Privacy Policy

TWINVERSE Privacy Policy

1. Who we are

TWINVERSE is funded by European Climate, Infrastructure and Environment Executive Agency (CINEA) under Grant Agreement No. 101270783, with a total budget of 5 988 205.25 euros. The project started on 1 May 2026 and will last for 36 months.

Europe’s cities produce over 70% of global CO₂ emissions and are home to three-quarters of the EU’s population. TWINVERSE is building the infrastructure to help cities meet this challenge with precision, transparency and verifiable data. With 26 partners across 7 European countries, the project brings together research institutions, cities, industry and civil society networks to design AI-enhanced digital twins that help cities achieve climate neutrality.

Over three years, TWINVERSE will deliver a set of tools, methods and models that unlock system-wide change:

• Developing a federated ecosystem of interoperable, AI-enhanced digital twins across six European cities.
• Building modular, explainable AI-powered services addressing urban heat, energy and cooling poverty, sustainable mobility, and winter resilience.
• Creating TWINSENSE, a citizen engagement tool that brings resident input directly into planning decisions.
• Developing the TWINVERSE Data Space Suite, enabling cities to share insights securely while keeping full control of their own data.
• Building open-access resources, training and a policy engagement hub to support replication in cities beyond the consortium.

TWINVERSE is relevant in a global context, where cities everywhere face the same pressures of climate adaptation, resource constraints and citizen expectations. By applying federated data spaces, AI and digital twin technology, TWINVERSE brings European expertise to a wider stage, setting a model for climate-neutral, antifragile urban futures.

Use cases include six mission cities across five countries: Milan (Italy), Cork (Ireland), Kalamata (Greece), Lappeenranta (Finland), Vitoria-Gasteiz (Spain), and Turin (Italy), covering challenges from urban heat and energy poverty to sustainable mobility and winter services. Throughout the project, TWINVERSE engages with city authorities, researchers, technology providers and citizens to ensure results are practical, scalable and ready for real-world use.

The project partners of the TWINVERSE consortium, listed below, process certain types of personal data for the project. Each partner is responsible for the personal data they collect and process during their activities under the framework of the project:

• LINKS Foundation (coordinator), Italy, https://linksfoundation.com/en/
• Politecnico di Milano (POLIMI), Italy, https://www.polimi.it/
• NCSRD, Greece, https://www.demokritos.gr/
• CERTH, Greece, https://www.certh.gr/root.en.aspx
• Fundación CIRCE, Spain, https://www.fcirce.es/en
• Tyndall National Institute, University College Cork (UCC-TYN), Ireland, https://www.ucc.ie/en/
• UIC, Spain, https://www.uic.es/ca
• VUB-FARI, Belgium, https://www.fari.brussels/
• Finnish Meteorological Institute (FMI), Finland, https://www.ilmatieteenlaitos.fi/
• DREVEN, Greece, https://dreven.gr/
• RINA, Italy, https://www.rina.org/en
• Libelium, https://www.libelium.com/libelium-lab/
• RealSim (REAL), Ireland, https://realsim.ie/
• Ingartek, Italy, https://www.ingartek.com/en/
• White Research (WR), Belgium, https://white-research.eu/
• Connect for Europe, Belgium, https://www.connectforeurope.com/
• The Association of Balkan Eco-Innovation, Serbia, https://balkanecoinnovations.org/
• ICONS, Italy, https://www.icons.it/
• Fondazione Piemonte Innova, Italy, https://piemonteinnova.it/
• Cluster de Movilidad y logistica, Spain, https://mlcluster.com/
• Open & Agile Smart Cities & Communities, Belgium, https://oascities.org/
• Municipality of Milan, Italy, https://www.comune.milano.it/
• Cork City Council, Ireland, https://www.corkcity.ie/en/
• Municipality of Kalamata, Greece, https://www.kalamata.gr/en/
• City of Lappeenranta, Finland, https://www.lappeenranta.fi/fi
• Vitoria-Gasteiz (CEA-VIT), Spain, https://cea.vitoria-gasteiz.org/portal/es/
• City of Turin, Italy

For further information, please feel free to reach out: info@twinverse-project.eu

2. How we collect your personal data

We collect personal data both directly and indirectly:

We obtain personal data directly from individuals in a variety of ways, including the following cases:

• an individual subscribes to our newsletter or follows our social media channels;
• an individual registers to attend meetings, workshops, Digital Twin Days and other events we host, and during attendance at such events;
• we establish cooperative relationships with an individual;
• we provide professional services pursuant to our contract with the European Commission;

We obtain personal data indirectly about individuals from a variety of sources, including:

• our research partners;
• our networks and contacts;
• public and open data sources such as public registers, news articles and internet searches;
• social and professional networking sites (e.g. LinkedIn, X).

