Privacy Policy

In accordance with the Regulation (EU) 2016/679, General Data Protection Regulation, in this Privacy Policy we inform you about:

Who is responsible for your data processing
Partners of the UPSURGE Consortium who have access to those data:

  • E-ZAVOD, ZAVOD ZA PROJEKTNO SVETOVANJE, RAZISKOVANJE IN RAZVOJ CELOVITIH REŠITEV (E-Institute, Institute for Comprehensive Development Solutions)

What data we collect
The identifying data of users and visitors of the Website who wish to contact with UPSURGE consortium are collected through the contact form (name, email address).
Some data are collected through cookies only to perform specific functions for the user. Such data is encrypted in a way that prevents access to it by unauthorized persons. More information about cookies policy below.

Purpose of the data collection
The data are collected for the purposes related to the UPSURGE project as listed below:

  • Respond to requests for information sent to us through the means of contact available.
  • Inform about news and events that may be of interest to you through communications and/or newsletters, provided that you give your consent to do so.
  • Comply with GDPR’s Article 6: lawfulness of processing.
  • Redesign and/or modify the functionality of the Website / services.
  • Perform statistical analysis.

How long will we keep your data?
The personal data provided will be retained no longer then for duration of the project and 5 years after the project completion (to 2030) or for the years necessary to comply with legal obligations.

How and where information is shared
The personal data you provide when completing the forms are incorporated into our database that is stored at E-zavod and are only used to process your requests and/or send you information about our services if you have requested it. Data can be processed by UPSURGE project partners, but only on prior written consent between E-zavod (data controller) and project partner who needs to process personal data.
Google Analytics: a web analytics service provided by Google, Inc. We use cookies, which are text files placed on your computer, to help analyse how users use the website. (See our cookie policy, see Privacy Policy Google Analytics below.

Security of your data
UPSURGE project attaches great importance to the security of all personally identifiable information of our users. However, it cannot guarantee the absolute impregnability of the Internet.
Our Website may contain links to and from other websites. If you access these pages, please note that you may be asked to provide personal data or information on these pages. We, therefore, recommend that when you visit these sites, you review their privacy policies and legal notices.

Rights and access to information
In accordance with current legislation, you may have the following rights:

  • Right of access to the information we hold about your personal data.
  • Right of rectification of your data, by which we will update and update the information and data we have according to the information you provide us.
  • Right to the portability of your data.
  • Right to erase your data.
  • Right to object to our processing your personal data.
  • Right to file a complaint with the UPSURGE project and/or the competent Data Protection Control Authority.

At any time, you can ask us, completely free of charge, either by letter or by e-mail, to exercise your rights, and if so you must include in your application a photocopy of your National Identity Document/Passport, as this is a very personal right. You have a possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

Your request should be sent to our GDPR Officer at the following address:
UPSURGE project
e-mail: and

Changes to the Privacy Policy
UPSURGE project reserves the right to modify this Privacy Policy to adapt it to new legislation or case law. We recommend that you visit it every time you browse the Website, in order to be always informed in advance of any information you may provide us with.


Information on Cookies, pursuant to Articles 13 and 122 of Leg. Dec. 196/2003 (“Privacy Law”), Article 2, Directive 2009/136/CE , Article 13 of the GDPR, and General Measures of the Italian Data Protection Authority of 8 May 2014.

What is a cookie?

Cookies are information placed on your browser when you visit a website or use a social network with your PC, Smartphone or tablet. Each cookie contains various data such as, for example, the name of the server from which it comes, a numeric identifier, etc. Cookies can remain in the system for the duration of a session (that is, until you close the browser used for web browsing) or for long periods and may contain a unique identifier. Cookies are sent from a webserver to the user’s browser and stored on his/her computer.

Types of cookies

The Upsurge website uses 2 types of Cookies:

Technical Cookies: essential for the correct functioning of the website and to provide the service offered and requested by a user.

