Type of Data we collect
When you (the
“User”) access and use the Pathways Platform, the following types of information that can be used to identify you (your
“Personal Data”) are collected and processed:
- Basic User information (e.g. name, contact details, affiliations)
- Communications (e.g. email correspondence)
- Usage Data (defined below)
- Technical Identifiers (such as functional trackers and analytics trackers)
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data and Technical Identifiers, collected automatically when using the Pathways Platform.
Unless specified otherwise, all Personal Data requested by the Pathways Platform is mandatory and failure to provide this data may make it impossible for the Pathways Platform to provide its services. In cases where the Pathways Platform specifically states that some Personal Data is not mandatory, Users are free not to communicate this data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact Sonder Collective.
Any use of Cookies – or of other tracking tools — by the Pathways Platform or by the owners of third-party services used by the Pathways Platform serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy published separately.
Users are responsible for any third-party Personal Data obtained, published or shared through the Pathways Platform.
Mode and place of processing the Data
Methods of processing
Sonder Collective takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated.
Sources of Data
Sonder Collective primarily receives Personal Data from the User directly (e.g. when the User enters personal information into their User account on the Pathways Platform). In some cases, Sonder Collective receives Personal Data from other sources. These are:
- the User’s employer or another organisation that the User is affiliated with (e.g. when the User’s research institute provides some information to Sonder Collective); and
- technical sources (Technical Identifiers collected by the Pathways Platform website).
Recipients of Data
In addition to Sonder Collective, in some cases, the Data may be shared with or otherwise accessible to external parties, such as:
- Sonder Collective collaborators acting as independent contractors;
- Sonder Collective affiliates and partners (e.g. organizations that fund or help us implement our projects);
- third-party technical service providers (e.g. web hosting service providers);
- IT companies (e.g. providers of software used in internal operations);
- external accountants, auditors and advisers (e.g. legal advisers or financial auditors);
- other service providers (e.g. communications agencies and consultants); and
- the User’s organization or research institute, ethical oversight bodies, or public authorities (e.g. in case we notify any misconduct or unlawful activity of the User in accordance with the Pathways Platform Terms of Use).
The above-mentioned parties are acting, as the case may be, as independent Data Controllers, as joint Data Controllers, or as Data Processors for Sonder Collective. Sonder Collective takes appropriate measures to ensure compliance with applicable laws when disclosing Personal Data to any independent Data Controllers or joint Data Controllers, or when engaging Data Processors.
The updated list of these parties as well as appropriate measures to ensure compliance may be requested from Sonder Collective at any time.
Please note that, in order to best serve the purpose and operation of the Pathways Platform, we may in the future hand over the platform, including Users' personal data contained therein, to another administrator. We will notify all Users on the platform or through other means before any transfer occurs.
Data Location and International Data Transfers
The Data is primarily processed on data servers operated or assigned by Sonder Collective. Data is also processed in the physical location of Sonder Collective's operating offices in the European Union and in any other places where the parties involved in the processing are located. Data is also processed by members and collaborators of Sonder Collective, who may be present in any location at the time of the processing.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. Data transfers also involve transferring the User’s Data to a country outside the European Union, for example when data is stored or processed on a data server located in a non-EU location.
Some of Sonder Collective’s Data Processors are located or have their data servers in countries outside the EU. Therefore, Data is transferred to the following countries:
- United States. This country has been designated by the EU Commission as a safe country for the transfer of personal data under the EU-US Data Privacy Framework (DPF). If the transfer is not subject to the DPF, Sonder Collective makes sure transfers are protected by contractual arrangements using the Standard Contractual Clauses (SCC) issued by the European Commission. Should Sonder Collective be unable to take any of these precautions, ultimately user consent will be requested for the transfer.
To find out more about Personal Data transfers, Users may contact Sonder Collective.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. A detailed description of retention times is provided at the end of this document.
The purposes of processing
The Data concerning the User is collected to allow Sonder Collective to provide and improve its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Web analytics
The services contained in this section enable Sonder Collective to monitor and analyse web traffic and can be used to keep track of User behaviour. We use these services to ensure the technical functioning and security of the platform, as well as to improve the usability of the platform.
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable the Pathways Platform to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of the Pathways Platform.
Some services among those listed below, if any, may work through geographically distributed servers. You may read more about data location and international data transfers above.
Infrastructure monitoring
This type of service allows the Pathways Platform to monitor the use and behaviour of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of the Pathways Platform.
Further information about retention times
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between Sonder Collective and the User shall be retained until such contract has been fully performed as well as for a reasonable time thereafter.
- Personal Data collected for the purposes of Sonder Collective’s legitimate interests shall be retained as long as needed to fulfill such purposes as well as for a reasonable time thereafter. Users may find specific information regarding the legitimate interests pursued by Sonder Collective within the relevant sections of this document or by contacting Sonder Collective.
Sonder Collective may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, Sonder Collective may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted or irreversibly anonymized in accordance with the provisions of the GDPR. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
A detailed listing of purpose-specific retention periods is shown at the end of this document.
The rights of Users
Users may exercise certain rights regarding their Data processed by Sonder Collective.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by Sonder Collective, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify Data and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, Sonder Collective will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from Sonder Collective.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority. In Finland, you may contact the Finnish Data Protection Ombudsman at https://www.tietosuoja.fi.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in Sonder Collective or for the purposes of the legitimate interests pursued by Sonder Collective, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know, however, that should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether Sonder Collective is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to Sonder Collective through the contact details provided in this document. Such requests are free of charge and will be answered by Sonder Collective as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by Sonder Collective to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, Sonder Collective will inform them about those recipients.
Additional details about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by Sonder Collective in Court or in the stages leading to possible legal action arising from improper use of the Pathways Platform or the related Services.
The User declares to be aware that Sonder Collective may be required to reveal personal data upon lawful request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, the Pathways Platform may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request. Any such additional information will be brought to the User’s attention clearly and transparently.
System logs and maintenance
For operation and maintenance purposes, the Pathways Platform and any third-party services may collect files that record interaction with the Pathways Platform (System logs) or use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from Sonder Collective at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
Sonder Collective reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within the Pathways Platform and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to Sonder Collective. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, Sonder Collective shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through the Pathways Platform (or third-party services employed in the Pathways Platform), which can include: the IP addresses or domain names of the computers utilised by the Users who use the Pathways Platform, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Pathways Platform) and the details about the path followed within the Pathways Platform with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using the Pathways Platform who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of the Pathways Platform. The Data Controller, unless otherwise specified, is Sonder Collective.
The Pathways Platform
The website and related electronic platform available at
https://projectpathways.org, collectively encompassing the means by which the Personal Data of the User is collected and processed.
Service
The service provided by the Pathways Platform as described in the relative terms (if available) and on this website.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
TrackerTracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.