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Privacy Policy

Welcome to Sustour! We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains what information we collect, how we use it, and what rights you have in relation to it. By using our site (https://www.sustour.com), you agree to the collection and use of your information in accordance with this policy.

 

Description of the SUCCESS project

The international SUSTOUR  project – “Supporting success for all – Universal Design Principles in Digital Learning for students with disabilities” – is funded with the ERASMUS+ Programme agreement number IT02-KA220-HED-000088304 The project is executed between October 2022 and December 2024.

The project delivers web applications (such as a learning platform, a website, and others) mainly for students with disabilities, their teachers, caregivers, and therapists. The project also communicates with such target groups in various ways to achieve its research goals.

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Scope of this Privacy Notice

This Privacy Notice sets out the criteria and the conditions under which the SUCCESS project collects, processes, stores, and transfers your personal data, how the confidentiality of such information is ensured as well as any law and/or regulation implemented or enacted in accordance with the GDPR (General Data Protection Regulation).

 

What Personal Data Do We Process and for what Purpose?

We will be processing the following personal data:

  1. For communicating with you via emails, newsletters, questionnaires, etc.

.Name

.Email address

.Preferred language

  • Role – such as student, teacher, caregiver, therapist, etc.

.Affiliation (school, institution, etc.)

  1. For creating and maintaining your user profile in our web applications

    • The data as above, but also:

.Nickname, username

.Profile picture

  • Learning outcomes and other data you decide to share via our web applications

  • For application maintenance and for security reasons

.Cookies

.IP Address

.Access date & time

  • record (log) of actions taken within applications

Providing the information above is necessary and if you choose not to provide certain information, you may not be able to use certain services or participate in certain activities.

 

Data Controller

The purpose and means of processing your data are determined by six joint data controllers from different European countries. Each data controller defined their contact point.

The joint data controllers and their contact points are the following:

  1. CNA AREA METROPOLITANA DI ROMA , Via Cristoforo Colombo, 283/A, 00147 Rome Italy. Contact email: melis@cnaroma.it

  2. UNIVERSIDAD DE GRANADA, Avda. del Hospicio, s/n C.P. 18010 Granada, Spain. Contact email: reme <reme@ugr.es>

  3. EURICON EPE, 24B Vasilissis Olgas Avenue, 54641 Greece. Contact the data protection officer: email: euricon@otenet.gr 

  4. UNIVERSITA DEGLI STUDI DI ROMA LA SAPIENZA, Piazzale Aldo Moro 5, 00185 Roma, Italy (URoma). Contact email: fernando.martinez@uniroma1.it

  5. Camara Granada, Luis Amador, 26 18014 Granada, Contact  e-mail aroda@camaragranada.org

 

Legal basis

Your personal data will be processed on the basis of:

your consent;

Additionally, we process your personal data on the basis of legitimate interest, which consists of providing users with technical solutions enabling them to use our web applications (based on each user's voluntary decision) and administering and maintaining the applications, which is not overridden by the interests or fundamental rights and freedoms of the user (data subject).

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When and How we Share Personal Data?

Your personal data, when necessary, will be shared with third parties, that are following the same practices and have implemented the security and data protection requirements to ensure the adequate protection of your personal data. Your personal data, when necessary, may be also transferred to a third country but only to third parties that implement suitable safeguards such as approved certification mechanisms or standard data protection clauses.

Due to the nature of the applications being used some data (name and email) may be visible to other users of the applications (e.g. your name and your posts in a forum).

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Personal Data Retention

Your personal data will be processed at least until the evaluation of the project (currently planned for may 2025), or as long as the web application services are provided (presently planned at least one year after the project ends). After this period your data will be anonymized and used only for statistical purposes.

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Security

To ensure the security of your personal data, we have in place the following measures:

  • Minimisation and pseudonymization of personal data we collect;

  • Multi-layers of firewalls to avoid the unauthorised external access;

  • Managing, limiting and controlling access to personal data;

  • Backup and redundancy;

  • Regular testing of the effectiveness of the measures implemented;

  • Safety and encrypted communication channels.

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Your Rights

You have the right to: 

  1. request access to your data;

  2. ask us to rectify information;

  3. withdraw your/parental consent what is not affecting the lawfulness of the processing based on the consent before its withdrawal;

  4. request the deletion of your account and data here.

Those rights can be exercised by contacting any of the contact points listed in section “Data Controller”.

Additionally, you have the right to lodge a complaint with a supervisory authority from any of the countries listed in section “Data Controller”.

 

Privacy notice updates

This privacy notice may be reviewed and updated from time to time – in such case the privacy notice will be labelled as “Revised (date)”. The initial version of this notice was created in May 2021.

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