Inclusive Camino de Santiago

Welcome to the web application and online training platform of the Inclusive Camino de Santiago (InCASA) project. We are dedicated to improving accessibility and participation in the Camino de Santiago pilgrimage for young people with disabilities

At InCASA we care about privacy and transparency. In addition, we undertake to process your data in compliance with current Data Protection regulations:

Regulation (EU) 2016/679 of 27 April 2016 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPDPGDD).

Below, we indicate in detail the processing of personal data that we carry out, as well as all the information related to them.

Who is responsible for the processing of your data?

Corporate name: Fundación Benéfica Docete Omnes

CIF: G18020917

Address: Calle Padre Villoslada 2, 18140, la Zubia, Granada, Spain

Telephone: +34 958 590 002

Email: fundacion@doceteomnes.com

In addition, the rest of the partners that make up the InCASA project are detailed below: Spain (Clictic S.L.), Romania (Offensive Tinerilor Asociatia), Portugal (EIA – Ensino e Investigação e Administração SA), Slovenia (RUSAALKA, Zavod za Kulturne Dejavnosti) and Poland (Viva Femina).

Contact details of the Data Protection Officer (DPO):

Grupo Altabir (Formacont SL), with CIF B18955195

C/ Luis Amador 26, Centro de Negocios Cámara de Comercio de Granada, P.0 – Of.B, Spain

Email: dpo@altabir.es

Some terms to keep in mind

This Privacy Policy applies to the project “Inclusive Camino de Santiago: An accessible journey for all” (InCASA). This project includes an accessible web application (“Compass Web App”) and a free online training platform (“Journey Blueprint & Chronicles“) designed to empower young people with disabilities, their caregivers and youth workers to participate in the Camino de Santiago pilgrimage. It aims to provide essential resources, training, and support for a meaningful pilgrimage experience.

“Personal Information,” “Personal Data,” or “Identified or Identifiable Person Information” means any information that relates to an identified or identifiable natural person. This may include direct identifiers (such as your name) and indirect identifiers (such as your IP address), as well as information about your opinions, experiences, or sensitive characteristics, such as disability.

What personal data do we collect and use?

The InCASA project collects and processes the personal information necessary to achieve its goals of providing an accessible learning platform and pilgrimage experience. The personal information we collect includes:

Your name and contact details, such as your full name and email address, mainly for account creation and communication.
Communication Records: If you communicate with us, we may keep records of such communication.
Information Provided Through Forms: When you use our online forms, we collect information such as your first name, last name, and email address. Fields marked with an asterisk are required, as this information is necessary to complete your application or provide access to services. All other information you share through these forms is at your discretion.
Information related to accessibility needs (special category data): In order to tailor the web application and training platform to your specific requirements and ensure an inclusive experience, we may collect information about your disability or specific accessibility needs (e.g., wheelchair user, visual impairment, specific learning accommodations). This is considered “special category data” under the GDPR and requires explicit consent for processing.
Learning Progress Data: Information related to your progress on the “Journey Blueprint & Chronicles” training platform, including courses completed, quizzes taken, and participation in learning resources.
User-generated content (Crowdsourcing): The “Compass Web App” includes a crowdsourcing section where users can share their experiences, tips, recommendations or feelings about the routes of the Camino de Santiago. This content, once submitted, may be publicly visible to other users of the application.
Usage/Analytics Data: Information about your visits to the web application and training platform, including but not limited to your IP address, browser used, device type, location (general region), page entries, and other communications and data sources accessed. This data helps us improve the user experience and the performance of the platform.
Documentary Participation Data: As part of the project, a documentary entitled “The Inclusive Way: A New History of the Camino de Santiago” will be produced, which will capture the experiences and learnings of the Learning, Teaching and Training Activities (LTTA). This can include video footage, photographs, personal stories, notes, and participant comments.

For what purpose do we process your personal data?

