Privacy Policy

/Privacy Policy
Privacy Policy2018-09-14T15:45:14+01:00
Overview – the key information you should be aware of

(A) Who we are

MyCorridor is a research project funded by the European Commission with the aim of facilitating sustainable travel across borders. MyCorridor is a consortium which includes 17 partners as listed in section 14 (the "MyCorridor Research Partners") ("we", "us", "our"). We are joint data controllers of your personal information collected in accordance with this privacy policy.

(B) Our values and what this policy is for

We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information. We also want you to know your rights in relation to your information, and you can find details of these here.

In line with these values, this privacy policy tells you what to expect when we collect and use personal information about you. We have tried to make it easy for you to navigate this privacy policy so you can find the information that is most relevant to you and our relationship with you.

We are always looking to improve the information we provide to our contacts so if you have any feedback on this privacy policy, please let us know using our contact details in section 15 [LINK].

By accessing or browsing our website, www.mycorridor.eu, (the "Site"), signing up to our newsletter, attending our focus groups, workshops or other project related events and by otherwise contacting us, you confirm that you have read and understood the entirety of this privacy policy.

This privacy policy was last updated on 6 September 2018. Please check back regularly to keep informed of updates to this privacy policy.

(C) Who this policy applies to

This policy applies to:
  1. MyCorridor e-newsletter recipients [LINK];
  2. MyCorridor focus group or other event attendees [LINK];
  3. Visitors to the Site [LINK]; and
  4. People who contact us with enquiries.
(D) Your rights to object

You have various rights in respect of our use of your personal information.  Two of the fundamental rights to be aware of are that:
  1. you may ask us to stop using your personal information for direct-marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
  2. you may ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person's, legitimate interest.
You can find out more information in section 10 [LINK].

(E) What this policy contains

This privacy policy describes the following important topics relating to your information (you can click on the links to find out more):
  1. How we obtain your personal information
  2. The personal information we collect about you
  3. How we use your personal information and the lawful bases on which we rely
  4. How we share your personal information and who we share it with
  5. International transfers
  6. Cookies
  7. Marketing
  8. Security
  9. How long we store your personal information for
  10. Your rights
  11. Children
  12. Changes to our privacy policy
  13. Third party websites
  14. MyCorridor Research Partners
  15. Complaints, questions and suggestions
1.              How we obtain your personal information

You may provide us with personal information about yourself voluntarily or we may automatically collect personal information from you, as set out in this privacy policy, if you access the Site, sign up for our e-newsletter, agree to participate in a MyCorridor focus group, attend a MyCorridor event, or contact us by phone, email, or other means. We may also receive information about you from third parties, such as our service providers, contractors, group companies, public websites and public agencies.

2.              The personal information we collect about you

2.1           MyCorridor e-newsletter recipients

If you have signed up for our e-newsletter via the Site, we will collect the following information from you:

(a)            your email address;

(b)            other information provided when you correspond with us; and

(c)            any updates to information provided to us.

2.2           MyCorridor focus groups or event attendees

If you are attending a MyCorridor focus group or event, we will collect the following personal information from you:

(a)            your name;

(b)            your email address;

(c)            your company's name;

(d)            other information provided when you correspond with us;

(e)            any updates to information provided to us;

(f)              your telephone number;

(g)            if you attend our focus groups or events, your photograph and event video footage, with your consent (we will give you further notice of this and request your consent for this at the relevant focus group or event); and

(h)            if you attend our sites, CCTV footage.

All other information collected during the focus groups will be anonymous and you will not be identifiable from the information collected.

2.3           Visitors to the Site

We, or third parties on our behalf, collect the following information automatically when you visit our Site:

(a)            e-mail address (if you register for our newsletter);

(b)            other information provided when you correspond with us;

(c)            any updates to information provided to us;

(d)            the following information created and recorded automatically when you visit our website:

(i)   technical information. This includes: the Internet Protocol (IP) address used to connect your computer to the internet address; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and platform. We use this personal information to administer our Site, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our webpages and frequency with which they do;

(ii)  information about your visit and your behaviour on our Site. For example, the pages that you click on. This may include the website you visit before and after visiting our Site (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data and location data.

