We are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person. This Privacy Policy (the “Privacy Policy”) describes how IDC Italia srl (“IDC” or “we”), as a project coordinator, handles, processes and protects personal data of our subscribers, survey participants and visitors to the website (the “users” or “you”) within the project UPCAST. The UPCAST project, funded by the Horizon Europe Programme. UPCAST provides a set of universal, trustworthy, transparent and user-friendly data market plugins for the automation of data sharing and processing agreements between businesses, public administrations and citizens. Our plugins will enable actors in the common European data spaces to design and deploy data exchange and trading operations guaranteeing (i) automatic negotiation of agreement terms, (ii) dynamic fair pricing, (ii) improved data-asset discovery, (iii) privacy, commercial and administrative confidentiality requirements, (iv) low environmental footprint, as well as ensuring compliance with (v) relevant legislation and (vi) ethical and responsibility guidelines.

As used in this Privacy Policy, “personal data” means information that identifies or can identify you. This Privacy Policy also informs you about your rights regarding personal data processing and how and by what means you can exercise them.

We recommend that you carefully familiarize yourself with this Privacy Policy.

DATA CONTROLLER and contact details

The controller of your personal data is IDC Italia srl, with its registered office at Viale Monza 14, 20127 Milan, Italy.

As set in this Privacy Policy, your personal data may be shared with other IDC entities or affiliates from the IDC group (“IDC Group”).

Updated contact details and other information on all companies of the IDC group can be found at

For requests and/or complaints related to this Privacy Policy you can contact us via e-mail at

Surveys relating to the UPCAST project

Completion of Surveys and Reports

Within the UPCAST project, you can participate in surveys targeted on digitalization on the European market and other initiatives of the UPCAST project. If you choose to participate in a survey, you will provide us with personal data, in particular your contact details (name, surname, email address, phone number, country, organization and job position) or potentially any personal data contained in your responses submitted within the survey. Based on your responses to the questions relating to your organization, you will be given a report which will help you understand your organization’s standing in respect of the digitalization, innovation or other survey topics.

The processing of personal data is necessary for the provision of our service to you, i.e. the preparation of the report tailored to your responses and organization.

The personal data that you provided to us will be processed for the period necessary to provide the service that you asked for when completing the survey. This period shall not exceed the period of 3 years.

Updates and follow-ups from IDC

To ensure that the report you are given upon the completion of a survey is as relevant and tailored to your organization as much as possible, we may contact you with additional questions and updates relating to the survey and the UPCAST project. The purpose of the processing of your personal data is ensuring the highest quality the project and survey reports and effective communication between you and us. The ground for processing is our legitimate interest to deliver relevant results and the best service possible. Your personal data are processed for the duration of our legitimate interest but no longer than 3 years from the moment of completion of the survey.

Updates and follow-ups from other contributors to the UPCAST project

If you grant us your consent when participating in a survey within the UPCAST project, we will provide your contact details (name, surname, email address, phone number, country, organization and job position) to our partners that also contribute to the project. This will enable us to provide you with even more relevant results of the survey and updates relating to the UPCAST project. The processing of your personal data is based on your consent which can be withdrawn at any time reaching out to us via the email address provided in Section 2 above. The purpose of the processing of your personal data is the further development and improvement of the UPCAST project and ensuring the highest possible quality and relevance of the results that you get upon completing our surveys.

The updated list of contributors to the UPCAST project who can gain access to your personal data if you grant us your consent is available at the official website of the UPCAST project at

Marketing communication

Contact form

You can submit any questions, comments or requests relating to the UPCAST project via our contact form which is available at If you do so, we will process the personal data that you provide to us, mainly your name, email and any information that you may provide to us in the body of your message.

We will process your personal data for the purpose of responding to you on the grounds of our legitimate interest that is effective communication between us and you in regard to your question or request. We will process your personal data for the period of duration of our legitimate interest, depending whether there are any actions or further communication following from your question or request. This period will not exceed 1 year from the moment of submission of the contact form.

