PRIVACY POLICY (GREENGAGE App)

Welcome to the GREENGAGE App, the Citizen Observer’s app of the EU project GREENGAGE (the “Project”).

This app helps the project to facilitate its so-called Citizen Observatories. The app is used to let interested citizens become Citizen Observers and help them collect environmental data of their surrounding neighbourhoods. This is done by either answering survey questions, measuring air pollution values with ab external mobile device or by letting themselves being tracked and their mode of transport being analysed to gain insights in the current mobility situation in a neighbourhood.

The app is managed and hosted by DigitalSunray and SushiDev, while the personal data regarding sign-up and login is controlled by the University of Deusto (“DEUSTO”) all three partners (“We”, “us”, “our”) to the Project. DEUSTO is the receiver and controller of the Personal Data processed in relation to the login to the app. SushiDev is the controller of the Personal Data processed in relation to the “Track Me” function of the app. All three partners are responsible for compliance with EU Data Protection Law.

The GREENGAGE consortium is responsible for the functionality of the app.

This Privacy Notice describes how we use the Personal Data of users of the app, i.e., individuals signing-up for using/logging into the app to participate in ongoing Citizen Observatories of the Project (“You”, “your”).

1. What Personal Data do We collect about You?

Depending on who You are and on how You engage with us, We collect Personal Data about You, for different reasons and based upon a specific legal basis.

  • Users of the app – When You open the GREENGAGE app for the first time, We

1. Collect information about You during the sign-up process. We collect either your name and e-mail address, or you authenticate via your Google of Apple login. In the latter case We do not collect your name, you just authenticate yourself.

2. Further we ask you to create a GREENGAGE ID where we ask you for the following personal information:

  • Citizen Observatory you will be part of
  • Gender
  • Level of Education
  • Work Status
  • Type of Organisation you represent
  • Social group you see yourself belonging to
  • Age

This GREENGAGE ID and the metadata we ask about is used for a collection of statistical data on the observers for anonymous scientific analyses on the data collected within the Citizen Observatories.

3. When using the “Track me” function of the app (which is invoked by the user, not automatically turned on) the app is collecting your current position and uploading the trajectory data to the servers of SushiDev once you press the “Stop Tracking” button. After upload, the data is further processed and your mode of transportation during your trip is extracted for further scientific analyses within the Citizen Observatory.

2. Why do we need your personal data (purpose of and legal basis for processing your data)

Subject to your voluntary consent,

  • Sushi Dev GmbH, Wiedner Gürtel 28/6, 1040 Vienna, Austria (pirker-ihl@sushi.dev)
  • University of Deusto (“DEUSTO”), Avda. Universidades, 24, Deusto, 48007 Bilbao, Bizkaia. (dpo@deusto.es)
  • VRVis GmbH, Donau-City-Straße 11, 1220 Vienna, Austria (wolosiuk@vrvis.at)

intend to process the categories of personal data listed below for the following purposes:

The overarching GREENGAGE platform, which the GREENGAGE app is part of, collects sociodemographic (which in basic terms means the study of humans) data. We collect the profiles of the Citizen Observers engaged in our project. This information is processed and aggregated anonymously, around categories or groupings, to do with individuals’ backgrounds (known as ‘socioeconomic and demographic’ data). GREENGAGE is committed to values around social inclusion, including everyone of all walks of life and experience. As such, we need to know that we are involving as many different types of people as possible in GREENGAGE-supported Citizen Observatories. This is known as aggregated data (raw data such as your level of formal education) which can be summarised to make sure we include, for example, a variety of age groups, work backgrounds and genders. The project’s “Terms of Use” explain how terms and conditions of using GREENGAGE Engine and data collection. It also refers to relevant data privacy and legal disclaimer documents.

The GREENGAGE App processes the following data (depending on the missions and the users’ input):

  • Username
  • Firstname
  • Lastname
  • Email
  • ID (Keycloak)
  • GPS track information (optional) in form of AIT Mode Binary data (which will be transformed into GeoJSON)
  • Geographical GPS Coordinates (eg. Spots)(optional)
  • Uploaded Images
  • Survey Submissions
  • Avatar
  • Photos
  • Mission related data (user inputs)

Reasons for data collection within the GREENGAGE App:

  • The GREENGAGE app is part of the Horizon Europe GREENGAGE project. The project is about building citizen observatories for GREENGAGE pilot cities. The purpose of citizen observatories is to gather environmental, infrastructure and contextual data that can help pilot cities in decision making or/and policy making. The GREENGAGE app allows to capture the data on pre-defined topics and tasks through surveys. It also allows to track GPS location for use of mobility mode (walking, cycling, motorised etc) through the MODE library.
  • The GREENGAGE app requires a user account and hence email address and names are required. Further, to perform socio-demographic analyses and measure Key Performance Indicators, basic socio-demographic data is collected through KeyCloak and only the KeyCloak ID is shared with the GREENGAGE app.
  • The GREENGAGE app needs the personal data to enable logging in using email address, and display name and avatar for better user experience.
  • Only GREENGAGE ID associated to every Citizen Observatory participant is stored in the centralized store. Personal data is stored in KeyCloak and is fully decoupled from the data stored whilst participants take part in thematic co-explorations.
  • The GREENGAGE app needs your precise location if you decide to let yourself be tracked for mode detection of your chosen type of travel.

