1. Party responsible for processing data
Instituto Tecnológico de la Energía («ITE»)
Parque Tecnológico de Valencia
Avenida Juan de la Cierva 24
46980 Paterna, Valencia, España
Contact for subject matter regarding data protection: [firstname.lastname@example.org]
2. Personal data categories to be processed by ITE
In accordance with General Data Protection Regulation compliance («GDPR»), ITE will process personal data of users of the web page https://watchplantproject.eu/ provided for managing enquiries, claims or requests via the aforementioned web page. Notably, and to this end, ITE will process the following personal data:
||First and last name
||Email and contact number
|Data pertaining to enquiry
||Subject matter of enquiry, as well as any additional data that the user may deem appropriate to provide for the purposes of management and response
3. To what purpose, and with what legal standing ITE processes personal data
Personal data provided by the user via this web page will be processed with the following objectives and in agreement with the legitimating bases explained below:
A) Handling enquiries, requests or claims arising from users via the contact form
ITE is obliged to process the user’s personal data provided in the contact form and which can be found on the web page (https://watchplantproject.eu/contact-biohybrid-system-technology-project/) with the objective of being able to manage properly any enquiries, requests or claims which may duly arise. In addition, ITE will process the contact details (e-mail) provided by said user in order to be able to send the enquiry to said address, as well as reply to any further doubt the user may have via this email.
B) Handling enquiries, requests, or claims arising from users by other means
The user has ITE’s contact details at his or her disposal on the web page (such as telephone number). In the case of said user opting to make a request, enquiry or claim directly via these means, ITE will process this personal data with the aim of being able to deal properly with said management and response. When deemed necessary, ITE will ask the user for specific contact details in order to reply to his or her enquiry or provide further information or documentation.
ITE will carry out the aforementioned on the grounds of the legitimate interest of guaranteeing correct management, service and response to user requests, enquiries or claims and to forward them any requested information or documentation. Accordingly, ITE understands that from the initial moment in which the user contacts the organization, a reasonable expectation exists as to their personal data being processed for the sole purpose of dealing with their request, regardless of the channel used (whether that be via the contact form or by telephone or electronic means).
In this respect and in accordance with GDPR compliance ITE has developed what is known as a «balancing test». This is an internal analysis whose objective it is to confirm that ITE’s legitimate interest in no way harms the interests of the users with regards to their personal data.
As a result of the above-mentioned, ITE understands that this processing will in no way affect user privacy, insofar as that only absolutely essential data will be processed in order to deal with the request and for the sole purpose of ensuring that it has been handled correctly.
Furthermore, and in all cases, the user reserves the right to object to said processing, as specified in the following Section 6.
C) Transferring personal data to web page partners
In the case of a user request referring to any of ITE’s partners in the WATCHPLANT project (for example, KTH, CSIC, CYBRES), and whose data can be found on the web page (in the section “Partners”), ITE will transfer personal data of said user to the corresponding organization, in accordance with subject matter of the request.
The user can also consult the list of partners in the section “Addressees to whom user personal data will be disclosed”
The only user data to be disclosed will be first and last name, contact details and enquiry subject matter so that the partner may deal with the enquiry in an appropriate manner or forward on to ITE the information and documentation needed to manage the matter in an appropriate manner.
ITE will carry out said processing on the grounds of a legitimate interest, justified by the need to manage the user’s request in the most appropriate manner (for instance, if an enquiry refers to the Spanish National Research Council’s (CSIS) participation in the project, said organization needs to be able to evaluate that matter). Accordingly, ITE understands that in the very moment that a user raises an issue with regards to the activity carried out by a specific partner, there exists a reasonable expectation that personal data may be transferred to said partner with the sole purpose of being able to respond to the request.
In accordance with GDPR compliance, with regards to the «balancing test» referred to in the previous section, the implications of transferring user data to partners has been analyzed.
