Last update: September 22 – 2026
1. Data Controller
Comparative Research Network e.V. (CRN) [full street address], Berlin, Germany Registered: [Vereinsregister / VR no.] — non-profit association, established 07/09/2007 E-mail: [privacy contact address] Data Protection Officer: [name and contact, or delete this line if none is appointed]
This website is published within the Erasmus+ KA2 cooperation partnership “Eurbanities Game Based Learning for the Just Transition of Cities” (Justurbanities), grant agreement no. 2024-1-DE02-KA220-ADU-000247930, running from 1 September 2024 to 31 August 2027 and co-funded by the European Union through the German National Agency (DE02 — Nationale Agentur Bildung für Europa beim Bundesinstitut für Berufsbildung).
The consortium comprises seven organisations: CRN (DE, coordinator), Almost There AB (SE), Stowarzyszenie Na Drodze Ekspresji (PL), StadtLABOR Innovationen für urbane Lebensqualität GmbH (AT), Euro-Net (IT), Asociatia pentru Tranzitia Urbana (RO) and E35 Fondazione per la Progettazione Internazionale (IT).
Each partner acts as an independent controller for the personal data it collects in its own local activities — Local Stakeholders’ Panels, workshops, interviews, local events and multiplier events. This policy covers only the processing carried out through this website.
2. Personal data we process
a) Navigation data. Our servers automatically record the IP address, browser type and version, operating system, date and time of the request, pages visited and referring URL.
b) Cookies and similar technologies. See section 6.
c) Document downloads. When you download a project document (handbook, eBook, curriculum, toolkit), our download manager records the file, the date and time, the IP address of the request and, if you are signed in, your user identifier.
d) Registered accounts. The platform offers registration in order to access the interactive learning and gaming areas and the internal discussion space. We process the first name, last name and e-mail address you provide, the standard account data (username, encrypted password, registration date, last login) and any profile information you choose to add.
e) Content you publish. Comments, posts and contributions you make in the platform’s internal discussion space are visible to other registered members, together with the name or username you use.
f) The interactive Stakeholder Map. The platform publishes a map and catalogue of organisations active in urban participation, compiled by the project partners. Entries concern organisations; where an entry includes the name, role or professional contact details of an individual, those data are processed on the basis of our legitimate interest in connecting actors working on urban participation (Art. 6(1)(f) GDPR). Since these data are not collected directly from the individuals concerned, Art. 14 GDPR applies: everyone appearing on the map is informed when their entry is created and may object to being listed or ask for its removal at any time by writing to [e-mail address]. We act on such requests without delay.
g) Videos and other audiovisual material. The project produces short videos presenting the members of the Local Stakeholders’ Panels, published on this website and on the project’s YouTube channel. Anyone appearing in a video has given prior written consent (Art. 6(1)(a) GDPR), collected by the partner organising the recording, and may withdraw that consent at any time; the video is then removed or re-edited.
h) Correspondence. If you write to us by e-mail or through our social media channels, we process your contact details and the content of your message in order to reply.
i) Embedded content. Pages containing videos load content from third-party providers, which may set cookies and process your IP address (section 7).
3. Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Delivering the platform and keeping it secure | Legitimate interest — Art. 6(1)(f) |
| Providing requested documents; creating and managing accounts | Performance of pre-contractual measures / of the relationship — Art. 6(1)(b) |
| Hosting the internal discussion space and publishing user contributions | Performance of the relationship — Art. 6(1)(b) |
| Compiling and publishing the Stakeholder Map | Legitimate interest — Art. 6(1)(f) |
| Publishing videos featuring identifiable individuals | Consent — Art. 6(1)(a) |
| Statistics, analytics and marketing cookies | Consent — Art. 6(1)(a) |
| Measuring dissemination and reporting project results to the European Commission, EACEA and the German National Agency | Legitimate interest and compliance with the grant agreement — Art. 6(1)(f) and 6(1)(c) |
| Replying to your messages | Legitimate interest — Art. 6(1)(f) |
Browsing the site and downloading documents do not require you to accept optional cookies.
