You are not legally required to provide the Hub Owner with any Personal Data, but without it, the Hub Owner will not be able to provide you with the full range or with the best experience of using the Hub Services (for instance, you may have a user Account, but you will not be able to access or participate in certain aspects the Website, the Hub or the Hub Services, including participation in any forums.
1. Definitions and Interpretation
|Data Protection Legislation||means the General Data Protection Regulation (EU) 2016/679 as implemented and enacted into the domestic laws of Norway, Poland and the Republic of Croatia.|
|HUB||means the ZEVInnovation hub platform, owned and operated by the HUB Owner and hosted at the domain address: http://www.zevinnovation.eu/hub/.|
|HUB Owner||Means the owner, operator and moderator of the Hub and the owner and operator of the Website.|
|Personal Data||has the meaning as set out in clause 4 below.|
|Service Providers||has the meaning set out in clause 12.|
|Website||means the ZEVInnovation project website hosted at the domain: www.zevinnovation.eu.|
2. Information About the HUB
2.1. The Hub and the Website are owned and operated by Centar za transfer tehnologije d.o.o (The Centre of technology transfer LLC), an organisation registered in the Republic of Croatia with the following details:
- Registered address: Ul. Ivana Lučića 5, 10000 Zagreb, Croatia
- Registered company number: 080077063
- Email address: email@example.com.
3. What Does This Policy Cover?
4. What Is Personal Data?
4.1. Personal data is defined by the Data Protection Legislation as "any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier" (Personal Data).
4.2. Personal Data is, in simpler terms, any information about you that enables you to be identified. Personal Data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
5.1. Under the Data Protection Legislation, you have the following rights, which the Hub Owner will always work to uphold:
b) The right to access the Personal Data the Hub Owner holds about you.
c) The right to have your Personal Data rectified if any of your Personal Data held by the Hub Owner is inaccurate or incomplete.
d) The right to be forgotten, i.e. the right to ask the Hub Owner to delete or otherwise dispose of any of your Personal Data held by the Hub Owner.
e) The right to restrict (i.e. prevent) the processing of your Personal Data.
f) The right to object to the Hub Owner using your Personal Data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if the Hub Owner is relying on your consent as the legal basis for using your Personal Data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided Personal Data to the Hub Owner directly, the Hub Owner is using it with your consent, and that data is processed using automated means, you can ask the Hub Owner for a copy of that Personal Data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. The Hub Owner will not use your Personal Data in this way.
5.2. It is important that your Personal Data is kept accurate and up-to-date. If any of the Personal Data held by the Hub Owner changes, please keep the Hub Owner informed for as long as it holds that data.
For further information about your rights or if you have any cause for complaint about the Hub Ownersâ€™ use of your Personal Data, you have the right to lodge a complaint with the Croatian Personal Data and Protection Agency at:
Croatian Personal Data and Protection Agency
Agencija za zaÅ¡titu osobnih podataka
Selska cesta 136
Tel: +385 1 4609 000
firstname.lastname@example.org or email@example.com
6. What Data Do You Collect and How?
6.1. The Hub Owner will collect three main categories of data which it identifies as being Personal Data:
- Data automatically collected or generated
- Data received from you
- Data received from Google and other channels
Such data consists of connectivity, technical or aggregated usage data, such as IP address, user statistics, user preferences, unique advertising ID (e.g. IDFA; you may reset such ID based on the operating system instructions, non-identifying data regarding a device, operating system, browser or App version, mobile carrier, locale and language settings, user activity in relation to the Hub Services, in-Hub activity (such as userâ€™s usage, content/product interaction and advertising data); diagnostic data (i.e. crash data and Hub performance data).
The Hub Owner does not use such data to learn a personâ€™s true identity or contact details, but mostly to have a better understanding on how users and Hub Members typically use and engage with the Hub, the Website and the Hub Services. The use of such technical and device data also helps the Hub Owner and Hub Partners to deliver interest-based or otherwise more effective advertisements and Content, to optimize ad management and the Hub Memberâ€™s or users' viewing experience), and to improve the overall performance and user experience of the Hub.
You may provide us Personal Data voluntarily, such as when you set up an Account as a Hub Member, contact the Hub Owner or any HUB Partner (through Facebook, Messenger, e-mail, or any other channel, including any support services), when you post on the HUBâ€™s public and private forums, including but not limited to either the private Innovation for incubation/mentoring, public Community Innovation/Forum or other groups, when you provide your e-mail address (such as when you sign-up to receive e-mail updates or notifications), when you participate in calls for innovations and other promotions, when you interact with other users, Hub Members and / or Hub Partners through the in-Hub forums or when you choose to share your Facebook, Google, or similar accounts to any of our platform segments.