2.4           People who contact us with enquiries 

We, or third parties on our behalf, may collect and use any of the following information about you:

(a)            your name including your title;

(b)            your postal address;

(c)            your email address;

(d)            your telephone number;

(e)            information provided when you correspond with us; and

(f)             any updates to information provided to us.

3.              How we may use your information and the lawful bases on which we rely

The lawful bases for using your personal information are set out in this section. We will only collect and use the personal information listed above, as set out in this section.

3.1           MyCorridor e-newsletter recipients

We collect, use and store your email address with your consent for the purposes of providing you with the MyCorridor e-newsletter. You can withdraw your consent at any point.

If you wish to unsubscribe from our e-newsletter at any time, you can do so by clicking the ‘UNSUBSCRIBE’ link, found at the bottom of any email we send you – or by sending your name and email address to info@iruprojects.org – stating ‘Unsubscribe’ in the email in the subject line or body of the email.

3.2           MyCorridor focus groups or event attendees

Our legitimate interests

We collect, use and store the following personal information for our legitimate interests. For example, to deliver the focus group or event, to improve MyCorridor events in the future, to improve or develop MyCorridor, for business administration, for compliance, insurance, safety, auditing and monitoring, research and development and quality assurance purposes, we will collect, use and store:

(a)            your email address so that we can confirm your attendance at the relevant focus group;

(b)            your name and email address to request feedback relating to the MyCorridor focus group or event which you attended, to assist in our research and development and to improve and develop MyCorridor, its events and services;

(c)            your company's name, to understand the types of people interested in MyCorridor and MyCorridor events;

(d)            your email address or other contact information you have provided to us for the purposes of responding to your queries or requests for information in relation to MyCorridor or MyCorridor focus groups and events;

(e)            where it is in our legitimate interests to do so, we will use your contact details to invite you to other MyCorridor focus groups and events;

(f)             CCTV footage if you visit one of our sites, for ensuring the security of our staff and visitors, and our and their property.

Consent 

With your consent, we will use your personal information for the following purposes:

(a)            your photograph taken at a MyCorridor focus group or event, for MyCorridor-related dissemination activities on various social media platforms, to raise awareness of MyCorridor, and for internal purposes. Where we use your photograph for these purposes, no other personal information will accompany the photograph, for example, we will not display your name or contact details with that photograph;

(b)            to provide you with follow-up information relating to the MyCorridor focus group or event, which you attended;

(c)            to provide you with information relating to other MyCorridor focus groups and events, which may be of interest to you, where consent is required by law.

You can opt out of receiving information relating to MyCorridor focus groups and events at any time by clicking the ‘UNSUBSCRIBE’ link, found at the bottom of any marketing or promotional email we send you.

3.3           Visitors to the Site

If you visit our Site, we will collect information from you for our legitimate interests:

(a)            to allow you to access and use our website;

(b)            to understand the content that you are most interested in, so that we can more appropriately tailor the website to meet your preferences;

(c)            to provide technical support;

(d)            to ensure the security of our Site;

(e)            to provide you with the information that you request from us; and

(f)             for improvement and maintenance of our Site. Such details will be anonymised as far as is reasonably possible.

3.4           People who contact us with enquiries 

We will collect, use and store the following information from you for our legitimate interests to deal with:

(a)            any enquiries or issues you have about MyCorridor;

(b)            any questions you may have about how we collect, store and use your personal information; or

(c)            any requests made by you for a copy of the information we hold about you.

3.5            Other information we collect

Whatever our relationship with you is, we also collect, use and store personal information for the following additional reasons:

(a)            for internal corporate reporting, business administration, research and development, and to identify and implement business efficiencies.  We may process your personal information for these purposes where it is in our legitimate interests to do so;

(b)            to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so;

(c)            to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so;

(d)            if you are a journalist or work for an institution/trade association in our industry, we may collect information about you from public sources. Where it is in our legitimate interests to do so, we will use your contact details to invite you to write news articles about MyCorridor; to invite you to our events; to send you promotional material; and for press releases; and

(e)            if you visit one of our sites, we may also collect personal information about you on CCTV.