According to Art. 6 para. 1 lit. a General Data Protection Regulation (GDPR) your personal data will be processed for this purpose if you give your express consent.

If you have given your express consent your data will also be processed on the legal basis of legitimate interest according to Art. 6 para. 1 lit. f GDPR for the purpose of proving compliance with due diligence obligations such as the guidelines for good scientific practice.

Furthermore, your data may be processed by AIT Austrian Institute of Technology GmbH („AIT“) and the GREENGAGE consortium according to Art. 2d para. 3 Forschungsorganisationsgesetz (FOG) for other scientific research purposes relating to GREENGAGE project if these are not aimed at producing person-related results.

3. Data controller

The following organizations are responsible as joint controllers for processing:

  • Sushi Dev GmbH

Wiedner Gürtel 28/6, 1040 Vienna, Austria, support@sushi.dev, +43 1 934 6339 210The contact details of the Data Protection Officer are:

Wiedner Gürtel 28/6, 1040 Vienna, Austria, pirker-ihl@sushi.dev

  • DEUSTO

24, Universidades Avenue – Bilbao (CP-48007)The contact details of the Data Protection Officer are:

24, Universidades Avenue – Bilbao (CP-48007), Mikel García Llorente, Internal Audit and Control Manager as a Data Protection Officer (DPO),  dpo@deusto.es, +34 94 413 94 30

  •  VRVis GmbH

Donau-City-Straße 11, 1220 Vienna, AustriaThe contact details of the Data Protection Officer are:

Donau-City-Straße 11, 1220 Vienna, Austria, wolosiuk@vrvis.at, +43 1 908 98 92 314

4. Which of your data will be processed (type of personal data)

The following data will be collected and processed:

  • Username
  • Firstname
  • Lastname
  • Email
  • ID (Keycloak) – referred in the project as GREENGAGE ID
  • GPS track information (optional) in form of AIT Mode Binary data (which will be transformed into GeoJSON)
  • Geographical GPS Coordinates (eg. Spots)(optional)
  • Uploaded Images
  • Survey Submissions
  • Avatar
  • Photos
  • Mission related data (user inputs)

5. Data processed in the GREENGAGE App

A user can sign-up to the GREEN ENGINE by creating a log-in on the website https://me.greengage-project.eu/ which allows users to sign-in to the GREENGAGE tools. The GREENGAGE App gathers task and missions’ data and stores them on SushiDev’s servers. For further analysis of the data by the GREENGAGE Citizen Observers, the collected data is then pseudonymised and transferred to a Druid storage (also part of the GREEN Engine platform) which is GREENGAGE project’s central data repository. The data will then be analysed by different tools e.g., textual analytics tools and visualised in Superset (also part of the GREEN Engine platform). The results will be completely anonymous and all the data shared through different repositories will be in anonymised form.

6. Recipients of your personal data

By signing the Declaration of Consent (i.e., ticking the consent box at the bottom of the GREENGAGE sign-up page) you agree that your data processed as part of this study will be disclosed to the following recipients:

  • Consortium Partner Sushi Dev GmbH

Wiedner Gürtel 28/6, 1040 Vienna

Austria

  • Consortium Partner DEUSTO

Universidades, 24, Deusto, 48007 Bilbao, Bizkaia

Spain

  • Consortium Partner VRVis GmbH

Donau-City-Straße 11, 1220 Vienna

Austria

  • Consortium Partner MindEarth

Reitschulstrasse 5, 2502 Biel,

Switzerland

GREENGAGE App API Infrastructure

GREENGAGE’s app back-end infrastructure is hosted on German Servers belonging to DigitalOcean. This includes the following technological components:

  • Database
  • Kubernetes Cluster
  • Filestorage (S3 Buckets) – also part of the CDN from DigitalOcean.

Further information about DigitalOcean can be found under the following url https://www.digitalocean.com/legal

Apache Superset

This tool is hosted at VRVIS’s self-managed computing infrastructure located in Vienna, Austria. Data gathered at GREENGAGE app (anonymized, only providing the GREENGAGE ID associated to a user) may be processed with this tool.

Apache Druid

This tool is hosted at VRVIS’s self-managed computing infrastructure located in Vienna, Austria. This is the tool where data for ulterior processing is stored centrally.

Apache NiFi

This tool is hosted at VRVIS’s self-managed computing infrastructure located in Vienna, Austria. Workflows of data may be generated through this tool, some of its data is coming from GREENGAGE app.

