own privacy policies and terms of service.
12. Children’s Privacy
This website is not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data without appropriate consent, please contact us at admin@return-ewaste.eu and we will delete such data promptly.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or project activities. The date of the most recent revision is shown at the top of this page.
For material changes, we will notify newsletter subscribers by email. Continued use of the website after any update constitutes acceptance of the revised policy. We encourage you to review this page periodically.
14. Contact
For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact us:
MoreThanDigital International GmbH
Zugerstrasse 77, 6340 Baar, Switzerland
Email: admin@return-ewaste.eu
Website: return-ewaste.eu
This project has received funding from the European Union’s Horizon Europe research and innovation programme under grant agreement No. 101181128, and from the Swiss State Secretariat for Education, Research and Innovation (SERI). Views and opinions expressed are those of the author(s) only and do not necessarily reflect those of the European Union or SERI.
