Personal Data Protection Notice

The European Mathematical Cup (EMC) is an international mathematics competition organised by the Croatian non-profit association Mladi nadareni matematičari „Marin Getaldić“ (Young Gifted Mathematicians “Marin Getaldić”, hereinafter: MNM).

The European Mathematical Cup is organised by two juries with distinct responsibilities. The Central Jury is the larger, primarily mathematics-focused body responsible for reviewing and evaluating solutions, ensuring consistency in marking, and handling appeals. For these tasks, its authorised members need access to participants’ identifying information, competition categories, local organiser codes, and scanned solutions during the central marking and appeal process. The Organisational Jury is the smaller body responsible for practical and administrative matters, including coordination with local organisers, competition logistics, and the administration of results and awards. Its members access personal data only to the extent necessary for their assigned duties, which may include administering participant records, publishing results, and arranging prizes.

Members of the two juries may need access to different personal data depending on their assigned tasks. Access is limited to the information necessary for those tasks.

MNM is committed to protecting the personal data of participants, local organisers, prize winners, and other individuals involved in the competition, in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation, or GDPR).

This notice explains what personal data are processed in connection with the EMC, the purposes and legal bases for processing, who may have access to the data, how long the data are retained, and how individuals can exercise their data protection rights.

1. Who is responsible for processing personal data?

The data controller for the processing activities described in this notice that are determined by MNM is:

Mladi nadareni matematičari „Marin Getaldić“ (MNM)
Ferenščica I. 70
10000 Zagreb, Croatia

General contact: mnm@mnm.hr
Privacy-related questions and requests: emc@mnm.hr

MNM determines the purposes and means of the personal data processing activities it carries out in connection with the organisation and administration of the EMC. These activities include the processing of participant information and competition scripts, the central marking and appeal process, the administration and publication of results, and the organisation of prizes, as described in this notice.

Local organisers collect and use personal data as part of running the competition at their respective locations, including ensuring that they have a valid legal basis for collecting and using those data and that they are permitted to transmit the necessary data to MNM. Their data protection responsibilities depend on the activities they carry out and the decisions they make about how and why personal data are processed. They may act as separate data controllers for some activities. Where data are transferred to MNM, MNM is responsible for ensuring that its subsequent processing has an appropriate legal basis and complies with its own obligations under the GDPR.

2. Personal data of competition participants

2.1. What data do we process?

For the central administration of the EMC, we processe the following personal data of participants:

  • Full name, to identify participants and associate them with their submissions.

  • Competition category (Junior or Senior).

  • Country and local organiser code, to identify the country and local organiser through which the participant takes part.

During central marking and the appeal process, we also process scanned copies of participants’ submitted solutions. These scans may contain the participant’s name, the location where the contest was taken, their competition category, problem numbers, handwritten mathematical work, and marking annotations or translations provided as part of the marking process.

Participants normally register through a local organiser. Local organisers collect and initially mark the solutions before submitting the required scans and marking information to the central organisers in accordance with the Rules for local organisers. We process these materials to review marking, ensure consistency across locations, resolve appeals, and verify competition results.

The local organiser code identifies the local organiser through whom a participant takes part in the competition. It consists of ISO 3166-1 alpha-3 code of the country followed by a dash and a single-digit number identifying that local organiser within the country. Since this code can be associated with a particular country and participant, it may constitute personal data when it enables the participant to be identified or distinguished.

We do not require participants to provide their home addresses, dates of birth, telephone numbers, or personal email addresses to MNM for the central administration of the EMC.

2.2. Why do we process these data?

We process participants’ data for the following purposes:

  • Registering and identifying participants in the central competition system.

  • Associating participants with their submitted solutions.

  • Reviewing marking and ensuring consistency and fairness across different locations.

  • Handling appeals and verifying results.

  • Calculating, verifying, and maintaining competition results.

  • Publishing official results in accordance with the competition rules.

  • Maintaining a historical record of past editions of the EMC.

We use the data only to the extent necessary for these purposes and do not use them for commercial advertising, unrelated marketing, or profiling.

2.3. What is the legal basis for processing?

For central competition administration, the review of solutions, appeals, and the maintenance of competition records, MNM relies on its legitimate interests under Article 6(1)(f) of the GDPR.