3. What types of data we collect

We only collect the data necessary for our project’s smooth implementation. These data fall into the following categories:

• contact details (name, surname, e-mail address, phone number);
• professional information (job title, organisation, field of expertise);
• demographics (e.g. age, gender, nationality);
• information about what a person knows or believes, for example through citizen engagement activities such as TWINSENSE;
• videos and photos (from people attending our events, webinars, workshops, etc.).

4. Bases of lawful processing

We process personal data on the following legal bases:

• Legal obligations, for processing activities required for compliance with applicable national and European legislation, as well as with the specific legal and regulatory framework of the European Union.
• Consent, for processing activities such as organisation of meetings, workshops, other events, and dissemination of the project’s results.
• Contractual obligations, for processing activities such as reporting to the European Commission and complying with the project’s publicity obligations.

5. What we do with your personal data

We process your personal data for the purpose of:

• Disseminating our project’s results to different types of stakeholders;
• Sending invitations and providing access to guests attending our meetings, events, webinars and workshops;
• Administering, maintaining, and ensuring the security of our information systems, applications, and website;
• Processing online requests or queries, including responding to communications from individuals;
• Complying with contractual, legal, and regulatory obligations.

6. How we secure your personal data when we process it

We continuously apply a personal data risk assessment process to identify, analyse, and evaluate the security risks that may threaten your personal data. Based on the results of this risk assessment, we define and apply a set of technical and organisational measures to mitigate these security risks, including but not limited to:

• Data Protection Policies to guide personnel involved in the TWINVERSE project when processing your data;
• Written contracts with organisations that process personal data on our behalf;
• Non-Disclosure Agreements with personnel of the TWINVERSE consortium partners;
• Back-up processes, anti-malware protection, access control mechanisms, etc.

Some TWINVERSE partners have appointed a Security, privacy and ethics representative:

DREVEN: Tasos Karakostas; Artemis Lavasa; Marianthi Vetsou

UCC-TYN: Karen Mould

Ingartek: Jose Viteri

NCSRD: Thanasis Sfetsos

CERTH: Sotiris Paraskevopoulos

City of Lappeenranta: Rozabela Singh

Libelium: Juan Francisco Inglés

LINKS Foundation: Claudio Rossi; Benedetta Matcovich

Cluster de Movilidad y logistica: Santiago Cortés

Fondazione Piemonte Innova: Cristina Colucci

Politecnico di Milano: Laura Casone

RINA: Benedetta Barchi

UIC: Anaclara González Basilio

The Association of Balkan-Eco Innovation: Katarina Djokić

City of Kalamata: Vasileios Dionysopoulos

FARI: Valentina Dalla Giovanna

Cork city council: Corina Hanrahan

Connect for Europe: Simon Hughes-King; Rick Vearncombe

7. Do we share personal data with third parties?

Your personal data may be shared with trusted third parties to help us deliver efficient and quality services. When we do so, we ensure that recipients are contractually bound to safeguard the data we entrust to them before we share it. We may engage with several or all of the following categories of recipients:

• Parties that support us in providing our services (e.g., cloud-based software services such as Dropbox, Microsoft Teams, Microsoft SharePoint, Google);
• Our professional advisers, including lawyers, auditors, and insurers;
• Dissemination service providers (e.g., Mailchimp);
• Law enforcement or other government and regulatory agencies, or other third parties as required by and in accordance with applicable law or regulation;
• The European Commission, according to our relevant contractual obligations.

8. Do we transfer your personal data outside the European Economic Area?

We do not own file servers located outside the European Economic Area (EEA). However, some partners may use cloud and/or marketing services from reputable providers such as SharePoint, Dropbox, Mailchimp, Google, etc., situated both inside and outside the EEA. We always check that such providers comply with the relevant GDPR requirements before using their services.

