Privacy policy


The Hubs4Circularity Community of Practice will support the collaboration among various industries and society to jointly progress towards circular and sustainable industrial production. The network will be supported by a digital knowledge platform that will provide access to project results, technological solutions and best practices, and will support the process of constant learning from successful examples of existing and developing Hubs4Circularity.

Two consortia with complementary strengths and expertise, H4C Europe and H4C ECoP, have been selected by the European Commission to collaborate toward a common goal: to drive the Hubs4Circularity Community of Practice over the next four years (2022 – 2026).

The two consortia H4C Europe and H4C ECoP are collaborating with the Hubs4Circularity demonstration projects to develop a set of key performance indicators for Hubs4Circularity; they will define business models and promote funding and finance opportunities to boost industrial and industrial-urban symbiosis, and circularity. Together with actors from industries, regions and cities, they will identify further research and development gaps.

We are committed to giving you clarity on how we handle your data. H4C Europe and H4C ECoP operate under the names of their partners which include CIAOTECH; EGEN B.V.; ZEDO E.V.; CIRCE; COVESTRO; DECHEMA; INNOVATION ENGINEERING; VITO; SINTEF INDUSTRY; SINTEF HELGELAND AS; TNO; WATER EUROPE; EIT RAWMATERIALS; ACR+; ISQ; STRANEEIT CLIMATE-KIC; ICLEI; TECHNOPOLIS GROUP; INTERNATIONAL SYNERGIES LIMITED (ISL), hereinafter referred to commonly as ‘H4C Europe & H4C ECoP’.

In this Privacy Statement we inform you about our approach to handling and processing of data.


  1. Contact details

Innovation Engineering is the assigned H4C Europe & H4C ECoP project Data Protection Officer (DPO) and thereby the data controller. It is located at via Napoleone Colajanni, 4 – 00189 Roma (Italy) and it can be contacted by e-mail at


  1. Who is this Privacy Statement applicable to?

This Privacy Statement applies to all persons whose personal data H4C Europe & H4C ECoP process, with the exception of persons working at H4C Europe & H4C ECoP. Personal data means any data that contains information about persons through which those persons are identifiable.

This Privacy Statement applies to:

  • Users of the H4C Knowledge Platform
  • Visitors to the website of H4C Europe & H4C ECoP (
  • Recipients of newsletters from H4C Europe and/or H4C ECoP
  • Registered attendees of the events and webinars organized by H4C Europe and /or H4C ECoP
  • Potential users of the H4C Knowledge Platform that established contact with the H4C Europe and/or H4C ECoP consortia
  • Potential collaborators with whom H4C Europe and/or H4C ECoP have made or want to make contact
  • Any other person who contacts H4C Europe and/or H4C ECoP or whose personal data is processed by H4C Europe and/or H4C ECoP


This Privacy Statement does not apply to employees, temporary workers, student trainees, and applicants.


  1. Which personal data do we process?

By processing personal data we mean: collecting, recording, organizing, storing, updating, modifying, retrieving, consulting, using, providing by means of forwarding, distribution, or any other form of posting, bringing together, linking together, and to protect, erase or destroy your personal data.

We process personal data that you have provided to us, personal data generated during your visit to the website of H4C Europe & H4C ECoP (  and reading newsletters from H4C Europe and/or H4C ECoP, and personal data that we have derived from other sources, such as business social media platforms and business cards.


Personal information provided by you:

  • Contact details and other personal data needed to handle your interest in the H4C Europe and/or H4C ECoP projects,
  • Contact details (e.g. email address, first name and last name) and other optional personal data (e.g. telephone number, profile picture, position, address, links to social media channels, etc.) entered on contact forms or other web forms, and
  • Contact information provided during introductory talks, events, webinars (attendance lists), etc., such as information on e-mail signatures and business cards;
  • Potential audios and videos, photos. In the case of embedding videos and other content to the H4C Knowledge Platform, if you provide us with access to any site with video content, then you agree that we may share your video with, or obtain information about your video from third-party social media sites for at least two years of until you withdraw consent. You control the personal information to which you allow us to have access through the privacy settings on the applicable social media site and the permissions you give us when you grant us access to your personal information retained by the respective social media site about you.