These legitimate interests include organising a fair and reliable international mathematics competition, ensuring consistent marking, verifying results, handling appeals, and maintaining an accurate record of the competition.

The publication of official results is a distinct processing activity. Its legal basis and scope are assessed separately, taking into account the purpose of publication, the expectations and rights of participants, the nature of the information published, and the fact that many participants are minors.

MNM processes personal data only where the processing is necessary for the relevant purpose, and the participants’ interests and fundamental rights do not override the legitimate interests pursued.

Participants have the right to object to processing based on legitimate interests, as explained in Section 7. Following an objection, MNM will assess the circumstances and act in accordance with the GDPR.

2.4. What is the role of local organisers?

Participants normally register through a local organiser, who is their primary point of contact for questions about participation.

Local organisers are responsible for the personal data they collect and use for their own activities, including providing the information required by applicable data protection law and establishing an appropriate legal basis for their processing. Local organisers must also ensure that the transfer of personal data to MNM is lawful. Where consent is the applicable legal basis, valid consent must be obtained before relying on it.

When a local organiser transfers participant information and scanned solutions to MNM, MNM is responsible for ensuring that its own subsequent processing complies with the GDPR and has an appropriate legal basis.

MNM processes the data it receives for the central purposes described in this notice. MNM’s obligations as a data controller for its own processing are separate from the local organiser’s obligations for its activities.

2.5. Who has access to participants’ data?

Access to participants’ data is limited to people who need the information to perform their assigned duties.

During marking and the appeal process

Members of the Central Jury, consisting of MNM mentors and other volunteers involved in the central marking and appeal process, have access to the information necessary to perform their assigned duties. This includes:

  • Participants’ full names.

  • Their competition categories.

  • Their local organiser codes, which are associated with the relevant local organisers and countries.

  • Scanned copies of participants’ submitted solutions.

This access enables the Central Jury to identify submissions, evaluate solutions, review marking decisions, and handle appeals.

MNM uses third-party services, including Google Drive, to store and exchange competition files. Files are stored on the association’s shared drive, with access granted to authorised Central Jury members through their individual accounts. Access is limited to people involved in the central marking and appeal process.

Central Jury members must use these data exclusively for their assigned duties, maintain confidentiality, and must not download, copy, forward, or otherwise disclose them except where necessary and authorised for the competition process.

After the appeal process has concluded, access to working files is restricted to authorised persons who still need them for a documented administrative or archival purpose. Access is removed when it is no longer necessary.

After the competition

After the appeal process has concluded, final results are published on the official EMC website in accordance with the competition rules.

The rules provide that contestants ranking among the top 20 in their country may be included in the Official Results list. The Organisational Jury may also decide to publish partial results that exclude participants who score below a specified threshold. Consequently, not every participant’s results are necessarily published.

Published results may include participants’ names, competition categories, countries, and the results or rankings shown in the official results. The exact information published follows the rules applicable to the relevant edition of the EMC.

Published results are publicly accessible. Publication of results is separate from access to internal competition records. Access to internal records after the competition is restricted to authorised persons who need it for legitimate administrative, archival, or other documented purposes. Scanned solutions, internal marking records or names of all participants are not intentionally published as part of the official results.

Certificates are provided to local organisers for distribution to their respective participants. Local organisers are responsible for distributing the certificates locally. MNM does not publish certificates as part of the official results.

2.6. How long do we retain participants’ data?

We retain participants’ personal data only for as long as necessary for the purposes described in this notice, taking into account the nature of the data, the purposes of processing, and any applicable legal obligations.

Official results and internal historical records

Official results may be retained as part of the historical record of the EMC. They include the names, countries, and results of participants selected for publication in accordance with the rules applicable to the relevant edition.

MNM also maintains internal historical records of participants and their final results, including the information necessary to verify past participation, respond to reasonable enquiries about historical results, and maintain an accurate record of previous editions. These records may include participants’ names, local organiser’s code, competition categories, final results, placements, and awards, where applicable.

Internal historical records are not publicly accessible. Access is restricted to authorised members of the Organisational Jury who need the information for their assigned duties. MNM periodically reviews the information retained to ensure that the scope and continued retention of these records remain justified.

Scanned solutions and detailed marking records

Scanned solutions and detailed marking records, including marking breakdowns and comments, are retained during central marking and the appeal process and for an additional 12 months after the final results are published, provided that the appeal process has concluded.

