Privacy Policy – App Global Passport Project

Privacy Policy


This Application collects some personal data from its users.


Owner of the data processing


Associazione Kosmopolis

Via Francesco Saverio Correra, 127

80135 Naples (NA) – Italy

VAT: 95270880636




Definitions and legal references


Personal Data (or Data)

Personal data is any information that – directly or indirectly, also in connection with any other information, including a personal identification number – identifies a natural person or makes a natural person identifiable.


Usage data

Usage data is the information automatically collected through this Application (including third-party’s applications integrated into the present Application), which includes: IP addresses or domain names of the computers used by the User who connects to this Application; addresses in URI notation (Uniform Resource Identifier); the time of the request; the method used to forward the request to the server; the size of the file obtained in response; the numerical code indicating the status of the response from the server (successful, error, etc.); the country of origin; the characteristics of the browser and operative system used; different forms of time-related information (e.g. the time spent on each page) and the details related to the itinerary followed within the Application, with particular reference to the sequence of the pages viewed, the parameters of the operating system and the IT environment of the User.



The person using this Application, unless specified otherwise, coincides with the Data Subject.


Data Subject

The natural person to whom the Personal Data are related.


Data Processor (or Manager)

The natural person, legal person, public administration and any other entity that processes personal data on behalf of the Data Controller, as stated in the present Privacy Policy.


Data Controller (or Owner)

The natural or legal person, public authority, service or other entity which, individually or in the aggregate, determines the purposes and means of personal data processing as well as of the tools adopted, including the security measures regarding the operation and use of this Application. The Data Controller, unless specified otherwise, is the owner of this Application.


This Application

The hardware or software through which the Personal Data of Users are collected and processed.



The service provided by this Application, as defined in the Terms and Conditions of Use.


European Union (or EU)

Unless specified otherwise, any reference to the European Union contained in this document refers to all the current member states of the European Union and the European Economic Area.



Small portion of data stored in the User’s device.


Legal references

The present Privacy Policy  is based on multiple legislative systems, including articles. 13 and 14 of the Regulation (EU) 2016/679.


Unless specified otherwise, the present Privacy Policy refers exclusively to this Application.


Types of data collected


Among the Personal Data collected by this Application, either independently or through third parties, are: cookies, usage data, name, surname, E-mail address, nationality, gender and date of birth.


Details on each type of data collected are provided in the dedicated sections of the present Privacy Policy or by specific notifications displayed before the data are collected.


Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically while using this Application. Unless specified otherwise, all data requested by this Application are mandatory. If the User refuses to enter them, it may be impossible for this Application to provide the Service.


If this Application indicates some Data as optional, Users are free to refrain from entering such Data, without any consequence on the availability of the Services or on their operation. Users who have doubts about which data are mandatory can contact the Owner.


Any use of Cookies – or other tracking tools – by this Application or by the owners of third party’s services used by this Application, unless specified otherwise, is intended to be for the provision of  the Service requested by the User, in addition to further purposes described in this document and in the Cookie Policy, if available.


The User is responsible for the third parties’ Personal Data obtained, published or shared through this Application and guarantees to have the right to communicate or disseminate them, removing the Owner from any liability to third parties.



Method and place of processing for the collected data


Processing methods

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data. The processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Application (e.g. administrative, commercial, marketing, legal, system administrators) or external subjects (e.g. suppliers of third parties’ technical services, post couriers, etc. hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller.


Legal basis of the processing

The Owner processes Personal Data relating to the User based on at least one of the following conditions:

  • the User has given their consent for one or more specific purposes; Note: in some jurisdictions the Data Controller may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such treatment. However, this is not applicable if the processing of Personal Data is governed by the European legislation on the protection of Personal Data;
  • the processing is necessary for the execution of a contract with the User and/or for the execution of pre-contractual measures;
  • the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
  • the processing is necessary for the performance of a task of public interest or for the exercise of the public authority vested in the Owner;
  • the processing is necessary for the pursuit of the legitimate interest of the Data Controller or of third parties.


However, it is always possible to ask the Data Controller to clarify the legal basis of each treatment and, in particular, to specify whether the treatment is based on the law, provided for by a contract or necessary to terminate a contract.



The Data is processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For more information, it is recommended to contact the owner.


The User’s Personal Data may be transferred to a country other than that in which the User is located. To obtain further information on the place of processing, the User can refer to the Section related to the details on the Personal Data processing.


The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization governed by public international law or consisting of two or more countries, such as the United Nations, as well as regarding the security measures adopted by the Data Controller to protect the Data.


In case of transfer, the User can refer to the relative sections of the present Privacy Policy or request further information from the Data Controller at the contact details indicated in this document.


