Privacy policy

Privacy Policy Shift2Sustain 

This privacy policy (hereinafter, “Privacy Policy“) informs you about the data processing carried out regarding visitors (the “Visitors“) who access to the Shift2Sustain platform. If you have any questions or would like to receive more information in this regard, please write at info@eiturbanmobility.eu. 

1. WHO ARE THE DATA CONTROLLERS OF YOUR DATA? 

The data controller is the one who decide the purpose for which your personal data is processed, in this case, is EIT KIC Urban Mobility S.L (“EIT UM”) located at Carrer Pamplona 104, 3rd floor, (08018) Barcelona, Catalonia, Spain, and the legal entities of EIT UM group mentioned below (i.e.: Innovation Hubs and Foundation) (hereinafter, the “EIT UM Group”).  

  •  EIT Urban Mobility Innovation Hub Central, Freddie-Mercury-Straße 5 80797 Munich, Germany  
  • EIT Urban Mobility Innovation Hub South S.L., Carrer Pamplona, 3rd floor, 104, Barcelona (08018), Catalonia, Spain, 
  • EIT Urban Mobility Innovation Hub East, s.r.o., Národní 135/14, 110 00 Praha   
  • EIT Urban Mobility Innovation Hub North ApS, c/o Blox, Bryghuspladsen 8, 3 København K,1473, Denmark  
  • EIT Urban Mobility Sweden AB, Registered Office situated in Simrishamn, Sweden 
  • EIT Urban Mobility Innovation Hub West B.V., Prins Hendrikkade 21e –5th floor, 1012 TL Amsterdam, the Netherlands   (hereinafter: “Innovation Hubs”).  
  • FUNDACIÓ EIT URBAN MOBILITY FOUNDATION, Carrer Pamplona, 104, 3rd floor, Barcelona (08018), Catalonia, Spain. (hereinafter: “Foundation”).

2. WHAT IS “PERSONAL DATA” 

Personal data (“Data”) is any information about an identified or identifiable natural person (the “Data Subject”). The Personal Data that the Controllers process comes from the information that you as a Visitor provide when you contact us and any other information you share with EIT UM via email. 

The form indicates the data that is mandatory, with an asterisk. Data that are not marked as mandatory by an asterisk are optional. Only the Data necessary for each purpose are collected. Please note that if you do not provide the mandatory information, the Controller may not be able to deal with your query or request or to manage the processing.  

3. WHAT DATA ARE PROCESSED BY THE CONTROLLER? 

(a) Identification data: name, surname.  

(b) Contact data: email address* 

(c) Technical and localization identifiers: We may collect location, device and system information data.* 

(d) Technology Usage Data: data collected through the website, including Interaction data (e.g., clicks, scroll behavior, and other actions performed on the website); Navigation data (pages visited, events triggered, and paths taken through the website); Engagement metrics (time spent on pages, session duration, and frequency of visits).* 

To ensure the security of your personal information, it is created, stored, and transmitted securely in various paper and electronic formats. Access to this information is restricted to EIT UM and EIT UM Group staff with a legitimate interest for the purpose of fulfilling their contractual duties, and our utilization of your personal information will be proportionate and not excessive. 

4. FOR WHAT PURPOSE DO WE PROCESS AND HOW WE COLLECT YOUR PERSONAL DATA? 

We collect and use personal data for the following purposes:  

(a) Communication with Visitors; via email or through Shift2Sustain contact form; 

(b) Conduction of statistical analysis; 

(c) Supporting the Shift2Sustain website involves enhancing the Visitor experience, monitoring the system and providing Helpdesk troubleshooting services. 

(d) Exercising any available based on the applicable law, such as use for the establishment, exercise or defence of legal claims, and fulfilling all the obligations as set out by the applicable law; 

5. WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR DATA? 

(a) Consent for information and technical support; 

(b) Legitimate interest for providing functional online platform and services  

(c) Legitimate interest to enforce or exercise any rights that are available to us based on the applicable law, such as use for the establishment, exercise or defence of legal claims. 

(d)Compliance with legal obligations in order to fulfil our obligations as set out by the applicable law. 

(e) Process of data when necessary to protect the vital interests of the user or of another natural person and/or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. 

Shift2Sustain will process your personal information for legitimate interest purposes, encompassing the following: 

  • To ensure the delivery of a high-quality visitor experience on the website. 
  • To communicate effectively with you through email. 

We consider the processing of your personal information for these purposes to be either necessary for ensuring the smooth functioning of the website, or necessary for compliance with our legal obligations, or necessary for the pursuit of the legitimate interests of Shift2Sustain. 

If specific uses of your personal information require your consent, we will obtain it at the appropriate time, and you retain the right to withdraw your consent at any time. We will not use your personal information to carry out any wholly automated decision-making that affects you. 

