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Principles for Data Collection

Mroya is an independent, non-profit research laboratory operating in the public interest.
All data collection and processing activities conducted by Mroya are guided by the principles of scientific integrity, proportionality, and responsibility, and are carried out in accordance with applicable European data protection laws, including the General Data Protection Regulation (GDPR).

Research Purpose and Public Interest

Data is collected and processed exclusively for scientific and research purposes, as defined under Article 89 of the GDPR.
Our research activities are intended to contribute to knowledge, critical inquiry, and public understanding, and are not conducted for commercial exploitation, profiling, advertising, or behavioral targeting.

Where applicable, Mroya relies on the legal bases provided for scientific research conducted in the public interest, including legitimate research interests and statutory research exemptions recognized under European Union law.

Data Minimization and Proportionality

We adhere to the principle of data minimization.
Only data that is strictly necessary for the defined research objectives is collected and processed. We do not seek to collect personal data unless it is essential to the integrity and validity of a specific research activity.

Whenever possible, data is:


 • anonymized,


 • pseudonymized,


 • aggregated, or


 • processed in a manner that prevents the identification of individuals.

Special Categories of Data

Mroya does not intentionally collect special categories of personal data (as defined under Article 9 GDPR) unless such data is indispensable for a clearly defined scientific purpose and appropriate safeguards are in place.

In such cases, processing is carried out solely within the scope of lawful research exemptions and subject to enhanced technical and organizational protections.

Safeguards and Responsible Processing

All research-related data processing activities are subject to appropriate safeguards, including:


 • access limitation,


 • secure storage practices,


 • internal review of research necessity,


 • and ongoing assessment of data relevance.

Data is not retained longer than necessary for research purposes and may be archived in anonymized or non-identifiable form for longitudinal or historical research where permitted by law.

Rights of Data Subjects

Where personal data is processed, Mroya respects the fundamental rights and freedoms of data subjects as provided under applicable law.

Certain data subject rights may be restricted or adapted where such limitations are lawful and necessary to ensure the integrity, feasibility, or validity of scientific research, in accordance with Article 89 GDPR and relevant national implementations.

No Commercial Use

Mroya does not sell, trade, or commercially exploit personal data.
Data is never used for marketing, advertising, or automated decision-making affecting individuals.

Transparency and Accountability

Mroya remains committed to transparency regarding its research practices and data governance principles.
This page outlines the general framework guiding our approach to data collection and does not constitute a contractual or legal guarantee beyond what is required under applicable law.

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