Once you connect the Hub and / or Website to your Google, or similar account, the Hub Owner receives access to your profile, including (to the extent you defined it as public), as applicable, your full name, e-mail address, gender, photo, locale, time zone. This will also allow the Hub Owner to present your public profile pictures inside the Hub and to create in-Hub community networks and forums. In addition, the Hub Owner may receive from Google and other selected marketing channels, general information concerning the performance of advertising campaigns, such as the targeted age group or interests, and the Hub Owner, Hub Partners and any other partners may be able to link such general data to any other data in the possession of the Hub Owner.
6.2. If you access the Website or the Hub Services through a third party or connect the Hub Services or Website to any third-party account, you should also read their terms and conditions and privacy policies. If you are unclear about what information a third-party application is sharing with the HUB Owner, please visit that third-party application's website in order to learn more about their privacy practices.
7. How Do You Use My Personal Data?
7.1. The legal basis for which the Hub Owner collects and uses your Personal Data will depend on the particular purpose for which your data is being processed, however, the Hub Owner generally uses the Personal Data for the following reasons:
- Performance of a contract
- Legitimate interests
- Compliance with a legal obligation
The Hub Owner will use the Personal Data on this basis, which is necessary to make the Website and Hub Services available to you as a user or Hub Member, including when you choose to log in through a third party, and support services, available to you, and to send you service communications, notifications and news.
In limited cases (where you choose to sign up to receive direct marketing emails, where you accept Cookies on the Hub or Website, the Hub Owner will process your Personal Data based on your consent. You can withdraw your consent at any time by contacting us.
The Hub Owner will process your Personal Data based on its legitimate interests in maintaining and improving the Website and the Hub Services, understanding how the Hub Services and Website are used, serving effective advertisements within the Hub, on the Website and through other channels, improving the Hubâ€™s service and support operations, fraud detection and protecting and securing users, Hub Members, ourselves and the Hub Services.
In limited cases the Hub Owner may process your Personal Data where it needs to do so to comply with a legal obligation e.g. which is set out in an applicable law, or if it receives an order from a court or regulatory body.
7.2. The purposes for which the Hub Owner will use Personal Data are described in more detail below:
- To facilitate, operate, and provide the Website, the Hub and the Hub Services;
- To authenticate the identity of users and Hub Members, and allow them access to the Hubâ€™s additional features;
- To provide users and Hub Members with customer care, assistance and technical support services;
- To enable you to interact with other users, Hub Members and Hub Partners in the Hub including but not limited to; (i) in relation to the private Innovation for incubation/mentoring and the Community Innovation/Forum, for the purposes of enabling you to exchange views, skills, experiences and knowledge with other Hub Members; (ii) in relation to the Hubâ€™s networking services, introducing you to other Hub Members, other users and potential investors for the purpose of identifying collaboration and funding opportunities; (iii) and for the purposes of providing the evaluating and mentoring services, providing your contact details to the relevant Hub Partner as evaluator and/or mentor;
- To further develop, customize and improve the Hub, the Hub Services and the Website, or to improve your user experience, based on common or personal preferences, experiences and difficulties;
- To manage and deliver advertisements more effectively, including contextual, behavioural and interests-based advertising based on your activity within the Hub, based on your preferences or other data available to the Hub Owner or to the Hub Ownersâ€™ business partners, including for re-targeting purposes;
- To contact users and Hub Members (via e-mail or any other available channels) with general or personalized service-related messages (such as confirmations or system maintenance notices); to contact users and Hub Members with promotional messages (such as idea submission call updates, news, new features, additional services, etc.); and to facilitate, sponsor and offer certain events and promotions;
- To support and enhance the Hub and Hub Ownerâ€™s data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
- To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which the Hub Owner, Hub Partners or any selected business partners may use to provide and improve the Hub, the Hub Services and Websiteâ€™s respective services; and
- To comply with any applicable laws and regulations
8. Marketing and Advertising
8.1. With your permission and/or where permitted by law, the Hub Owner may also use your Personal Data for marketing purposes, which may include contacting you by email and / or telephone with information, news, offers and information in relation to the Hub Services, including but not limited to information relating to project funding opportunities, call dates and deadlines.