Personal data obtained from other sources:

  • personal data available on public business social media platforms such as LinkedIn,
  • personal data obtained from the Trade Register of the Chamber of Commerce,
  • personal data available on public business websites, and
  • Innovation and funding data available on public sources.


  1. What do we use your personal data for?

We use your personal data for different purposes. These are listed and elaborated on below:

  • Deliver H4C Europe and/or H4C ECoP services by our partners and upon your request, as well as to provide and maintain H4C Knowledge Platform services, for instance, by monitoring your use of such services.
  • Manage your account and requests, when registering as a user of the H4C Knowledge Platform. The personal data you provide can grant you access to different platform functionalities and services that are available as a registered user. Similarly, such personal data can be used to manage and attend your requests to us.
  • Support the outreach campaigns by promoting the events, webinars, and other activities of the H4C Europe and/or H4C ECoP project, including news, special offers and general information about other goods, services and activities offered on the H4C Knowledge Platform.
  • Send you information mailings, such as the H4C Europe and/or H4C ECoP project newsletter. There are three ways you may receive the H4C Europe and/or H4C ECoP project newsletter: (1) you may opt-in to the newsletter via the sign-up form on the project website of H4C Europe &r H4C ECoP; (2) as a registered user on the H4C Knowledge Platform, once you sign up for our H4C Knowledge Platform, we automatically add you to our mailing list; and/or (3) as a registered user for an H4C Europe and/or H4C ECoP project event, we will automatically add you to our mailing list. You can unsubscribe at any time. As further explained below, the newsletter is sent via Mailchimp, a third-party service provider, with whom we share only your first name, last name, employer and e-mail address.
  • Send you H4C Knowledge Platform-related mailings, in the event that you have registered to and use the H4C Knowledge Platform. They include and are not limited to confirmation, notification, updates and general communication mailings related to the H4C Knowledge Platform functionalities, services or your personal account. These mailings are essential for the functioning of certain processes and services, for troubleshooting problems with your account, for resolving technical issues and/or customer support. Other non-essential and optional mailings may include polls, surveys, or similar mailings to help improve our services. You can change your H4C Knowledge Platform-related mailing preferences at any time under your account settings.
  • Improve overall services, marketing campaigns, and your H4C Knowledge Platform experience (usability) through anonymised data analyses that will serve to identify, for instance, usage trends and determine the effectiveness and efficiency of our processes and initiatives.


Compliance with legal obligations

Maintaining contact with you.

Your contact data are kept in EU located relationship management system and may be used for the purpose of sending newsletters, updates, invitations to events and seminars, and sending information you requested from us.

Improving our product and service information and carrying out targeted marketing campaigns.

Part of our service is to keep you informed with information that is relevant to you and your business. To make this possible, we combine and analyse the personal data available to us. On that basis, we determine which information and channels are relevant and which moments are most suitable for providing information or establishing contact. In marketing campaigns, we do not process special personal data or confidential data. If we would like to create a personal, individual customer profile, we will ask for your prior permission. Withdraw of consent is always possible.

We analyse the following information:

  • Interaction data: Obtain personal data and contact between H4C Europe and/or H4C ECoP and you. For example about your use of the website of Europe & H4C ECoP or supported applications. This also applies to offline interactions, such as how often and when there is contact between H4C Europe and/or H4C ECoP and you.
  • Behavioural data: Personal data that H4C Europe and/or H4C ECoP process about your behaviour, such as your preferences, opinions, wishes and needs. We can derive this data from your surfing behaviour on the website of Europe & H4C ECoP, reading the newsletters of H4C Europe and/or H4C ECoP or by requesting information. But also through contact, incoming telephone calls and e-mail contact with the partners of Europe and/or H4C ECoP. Information obtained through tracking cookies, we collect and use only with your permission, which you can always withdraw. See our cookie policy.
  • Performing and analysing research on client satisfaction: Sometimes we ask clients to cooperate in a client satisfaction survey. This is done through an online questionnaire. Participation is voluntary. Prior to each client satisfaction survey you will receive further information about the working method and the way we deal with the information gathered.

Improving and securing the website of H4C Europe & H4C ECoP

Creating user statistics. The user statistics of the website of H4C Europe & H4C ECoP enable us to track the number of visitors, the duration of the visit, which parts of the website are being viewed and the click-behaviour. It concerns generic reporting, without information about individuals. We use the information obtained to improve the website of H4C Europe & H4C ECoP.