The InCASA project collects and processes your personal information for the following specific purposes:

To provide platform services: To create and manage your user account on the “Compass Web App” and the “Journey Blueprint & Chronicles” training platform, and to provide you with access to all available resources and functionality.
To personalise your experience: To tailor the web application and training platform content, information about routes, accommodations, and services to your specific accessibility needs and preferences.
To facilitate learning and training: Deliver training courses and resources for caregivers, youth workers, and organisational staff, covering topics such as planning activities, identifying accessibility challenges, and tailoring activities to individual needs.
To enable user interaction and community building: To allow users to share experiences, tips, and recommendations through the crowdsourcing section of the web app, fostering a sense of community and a shared journey.
For project evaluation and improvement: Conduct statistical and analytical studies and research to improve the content, features, and overall effectiveness of the web application and training platform. This includes monitoring participation rates and assessing the impact of training activities.
For dissemination and awareness: Produce and share the documentary “The Inclusive Way: A New History of the Camino de Santiago”, which captures the journey and impact of the project, raising awareness about inclusion and accessibility in outdoor cultural activities.
To promote security and compliance: To promote the safety and security of people, facilities, systems, and data, ensure compliance with internal policies and procedures, manage communications, investigate and manage incidents and complaints, and comply with legal obligations, including cooperation with law enforcement or regulatory investigations.

What is the legitimacy for the processing of your data?

The GDPR requires us to have a valid legal basis for processing your personal data. Our legal bases for processing your personal information are as follows:

Contractual necessity (GDPR Art. 6(1)(b): The processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract. This applies to data necessary to provide you with access to the web application and the functionalities of the training platform, manage your account and provide the main services of the project.
Explicit consent (GDPR arts. 6.1.a and 9.2.a): For the processing of data of special categories, such as information about your disability or accessibility needs, we rely on your explicit consent. This consent will be obtained in a clear and separate form at the time of collection, informing you precisely how this sensitive data will be used to personalise your experience. Your explicit consent is also required for your participation in the documentary “The Inclusive Way: A New History of the Camino de Santiago”, including the use of your images, videos and personal stories for public dissemination. You have the right to withdraw your consent at any time (see Section 9).
Legitimate interests (GDPR art. 6.1.f): We may process certain personal information based on our legitimate interests in the development and improvement of the InCASA project, provided that these interests do not override your fundamental rights and freedoms. This may include:
- Conduct statistical analysis and research to improve the platform’s content and user experience.
- Promote the security of our systems and manage internal communications and systems.
- Disseminate the results of the project and raise awareness of inclusion in outdoor activities in general, where individual privacy is respected (e.g. aggregated or anonymised data, or with the specific consent of identifiable persons).
Legal obligation (GDPR art. 6.1.c): We may process your personal information where it is necessary to comply with a legal obligation that applies to us (e.g. responding to legal requests from authorities, keeping records for audit purposes of the Erasmus+ Programme).

Do you have to provide us with the personal information we have requested?

While you are not required to provide us with all personal information, certain data is necessary to fully access and use the Compass Web App and the Journey Blueprint & Chronicles training platform. If you do not provide the required information (e.g., name, email for account creation, or explicit consent to the processing of disability-related data if you wish to receive personalised accessible features), we may not be able to provide you with access to certain content or services.

How long do we keep your data? (Data Retention)

The InCASA Project will keep your personal information for a maximum period of 5 years from your last interaction or the last activity registered with our platforms. This retention period is aligned with the requirements of European projects such as Erasmus+. After this period, your personal information will be securely deleted or anonymised, unless a longer retention period is required or permitted by law.

Do we disclose the information to third parties? (Transfer of data)

Yes, in order to achieve the objectives of the project, we communicate your information to specific third parties in the following circumstances.