After the marking and appeal process has concluded, access to these records is restricted to authorised persons who need them for a documented purpose. They may be retained beyond this period where necessary for an ongoing dispute or to comply with a specific legal obligation. Any extended retention is limited to what is necessary for the relevant purpose.

When these records are no longer necessary, MNM deletes them or, where appropriate, anonymises them so that the individuals concerned can no longer be identified.

MNM deletes or anonymises other personal data when they are no longer necessary for their documented purposes, unless continued retention is required by law or is otherwise justified by an applicable legal basis.

3. Personal Data of Physical Prize Winners

We sometimes award best participants (e.g. all first prize winners, or everyone over a certain threshold) with physical prizes. To arrange the delivery, a form to collect the necessary data is sent to local organisers and forwarded to relevant participants by them.

3.1. Physical Prize Winners

Depending on the criteria for awarding prizes in a particular edition, physical prizes may include prizes provided by MNM and its sponsors, or prizes provided exclusively by sponsors.

Prizes provided by MNM and its sponsors

For prize packages that include prizes provided by MNM, the Organisational Jury collects the information necessary to arrange delivery through a dedicated form.

Responses are accessible only to authorised MNM personnel involved in prize administration. MNM arranges shipment and shares the recipient’s name, postal address, and any other information strictly necessary for delivery with the relevant courier or delivery service.

Where necessary, MNM may also share aggregated or summarised information with sponsors or suppliers, such as the number of T-shirts required in each size. Such summaries do not include personal data.

This way, your data does not get shared with any sponsors or suppliers, and we ensure you get all physical prizes you got in a single package.

Prizes provided exclusively by sponsors

Some prizes are provided and delivered exclusively by sponsors and do not include prizes provided by MNM. In these cases, the relevant sponsor may prepare a separate form, which the Organisational Jury forwards to local organisers for distribution to eligible participants.

The processing of personal data submitted through such a form is described in the privacy information provided by the organisation responsible for that processing. MNM does not collect personal data for prizes arranged directly by sponsors, and in that case the rest of this section is not applicable. 

3.2. What personal data do we collect?

For physical prizes arranged by MNM, we collect the following personal data from prize winners, as necessary to arrange delivery:

  • Name — to identify the recipient and arrange delivery.

  • Postal address — to deliver the prize.

  • T-shirt size — where a T-shirt is awarded.

  • Email address and phone number — optional, for communication about delivery if needed.

If you prefer, you may provide the contact and delivery details of a parent or legal guardian instead of your own. Please ensure that they have agreed to their details being provided to MNM for this purpose.

MNM does not collect personal data for prizes arranged directly by sponsors.

3.3. Why do we process these data?

We process these data solely to contact prize winners, arrange shipment, communicate about delivery where necessary, and ensure that the prizes reach their intended recipients.

MNM shares the recipient’s name, postal address and other relevant delivery information with the courier service so that the prize can be delivered.

Where T-shirts or other items are ordered from a supplier or sponsor, MNM may share aggregated information about the required sizes and quantities. This information does not include recipients’ names, postal addresses or individual contact details.

3.4. What is the legal basis for processing?

MNM processes the personal data necessary to arrange and manage prize delivery on the basis of its legitimate interests, pursuant to Article 6(1)(f) GDPR. These interests consist of administering awards and ensuring that prizes can be delivered to their recipients.

MNM limits the data processed to what is necessary for these purposes and restricts access to authorised persons. Prize winners may choose not to provide the information necessary for delivery; in that case, MNM will be unable to deliver the physical prize.

3.5. Who has access to these data?

Access to prize-delivery information is restricted to authorised MNM personnel who need it to arrange or manage delivery.

MNM shares the recipient’s name, postal address and any other information necessary for delivery with the courier service. The courier receives only the information needed to perform its delivery service.

Suppliers and sponsors involved in producing or ordering prizes receive only aggregated information about required sizes and quantities. They do not receive individual recipients’ delivery details from MNM.

For prizes arranged directly by a sponsor, the sponsor independently collects and manages any personal data required for delivery. MNM does not collect or have access to the responses submitted through the sponsor’s form. The sponsor is responsible for informing recipients about its own personal-data processing.

3.6. How long do we retain these data?

MNM retains prize-delivery information for 12 months after the prize has been dispatched by MNM. This period allows time to retry delivery where possible and resolve delivery-related issues.