In accordance with this, ITE understands that transferring user data will in no way harm privacy, given that this is essential in order to be able to deal with the user’s request in an appropriate manner, thus enabling the partner to send any information or documentation that has been requested or that is relevant to the subject matter of the enquiry.
In addition, ITE informs users that the contact details of all partners can be seen on the web page, in addition to specific links to their web pages, where their Privacy Policies can be found.
Likewise, the user can exercise his or her right to object to said processing, as indicated in section 6.
4. Period of time during which ITE will keep data
ITE will handle the user’s personal data during the period of time required to process and deal with the enquiry, and depending on whether or not said user requests any further information in addition to that already transferred by ITE.
As soon as the enquiry is understood to have been dealt with or closed, ITE will keep the user’s personal data (having been duly blocked), in order to comply with any potential legal obligations which are enforceable by law. In addition to this, ITE will make them available to the competent Public Administrations, Courts and Tribunals or Prosecution Service, during the limitation period on cause of actions which may arise regarding the processing of personal data and/or legally stipulated storage periods.
Not withstanding the foregoing, ITE will store data provided by the user during a period of three years, in full compliance with personal data protection regulations and information society services.
Once the aforementioned time periods have elapsed, ITE will proceed to eliminate said personal data.
5. Addressees to whom user personal data will be disclosed
The user’s personal data may be transferred to the third parties indicated below:
- Primarily and in the case of being an essential part of the enquiry, to the WATCHPLANT project partners who use this web page, namely:
- Kungliga Tekniska Hoegskolan (KTH) (www.kth.se).
- Research Center of Advanced Robotics and Environmental Science (CYBRES) (www.cybertronica.de.com).
- CIM-mes Projekt Sp. z o.o. (CYM-mes) (www.cim-mes.com.pl).
- The Spanish National Research Council (CSIC) (www.csic.es).
- University of Zagreb Faculty of Electrical Engineering and Computing (FER) (larics.fer.hr/larics).
- Universität zu Lübeck (LÜBECK uni) (www.uni-luebeck.de).
- Any third party to whom ITE may legally be obliged to facilitate information, such as Courts and Tribunals, Public Authorities (eg: The Spanish Data Protection Agency).
- Aside from the aforementioned data communications, ITE can count on the collaboration of third party service providers who may have access to personal data and who will handle them in the name of and on behalf of ITE by virtue of provision of services.
ITE complies with appropriate criteria when selecting service providers with the aim of fulfilling its obligations regarding data protection and commits to entering into the corresponding agreement concerning data processing, by way of which ITE will, inter alia, insist upon the following obligations: applying appropriate technical and organizational measures; processing personal data for the agreed purposes and solely following instructions documented by ITE; and deleting or returning data to the organization subsequent to the termination of services.
ITE may specifically contract a provision of services via a third party provider to carry out this professional activity, including but not limited to the following sectors: logistics services, legal counsel, information service providers, physical security companies, courier service providers (including instant courier service), or infrastructure management and maintenance companies.
6. User rights with regards to data protection
- The user reserves the right to obtain confirmation as to whether or not ITE processes his or her personal data and, in this case, have access to the data, as well as the right to insist on rectification of inaccurate data or, where appropriate, request that this data be eliminated when, inter alia, it is no longer required for the purposes for which it was obtained.
- In certain circumstances and for reasons relating to the user’s personal situation, in addition to those situations where ITE may process data on the grounds of legitimate interest, said user may object to processing. In this case, ITE will refrain from data processing, except in the case of compelling legitimate grounds or for the exercise and defense of potential claims. Accordingly and when justified in compliance with data protection regulations, the user will have the right to request restrictions on data processing.
- The user may exercise all aforementioned rights in written form to [email@example.com] providing a copy of his or her identity document.
- Finally, and in particular in the case of not being fully satisfied with regards to exercising rights, the user may lodge a complaint with ITE and/or with the Spanish Data Protection Agency (the competent Supervisory Authority as such) via its web page https://www.aepd.es