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Privacy Policy

Last updated: June 2, 2023 

 

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You respond to any of our surveys and tells You about Your privacy rights and how the law protects You. 

 

Interpretation and Definitions 

Interpretation 

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or plural. 

 

Definitions 

For this Privacy Policy: 

  • Project (referred to as either “the Project”, “We”, “Us”, or “Our” in this Privacy Policy) refers to the project IN2CCAM. 
  • Country refers to: Belgium. 
  • Personal Data is any information that relates to an identified or identifiable individual. 
  • Partner means any natural or legal person who processes the data on behalf of the Project. It refers to companies or other legal entities who have signed the Grant Agreement and Consortium Agreement of the Project. 
  • Consortium or Partners is the total set of Partners who signed the Grant Agreement and Consortium Agreement. 
  • Website refers to the IN2CCAM website, accessible from https://in2ccam.eu. 
  • You means the individual providing information through any of Our surveys. 

 

Collecting and using your (Personal) Data 

Purpose 

The Project collects data to execute research activities towards integrating CCAM services in fleet and traffic management. The Project consortium has been set up such that Our Partners, in principle, represent the relevant stakeholders. However, we need to collect a wider view to provide significantly relevant views, results, and services. Several specific surveys will be executed as part of the Project to serve this purpose.  

Each specific survey will clarify the exact purpose of that survey. 

All surveys by the Project are subject to a reviewing procedure defined in the Default Privacy Policy document and are approved by the Ethics Manager before being circulated.

 

Types of Data and their collection 

Within the project, no Personal Data is collected by default. If a survey requires collecting Personal Data, this will be justified in the introduction. 

The types of data that are collected are specified in the surveys. 

The collection is performed using privacy-safe tools, using the option of anonymous responses. This ensures that data like IP addresses are not registered. Furthermore, only tools that store data within the EU legislative boundaries are used. This excludes free versions of the major providers. 

The preferred tool for collecting data is EU Survey, and only the Partner responsible for the collection has access to the individual results. 

 

Collection and use of Personal Data 

In specific and duly justified cases, Your Personal Data may be collected. Personal Data will only be used to contact You. In no circumstances will Your Personal Data be shared outside the Project. Your Personal Data may be shared within the Consortium if another Partner than the collector will be responsible for contacting You. 

 

Use of data 

The collected data will be used to achieve the purpose defined in the specific surveys.  

Use of Personal Data 

Personal Data will only be used to contact You, or to identify You in case You choose to execute your rights. 

Protection 

Collected data will be stored initially in the survey tool. After the survey is closed, the final responses will be transferred to an area with restricted access. Typically, the local network of the Partner or the Project’s collaboration environment (SharePoint).  

Protection of Personal Data 

Personal Data will only be available in the survey tool and might be stored encrypted in a limited access area on the intranet of the partner responsible for contacting You.  

All Partners ensure their IT network and equipment complies with the latest versions and security patches of the applied tools. 

Retention 

The Project will retain Personal Data for the duration of the task that collected Your Data, extended potentially until the closure of the project. 

Legal base 

The legal base for collecting all Data, including Personal Data, is informed consent. By submitting the surveys, the data subject consents to its use. This Privacy Policy defines how data subjects can execute their rights, including withdrawing consent in several ways below. 

 

Executing Your rights 

Per the GDPR​​, data subjects have the following rights: 

Figure 1: The eight rights of data subjects​

The right to be informed 

Through this default privacy policy and the introductions of the forms, the data subjects are informed of the Project’s data collection and processing. 

In case of a need for additional information, the first point of contact should be the contact person mentioned in the forms. Generally, the Project’s Ethics Manager can be contacted, also mentioned on the forms. 

The right of access 

The Project does not collect Personal Data by default; consequently, any data submitted in forms will be anonymous and impossible to link to the individuals who provided the data. Providing access to that data is impossible as well without additional (Personal) information from the data subject. 

In cases where the Project collects contact details, access to their data will be granted by approaching the contact person mentioned in the form. 

The right of rectification 

The Project does not collect Personal Data by default; consequently, any data submitted in forms will be anonymous and impossible to link to the individuals who provided the data. Rectifying that data is impossible without additional (Personal) information from the data subject to identify the data. 

In cases where the Project collects contact details, rectifying that data can be performed by approaching the contact person mentioned in the form. 

The right to object to processing 

The Project does not collect Personal Data by default; consequently, any data submitted in forms will be anonymous and impossible to link to the individuals who provided the data. Preventing the data from being processed is impossible without additional (Personal) information from the data subject to identify the data. 

In cases where the Project collects contact details, preventing the data from being processed will result in removing the entry. This can be requested by approaching the contact person mentioned in the form. 

Rights in relation to automated decision-making and profiling 

The Project does not apply automated decision-making and profiling. 

The right to be forgotten 

The Project does not collect Personal Data by default; consequently, any data submitted in forms will be anonymous and impossible to link to the individuals who provided the data. Removing data is impossible without additional (Personal) information from the data subject to identify the data. 

In cases where the Project collects contact details, removing the data can be requested by approaching the contact person mentioned in the form. 

The right to data portability 

The Project does not offer a commercial service that can be procured elsewhere. Porting the data would mean obtaining the data (see 3.3.2 – The right of access) and removing the data (see 3.3.6 – The right to be forgotten). The data subject can then do anything with the data as the subject sees fitting. 

The right to restrict processing 

The Project does not collect Personal Data by default; consequently, any data submitted in forms will be anonymous and impossible to link to the individuals who provided the data. Restricting data processing is impossible without additional (Personal) information from the subject to identify the data. 

In cases where the Project collects contact details, restricting processing will result in data removal (see 3.3.6 – The right to be forgotten).