To the members of the InCASA Project Consortium: Your information may be shared among the project partners: Fundación Docete Omnes (Spain, Coordinator), Offensive Tinerilor Asociatia (Romania), EIA – Ensino e Investigação e Administração SA (Portugal), RUSAALKA, Zavod za Kulturne Dejavnosti (Slovenia), Clictic S.L. (Spain) and Viva Femina (Poland). Different partners perform different functions (e.g., Clictic for web application development, Rusaalka for documentaries, FDO for platform hosting and maintenance, OT for quality management, EIA for dissemination) and, as a result, your information may be shared with them for specific and defined purposes described in this Policy. These partners are bound by contractual agreements to protect your data in accordance with GDPR standards.
Associate partners: The project also has associate partners (e.g. ONCE Foundation, FEGRADI, Andalusian Youth Institute (IAJ), CPEEE Jean Piaget). If it is necessary to share personal data with them, it will be done under strict data processing agreements and only for the purposes explicitly set out in such agreements.
Service Providers: We may use third-party service providers (data processors) to help us operate our web application and training platform, such as hosting providers (e.g., FDO’s virtual private server), analytics providers, or communication tools (e.g., Microsoft Office 365 OneDrive for collaboration). These service providers only process your personal information on our behalf and under our instructions, and are contractually obliged to protect your data in accordance with the GDPR.
Legal and regulatory bodies: We will share information with public authorities, regulators, law enforcement and other bodies where we are legally obliged, authorised or deemed necessary to do so (e.g. for audits of Erasmus+ projects or in response to legal requests).

Do we disclose personal data outside the European Union (EU) / European Economic Area (EEA)?

All the project partners are located within the European Union (Spain, Romania, Portugal, Slovenia, Poland). Therefore, personal information is primarily processed within the EU/EEA.

If, in unforeseen circumstances, data transfers to countries outside the EU/EEA become necessary (e.g. if a service provider uses servers outside the EU/EEA), we will ensure that appropriate safeguards are in place as required by the GDPR. This usually involves relying on:

Adequacy decisions: Transfers to countries that the European Commission considers to offer an adequate level of data protection.
Standard Contractual Clauses (SCCs): Contractual clauses approved by the European Commission that provide adequate safeguards for data transfers.
Binding Corporate Rules (BCRs): For intra-group transfers within multinational corporations.

We will explicitly inform you if such international transfers occur and the safeguards on which it is based.

What are your rights when you provide us with your data?

Any person has the right to obtain confirmation as to whether or not InCASA is processing personal data concerning them.

Data subjects have the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, to request its deletion when, among other reasons, the data is no longer necessary for the purposes for which they were collected. You also have the right to data portability.

In certain circumstances, the interested parties may request the limitation of the processing of their data, in which case we will only keep them for the exercise or defense of claims.

In certain circumstances and for reasons related to their particular situation, data subjects may object to the processing of their data. In this case, InCASA will stop processing the data, except for compelling legitimate reasons, or the exercise or defence of possible claims.

You may exercise your rights in the following way: by going to dpo@altabir.es or C/ Luis Amador 26, Centro de Negocios Cámara de Comercio de Granada, P. 0 – Of. B., Spain.

When commercial communications are sent using the legitimate interest of the controller as a legal basis, the interested party may object to the processing of their data for this purpose.

If you have given your consent for a specific purpose, you have the right to withdraw the consent given at any time, without affecting the lawfulness of the processing based on consent prior to its withdrawal.

In the event that you feel that your rights regarding the protection of your personal data have been violated, especially when you have not obtained satisfaction in the exercise of your rights, you can file a complaint with the competent Data Protection Supervisory Authority through its website: www.aepd.es.

What happens to data security when using InCASA’s platforms?

We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of processing your personal data. This includes:

Secure infrastructure: The “Compass Web App” and the training platform “Journey Blueprint & Chronicles” are hosted on a Virtual Private Server (VPS) maintained by Docete Omnes Foundation, which guarantees a controlled and secure environment.
User Account Security: You are responsible for keeping your login details to your profile secure, specifically your chosen password. These login credentials are for your use only and should not be shared with any other person.
Data Protection Measures: We implement measures to protect against unauthorised access, alteration, disclosure, or destruction of your personal data, including pseudonymisation, data minimisation, and access controls.

How do we handle changes to this policy?

The terms of this Privacy Policy may change from time to time to reflect changes in our data processing practices or legal requirements. We will post any relevant changes through the relevant notices on the project website and/or by contacting you through appropriate channels (e.g. email), where required by law.