Commercial information about IDC products, services and events

If, at the time of the completion of a survey, you grant us your consent, we may also send you commercial information about our products, services or events organized by us or other entities of the IDC group. In such case, the purpose of the processing is the market research, promotion of our products, services and events, particularly sending offers and personalized commercial information, organization and promotion of events and other marketing activities of the IDC and other entities of the IDC group.

The personal data are processed based on your consent, that you can withdraw at any time. Each email with commercial information will provide a link which you can click on to unsubscribe. The retention period corresponds to the duration of the consent and shall not exceed the period of 3 years from the date when the consent was granted.


We use cookies and other technologies (such as site measuring software and user experience software) to enhance your online experience and learn about how you use our website and other services in order to improve the quality of the UPCAST project. We may combine data gained through cookies with other data you provide to us.

Upon visiting our website, we will ask for your consent to use cookies.

Below you will find the basic information about cookies and explanation on how exactly our website makes use of them.

What are cookies?

Cookies are small text files sent to your device. Although cookies contain identifying information, they do not contain any information that identifies you personally, but rather allow us to recognize you upon return to our website. If you do not want to accept a cookie while visiting our website, you should be able to change the settings in your browser to disable this function (more information on how to do it – below), but there might be sections of the site that you will be unable to access if you do so.

Why cookies are being used on this website?

We utilize cookies to help us analyze how users use our services, and similar technologies (e.g. device identifiers, ad tags) to recognize you and/or your device(s) on, off and across different devices and our services, as well as to improve the services we are offering, to improve marketing, analytics, or website functionality.

What type of cookies are placed?

In the course of your browsing sessions the following types of cookies may be employed by our website:

user interface customization cookies (i.e. cookies memorizing your preferences);

authentication cookies (i.e. cookies allowing you to leave and return to our websites without having to re-authenticate yourself);

video player cookies (i.e. cookies storing data needed to play back video or audio content and storing your preferences);

first party analytics cookies (i.e. cookies memorizing the pages you visited and providing information about your interaction with those pages); and

third party analytics cookies (i.e. cookies from third party suppliers tracking our website’s statistics and vice versa).

Apart from the aforementioned, are any other data being collected?

Likewise, we will track your process across our website to verify that you are not a bot and to optimize our services:

information regarding your browser and device;

data collected through automated electronic interactions;

application usage data;

statistical information about your use of our website.

If you send us an email (e.g. to request information or provide feedback on website content), the information you provide will only be used to help us to gather the information requested and to respond to your message.

When you visit any of our websites, our servers also log your global IP address, which is a number that is automatically assigned to the network your computer is part of.

How long are the data collected by cookies retained?

The processing of your personal data collected by cookies is based on your consent which can be withdrawn at any time via browser settings. If you accept the cookies on our website, we will collect and process your personal data for the period of 13 months. All persistent cookies are removed from your device after the expiration of this period and we will no longer process your personal data.

How do I change my cookie settings?

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit or

To opt out of being tracked by Google Analytics across all websites visit

Links to External Websites

We may refer to, or establish relations with, other companies, organizations and public bodies that will enable you to access their websites directly from ours. Each of them will operate its own policy regarding the use of cookies and collection and use of information. If you have any concerns regarding the manner in which your data will be used, we recommend referring to the privacy statements on relevant websites.

IDC will strive to provide you with links to high quality, reputable websites which we think will be of interest and relevance to you. However, please note that we are not responsible for the content of such websites and cannot accept responsibility for any issues arising in connection with the third party’s use of your data, the website content or the services offered to you by these websites.

Google Analytics

The UPCAST website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies (text files placed on your computer) to help the website operators analyze how users use the site. The information generated by the cookie about your use of this website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.

Social media

When you visit, like, follow or otherwise engage with our social media pages or accounts (including, to the applicable extent, use of your social media user account), we may be considered joint-controllers of your personal data with the provider of the particular social media/network. We do not use your personal data in any other way than described in this Privacy Policy. In order to find out more information about how the social media/network provider uses your personal data and other information, please contact the respective provider.


