Privacy Policy

WHO ARE WE?

This website is dedicated to the COMHOM Project(the “Project”). COMHOM is a three-year project aiming to transform the response to homelessness through digitalisation, social innovation, and data-driven tools. The project focuses on improving the collection, sharing, and use of data on homelessness through the development of a standardised Monitoring & Evaluation (M&E) framework and the creation of the COMHOM digital platform. The Project’s Partners which will process your personal data collected through the website are:

Fundació Privada per la Recerca i Docència Sant Joan de Déu, established in Santa Rosa, 39-57 08950 Esplugues del Llobregat (Barcelona), Spain [FSJD-CERCA];

Sant Joan De Déu Serveis Socials Barcelona, established in C/Creu dels Molers 21, Barcelona 08004, Spain [SJDSS]

and

European Social Network, established in Avenue des Arts 3 4 5 Etage 8, Bruxelles 1210, Belgium [ESN].

These organizations act as joint controllers of the data collected through the website and used for the dissemination and communications activities related to the Project and you can contact them at info@comhom.eu.

They have signed a joint controllership agreement, and you can receive an abstract of this agreement by contacting them at the email addresses indicated above.

LINKS

This website may contain links to websites operated by third parties. We are not responsible and have no control over how they operate or how they process data. We encourage you to read their privacy notices before using those websites.

WHAT TYPES OF DATA DO WE PROCESS AND WHY?

1. Browsing data

The information systems and software procedures relied upon to operate this website acquire personal data as part of their standard functionalities; the transmission of such data is an inherent feature of Internet communication protocols. This data category includes the IP addresses and/or the domain names

of the computers and terminal equipment used by any user, the URI/URL (Uniform Resource Identifier/Locator) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the user’s operating system and computer environment. This data is necessary to operate web-based services in a secure and stable manner. Data will be deleted immediately after the access or within ten days. The legal basis (i.e. the basis required by law for processing your data) of the processing to operate the website, is the legitimate interest of the COMHOM partners to promote the Project and its activities (Art. 6(1)(f) GDPR).

2. Data communicated by you

a) when you contact us: if you send an e-mail message to the addresses listed on the website or if you contact us through the Contact form, we will process your data (name, e-mail address, organization, content of the message) only to reply to your requests. The legal basis is the necessity to perform the contract or to take steps at the request of the data subject prior to entering into a contract (Art. 6(1)(b) GDPR); b) when you subscribe to our newsletter: we will process your name, surname and e-mail address, to send you communications about the Project. The legal basis is your consent (Art. 6(1)(a) GDPR).

3. Data we use when we must comply with legal obligations or defend our right

If necessary, your data could be processed to fulfill legal obligations. The legal basis of the processing is the necessity to comply with a legal obligation to which the controller is subject (Art. 6(1)(c) GDPR). Sometimes we may also need to use your data to defend or establish our rights. The legal basis of the processing is our legitimate interest in defending our rights (Art. 6(1)(f) GDPR). In these cases, the data will be held for the time required by law or authority or for the time necessary to enforce or defend our right.

ARE YOU REQUIRED TO PROVIDE US WITH YOUR DATA?

As mentioned, browsing data is automatically acquired upon access. On the other hand, you are not obliged to communicate with us. It’s all optional. However, if you would like to receive an answer to your questions, you will need to provide us with the data indicated above.

Consent for the newsletter is optional. If you decide not to sign up for our newsletter, you will not be updated on our updates, news and events concerning the Project.

COOKIES

Cookies are small text files stored on users’ devices by the server of the website they are visiting and contain information about the user’s navigation that can be read by the same server in subsequent browsing sessions. Cookies do not harm the device and enable a better browsing experience. Our website uses cookies. To know more about the cookies, we use on our website, please refer to our Cookie Policy.

WHO DO WE COMMUNICATE YOUR DATA TO?

We can communicate the data to our service providers which carry out some services on our behalf (such as website providers, email services providers and other IT services providers) as data processors in accordance with a data processing agreement.

We can communicate the data to other public or private bodies whenever we are obliged to do so to comply with law or regulatory requirements.

DO WE TRANSFER YOUR DATA?

We store your data in Europe. However, some of our suppliers when providing their services can access data from countries outside of the EU/EEA, such as Mailerlite (from US). In these cases, data is transferred only in the presence of the safeguards indicated in the applicable data protection legislation. In particular, the transfer will take place: – to destination countries for which the European Commission has issued an adequacy decision (art. 45 GDPR) or – on the basis of the Standard contractual clauses (“SCCs”) adopted by the EU Commission (art. 46 GDPR) provided that supplementary security measures are also in place.

HOW LONG DO WE KEEP YOUR DATA?

The data you provide us through contact forms or through spontaneous emails will be retained for the time needed to reply to you and, in any case, for a maximum of six months. Your email address collected to send you the newsletter will be held for the duration of the Project and for a further 2 years. However, you can withdraw your consent at any time and the joint controllers will stop the processing.

YOUR RIGHTS

You have certain rights in connection with the data processing.

  • You have the right to access your data and to modify or correct your data.
  • You can obtain the erasure of personal data and the restriction of the processing when certain conditions are met.
  • You have the right to receive a copy of your personal data in a structured, commonly used and machine-readable format or ask us to transmit that data to
  • another controller, where technically feasible, if the processing is based on consent or on a contract and is carried out by automated means.
  • You have the right to withdraw the consent you have given at any time, without affecting the lawfulness of the processing carried out before the withdrawal.
  • You can always object to the processing of your personal data for direct marketing purposes and, on grounds relating to your particular situation, you can also object to the processing of your personal data based on the legitimate interest of the controller.
  • You can lodge a complaint with the data protection authority of your country if you believe that your rights have been breached.

If you wish to exercise one of these rights or simply have more information about our data protection practices, you can contact the joint controllers at info@comhom.eu.

CHANGES TO THE PRIVACY POLICY AND OUR DUTY TO INFORM YOU OF CHANGES

We keep our privacy policy under regular review and may modify and revise it occasionally. Any information we collect is subject to the privacy policy in effect at the time such information is collected. Any changes we make to our privacy policy in the future will be posted on this page and, where possible, notified to you by email.

Last updated 11.06.2025