Privacy Policy

Who we are

HEROES is an EU-funded project (Grant Agreement no: 101021801) which started in December 2021 and will end in December 2024. For further information on the project, you can contact the project coordinator, UCM (Complutense University of Madrid), at [heroes@ucm.es]

Scope of this privacy policy

The HEROES consortium has prepared this privacy policy to inform website visitors, our partners and other stakeholders about how we process personal data in the website and the project. We are committed to processing personal data responsibly, securely, and proportionally throughout our activities in compliance with the General Data Protection Regulation 2016/679 (“GDPR”) and any other European or national applicable laws. [1].

How we collect your personal data

We collect personal data both directly and indirectly from individuals.

• Directly:
  • When you subscribe to our newsletter/s
  • When you register to attend meetings and events we host and during your attendance at such events
  • When you visit the offices of our partners
  • When we are establishing a research relationship
  • When we are performing professional services pursuant to our contract with the European Commission
  • When you participate in our research activities that we perform either independently or in collaboration with you.
• Indirectly: we obtain personal data indirectly about individuals from different sources, including:
  • Our research partners
  • Our networks and contacts
  • Public and open data sources such as public registers, news articles and Internet searches
  • Social and professional networking sites (e.g., LinkedIn, Twitter).

The personal data types we collect

We collect the following types of personal data about individuals, including:

• Contact details (e.g., name, job title, organisation and email).
• Personal information (e.g., age, gender, country of residence) that is collected for research purposes to understand how these characteristics influence a particular research area.

We only collect special categories of personal data, upon obtaining prior consent for project administrative purposes, such as:

• Dietary restrictions and identification documents when registering for in-person events such as project workshops
• Expense forms submitted for internal reimbursement from attendance at such events

The lawful bases for processing personal data

During the HEROES research project, each of the partners will act as the data controller and therefore will be responsible for the implementation of data protection rules in relation to the processing operations it will perform. HEROES partners will be considered as joint controllers when they jointly determine the purposes and means, or at least the essential elements of these purposes and means, for data processing operations that will be performed within the HEROES project. For the personal data processed by any partner in the HEROES consortium, the applicable legislation is the GDPR.

There are different bases on which the consortium processes personal data:

• Consent – When you provide us with your personal data directly, for example, when you subscribe to our newsletter.
• Legal obligations– We may process personal data in order to meet a legal obligation, e.g., reporting to the European Commission and promoting project results to multiple audiences, including the media and the public.
• Legitimate interests – We process personal data when it is necessary for us to achieve the following legitimate interests:
• Enhancing our research delivery; and
• Undertaking dissemination activities

Purposes of the data processing

HEROES partners collect such data from our research activities, including interviews, workshops we conduct, and trials where we will work with you to elaborate, test, and validate our solutions through national/regional demonstrators or a large-scale cross-border simulation exercise. Outputs will include technology and written guidance.

We process personal data with the purpose of:

• Conducting research (e.g., interviews, surveys)
• Promoting our research to different types of stakeholders
• Sending invitations and providing access to guests attending our events and webinars
• Processing online requests or queries, including responding to communications from individuals
• Complying with legal and regularity obligations.

Security of the data processing

We have put technical and organisational security policies and procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration, or destruction. We aim to ensure that access to your personal data is password protected. We encrypt EU classified data and data are restricted only to a limited number of individuals who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information. We install and regularly update all security and anti-virus software in use on all of our systems, nevertheless the security of data transmitted over the internet cannot be completely guaranteed. In addition, the consortium is conducting a privacy and ethics impact assessment (in line with GDPR Art. 35) over the duration of the project, wherein the consortium will identify and assess any ethical or data protection risks and find solutions to overcome any such risks.

Do we share personal data with third parties?

The HEROES consortium will generally not share personal information with anyone except the European Commission, if it so requests. All partners will treat information received from other partners as confidential and will not disclose it to third parties, unless it is obvious that the information is already publicly available or there is a legal obligation to do so. The partners will impose the same obligations on their employees and suppliers.