If a delivery-related dispute or issue remains unresolved at the end of this period, MNM may retain the relevant information for longer, but only for as long as necessary to resolve the issue or comply with a specific legal obligation.

When the applicable retention period ends, MNM deletes or anonymises the information, unless continued retention is required by law or justified by another applicable legal basis.

4. Personal data of local organisers

4.1. What data do we process?

Depending on their role and the requirements of a particular edition of the EMC, we may process the following personal data of local organisers:

  • Full name and affiliation: to identify the person responsible for organising the competition locally.

  • Location: the country and, where applicable, the city in which the competition is organised.

  • Contact email address: to communicate with the local organiser and, where applicable, publish their contact information on the EMC website.

  • Contact telephone number: where provided and needed for practical coordination during a particular edition.

  • Operational information: information such as the planned competition date, expected number of participants, and other practical details needed to coordinate the current edition.

  • participants, and other practical information needed to coordinate the current edition.

We collect and use only the information necessary for the relevant purpose. Name, contact email and location are used for all purposes discussed in subsection 4.2. Telephone numbers and operational information are not published on the EMC website and are not automatically included in the internal contact archive for future editions, and are only used for coordination of the current edition.

4.2. Why do we process these data, and who has access to them?

We process local organisers’ personal data for three distinct purposes.

A. Public information about local organisers

We publish the local organiser’s name, location, and contact email address on the official EMC website so that prospective participants and other interested persons can identify their local organiser and contact them regarding the competition.

This information is publicly accessible. We do not publish local organisers’ telephone numbers or operational information as part of the public list. Local organisers may contact us to request corrections or removal of their published information.

B. Internal contact archive for future editions

We retain the local organiser’s name, location, and contact email address in an internal archive so that the Organisational Jury can contact previous local organisers about future editions of the EMC and coordinate the continued organisation of the competition.

The archive is not publicly accessible. Access is restricted to authorised members of the Organisational Jury who need the information for communication and coordination concerning future editions. The information is not shared with other organisations or individuals for their own independent purposes.

Telephone numbers and operational information collected for a particular edition are not added to this archive. If we need additional contact information for future editions, we will inform the local organiser of the relevant purpose and establish an appropriate legal basis before using it for that purpose.

C. Coordination of the current edition

We use contact details and operational information to coordinate the current edition of the EMC. This may include communicating deadlines, confirming the competition date and location, estimating participation, coordinating the submission of competition materials, and resolving practical organisational issues.

Access is restricted to authorised members of the Organisational Jury and other persons specifically involved in the relevant organisational task, to the extent that they need the information to perform their duties.

Telephone numbers, where collected, are used only when necessary for practical coordination. Operational information is used for the edition and purposes for which it was collected, unless further use is separately justified under an applicable legal basis.

4.3. What is the legal basis for processing?

For coordinating the current edition of the EMC, MNM relies on its legitimate interests under Article 6(1)(f) of the GDPR, subject to a documented assessment confirming that this basis is appropriate. These interests include coordinating local organisers, ensuring that competition materials are submitted correctly and on time, and addressing practical organisational issues. We limit the information used to what is necessary for these purposes and take into account the rights and interests of local organisers.

For publishing a local organiser’s name, location, and contact email address on the EMC website, and for retaining these details in the internal contact archive for future editions, MNM relies on the local organiser’s consent under Article 6(1)(a) of the GDPR.

Consent must be freely given, specific, informed, and unambiguous. The local organiser may withdraw their consent at any time by emailing emc@mnm.hr. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Where another legal basis is required or more appropriate for a particular activity, MNM will establish and document that basis before carrying out the processing.

4.4. Withdrawal of consent and requests for changes or removal

Local organisers may withdraw their consent to publication or inclusion in the internal contact archive at any time by emailing emc@mnm.hr. They may also request corrections to their published contact information.

Following withdrawal of consent, MNM will stop the relevant consent-based processing and remove the affected information from the website and internal archive, unless another valid legal basis or legal obligation justifies retaining particular information. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

Requests concerning operational information or other processing activities may also be sent to emc@mnm.hr. MNM will assess such requests in accordance with the GDPR and the legal basis applicable to the relevant processing.

