Privacy Policy
Information on the processing of personal data of users of the INTERCLUSTER Questionnaire, pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR)
Last updated: 29 September 2026
1. About this notice
This notice explains how personal data are processed when you use the INTERCLUSTER Questionnaire available at https://intercluster.interreg-ipa-adrion.eu (the "Questionnaire"). The Questionnaire is part of the project INTERCLUSTER – "Promoting Interregional logistic clustering in Adrion Area" (project ID IPA-ADRION00290), co-funded by the European Union through the Interreg VI-B IPA ADRION Programme 2021-2027.
The Questionnaire collects information from stakeholders of the logistics sector in the Adriatic-Ionian area (public authorities, logistics companies, research institutions, business support organisations and NGOs) in order to define the initial composition of the ADRION macro-regional logistics cluster and its national/regional clusters, to understand stakeholders' views on logistics in their cluster and on the future of logistics services and technologies, and to share the results with participants.
The protection of personal data is governed by the GDPR and, for Italy, by Legislative Decree 196/2003 (Italian Privacy Code) as amended. This notice does not cover other websites, pages or services reachable through links, including the website of the Interreg IPA ADRION Programme, which has its own privacy policy.
2. Data Controller
The Data Controller is Aeroporti di Puglia S.p.A., Viale Enzo Ferrari, 70128 Bari, Italy, project partner of INTERCLUSTER responsible for the Questionnaire and the e-networking platform (the "Controller").
Contact for privacy matters: ipa-adrion@regione.emilia-romagna.it.
Data Protection Officer (DPO): dpo@aeroportidipuglia.it.
3. Categories of personal data processed
The Questionnaire is addressed to organisations. Most answers concern your organisation and not you personally. However, the following personal data may be processed:
- Contact data of the person filling in the Questionnaire (the "compiler"): username and e-mail address. Where the Questionnaire offers an anonymous option, these data are not collected.
- Organisation data: name of the organisation, stakeholder group (e.g. public authority, logistics operator, research institution, business support organisation, NGO), country. These are not personal data unless they refer to an identifiable individual (e.g. a sole trader).
- Questionnaire answers: your views on logistics in your cluster, on the future of logistics services and technologies and on possible cooperation topics, together with the date and time of submission.
- Account data (only if you request registration or log in): username, name, e-mail address, organisation, registration status and login history, managed through the platform's authentication service.
- Technical and browsing data: IP address, browser and device information, date and time of requests, pages requested and server responses. These data are generated automatically by the functioning of the website and are also used to protect the service (for example, to limit repeated submissions from the same network).
Please do not include in free-text answers special categories of data (e.g. health, political opinions, trade union membership) or personal data of third parties.
4. Source of the data
Data are provided directly by you when you fill in the Questionnaire or request registration. If you were invited to the Questionnaire by a project partner, your business contact details (name, e-mail, organisation) may have been obtained from the partner's professional contacts, from mailing lists of potential cluster members compiled within the project, or from publicly available sources such as organisation websites and business registers.
5. Purposes and legal bases of the processing
| Purpose | Legal basis (GDPR) |
|---|---|
| Collecting and analysing the answers to identify stakeholders, needs and cooperation areas and to define the initial composition of the ADRION macro-regional logistics cluster and its clusters | Art. 6(1)(e) – performance of a task carried out in the public interest, i.e. implementation of the INTERCLUSTER project co-funded under the Interreg IPA ADRION Programme |
| Contacting you about your answers, inviting your organisation to join the cluster and its activities, and sharing the results of the Questionnaire | Art. 6(1)(e) or 6(1)(f) as above |
| Preparing aggregated or anonymised statistics, reports and project deliverables (e.g. the cluster strategy and action plan) | Art. 6(1)(e) or 6(1)(f) as above |
| Managing registration requests, user accounts and authentication | Art. 6(1)(b) – performance of the Terms of Service you accept when registering |
| Ensuring the security of the service, preventing abuse and fraud, rate limiting | Art. 6(1)(f) – legitimate interest in protecting the service |
| Complying with EU funding rules on monitoring, controls, audits and document retention | Art. 6(1)(c) – legal obligation under Regulation (EU) 2021/1060 and Regulation (EU) 2021/1059 |
| Establishing, exercising or defending legal claims | Art. 6(1)(f) – legitimate interest |
Providing the data marked as mandatory is necessary to submit the Questionnaire or to register; if they are not provided, submission or registration will not be possible. All other data are optional. Personal data are not re-used for purposes different from those stated above.