6. HOW LONG WILL BE YOUR DATA KEPT? 

We protect personal data with reasonable security measures, retaining it only for the period necessary for the purposes for which it is stored. Withdrawal or objection may lead to data removal, but legal obligations may require retention in order to file a legal claim or defend ourselves against a legal claim, or for evidential purposes. Please note that we will process the personal data necessary to ensure your request. 

Your Data will be kept for the period of time necessary for the purpose for which they were collected, and specifically:  

a. In relation to communications arising from the contact form, your Data will be processed for the time necessary to respond to your request, whether it concerns the information you have asked for or the resolution of technical issues you may have experienced, and, in any case, until you revoke your consent or object to the processing. 

Once the Data are no longer necessary for the purpose for which they are processed, only the data required will remain blocked for the sole purpose of meeting any liability or obligations that may arise from the processing thereof. 

7. WHO ARE THE DATA RECIPIENTS? 

Your Data may be communicated to service providers that assist the Controller in carrying out their business, for example, IT tools, technical support services, analytics services, etc.  

Minimum necessary data will be shared with partners and third parties, implementing technical measures where appropriate. All third-party service providers processing data on behalf of EIT UM are obligated to implement suitable security measures to safeguard users’ data in accordance with EIT UM policies. 

We may disclose your personal data in the event such disclosure is required or necessary to fulfil a legal obligation. We may also disclose personal data to protect your vital interests or the vital interest of another natural person. 

We may also disclose your personal data to third-party applications, websites and services (“Third-Party Services”). 

We are not responsible for the use of your personal data by Third-Party Services. In such case, the Third Party Services will act as controller.  

8. WHAT ARE YOUR RIGHTS?  

This article lists your principal rights under General Data Protection Regulation. We have tried to summarize them for you in a clear and legible way.   

To exercise any of your rights, please send us a written request in accordance with this Privacy Policy. We will respond to your request without undue delay, but in any event within one month of the receipt of the request. In the event of an extension of the term to respond or in the event we do not take action on your request, we will notify you.   

The right to access: You have the right to confirmation as to whether or not we process your personal data and, in the event we do so, you have the right to access such personal data, together with certain additional information that you also find listed in this Privacy Policy.   

You have the right to receive from us a copy of your personal data we have in our possession, provided that this does not adversely affect the rights and freedoms of others. The first copy will be provided free of charge, but we reserve the right to charge a reasonable fee if you request further copies.   

The right to rectification: If the personal data we hold about you is inaccurate or incomplete, you have the right to have this information rectified or, taking into account the purposes of the processing, completed.   

The right to erasure (right to be forgotten): In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include:   

(a) The personal data are no longer needed in relation to the purposes for which they were collected or otherwise processed;   

(b) You withdraw your consent, and no other lawful ground exists;   

(c) The processing is for direct marketing purposes;   

(d) The personal data have been unlawfully processed; or,   

(e) Erasure is necessary for compliance with EU law.   

There are certain exclusions to the right to erasure. Those exclusions include where processing is necessary,   

(a) for exercising the right of freedom of expression and information;   

(b) for compliance with a legal obligation; or,   

(c) for the establishment, exercise or defence of legal claims.   

The right to restrict processing: You have the right to restrict the processing of your personal data (meaning that the personal data may only be stored by us and may only be used for limited purposes), if:   

(a) You contest the accuracy of the personal data (and only for as long as it takes to verify that accuracy);   

(b) The processing is unlawful and you request restriction (as opposed to exercising the right to erasure);   

(c) We no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; or,   

(d) You have objected to processing, pending the verification of that objection.   

In addition to our right to store your personal data, we may still otherwise process it but only:   

(a) with your consent;   

(b) for the establishment, exercise or defence of legal claims;   

(c) for the protection of the rights of another natural or legal person; or,   

(d) for reasons of important public interest.   

We will inform you before we lift the restriction of processing.   

The right to data portability: To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.   

You also have the right to have your personal data transferred directly to another company, if this is technically possible, and/or to store your personal data for further personal use on a private device.   

The right to object to processing: You have the right to object to the processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:   

(a) The performance of a task carried out in the public interest or in the exercise of any official authority vested in us;   

(b) The purposes of the legitimate interests pursued by us or by a third party.   

If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.   

The right to complain to a supervisory authority: If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement addressing your claim to the correspondent Supervisory Authority which you can find here.   

If you are unhappy with how your information is handled or with our response, you can file a complaint at info@eiturbanmobility.eu  (Article 77 GDPR).

9. INTERNATIONAL TRANSFERS  

No international transfers are currently foreseen. We will ensure that any transfer of personal data to countries outside of the European Economic Area will take place pursuant to the appropriate safeguards. 

10. COOKIES 

Refer to Shift2Sustain Cookie Policy for information on website cookies. 

11. AMENDMENTS TO PRIVACY POLICY 

This Privacy Policy may be modified, with the latest version available on the Shift2Sustain website.