1. Data Controller

The data controller for the CitiAir app is:

OPENCONTENT SCARL – Via Valentina 11, 38121 Trento. Email: info@opencontent.it

2. Information We Collect

The CitiAir app is designed to minimise the use of personal data. 

The app collects only the personal data strictly necessary to operate the service and manage problem reports; it does not collect or store any personal data beyond these purposes.

2.1 Email Address (voluntary)

The app allows you to voluntarily submit issues that you notice in your city. When submitting an issue, you will be asked to provide an email address.

• Your email address will be used exclusively to:

• contact you for clarification about the issue you reported, or
• provide feedback on how your report has been handled.

• We will not use your email address for marketing purposes and will not share it with third parties for their own marketing.

2.2 Geolocation Data

The app uses geolocation information from your device to:

• show information about nearby points of interest, and
• allow you to pinpoint and report local air-quality or nature-based solution (NBS) issues.

This geolocation data:

• is processed only during your active session in the app;
• is not stored together with your email address or with any other identifier that directly identifies you;
• is cleared when you close the current session or stop using the relevant feature.

We may use geolocation information in an aggregated and anonymous form (see “Sharing of Information” below) to support environmental analysis and decision-making.

2.3 Technical / Log Data

When you use the app, our systems and those of our service providers may temporarily process certain technical information, such as:

• IP address,
• date and time of requests,
• basic device information,
• app version and technical error logs.

These data are processed only as needed during the session (for example, for security, debugging and ensuring the proper functioning of the service) and are then deleted or anonymised. They are not combined with your email or used to build a user profile.

3. Legal Basis for Processing

In compliance with the European General Data Protection Regulation (GDPR) 679/2016, we process your personal data based on the following legal bases:

• Consent (Art. 6(1)(a) GDPR) When you voluntarily provide your email address and submit an issue, you give your consent for us to use that email address to manage and follow up your report.

• Legitimate Interests (Art. 6(1)(f) GDPR) We may process anonymous or aggregated data, and limited technical/log information, in order to:

• ensure the security and proper functioning of the app;
• improve the quality and effectiveness of environmental and air-quality services;
• defend our rights in case of disputes.

• Legal Obligations (Art. 6(1)(c) GDPR) In some cases, we may be required to retain or disclose certain information to comply with applicable laws or with requests from competent authorities.

4. How We Process and Store Your Data

Your personal data (primarily your email address and the content of your report) are processed using secure IT systems and procedures designed to ensure confidentiality, integrity and availability.

• Data are accessed only by authorised personnel and by service providers (for example, hosting providers or IT contractors) who act on our behalf and follow our instructions.
• Data are generally stored on servers located within the European Economic Area (EEA).
• If we ever need to use service providers located outside the EEA, we will ensure that appropriate safeguards are in place (such as adequacy decisions or standard contractual clauses).

5. Device Permissions

The CitiAir app may request access to certain features of your device:

• Location Used to determine your position and display nearby points of interest or to geolocate an issue you report.

• Camera / Photos (only if such features are available in the app) Used to allow you to attach images to your issue report, if you choose to do so.

You can grant or revoke these permissions at any time through your device’s operating system settings. If you revoke a permission, some functions of the app may not work correctly, but you can stop using or uninstall the app at any time.

6. Data Retention

We keep your email address and the content of your report only for as long as necessary to:

• manage and resolve the issue you have reported;
• handle any follow-up or feedback;
• fulfil related legal or contractual obligations, if any.

As a general rule, your email address will be deleted or irreversibly anonymised within six (6) months after your reported issue has been resolved or the feedback process has been completed, unless a longer retention is required by law or justified by the need to protect our rights (for example, in case of disputes).

Session-based geolocation and technical/log data are processed only for the duration necessary for the session and then deleted or anonymised.

7. Sharing of Information

We do not share your email address with third parties, except:

• with service providers that support the operation of the app (e.g., hosting providers, IT maintenance), who act on our instructions and under data processing agreements;
• where required by law, by a competent authority or to defend our rights.

We may use and share anonymous, aggregated data derived from geolocation and issue reports with:

• local authorities,
• project partners,
• other stakeholders involved in air-quality improvements and environmental research.

This aggregated data does not allow the identification of individual users.

8. Your Rights and How to Exercise Them

You have the right to:

• request confirmation as to whether we hold your email address in connection with the CitiAir app;
• request deletion of your email address and associated personal data, where they are no longer necessary for the purposes described above.

You can exercise these rights by contacting us at the city-specific email address or at the previously indicated general contact.

We will respond to your request as soon as reasonably possible and, where GDPR applies, within one (1) month from receipt of your request, in accordance with applicable law. Requests are normally handled free of charge unless they are manifestly unfounded or excessive.

9. System Logs, Security and Defence of Rights

For security and maintenance purposes, and to prevent or investigate possible abuse of the CitiAir app, our systems and those of our service providers may temporarily process and store technical data and logs (for example, IP address, timestamps and error traces) as described above.

These data may be used, where strictly necessary, to:

• detect and resolve technical issues;
• ensure the security and stability of the service;
• defend our rights in legal proceedings, for example in case of suspected misuse or cyberattacks.

Such logs are retained only for the period strictly necessary for these purposes and are then deleted or anonymised.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time, for example to reflect:

• changes in the app or in the way we process data;
• new legal requirements or guidance from supervisory authorities.

Any updated version will be made available within the app and will indicate the date of the latest revision. If we make material changes that significantly affect the way we process your personal data, we will inform you through the app or by other appropriate means. Where required by law, we will ask for your renewed consent.

Thank you for using CitiAir and for helping to improve the quality of life in your community.

Consent to the processing of personal data

In accordance with the provisions of Article 6, point 1, letter a) and Article 7 of the GDPR, when you voluntarily provide your email address and report a problem, you express your informed and free consent to the use of your email address and geolocation data to manage and follow up on your report.