Third-party Cookies: visiting Upsurge Website you may receive cookies from sites managed by other organizations (“Third Party”) that can reside in Italy or abroad. They are cookies related to:

Monitoring Website’s visits: To analyse use of the site we employ Google Analytics, a web service provided by Google, Inc. (“Google”). As stated by the General Measures of the Data Protection on cookies of 8 May 2014, analytics cookies are assimilated to technical cookies used to collect information on the number of users and how they visit the website. The information generated by the cookie about your use of the website (including your IP address) will be stored by Google on servers in the United States. Google (independent data controller) will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out by Google Privacy Policy. However, Google offers tools that can make the IPs anonymous. Please, check Google cookie policy for Google Analytics at and learn more about how Google – third party – manages data of their users in Google Support.

Social Network: UPSURGE website uses social plugins (“plugins”) provided by the social network Facebook, Twitter, Linkedin and Instagram. The presence of these plugins, involves the transmission of cookies to and from all sites operated by third parties. The management of the information collected by “third parties” shall be governed by the relevant information which please refer.

Listed here below the links to cookie policies of the main social networks:

Data Management

Data are managed by OpenContent by means of automatic tools. Data is not divulged or disseminated.

Data supply

Technical cookies apart, data supply is responsibility of website user, which is informed and is compliance with the Cookies policy, including the usage of third-party services.

Denial of consent

It is possible to allow or block cookies on your PC, however, this website works best when all types of cookies are allowed. The cookie settings can be controlled and modified from your browser’s “Preferences”. Select the browser you use below for information on how to modify cookie settings.

  • Chrome
  • Firefox
  • Internet Explorer
  • Opera
  • Safari

If you wish to block the installation of cookies generated by our site it is necessary to personalize the settings of your PC or other device by blocking all the cookies, where permitted, or by activating a warning message when cookies are stored.

Visit the site for further information on cookies and on how they affect your navigation experience. It is important to remember that disabling cookies can stop you using some, if not all, of the functions or sections of a website.

Rights of the data subject

Data subject can in any moment make use of their rights as in Article 7, Leg. Dec. 196/2003. Specifically:

  • Right to information: this right provides the data subject with the ability to ask a company for information about what personal data (about him or her) is being processed and the rationale for such processing. For example, a customer may ask for the list of processors with whom his or her personal data is shared.
  • Right to access: this right provides the data subject with the ability to get access to his or her personal data that is being processed. This request provides the right for data subjects to see or view their own personal data, as well as to request copies of the personal data.
  • Right to rectification: this right provides the data subject with the ability to ask for modifications to his or her personal data in case the data subject believes that this personal data is not up to date or accurate.
  • Right to withdraw consent: this right provides the data subject with the ability to withdraw a previously given consent for processing of their personal data for a purpose. The request would then require the company to stop the processing of the personal data that was based on the consent provided earlier.
  • Right to object: this right provides the data subject with the ability to object to the processing of their personal data. Normally, this would be the same as the right to withdraw consent, if consent was appropriately requested and no processing other than legitimate purposes is being conducted. However, a specific scenario would be when a customer asks that his or her personal data should not be processed for certain purposes while a legal dispute is ongoing in court.
  • Right to object to automated processing: this right provides the data subject with the ability to object to a decision based on automated processing. Using this right, a customer may ask for his or her request (for instance, a loan request) to be reviewed manually, because he or she believes that automated processing of his or her loan may not consider the unique situation of the customer.
  • Right to be forgotten: also known as right to erasure, this right provides the data subject with the ability to ask for the deletion of their data. This will generally apply to situations where a customer relationship has ended. It is important to note that this is not an absolute right, and depends on your retention schedule and retention period in line with other applicable laws.
  • Right for data portability: this right provides the data subject with the ability to ask for transfer of his or her personal data. As part of such request, the data subject may ask for his or her personal data to be provided back (to him or her) or transferred to another controller. When doing so, the personal data must be provided or transferred in a machine-readable electronic format.