Datahub

This tool is hosted at VRVIS’s self-managed computing infrastructure located in Vienna, Austria. Datasets and visualizations generated in thematic co-explorations are published here.

Data Quality Dashboard

This tool is hosted at VRVIS’s self-managed computing infrastructure located in Vienna, Austria. Data gathered with GREENGAGE app is curated and improved through this tool.

MODE library  

AIT’s MODE library is embedded into the GREENGAGE App and is collecting GPS tracks which are then analysed to detect the mobility mode the person tracking themselves was using. This data is stored on Sushi Dev’s back-end servers located in Germany.

7. Storage period of your personal data

After completion of the GREENGAGE project (December 2025) your personal data will be retained for as long as necessary to provide evidence of compliance with good scientific practice in accordance with the relevant guidelines. Research data must currently [2] be retained for a period of ten years in principle. If this period changes in the future your data will be stored for a correspondingly shorter or longer period.

8. Automated individual decision-making, including profiling

The GREENGAGE tools gather qualitative data provided by the users/Citizen Observers. The App processes data but it does not create an explicit profile of its users.

9. What rights do you have and how can you contact us

Under the corresponding data protection conditions, you are entitled:

  • Request access to your Personal Data. This enables You to receive a copy of the Personal Data We hold about You and to check that We are lawfully Processing it.
  • Request correction of the Personal Data that We hold about You. This enables You to have any incomplete or inaccurate information We hold about You corrected.
  • Request erasure of your Personal Data. This enables You to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where You have exercised your right to object to Processing (see below).
  • Request the restriction of Processing of your Personal Data. This enables You to ask us to suspend the Processing of Personal Data about You, for example if You want us to establish its accuracy or the reason for Processing it.
  • Request the transfer of your Personal Data to another party (right to data portability).
  • Withdraw your consent You can withdraw your consent to not participate further in the data collection of the GREENGAGE project. Your withdrawal will be through https://me.greengage-project.eu. However, the withdrawal of consent does not affect the lawfulness of processing based on the consent before its withdrawal.

To exercise your rights as Data Subject, make queries or complaints, please contact privacy@greengage-project.eu. When You provide your consent to the Processing your Personal Data for a specific purpose, You have the right to withdraw your consent at any time. When We process your Personal Data based on our legitimate interest You have the right to object to such Processing. To object to the Processing, please contact privacy@greengage-project.eu. If You are dissatisfied with any aspect of our handling of your Personal Data, You have the right to make a complaint at any time to the relevant Supervisory Authority.

In cases of suspected violation of the data protection provisions please contact the GREENGAGE coordinator (jan.peters-anders@ait.ac.at). Furthermore, you can contact the Austrian Data Protection Authority (www.dsb.gv.at).

If you require further information about your rights as a GREENGAGE App user itself, or if you have further questions, or wish to exercise your rights or abort your GREENGAGE Citizen Observatory participation, please contact manuel.pirker-ihl@sushi.dev or jan.peters-anders@ait.ac.at .

10. Obligation to provide data

You are not obliged to provide your data, this is voluntary, but in this case the GREENGAGE App cannot be used.

11. Do We Change the purpose of the processing?

We will only use your Personal Data for the purposes for which We collected them, unless We reasonably consider that We need to use them for another reason and this is compatible with the original purpose. If We need to use your Personal Data for an unrelated purpose, We will notify You and We will explain the legal basis that allows us to do so.

12. How do we protect your Personal Data?

Your Personal Data are treated as confidential. We never pass on your contact details to third-parties for commercial purposes. We have put in place appropriate administrative, physical and technical measures. We update and test our security technology on an ongoing basis. We restrict access to your Personal Data to those employees and staff who need to know that information to provide benefits or services to You. In addition, We train our staff about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our staff’ privacy responsibilities.

13. How long do we store your Personal Data?

We store your Personal Data until the end of the Project (expected December 31, 2025). We might delete Personal Data before the end of the Project if We achieve the purpose for which We collected them. When We process your Personal Data based on your consent (e.g., when We analyse the data the Citizen Observers collected), You have the right to withdraw your consent at any time (see section 5 below). In this case, Your Personal Data will be deleted, but not the data you have anonymously collected. However, the withdrawal of consent does not affect the lawfulness of processing based on the consent before its withdrawal.

14. How will we update the Privacy Notice?

We may revise this Privacy Notice from time to time and any revisions will be made available to You via our website.

15. How can You contact us?

If You have any queries concerning the processing of your Personal Data, You may address them by email at privacy@greengage-project.eu.

16. Our Details

AIT Austrian Institute of Technology
Giefinggasse 4
1210 Vienna
Austria

17. Glossary

  • “EU Data Protection Law” means the General Data Protection Regulation 2016/679 (“GDPR“) and the national privacy laws, as amended from time to time.
  • “EU” refers to “European Union”.

18. Related documents

  • GREENGAGE Privacy Policy
  • Cookie Policy
  • Terms of Use
  • Participant Information Sheet
  • Parental Consent Form (EN)