4.5. How long do we retain these data?

We retain local organisers’ personal data only for as long as necessary for the purposes described above.

  • Public contact information: retained on the EMC website for the relevant edition while publication remains covered by valid consent. Following withdrawal of consent or the end of the relevant edition, the information is removed unless another valid legal basis or legal obligation justifies continued publication.

  • Internal contact archive: reviewed periodically to determine whether the contact remains relevant to future editions. Where processing is based on consent, the information is removed following withdrawal of consent unless another valid legal basis or legal obligation justifies continued retention.

  • Current-edition operational information: retained until the relevant edition’s organisational and administrative follow-up has been completed and the information is no longer needed, unless a specific legal obligation or other valid legal basis justifies longer retention.

MNM periodically reviews these records and deletes or anonymises information that is no longer necessary for its documented purposes.

5. Data minimisation and security

MNM aims to collect and process only personal data that are adequate, relevant, and necessary for the purposes described in this notice.

We take appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, loss, or destruction.

Access to personal data is restricted to authorised persons who need the information to perform their assigned duties. Persons involved in handling personal data are expected to maintain confidentiality and use the data only for authorised purposes related to the competition.

MNM does not use personal data for automated decision-making, including profiling.

6. Data Retention

MNM retains personal data only for as long as necessary for the purposes for which they were collected, taking into account the nature of the data, the purpose of processing, and any applicable legal obligations.

Different categories of personal data are subject to different retention periods, as described in the relevant sections of this notice:

  • Competition records: Official results may be retained as part of the historical record of the EMC. Internal historical records are retained only to the extent necessary to maintain an accurate record of past participation and results and to respond to reasonable enquiries. Scanned solutions and detailed marking records are retained during central marking and the appeal process and for an additional 12 months after the final results are published, provided the appeal process has concluded. If the appeal process concludes later, this period begins when it concludes. Longer retention is limited to cases where necessary to resolve an ongoing dispute or comply with a specific legal obligation.

  • Prize-delivery information: Retained for 12 months after the prize has been dispatched by MNM. Where a delivery-related issue or dispute remains unresolved, the relevant information may be retained for longer, but only for as long as necessary to resolve it or comply with a specific legal obligation.

  • Local-organiser information: Operational information is retained for the administration and follow-up of the relevant edition and deleted or anonymised when no longer necessary. Public contact information and contact details retained for future editions are subject to the conditions and retention practices described in Section 4.

MNM restricts access to retained records to authorised persons who need the information for their assigned duties. We periodically review retained personal data and delete or anonymise information that is no longer necessary for its documented purposes, unless continued retention is justified by an applicable legal obligation or another valid legal basis.

7. Your rights

Under the GDPR, you may have the following rights in relation to your personal data, subject to the conditions and limitations established by law:

  • Right of access: Request confirmation of whether we process your personal data and, where applicable, obtain access to those data.

  • Right to rectification: Request correction of inaccurate personal data or completion of incomplete data.

  • Right to erasure: Request deletion of your personal data where the applicable legal conditions are met.

  • Right to restriction of processing: Request that we restrict the processing of your personal data in certain circumstances.

  • Right to data portability: Receive certain personal data you have provided to us in a structured, commonly used, machine-readable format, or request their transfer to another controller, where the legal conditions are met.

  • Right to object: Object to processing based on our legitimate interests, on grounds relating to your particular situation. We will assess the objection in accordance with the GDPR.

  • Right to withdraw consent: Where processing is based on consent, withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

These rights do not apply in the same way to every processing activity. Whether a particular request can be fulfilled depends on the applicable legal basis and circumstances.

To exercise your rights, withdraw consent, request removal of your personal data, or ask questions about our data processing, contact us at emc@mnm.hr. Requests concerning participant records, published results, local-organiser information, or prize-delivery details may all be sent to this address. Please specify the nature of your request so that we can identify the relevant processing activity and respond appropriately.

We will assess and respond to requests in accordance with applicable law. Where a request cannot be fulfilled in full, we will explain the reasons and any applicable limitations.

If you believe that your personal data have been processed unlawfully, you have the right to lodge a complaint with the Croatian Personal Data Protection Agency (AZOP) or another competent data protection supervisory authority.

8. Changes to This Notice

We may update this notice when our data processing practices or applicable legal requirements change. The current version will be published on the official EMC website.

Last updated: October 2026