6. Recipients of the data
Personal data are accessed only by authorised staff and may be shared with:
- INTERCLUSTER project partners, for the composition and activation of the clusters in their countries and for the analysis of the results: Chamber of Preveza (Lead Partner, Greece), Aristotle University of Thessaloniki (Greece), Chamber of Commerce and Industry of Serbia (Serbia), Ministry of Agriculture and Rural Development (Albania), Centre for Competitive Skills (Albania), University of Mostar (Bosnia and Herzegovina), Foreign Trade Chamber of Bosnia and Herzegovina (Bosnia and Herzegovina), Slovenian Logistics Association (Slovenia), Institute for Sustainable Development (Slovenia), CNA – National Confederation of Crafts and SMEs, Bari (Italy) and Aeroporti di Puglia S.p.A. (Italy). Partners act as independent controllers.
- Service providers acting as processors under Art. 28 GDPR, which develop, host and maintain the platform: Cargo Start S.r.l., Rome, Italy – software development and maintenance; ILP Consulting – hosting and infrastructure.
- Programme and control bodies, only where required for monitoring, verification and audit: the Managing Authority (Emilia-Romagna Region), the Joint Secretariat, controllers, auditors and evaluators appointed by the Programme, the European Commission and other EU bodies competent for the protection of the EU financial interests.
- Public authorities, where required by law.
Results are published or shared with participants only in aggregated form that does not allow individual respondents to be identified, unless you have agreed otherwise.
7. Transfers outside the European Economic Area
Some project partners are established in Albania, Bosnia and Herzegovina and Serbia, which are outside the European Economic Area. Where personal data are transferred to these partners, the transfer is covered by appropriate safeguards pursuant to Article 46 GDPR, such as the Standard Contractual Clauses adopted by the European Commission, so that the protection travels with the data. You can obtain information on these safeguards by contacting the Controller.
8. Retention period
- Questionnaire data and contact data: kept for the duration of the project (planned end: 31 August 2027) and afterwards for the retention period required by Article 82 of Regulation (EU) 2021/1060 (five years from 31 December of the year in which the last payment to the partner is made). They are then deleted or irreversibly anonymised. Aggregated and anonymised results may be kept without time limits.
- Account data: kept as long as the account is active and deleted within 12 months of your request for deletion or of the end of the project, unless they must be kept longer for the reasons above.
- Technical and browsing data: kept for no longer than seven days, except for security logs, which are kept for up to 90 days or longer where needed to investigate an incident.
- Data processed on the basis of consent: until consent is withdrawn.
If your organisation joins the cluster, the data needed for its operation will be processed according to the privacy notice provided at that time.
9. Security
The Controller and its processors adopt appropriate technical and organisational measures to protect personal data, including encrypted connections (HTTPS), authentication through a dedicated identity service, role-based access limited to authorised staff, logging, data minimisation and publication of results only in aggregated form. Data are stored on servers located in the European Union.
10. Automated decision-making
No decisions based solely on automated processing, including profiling, are taken on the basis of your data.
11. Your rights
Under Articles 15-22 GDPR you have the right to access your personal data, to obtain their rectification or erasure, to restrict their processing, to receive them in a portable format (where applicable) and to object to processing based on Article 6(1)(e) or (f). Where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.
To exercise your rights, write to ipa-adrion@regione.emilia-romagna.it or to the DPO. We will reply within one month, which may be extended in the cases provided for by the GDPR.
If you believe that the processing of your data infringes the GDPR, you have the right to lodge a complaint with the Italian supervisory authority, the Garante per la protezione dei dati personali (www.garanteprivacy.it), or with the supervisory authority of the EU Member State where you live or work, and to bring legal proceedings under Articles 77-79 GDPR.
12. Changes to this notice
This notice may be updated, for example following changes to the Questionnaire or to the applicable rules. The current version is always available on this page, with the date of the last update.