9. Do we use cookies?

Our website, https://www.twinverse-project.eu/, uses cookies. We use cookies to improve site navigation and to analyse our traffic. In the following paragraphs, you will learn what cookies are, which cookies we use, and how you can disable their use.

Cookies are small alphanumeric text files that are transferred from websites you visit to your computer, smartphone, tablet or other electronic device. Cookies assign your device a unique ID, which becomes your identity each time you return to a website. Cookies do not damage your electronic equipment, nor can they read information from other files on your device.

Websites use cookies to remember your actions and preferences, such as language and display settings, for a period of time, so that you do not need to re-enter these preferences on every visit. Cookies also help website owners understand how visitors use their site.

Data protection legislation allows us to store cookies on your device if they are strictly necessary for the operation of our website. For all other types of cookies, we need your consent. You can change or withdraw your consent at any time from the Cookie Settings on our website.

On our website, we use following cookies:

Necessary

Necessary cookies are required to enable the basic features of this site, such as providing secure log-in or adjusting your consent preferences. These cookies do not store any personally identifiable data.

Analytics

Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc.

You can delete cookies and prevent them from being installed through your browser settings; the exact process varies by browser. If you wish to stop sending information to Google Analytics, you can install the Google Analytics Opt-out Browser Add-on.

You may review and change your cookie settings, other than strictly necessary cookies, at any time by clicking Cookie Settings on our website.

10. Your rights

You have the following rights regarding our processing of your personal data:

• Right to withdraw consent, you can withdraw consent previously given for one or more specified purposes. This does not affect the lawfulness of processing carried out before withdrawal.
• Right of access, you can ask us to confirm whether we process personal data about you, and if so, request a copy of that data.
• Right to rectification and erasure, you can ask us to correct inaccurate or incomplete records, or to erase your data once consent is withdrawn or the data is no longer needed for its original purpose.
• Right to restriction of processing, you can ask us to temporarily restrict processing while accuracy is verified, or where you prefer restriction to erasure, or to preserve data for a legal claim.
• Right to data portability, in some circumstances, you can ask us to transmit personal data you have provided to another entity in a structured, commonly used, machine-readable format.
• Right to object, you can object to our use of your personal data for direct marketing, including profiling or automated decision-making. We may retain minimal information, such as an email address, to comply with a request to stop marketing to you.
• Right to complain to your local Data Protection Authority regarding any concerns about our data handling practices.

To exercise any of these rights, contact us at [confirm official project email]. We will examine your request against applicable privacy and data protection law and respond within 30 days of receipt. We may ask for identification, such as a copy of your identity card or passport, to prevent unauthorised disclosure of your personal data. If the complexity or volume of requests prevents a prompt response, we will notify you of the delay within 30 days, which will not exceed two months from the expiry of the initial 30-day period.

11. How long do we retain personal data?

We retain personal data to provide our services, stay in contact with you, and comply with applicable laws, regulations and contractual obligations. We are required to retain data concerning EU-funded projects for up to five years after the end of the project, unless auditors request further retention. After the retention period expires, and absent further legitimate grounds for retention, we will dispose of personal data securely.

12. Disclaimer of liability for third-party websites

Although our site may contain links to third-party sites, including the sites of TWINVERSE consortium partners, we are not responsible for the privacy practices or content of those sites, and we expressly disclaim liability for any loss or damage caused by the use of these links. We do not monitor the privacy practices or content of third-party sites. If you have questions about another site’s privacy practices, please contact that site’s responsible personnel. We recommend reading the privacy policy of each website you interact with.

We may also provide social media features that let you share information on your social networks and interact with TWINVERSE on various platforms. Use of these features may result in the collection or sharing of information about you. We recommend reviewing the privacy policies of the social networking sites you use, to understand what information they may collect, use and disclose.

13. Children

We do not knowingly collect, use or disclose information from children under the age of 16. If we learn that we have collected the personal information of a child under 16, we will take steps to delete it as soon as possible. Please contact us immediately if you become aware that a child under 16 has provided us with personal information.

14. Revisions of this Privacy Policy

We reserve the right to revise this Policy at any time. The current version will always be available on our website, indicating the date it entered into force, so you know when the most recent revision took place. If there are critical changes to this policy, or if our personal data practices change significantly, we will notify you by posting the changes on our website.