We may occasionally share personal data with trusted third parties, such as those listed below, to help us deliver efficient and quality services. When we do so, we ensure that recipients are contractually bound to safeguard the data we entrust to them before we actually share the data. We may engage with several or all of the following categories of recipients:

• Parties that support us as we provide our services (e.g., cloud-based software services such as Dropbox, Microsoft Sharepoint, Google Analytics)
• Our professional advisers, including lawyers, auditors and insurers
• Payment services providers
• Marketing services providers
• Law enforcement or other government and regulatory agencies (e.g., tax authorities) or to other third parties as required by, and in accordance with applicable law or regulation
• The European Commission when we are required by them to do so in relation to our work with them on EC-funded FP7 and H2020 projects.

Do we transfer personal data outside the EU?

We store personal data on servers located in the EU, however, we transfer personal data to reputable third-party service providers, notably SharePoint, Dropbox, and Google, who may be located outside of the EU. All project partners are required to safeguard personal data in accordance with our contractual obligations and data protection legislation.

Do we use cookies?

Cookies are small text files that are placed on your computer in order to make websites work better and to provide information to the owners of the website about its use by visitors. We only use third-party cookies on our website. Where cookies are used, a statement will be sent to your browser explaining the use of cookies. To learn more, please refer to our cookie policy. We give visitors the option of not having cookies from our website.

Data protection rights

If we are processing your personal data, you have the following rights. You can exercise your rights by emailing us (see below) including:

• Right to withdraw consent – You can withdraw consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
• Right of access – You can ask us to verify whether we are processing personal data about you and if so, to have access to a copy of such data.
• Right to restriction of processing – You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
• Right to data portability – In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company.
• Right to object – You can object to our use of your personal data for direct marketing purposes, including profiling or where processing has taken the form of automated decision-making. However, we may need to keep some minimal information (e.g., e-mail address) to comply with your request to cease marketing to you.
• Right to make a complaint to your local Data Protection Authority (DPA) (see https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm) regarding any concerns you may have about our data handling practices.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make an initial request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.

How long do we retain personal data?

We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations and professional obligations to which we are subject. Please note that we have an obligation to retain data concerning European Union research projects (H2020, Action Grants, FP7, etc.) for up to five years after the end of the project (unless further retention is requested by auditors).

Use of information appearing on this site

The content of this website, including texts, images, photographs, audio, video, graphics, logos, domain names, user interfaces, user “look and feel”, is protected by the provisions of national and international intellectual property laws. Unless otherwise indicated, you are authorised to view, copy, print, and distribute (but not modify) the content of this website, provided that such use is for solely personal and non-commercial purposes. Please acknowledge the source. All logos and trademarks are excluded from the above mentioned general authorisation. In cases of doubt as to the conditions of use or reproduction of a particular item, please contact us at: heroes@ucm.es

Do we link to other websites?

Our websites may contain links to other sites, including the sites of the consortium partners, which are not governed by this privacy policy. Please review the destination websites’ privacy policies before submitting personal data on those sites. Whilst we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security or privacy practices employed by other sites.

Disclaimer and limitations of liability

We aim to keep the information that appears on the HEROES website as complete and up to date as possible. If errors are brought to our attention, we will take all reasonable steps to make any necessary corrections within a reasonable time. Please be aware that the information published on our website is for informational purposes only. None of the information contained on the website constitutes legal or professional advice, nor can we accept responsibility for how it might be used, and we are not responsible or liable for any errors or omissions in any of the information provided on the website might be used. We cannot be held liable for any direct or indirect damage which may result from use of this site. Links to other websites are provided in good faith and for information only. A link to another website does not mean that we endorse or accept any responsibility for the content or use of such website. While we take all possible steps to minimise disruption caused by technical errors, we cannot guarantee that our website will not be interrupted or otherwise affected by such problems. Please note that access may be suspended temporarily and without notice in the case of system failure, website maintenance or repair, or for reasons beyond our control.

Do we change this privacy policy?

We regularly review this privacy policy and will post any updates to it on this webpage. This privacy policy was last updated on 31 March 2022

Contact us

If you have any concerns as to how your data is processed or if you have some issues or queries concerning the HEROES website, you can contact us at: heroes@ucm.es

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[1] Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).