4. Retention periods
- Server and security logs: [12] months.
- Visitor statistics (WP Statistics): [12] months, after which records are automatically purged.
- Download logs, including IP address: [12] months, after which they are deleted or anonymised.
- Account data: for as long as the account exists and for [24] months after the last login. Accounts remain available after the project ends, as the platform is maintained as an open educational resource.
- Content published in the discussion space: until you delete it or ask us to.
- Stakeholder Map entries: until the project’s sustainability period ends or the organisation or individual objects.
- Videos: until consent is withdrawn, or until the project’s dissemination material is retired.
- Correspondence: [24] months from the last exchange.
- Consent records (cookie banner): [12] months, then consent is requested again.
- Documentation required for Erasmus+ audit purposes, including aggregated and anonymised dissemination figures: five years from the payment of the balance of the project, which ends on 31 August 2027.
5. Recipients
Personal data are accessible to authorised staff of the Controller and to the following processors appointed under Art. 28 GDPR:
- Euro-Net (Potenza, Italy) — development, technical management and maintenance of the platform and of the interactive map, under the project’s work package 2.
- Netsons S.r.l. (Italy) — web hosting and backups. The website’s data are stored on servers located within the European Union.
Visitor statistics are collected with WP Statistics, a self-hosted tool: the data remain in the website’s own database on the hosting server and are not transmitted to any external analytics provider. No newsletter or e-mail marketing service is currently in use; should one be introduced, this policy will be updated beforehand.
Project partners receive aggregated and anonymised figures, except where a partner is itself the organiser of a local activity and therefore an independent controller for the data of its own participants.
Project results and dissemination data are transmitted to the European Education and Culture Executive Agency (EACEA), to the German National Agency, to the Erasmus+ Project Results Platform and to the EPALE platform, as required by the grant agreement. Data may also be disclosed to auditors carrying out controls on the funded project.
6. Cookies
On first visit a banner lets you accept, refuse or select the categories of cookies:
- Functional — always active, technically necessary (session, security, storage of your consent choice). No consent required.
- Preferences — remember your settings, such as language.
- Statistics — measure visits and behaviour in anonymised or aggregated form. These statistics are produced by WP Statistics, which runs on our own server; IP addresses are anonymised or hashed before being stored and are never shared with third parties.
- Marketing — set by third parties to build interest profiles and serve targeted advertising.
Non-necessary cookies are set only after you give consent. You may change or withdraw your choice at any time via the “Manage consent” link, and delete cookies through your browser settings. Withdrawal does not affect the lawfulness of processing carried out beforehand.
7. Third-party services and transfers outside the EU
This website includes content from, or links to:
- YouTube (Google Ireland Ltd. / Google LLC) — the project’s video channel and embedded videos;
- Facebook and Instagram (Meta Platforms Ireland Ltd.) and LinkedIn (LinkedIn Ireland Unlimited Company) — project profiles and embedded content;
- [Map or podcast provider, if third-party — specify].
Website statistics do not involve any third-party provider (see section 5).
These providers are independent controllers for the data they collect and may transfer data to the United States, on the basis of the European Commission adequacy decision for the EU–US Data Privacy Framework and/or Standard Contractual Clauses, with appropriate supplementary safeguards. Please consult their own privacy policies.
8. Your rights
Under Arts. 15–22 GDPR you may request access to your personal data, rectification, erasure, restriction of processing and portability, and you may object to processing based on legitimate interest — including being listed on the Stakeholder Map. Where processing rests on consent, you may withdraw it at any time.
Requests go to [e-mail address]; we reply within one month.
You may also lodge a complaint with a supervisory authority, in particular the Berliner Beauftragte für Datenschutz und Informationsfreiheit (competent for the Controller) or the authority of your country of residence.
9. Automated decision-making
No profiling or automated decision-making within the meaning of Art. 22 GDPR is carried out through this website. The educational game does not evaluate players for any purpose outside the game itself.
10. Changes
This policy may be updated to reflect changes to the platform or to applicable law. The date at the top always indicates the current version.