8.2. You will not be sent any unlawful marketing or spam. The Hub Owner will always work to fully protect your rights and comply with its obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out of receiving such communications from the Hub Owner.
8.3. Except for the purposes of introducing you to a Hub Partner for the purposes of the mentoring and other Hub Services, the Hub Owner will always obtain your express opt-in consent before sharing your Personal Data with any third parties for marketing purposes.
8.4. The Hub Owner will only use your Personal Data for the purpose(s) for which it was originally collected unless it reasonably believes that another purpose is compatible with that or those original purpose(s) and it needs to use your Personal Data for that purpose. If the Hub Owner does use your Personal Data in this way and you wish the Hub Owner to explain how the new purpose is compatible with the original, please contact the Hub Owner.
8.5. If the Hub Owner needs to use your Personal Data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, it will inform you and explain the legal basis which allows it to do so.
8.6. In some circumstances, where permitted or required by law, the Hub Owner may process your Personal Data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8.7. The Hub Owner uses certain data about you in order to improve the Hub and the Webisteâ€™s advertising practices and make the ads the Hub and the Website delivers more effective, relevant and enjoyable, including by deploying interest-based advertising, as well as targeting and ad measurement and attribution systems.
8.8. Such data includes your device advertising identifiers (e.g. IDFA or Advertising ID), to the extent available), data related to your third party profile (if any, such as your gender, region or country), product data and other demographic and interests-based information that the Hub Owner may have received from or about you, based on your consent or another legal basis.
8.9. The ads delivered by the Hub Owner may be shown within the Hub, via the Hub Services, on the Website or through other channels, such as third party websites and applications.
9. How Long Will You Keep My Personal Data?
9.1. Your Personal Data may be maintained, processed, accessed and stored by the Hub Owner and, where applicable, its authorized affiliates, Service Providers, Hub Partners and other business partners in and from the Republic of Croatia and other jurisdictions, as necessary for the proper delivery of the Hub Services, or as may be required by law. The Hub, the Hub Owner and each of the Hub Partners is based in a jurisdiction which is considered by the Croatian authorities and the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents.
9.2. While privacy laws may vary between local jurisdictions, the Hub Owner has taken reasonable steps to ensure that your Personal Data is treated by its affiliates, Service Providers and the other parties set out above, in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction. Where we transfer Personal Data from the Republic of Croatia or EEA, to countries outside the EEA which are not considered by the Croatian authorities or European Commission to offer adequate protection, we generally make such transfers subject to approved data transfer agreements.
9.4. Please note that except as required by applicable law, the Hub Owner will not be obligated to retain your Personal Data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you.
10. How and Where Do You Store or Transfer My Personal Data?
10.1. The Hub Owner will only store your Personal Data in the Republic of Croatia. This means that it will be fully protected under the Data Protection Legislation.
10.2. The Hub Owner will only store your Personal Data within the European Economic Area (the EEA). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your Personal Data will be fully protected under the Data Protection Legislation and/or to equivalent standards by law.
10.3. The security of your Personal Data is essential to the Hub Owner and the Hub Partners and to protect your Personal Data, the Hub Owner will take a number of important measures, including the following:
- limiting access to your Personal Data to those employees, agents, contractors of the Hub Owner and/ or the Hub Partners and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; and
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your Personal Data) including notifying you and/or the Croatian Personal Data and Protection Agency where the Hub Owner is legally required to do so;
11. Data Sharing
11.1. The Hub Owner may share your Personal Data with certain third parties, including law enforcement agencies, the Hub Partners, Service Providers and its affiliates. The main circumstances in which the Hub Owner may share data are summarised below:
- Compliance with Laws, Legal Orders and Authorities
- Service Providers and Business Partners
- Third Party Integrations
- Protecting Rights and Safety
- Hub Partners and their Affiliated Companies
The Hub Owner may disclose or allow government and law enforcement officials access to certain Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur with or without notice to you, if the Hub Owner has a good faith belief that it is legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
The Hub Owner may engage selected third party companies, contractors and individuals to perform services complementary to its own (e.g. hosting services, data analytics services, marketing agencies and advertising services and tools, data and cyber security services, fraud detection and prevention services, payment processing services, customer support partners, external moderators and testers, user engagement services, e-mail distribution and monitoring services, session recording, and the Hub Ownerâ€™s business, legal, financial and compliance advisors) (collectively, Service Providers). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and complementing our Services, and may only use it for such purposes.