Your personal data may be shared with:

within the IDC Group (;

other contributors to the UPCAST project based on your consent ( );

providers of IT, marketing or administrative services;

external auditors, consultants, tax advisors and legal representatives bound by confidentiality obligation for the protection of our legitimate interests;

public prosecution bodies, courts and administrative authorities in accordance with our legal duties.

We have entered into agreements on processing of personal data with our processors of personal data (with the exception of cases where the conclusion of such agreement is not obligatory, for example, when transferring personal data to public authorities), which ensure at least the same level of protection thereof as this Privacy Policy.

For instances when the personal data is transferred outside of the EU/EEA, we have ensured adequate safeguards, particularly we have entered into standard contractual clauses as approved by the European Commission.

Data Security

We have implemented and maintain appropriate technical and organizational measures, internal controls and information security processes in accordance with legal requirements and market standards corresponding to a possible threat to you as the data subject. We also take into consideration the state of technological development in order to protect your personal data from accidental loss, destruction, alterations, unauthorized disclosure or access. Such measures may, among other things, include taking reasonable steps to ensure the liability of relevant employees who have access to your data, training of employees, regular backups, procedures for data renewal and management of incidents, software protection for devices on which personal data are stored, etc.


If you wish to exercise any of your rights according to this Article or according to applicable legislation, please contact us using the contact information listed in Article 2 above.

Also, if applicable, we will inform each recipient to whom your data have been provided according to Article 7 of this Privacy Policy of the measures taken or of the erasure of your personal data or of the restriction of processing in accordance with your request, if such a notification is possible and/or does not involve disproportionate effort.

We do not carry out automated decision-making or profiling.

Access to and portability of your personal data

You have the right to obtain confirmation as to what personal data we process or do not process with respect to you. Should you request it, we can send some of your personal data (namely the data that we process on the basis of the fulfilment of a contract and/or your consent) directly to a third party (to another data controller) whom you state in your request, provided that such request does not affect the rights and freedoms of other persons, and provided that it is technically feasible

You can access your personal data via aforementioned contact details.

Withdrawal of consent

Granted consent to the processing of your personal data can be withdrawn at any time without giving reason. For such purpose, please seek the unsubscribe button in emails that we sent to you or contact us via the contact details set out in Section 2 of this Privacy Policy. In such a case, we will erase your personal data within 30 days from the withdrawal of your consent.

Please note that the withdrawal of your consent does not affect the lawfulness of processing conducted on the basis of consent prior to its withdrawal

Rectification of your personal data

According to applicable legislation, you have the right to rectification of your personal data that we are processing if you find that they are inaccurate or incomplete.

To request rectification of your personal data, please contact us via the aforementioned contact details.

Erasure of your personal data

You can request erasure of your personal data at any time. The scope within which we can comply with your request for erasure of personal data may be limited by our statutory obligations to store some personal data, particularly on the basis of accounting and tax regulations, etc. Further, we will also erase all of your personal data (and ensure thereof by the processors that we engage) if you withdraw your consent.

Restriction of processing

If you request us to restrict the processing of your personal data, for example when you contest the accuracy, lawfulness or our need to process your personal data, we will limit processing of your personal data to a necessary minimum (storage), and if applicable we will only process this data to establish, exercise or defend legal claims or where necessary in order to protect the rights of other natural or legal person, or for other limited reasons required by the applicable law.. In case the restriction is lifted, and we continue processing your personal data, you will be informed accordingly without undue delay.

The request for restriction of processing can be made using the aforementioned contact details.

Objections to processing

You can object to data processing. If we do not demonstrate any compelling legitimate reasons for the processing which would override your interests or rights and freedoms, we will no longer process your personal data and will delete it without undue delay.

Objections to processing can be raised using the aforementioned contact details.

Complaint to a Data Protection Authority

You have the right to lodge a complaint pertaining to processing of data conducted by us with the competent data protection authority, i.e. the Italian Data Protection Authority, 121 Piazza di Monte Citorio, Roma 00186, Italy; website:


We may modify or update the Privacy Policy from time to time. Any changes to this Privacy Policy shall become effective with publication of the updated Privacy Policy at