  1. Security level

We protect personal data through technical and administrative security measures to minimize the risk of loss, misuse, unauthorized access, disclosure, and modification. You can think of security software such as a virus scanner and firewalls, a secure internet connection, encryption of data, and physical and administrative access controls to data and servers. The H4C Europe IT partner INNEN is ISO 27001 and ISO 9001 certified, for the ffiqs and Nehem processes where H4C Europe and/or H4C ECoP process sensitive, or large volumes of data.


  1. Storage of personal data

We do not store your personal data for longer than is strictly necessary for the execution of the purposes. If legal regulations apply to the storage, the personal data will not be kept longer than prescribed by law.


  1. Legal basis of the processing

We process personal data on the basis of one of the following legal grounds:

  • permission,
  • on the basis of an agreement or in the run up to the conclusion of an agreement,
  • legal obligation,
  • in connection with a legitimate interest.


A controller may only process personal data if this can be based on one of the limited enumerated legal grounds in the General Data Protection Regulation (AVG). The legal bases on which H4C Europe & H4C ECoP rely are:

  • Permission: If we have requested your permission to process your personal data and you have given this permission, then you also have the right to withdraw this consent.
  • Agreement or in the run up to the conclusion of an agreement: If you give us an assignment to provide innovation or financing consultancy services, we process personal data if and insofar as this is necessary for the execution of the assignment.
  • Legal obligation: We only provide personal data to supervisors of investigative authorities if this is legally required. We will take measures in such cases that are reasonably necessary to ensure that your personal data is protected as good as possible.
  • Justified interest: We may also process personal data if we have a legitimate interest and do not therefore disproportionately infringe your privacy. For example, we use your contact information to invite you for seminars and events.


  1. Processors

We may use service providers (processors) for the processing of your personal data that only process personal data in our order. We conclude a processing agreement with these processors that meets the requirements set by the General Data Protection Regulation (GDPR).

For example, we work with service providers that offer SaaS solutions (software as a service) or provide hosting services. Furthermore, there are ICT service providers who offer us support in keeping our systems safe and stable. We also use third-party services for sending newsletters and commercial e-mails. These are examples of parties that can be designated as (sub) processors as referred to in the General Data Protection Regulation (GDPR).


  1. Share personal data with third parties

Sometimes it is necessary to share your personal data with third parties, which – depending on the circumstances of the case – are necessary for the handling of your interest.

We may also share a basic set of contact details with the partners of the H4C ECoP and H4CEurope projects within Europe with the aim of enabling the activities and services of H4C Europe and /or H4C ECoP projects to you, such as but not limited to, connecting stakeholders in the Hubs4Circularity Community of Practice.

There are also legal obligations that lead to personal data being passed on to third parties.

In the following cases personal data will be provided to third parties:

  • If a court decision obliges us to provide personal data to third parties, we will have to comply with this.

Your personal data will not be shared with third parties for commercial purposes. There is one exception to this. Sometimes we organise a joint activity with another organization, such as an event or seminar. In that case, only the necessary contact details are exchanged.

We never sell your personal data to third parties and do not make automated decisions that could have significant consequences for you.



  1. Transfer outside the (European Economic Area – EEA)

Under the General Data Protection Regulation (AVG), personal data may only be passed on to parties outside the EEA when an appropriate level is guaranteed for the protection of personal data or when a specific deviation applies.

We may pass on personal data to a party outside the EEA when necessary for the execution of the contract on provision of innovation- or financing consultancy services.


  1. If you have questions about your personal data

Every person can exercise certain rights with respect to his or her personal data on the basis of the law. This gives you the right to inspect, rectify and delete personal data. You can also object to the use of your data or request that the use be restricted. In certain cases, you can request your data and take it to another party. For all these questions contact us.


  1. Complaints

If you have complaints about how we handle your personal data, you can contact us by sending a mail. We are happy to help you find a solution within a period of four weeks after receiving your request. If that does not work, you can always contact the Dutch Data Protection Authority.


  1. Changes

Developments go fast and as a result, there may also be changes in the personal data we request from you and the way in which we use your personal data. Regulations can also change. In that case, we will update this Privacy Statement. We, therefore, invite you to regularly check the Privacy Statement so that you are kept informed. In the event of major changes, we will also make you aware of this via the website of H4C Europe & H4C ECoP.