NUNSYS GROUP
LDT COMMONS
PROTECTION OF YOUR PERSONAL DATA
This privacy statement provides information about the processing and the protection of your personal data.
Processing operation: LDT Commons community platform, including electronic newsletters and diffusion of information relating to the LDT Commons initiative (updates, events, invitations to participate,publications and community activities).
Data Controller: Nunsys Group, S.A., with registered address at Calle Gustave Eiffel 3, Parque Tecnológico de Paterna, 46980 Valencia, Spain.
Data Processor: Sendinblue SAS (Brevo), with legal address at 106 boulevard Haussmann, 75008 Paris, France. Brevo acts as data processor for the management and delivery of electronic
communications on behalf of Nunsys Group.
Table of contents
1. Introduction
2. Why and how do we process your personal data?
3. On what legal ground(s) do we process your personal data?
4. Which personal data do we collect and further process?
5. How long do we keep your personal data?
6. How do we protect and safeguard your personal data?
7. Who has access to your personal data and to whom is it disclosed?
8. What are your rights and how can you exercise them?
9. Contact information
10. Where to find more detailed information?
1. Introduction
Nunsys Group, S.A. (hereinafter ‘Nunsys’) is committed to protecting your personal data and respecting your privacy. Nunsys collects and processes personal data in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, hereinafter ‘GDPR’), and with Spanish Organic Law 3/2018 of 5 December on theProtection of Personal Data and the Guarantee of Digital Rights (LOPDGDD).
This privacy statement explains the reason for the processing of your personal data, the way we collect,handle and ensure protection of all personal data provided, how that information is used and what rights you have in relation to your personal data. It also specifies the contact details of the Data Controller and the Data Protection Officer with whom you may exercise your rights.
The information below relates to the processing operation ‘LDT Commons’ — including electronic newsletters and diffusion of information relating to LDT Commons initiative updates, events, invitations and publications — undertaken by Nunsys Group.
2. Why and how do we process your personal data?
Purpose of the processing operation: Nunsys Group collects and uses your personal information to send you electronic newsletters and to share information relating to LDT Commons events, community activities, invitations to participate in initiatives, and publications.
What is LDT Commons?
LDT Commons is an open, inclusive and neutral community of practice that supports the uptake of Local Digital Twins across Europe. It connects cities, regions, Member States, innovators, academic actors and national frameworks around a common open-source technical foundation. LDT Commons is an initiative led by Nunsys Group.
For the electronic newsletter and communications service, people can subscribe voluntarily via a form published on the LDT Commons platform and through official social media channels (such as LinkedIn).
The subscription form is managed and hosted through the Brevo platform.
By subscribing to LDT Commons communications, you agree to receive information about events, community updates, invitations to participate, and publications related to the LDT Commons initiative.
Your personal data will not be used for automated decision-making, including profiling.
3. On what legal ground(s) do we process your personal data?
We process your personal data on the basis of your freely given, specific, informed and unambiguous consent (Article 6(1)(a) GDPR). You have subscribed to receive information about LDT Commons developments, activities, events and publications.
You may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.
4. Which personal data do we collect and further process?
In order to carry out this processing operation, Nunsys Group collects the following categories of personal
data:
Mandatory
• Email address
• First and last name
Optional
• City
• Position / role
• Organisation or institution
5. How long do we keep your personal data?
Nunsys Group only keeps your personal data for as long as necessary to fulfil the purpose of thecommunications service, i.e., until you unsubscribe. If you do not unsubscribe, your data will be retained for a maximum of five years from your last interaction with our communications.
Subscribers’ email addresses are stored until a subscriber requests removal from the list. Subscribers can request to be unsubscribed by following the unsubscribe link included in any email, or by sending arequest to privacy@nunsys.com. Appropriate action will be taken within one week of receiving the request.
6. How do we protect and safeguard your personal data?
All personal data in electronic format (emails, databases, subscriber lists, etc.) are stored on Nunsys Group’s systems and those of its data processors. All processing operations are carried out incompliance with the GDPR and applicable Spanish data protection legislation.
Nunsys Group has implemented appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, alteration or disclosure. These include access controls, encryption where appropriate, and regular review of data security practices.
Brevo, as data processor, is bound by a Data Processing Agreement with Nunsys Group and processes your data solely for the purpose of delivering electronic communications on our behalf, in accordance with the GDPR.
7. Who has access to your personal data and to whom is it disclosed?
Access to your personal data is limited to Nunsys Group staff responsible for managing LDT Commons communications, and to Brevo (Sendinblue SAS) as data processor for email delivery. All parties are bound by confidentiality obligations.
Your personal data will not be sold, rented or disclosed to any third party, except as required by law.
Brevo may process data within the European Economic Area; any transfers outside the EEA are governed by appropriate safeguards in accordance with Chapter V of the GDPR.
8. What are your rights and how can you exercise them?
Under the GDPR (Articles 15–22), you have the following rights as a data subject:
• Right of access: you may request a copy of the personal data we hold about you.
• Right to rectification: you may request correction of inaccurate or incomplete data.
• Right to erasure: you may request deletion of your personal data, subject to applicable legal obligations.
• Right to restriction of processing: you may request that we limit the processing of your data in certain
circumstances.
• Right to data portability: you may request your data in a structured, commonly used and
machine-readable format.
• Right to object: you may object to the processing of your personal data at any time.
• Right to withdraw consent: you may withdraw your consent at any time without affecting the lawfulness
of prior processing.
To exercise any of these rights, please contact the Data Controller at the address provided in Section 9.
You also have the right to lodge a complaint with the Spanish Data Protection Authority (Agencia
Española de Protección de Datos — AEPD, www.aepd.es) if you consider that your rights have been
infringed.
9. Contact information
Data Controller
Nunsys Group, S.A.
Calle Gustave Eiffel 3, Parque Tecnológico de Paterna, 46980 Valencia, Spain
Email: privacy@nunsys.com
Note: Please verify and update this email address with the official Nunsys privacy contact before
publication.
Data Protection Officer (DPO)
Nunsys Group is required to designate a Data Protection Officer under Article 37 GDPR where
applicable. For DPO-related enquiries, please contact: privacy@nunsys.com
Supervisory Authority
Agencia Española de Protección de Datos (AEPD)
C/ Jorge Juan, 6, 28001 Madrid, Spain
www.aepd.es
10. Where to find more detailed information?
For more information about data protection at Nunsys Group, or to review our general privacy policy,
please visit www.nunsys.com or contact us at privacy@nunsys.com.
Information about the LDT Commons initiative is available at: www.nunsys.com