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Summary

EUROPEAN INVESTMENT BANK – Data Protection Statement –

GREEN GATEWAY ADVISORY PROGRAMME

Full policy

1.     Introduction

The European Investment Bank (hereinafter “the EIB”) is committed to the protection personal data. The EIB collects and further processes personal data 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 (hereinafter the “EU DPR”). This data protection statement explains the reason for the processing, the way of collection, handling and ensuring protection of all personal data. Additionally, this statement further explains the ways in which the information is used, and the rights of the individuals concerned, that are available in relation to their personal data.

The information in relation to the processing operation Green Gateway Advisory Programme undertaken by the EIB is presented below.

2.     Controller

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

3.     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:

•       EIB Group Green Checker, including AI Chatbot

•       Green Gateway Helpdesk

•       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 (EU) 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, offices 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).

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: in order to support financial intermediaries increase green financing. This objective is supported by the Green Gateway programme as follows:

3.1. EIB Group Green Checker (including AI Chatbot)

Personal data are processed for the following purposes:

•       allowing users to assess the final beneficiary transactions or sub-projects against the applicable eligibility criteria;

•       providing users the possibility to obtain an estimate on energy, CO₂ and cost savings that can be implied by several standard energy efficiency measures;

•     summarising the EIB Group Green Checkers' estimate on energy, CO₂ and cost savings, the indication on eligibility and users data input in a pdf summary which they can download on the last page of the EIB Group Green Checker;

•     providing users with AI-generated guidance on green eligibility checks, navigation of applicable criteria, required inputs, and general process-related questions; 

•     supporting users in completing green eligibility assessments by clarifying technical parameters, mapping queries to the correct criteria or categories, and identifying missing information needed for the assessment;

•       collecting, registering, cataloguing enquiries users submit through the EIB Group Green Checker AI Chatbot. 

3.2. Green Gateway Helpdesk

Personal data are processed for the following purposes:

•       providing users 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;

•       giving access to a library of Frequently Asked Questions and guidance material related to green financing topics;

•       receiving, cataloguing and responding to enquiries submitted through the Helpdesk.

3.3. E-Learning platform

Personal data are processed for the following purposes:

•       providing with self-paced learning solutions to participants made up of selected staff from participating financial institutions (i.e. EIB and EIF financial intermediaries);

•       providing participants with an individual learning account with access to courses, certificates of completion of courses and record of activity in the platform;

3.4. Programme-wide purposes

Across the entire Green Gateway Advisory Programme, the EIB also processes personal data for the following overarching purposes:

•       hosting and maintaining users’ profile and the profile of the company or organisation they represent or are associated with, where registration is required;

•        keeping users informed of updates related to personal-data processing;

•        developing and improving the operation of the overall programme;

•        preparing and disseminating FAQ lists, templates and guidance, developing and delivering training and developing webinars;

•       monitoring and analysing usage to support further 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.

4.     Legal Basis of the processing

The legal basis for the processing of personal data in the context of the Green Gateway Advisory programme is the public interest. In particular the legal basis relies on 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 

5.     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

6.     What personal data does the EIB process?

6.1. EIB Group Green Checker

The EIB processes the following categories of personal data, insofar as they relate to identifiable individuals (the list is illustrative, not exhaustive):

•    name of the person confirming the assessment (signatory) as part of a green enterprise assessment, which is then recorded in the Green Checker Results PDF document to serve as self-declaration form;

•       contact details and address of the final beneficiary of the assessment (personal data if private individuals are concerned, non-personal in the case of legal entities);

•       specific energy prices applied for calculation of cost savings of the assessment (personal data if private individuals are concerned, non-personal in the case of legal entities);

•     location of the sub-project that is assessed, to evaluate affectedness of climate risks and/or to calculate impact estimates based on solar irradiation levels or similar (personal data if private individuals are concerned, non-personal in the case of legal entities);

•       energy consumption for the previous year (personal data if private individuals are concerned, non-personal in the case of legal entities);

•       estimated energy savings based on an energy audit or similar source (personal data if private individuals are concerned, non-personal in the case of legal entities);

•       investment costs of the project planned for implementation (personal data if private individuals are concerned, non-personal in the case of legal entities).

6.2. Green Checker AI Chatbot

The EIB processes the following categories of personal data:

•       user-provided content (chat messages): no personal data are, in principle, required for the use of the Green Checker AI Chatbot. Users are explicitly informed of this requirement through an initial on-screen disclaimer instructing to refrain from including any personal data in their prompts. Notwithstanding this safeguard, the EIB cannot fully control the content users voluntarily enter. As a result, the inadvertent processing of personal data may occur where such data are included in their queries;

•       online identifiers: session and conversation identifiers generated by the system (including pseudonymised IP addresses) that are linked to the user’s browser session;

•    usage and interaction data: information about how users interact with the Green Checker AI Chatbot, such as the time of the interaction and general technical signals that help the EIB ensure the system works properly;

•       any personal data contained in the content the data subjects generate.

6.3. Green Gateway Helpdesk

The EIB processes the following categories of personal data:

•       basic identification information associated with the Helpdesk account (e.g. full name, email address);

•       Helpdesk-specific attributes, such as the user’s role (i.e.  Agent providing support and participating in the operation of the Helpdesk or User benefiting from Helpdesks) and their access range;

•     if users 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;

•       if users are using the Helpdesk as the Helpdesk User, employment information about the company or organisation they represent or are associated with, city and country they work in;

•       any personal data contained in queries or messages submitted through the Helpdesk;

•       session cookies in order to identify users, operate and improve the application.

6.4. E-Learning platform

The EIB processes the following categories of personal data:

•       basic identification information needed to create and maintain an E-Learning account (e.g. full name, email address);

•       employment information relating to the company or organisation you represent or you are associated with, as well as your city and country of work;

•       learning-related data, such as course enrolment, learning progress, certificates of completion and activity records within the platform;

•       session cookies in order to identify users, operate and improve the application.

7.     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.

8.     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;

•       the service providers acting on behalf of the EIB, who process personal data under strict confidentiality and security obligations.

9.     International Transfers

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

10.  How long does the EIB keep personal data?

Personal data is kept 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.

11.  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).

12.  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 Luxembourg)


Summary

Please carefully read and confirm the disclaimer below.

If you do not accept the disclaimer, you may not use the EIB Green Gateway E-Learning System.

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.