If we rely on our legitimate interests for using your personal information, we will undertake a balancing test to ensure that our legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.  You can ask us for information on this balancing test by using the contact details at section 15 [LINK].

If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at info@iruprojects.org and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to provide certain services to you. For example, if you withdraw your consent to us processing your email address in relation to the MyCorridor e-newsletter, we will no longer be able to send you the e-newsletter.

4.              How we share your personal information and who we share it with

4.1           Unless set out below, we will not disclose, sell or rent your personal information to any third party unless you have consented to this. If you do consent but later change your mind, you may contact us using the contact details in section 15 [LINK] and we will cease any such activity.

4.2           We disclose information to third parties under the following circumstances:

(a)            with companies that assist us with delivering our e-newsletter and with our marketing, advertising and promotional activities. This includes Mailchimp, who assists us in providing you with the MyCorridor e-newsletter;

(b)            other third-party service providers: when we share anonymous information with them, to facilitate or to provide the Site and or e-newsletter on our behalf. This will include:

(i)              IT infrastructure companies that facilitate our provision of the Site to you, including suppliers of technical and support services, insurers, logistic providers, and cloud service providers;

(ii)             analytics and search engine providers that assist us in the improvement and optimisation of our Site. For example, Google Analytics.

(c)            upon their request, with the European Commission, as funders of MyCorridor and the Innovation and Networks Executive Agency (acting on powers of the European Commission) as necessary.

4.3           Any third parties with whom we share your personal information are limited (by law and by contract) in their ability to use your personal information for any purpose other than to provide services for us, or in the case of the European Commission and Networks Executive Agency, as part of their overall funding of MyCorridor. We will always ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this privacy policy and applicable laws.

4.4           We will also disclose your personal information to third parties for compliance with laws and legal proceedings: when we respond to court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. When we believe in our sole discretion it is necessary to share information in order to investigate, prevent or take actions against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person or as otherwise required by law.

5.              International transfers

We do not transfer personal information we received about you outside the European Economic Area.

6.              Marketing

6.1           We will collect and use your personal information for undertaking marketing by email in accordance with this privacy policy.

6.2           We may send you certain electronic marketing communications to you if you are attended a MyCorridor event or focus group and if it is in our legitimate interests to do so for marketing and business development purposes.

6.3           We will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal information to any third party for such marketing.

6.4           If you wish to stop receiving marketing communications, you can contact us by email at info@iruprojects.org.

7.              Cookies

7.1           Some pages on our Site use cookies, which are small files placed on your internet browser when you visit our Site. We use cookies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences, and so we can continue to produce engaging content. These cookies may track things such how long you spend on the Site and pages you visit, helping us to understand how we can improve the Site for you. Cookies also enable us to provide you with an optimised and continued experience.

7.2           Where we use cookies on our Site, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our Site or to use all the functionality provided through our Site.

7.3           For detailed information on the cookies we use and the purposes for which we use them, please refer to our cookies policy here http://www.mycorridor.eu/cookies-policy/. By continuing to use our Site, you are agreeing to our use of cookies as described in our cookies policy.

8.              Security

8.1           We are committed to protecting personal information from loss, misuse, disclosure, alteration, unauthorised access, unavailability and destruction and takes all reasonable precautions to safeguard the confidentiality of personal information, including through use of appropriate organisational and technical measures.

8.2           Whilst we take appropriate technical and organisational measures to safeguard the personal information that you provide to us, no transmission over the Internet can ever be guaranteed secure. Consequently, please note that we cannot guarantee the security of any personal information that you transfer over the Internet to us.

9.              How long we store your personal information for

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights. We will not hold your personal information for longer than five (5) years from the date it was provided to us or collected by us in accordance with the requirements of the European Commission, who is funding MyCorridor.