Retention period

The Data are processed and stored for the time required by the purposes for which they were collected. Thus:


  • Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
  • Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until this interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.


When the processing is based on the User’s consent, the Data Controller may keep the Personal Data for a longer time, until such consent is withdrawn. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority.


At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.



Processing purpose of the collected data


The User Data are collected to allow the Owner to provide its services, as well as for the following purposes: statistics, registration and authentication, integration with external platforms.


To obtain further detailed information on the purposes of the processing and on the Personal Data concretely relevant to each purpose, the User can refer to the relevant sections of the present document.



Details on the processing of personal data


Personal Data are collected for the following purposes and throuh the following services:


Contact the user (contact form)

By filling in the contact form of a support structure with their Data, the User consents to their use in order to respond to requests for information, support, or any other nature indicated by the header of the form of the AroundMe section of the detail of a structure.

Personal data collected: E-Mail address.



The services contained in this section allow the Data Controller to view the nationality, date of birth and gender of the User, but anonymously. It will not be possible to trace name and surname or e-mail.


Some Personal Data are used for the following purposes and through the following services:


User’s documents (Blockchain and IPFS)

The User has the possibility to use the document archive called DocWallet. Through this feature, the User can photograph (or select from the library of their device) their own document (or other), name it, and send it to the server managed by the Data Controller. The server will not store the document(s) on its hard drive (or SSD), but will encrypt it with the User’s private key (generated during the registration and only on the User’s device) and store it on IPFS and on the Blockchain. Only the reference to reach the document on the Blockchain will be stored on the server. The encrypted file is stored on IPFS, while the link to reach the IPFS file is also encrypted on the Blockchain. The server uses the User’s private key for encryption, but in this case it does not store it, so the only person authorized to decrypt the document is the User with their own private key. For more information on IPFS and Blockchain, see the following links:




Sharing of User documents (token generation)

The User has the option to select one or more documents in the DocWallet section and share them with operators authorized to view them. Through the “Generate Token” function, the User, after selecting one or more documents, can generate a token (6-digits number) to be communicated to an authorized external operator. Through the service portal, the operator can enter the token in the appropriate section and view the User’s documents. The token has a duration of 30 minutes, after which it will no longer be possible to view the documents. In this case, the User’s private key is stored (encrypted) on the server and kept exclusively for the 30 minutes of the token duration.


User rights


Users can exercise certain rights with reference to the Data processed by the Data Controller.

In particular, the User has the right to:

  • Withdraw their consent at any time. The User can withdraw the previously expressed consent for the processing of their Personal Data;
  • Oppose the processing of their data. The User can oppose the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are indicated in the section below;
  • Access their data. The User has the right to obtain information on the data processed by the Owner, on certain aspects of the processing and to receive a copy of the Data processed;
  • Verify and ask for rectification. The User can verify the correctness of their Data and request their update or correction;
  • Obtain the limitation of the processing. When certain conditions are met, the User may request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than their storage;
  • Obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.
  • Receive their data or have them transferred to another Owner. The User has the right to receive their Data in a structured format, commonly used and readable by an automatic device and, when technically feasible, to obtain its unhindered transfer to another Owner. This provision is applicable when the Data are processed with automated tools and the processing is based on the User’s consent, on a contract to which the User is a party or on contractual measures connected to it.
  • Submit a complaint. The User can lodge a complaint to the competent authority or take legal action.



How to exercise your rights

To exercise the User’s rights, Users can send a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible and no later than one month.


Further information on the treatment


Defense in court

The User’s Personal Data may be used by the Owner in court or in the preparatory stages for its eventual defense against abuses in the use of this Application or related Services by the User.


The User declares to be aware that the Owner may be obliged to disclose the Data by order of the public authorities.


Specific information


At the request of the User, in addition to the information contained in the present Privacy Policy , this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.


System log and maintenance

For to operation- and maintenance-related needs, this Application and any third parties’ services it uses may collect system logs, i.e. files that record the interactions and that may also contain Personal Data, such as the User IP address.


Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details indicated in the present document.


Changes to this privacy policy

The Data Controller reserves the right to make changes to this Privacy Policy at any time by informing the Users on this page. Thus, please consult this page regularly, referring to the date of the last changes indicated at the bottom of the document. In the event of non-acceptance of the changes made to the Privacy Policy, the User is required to cease the use of this Application and may request the Data Controller to remove their Personal Data. Unless specified otherwise, the previous Privacy Policy will continue to apply to the Personal Data collected up to the moment of

release and publication of the new Privacy Policy.



Last modified: May 12, 2021.