Privacy Policy

Data Controller

Willeasy S.r.l. — VAT IT02936410303. Contact for privacy matters: privacy@willeasy.net.

What data we process

• Account data: nickname/name, email, password (hashed), language and accessibility preferences.
• Accessibility needs (health data, Art. 9 GDPR): the disability/accessibility needs you optionally declare, used to tailor questions and aggregate territory accessibility.
• Contributions: place assessments, ratings, notes and photos you submit (photos keep GPS but author metadata is removed).
• Owner data (if you register a business): company name, VAT, contact name and phone.
• Technical data: strictly necessary session/security cookies (see the Cookie Policy).
• Feedback and reports: the message, and — only if you ask to be contacted — the name and email you provide on the feedback form. This data is sent by email to our helpdesk system (Odoo, provided by Odoo S.A.) only to reply to you; it is not stored in our own database. Anonymous submissions carry no identifying data at all.

Legal basis

• Account and core service: performance of the service you requested (Art. 6.1.b).
• Accessibility/health data: your explicit consent (Art. 9.2.a), collected before you provide it.
• Public-interest accessibility (PEBA): the data shown to municipalities is aggregated/anonymised.
• Feedback with a reply request: necessary to follow up on your own request (Art. 6.1.b) — no consent needed, the data is used only to answer you.

Students of the ACCESS Erasmus+ project

This section applies if you registered with an invitation link from your school.

• What we collect: a nickname (please do not use your full name), your email, your school (taken from the invitation link), your answers about the places you map, the notes and photos you add, and your declaration that your school has collected the consent of your parents or guardians. We do not ask for health or disability data from students.
• Why: so that you can take part in the project and map the accessibility of places around your school together with your class.
• Legal basis: consent (Art. 6.1.a). For students under the age of digital consent (14 in Italy, 16 in Poland; parental consent is required in Turkey) the consent is given or authorised by a parent or guardian, which your school collects before you register (Art. 8 GDPR). An administrator approves each account before it can be used.
• Who can see it: the project team. Students of your school can see a map of the places mapped by your school, but never who mapped them. Your answers, notes and photos are never shown on the public map or to business owners, and your nickname and email are never public. A point you add to the map (its name and position) is just a place on the map: please never use a person's name, and do not mark your home.
• Photos: faces are blurred on your device before a photo is sent and you are asked to confirm it; if that is not possible on your device the photo is not uploaded. Automatic detection is not perfect, so please do not photograph people. The location (GPS) stored inside the photo is kept, because it helps locate the barrier; the details of who took it (author, device serial number) are removed on our server.
• Your rights: from Account you can download your data or delete your account at any time. For students, deleting the account permanently deletes your answers, notes and photos. Places you added to the map remain, with no link to you.
• Retention: [to be defined with the Data Protection Officer — for the duration of the project at most].

Your rights

You can access, rectify, export and erase your data, and withdraw consent at any time, from Account → Your data / Delete account, or by contacting us. On erasure your contributions are kept but unlinked from your identity (shown as "Deleted user"), preserving public-interest accessibility data.

Retention

Account data is kept while the account is active. Check-ins expire after 30 days. Accessibility contributions may be retained in anonymised form for the public-interest purpose of the project.

This project is co-funded by EU/Regione FVG. You may lodge a complaint with the Italian Data Protection Authority (Garante).

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