The Hub Services allow you to integrate with certain third party services, such as in order to connect your third party account to a certain user or Hub Member profile, in which case you will be bound by the terms and conditions and privacy notices of said third parties (e.g., Google) â€“ so please make sure that you read and accept them in advance. The Hub Owner does not receive or store your passwords for any of these third party services.
The Hub Owner may share your Personal Data with others, with or without notice to you, if it believes in good faith that this will help protect the rights, property or personal safety of the Hub, the Hub Services provided, any Hub Member, Hub Partner or any users or members of the general public.
The Hub Owner may share Personal Data internally between the Hub Partners, for the purposes of providing the networking and mentoring services. In addition, should the Hub, the Hub Owner or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Data may be shared with the parties involved in such event. If the Hub Owner believes that such change in control might materially affect the Personal Data it holds, it will notify you of this event and the options available to you, via e-mail and/or by means of prominent notice on either the Website or the Hub.
11.2. For the avoidance of doubt, the Hub Owner may share your Personal Data in additional manners, pursuant to your explicit approval, or if it is legally obligated to do so, or if it has successfully rendered such data non-personal and anonymous.
11.3. If any of your Personal Data is shared with a third party, as described above, the Hub Owner will take steps to ensure that your Personal Data is handled safely, securely, and in accordance with your rights, the Hub Ownerâ€™s obligations, and the third partyâ€™s obligations under the applicable law.
12. Aggregated and analytical information
12.1. The Hub Owner may use standard analytics tools. The privacy practices of these tools are subject to their own privacy policies, and they may use their own cookies to provide their service.
12.2. The Hub and the Website use the standard analytics tools of Google Analytics and the Hub Owner may use additional or other analytics tools, from time to time. The privacy practices of these tools are subject to their own privacy policies.
12.3. The Hub and the Website use anonymous, statistical or aggregated information and may share it with our partners or Service Providers for legitimate business purposes. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that can be associated with you.
13. How Can I Control My Personal Data?
13.1. In addition to your rights under the Data Protection Legislation, when you submit Personal Data via the Hub or the Website, you may be given options to restrict the HUB Ownerâ€™s use of your Personal Data. In particular, the Hub Owner aims to give you strong controls on its use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from the Hub, which you may do by unsubscribing using the links provided in the emails).
14. Can I Withhold Information?
14.1. You may access certain areas of the Hub and the Website without providing any Personal Data at all. However, to use all features, functions and services available in the Hub or on the Website, you may be required to submit or allow for the collection of certain data.
15. How Can I Access My Personal Data?
15.1. If you want to know what Personal Data the Hub Owner holds about you, you can ask the Hub Owner for details of that Personal Data and for a copy of it (where any such Personal Data is held). This is known as a Subject Access Request.
15.2. All Subject Access Requests should be made in writing and sent to the email or postal addresses shown in clause 18.
15.3. There is not usually any charge for a Subject Access Request, however, if your request is â€˜manifestly unfounded or excessiveâ€™ (for example, if you make repetitive requests) a fee may be charged to cover the Hub Ownerâ€™s administrative costs in responding.
15.4. The Hub Owner will respond to your Subject Access Request within thirty (30) daysâ€™ from the date the request was received by the Hub Owner. The Hub Owner aims to provide a complete response, including a copy of your Personal Data within this period. In some cases, however, particularly if your request is more complex, more time may be required, (up to a maximum of three months from the date of receipt of your request). You will be kept fully informed of the progress of your Subject Access Request.
16. Data Security
16.1. In order to protect the Personal Data held by the Hub Owner and our Service Providers, the Hub Owner uses industry-standard physical, procedural and electronic security measures, including encryption where deemed appropriate. However, please be aware that regardless of any security measures used, the Hub Owner cannot and does not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties.
17.1. The Hub Services, the Website and some of our Service Providers utilize cookies, anonymous identifiers and other tracking technologies (collectively, Tracking Technologies) which help us provide and improve the Hub and Website services, personalize your experience and monitor the performance of our activities and campaigns, as well as the usage of the HUB and the Website as a whole.
18. Contacting the Hub Owner
To contact the Hub Owner with any questions regarding your Personal Data and data protection, including to make a Subject Access Request, please use the following details:
Email address: at firstname.lastname@example.org.
20. Law and Jurisdiction
20.2. In the event of any dispute, the Hub Owner and the Hub Partners would prefer to address any concerns and attempt to resolve them on an informal basis. In the event of any issue, problem, concern or claim, please contact us at: email@example.com.