10.           Your rights

10.1         You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at info@iruprojects.org at any time. You have the following rights:

(a)            Right of access.  You have a right of access to any personal information we hold about you.  You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; and details about how and why it is being used.

(b)            Right to update your information.  You have a right to request an update to any of your personal information which is out of date or incorrect.

(c)            Right to delete your information.  You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances.  You can ask us for further information on these specific circumstances by contacting us using the details in section 16 [LINK].

We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort.  You can ask us who the recipients are, using the contact details in section 16 [LINK].

(d)            Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances.  You can ask us for further information on these specific circumstances by contacting us using the details in section 16 [LINK].

We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort.  You can ask us who the recipients are using the contact details in section 16 [LINK].

(e)            Right to stop marketing: You have a right to ask us to stop using your personal information for direct marketing purposes.  If you exercise this right, we will stop using your personal information for this purpose.

(f)             Right to data portability: You have a right to ask us to provide your personal information to a third party provider of services.

This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.

(g)            Right to object.  You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person's legitimate interest.

10.2         We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, certain personal information may be exempt from such requests in certain circumstances. For example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.

10.3         If an exception applies, we will tell you this when responding to your request.  We may request you provide us with information necessary to confirm your identity before responding to any request you make.

11.           Children

We do not and will not knowingly collect information from any unsupervised child under the age of 16. Our Site, focus groups and events are not designed for under 16s.

If you are a child and we learn that we have inadvertently obtained personal information from you from our Site, or via any other source, then we will delete that information as soon as possible.

Please contact us at info@iruprojects.org if you are aware that we may have inadvertently collected personal information from a child.

12.           Third party websites

Our Site may, from time to time, contain links to websites operated by third parties including social media websites, partner networks and our group companies. Please note that this privacy policy only applies to the personal information that we collect through our Site and as otherwise stated in this privacy policy, and we cannot be responsible for personal information collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.

13.           Changes to our privacy policy

We will update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on our Site and, where appropriate, notified to you by post or email. Please check back frequently to see any updates or changes to our privacy policy.

14.           MyCorridor Research Partners

The entities listed below together form the MyCorridor Research Partners who are responsible for your personal information collected in accordance with this privacy policy. Each entity is part of the MyCorridor consortium and are together joint data controllers of your personal information provided to us in accordance with this privacy policy.

Amco Inspired Technologies http://www.amco.gr/el/

Certh (Centre for Research & Technology Hellas) https://www.certh.gr/

Chaps https://www.chaps.cz/

HaCon http://www.hacon.de/

IRU Projects https://www.iru.org/innovation/iru-projects

MAP Traffic Management https://www.maptm.nl/

Roma Mobilita https://romamobilita.it/it

Salzburg Research https://www.salzburgresearch.at/

Swarco Hellas A.E. http://www.swarco.gr/?lang=en

Swarco Mizar https://www.swarco.com/mizar

TomTom https://www.tomtom.com/en_gb/

TTS Italia Association https://www.ttsitalia.it/

University of Newcastle https://www.ncl.ac.uk/

University of Patras http://www.upatras.gr/en

Vivawallet https://www.vivawallet.com/en-eu/

Wings https://www.wings-ict-solutions.eu/

each a "Research Partner" and together the "Research Partners".

15.           Complaints, questions and suggestions

15.1         If you have any queries, complaints or suggestions about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact us using the appropriate email address below. We will investigate and attempt to resolve any complaint or dispute regarding the use or disclosure of your personal information, and will respond to your queries.

MyCorridor e-newsletter

Please contact info@iruprojects.org

MyCorridor focus group and events

Please contact [insert Swarco's email address].

For all other complaints, questions and suggestions

Please contact info@iruprojects.org

15.2         In accordance with Article 77 of the General Data Protection Regulation, you may also make a complaint to the Information Commissioner's Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place.  Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.

15.3         The practices described in this privacy policy statement are current as of 6 September 2018.