Privacy Policy

This Privacy Law Notice form the Up2Circ Members is to inform users about all the requirements of Reg. (UE) 2016/679 (GDPR) Information concerning personal data management in the frame of the Project.

The Up2Circ Project adopted a Data Management Plan (DMP) containing a description of how the data generated, collected and processed will be managed by the UP2CIRC project. This Privacy Policy Document is in line with the DMP. 

The 7 project partners have signed a Joint Controller Agreement so the data will be shared by them within the purposes of the project. 

Each of the partners refers also to its own privacy statements and rules published on its respective website. In some cases a particular partner is responsible for management of a specific data processing, as specified in the DMP. Tutech Innovation GmbH (TUTECH) is the administrator of this page. Please refer to our contact page to get all contact details

Data Management Legal basis 

Up2Circ has received funding from the European Commission’s Horizon Europe funding programme for research and innovation programme under the Grant Agreement no. 101091367. The content of this document does not represent the opinion of the European Commission, and the European Commission is not responsible for any use that might be made of such content.

The legal basis for data collection and processing through this website is either the necessity of contract performance in case you choose to use the information and services provided on our website or your consent given in case of registration through forms (Art 6 Abs. 1 DSGVO).

What data is collected on Up2Circ website?

  1. Data that you enter in forms on our web pages: If you register for an event, for the Up2Circ Circularity Assessment or if you submit a proposal to the Up2Circ Incentive Scheme, we will ask you about your name, contact data, company/organisation and sector.
  2. Data that you do not enter in forms on this website, but which is automatically transferred as general information from your browser to our web server (e.g. your IP address).
  3. Tracking / Matomo: The general information that your browser (Firefox, Chrome, Edge, Internet Explorer or other) sends with each request is stored in a so-called log file. This data is used exclusively for statistical purposes and for error analysis. The personal data is not utilized and, if possible, not collected in the first place. The anonymization of IP addresses by Matomo is switched on.

For what purpose will your data be collected and processed?

In the framework of the EU goals towards a more sustainable economy, Up2Circ project has the overall objective to accelerate and scale the transition of European SMEs towards a circular economy. The project will provide awareness raising, assessment, training and funding opportunities targeted to EU SMEs. Up2Circ will cooperate with EU innovation support stakeholders for increased outreach, customised advisory and training. Data are collected and processed to fulfil the project mandate according to Horizon Europe Grant Agreement 101091367. Data are shared among the seven project partners based on a Joint Controller Agreement. They will not be forwarded to any entities outside the consortium without explicit consent. Applications to the UP2circ calls will be shared with the appointed evaluators and the ethics advisor, who have signed a confidentiality agreement.

How long will data be stored?

Data captured in the back-end files of the Up2Circ website will be deleted with project end, which is 31.12.2026. All data relevant for project reporting obligations will be stored within the file management systems of the seven project partners to allow for possible external audits until 5 years after final payment as required by the Grant Agreement. After this period, the data will be deleted.

 We have deactivated all possible settings to prevent privacy issues. We do not collect the visitors IP address and our server settings are turned off: no log files are stored. We have to write reports and that is why we need some statistics to do so. Please read the last paragraph about Matomo to learn more about tracking.

Type of data and Data Treatment and purpose

The Up2Circ project will provide SMEs with opportunities including participation in training (Academy), workshops, assessments and Funding (Cascading Grants): to perform such activities, users have to register with their data, that will consist of: name, role, organisation, phone and email address. 

Furthermore, each activity will imply the need to collect and treat some personal data, as outlined hereafter:

Circularity Assessment: The answers and results of the assessment are visible to the project partners; the data will not be public.  SMEs from outside of the consortial regions upon their confirmation will be signposted to multipliers, like the regional EEN sustainability advisor for customised advisory.

Cascading Grants/Open Calls Applicants: for all participating SMEs, data will be shared among the 7 Up2Circ partners and external evaluators. Only for successful SMEs, the name of the organisation for successful applications will be related and shared through project reports and the Up2Circ website . Personal Data processed for applications and evaluation will be kept for up to 5 years after final payment to perform all the administrative tasks. For successful applicants, organisational bank information will be needed to provide payment to support participation.

Testimonials from SMEs (best practice examples, interviews, videos, success stories catalogue): users will be requested to give consent for publication of data such as name, position, company name and photos/videos. 

All these data will be stored by the project partners in Up2circ website back-end and Microsoft SharePoint\OneDrive.


We use forms on this page  website. Some forms are to get information from you about or for circular economy projects. In this case we inform you about the storage process next to the form. 

To perform the Assessments, we use an online-assessment form.

All other forms are connected with our content management system WordPress. When visitors leave comments on the site we collect the data shown in the comments form because the software needs it to handle the next step. We do not collect the visitor’s IP address and browser user agent string. This is used on most websites to help spam detection. We want the best possible privacy and that is why we don’t use the plugins for spam protection. But this is also the reason why we don’t provide a comment option on our pages. Comments are welcome: please sent us a message to the address mentioned on the top.


In some cases it is possible that we temporarily activate the comments options which is normally turned off on this page. If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site should not include embedded content (e.g. videos, images, articles, etc.). We don’t use this possibility because embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. We give you a link address instead to let you decide if you want to get in contact with the other website. We don’t use embedded content because these websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

How long we retain your data

Name, contact details and other Personal Data (email, telephone or any personal information needed for the organisation of events) processed for applications collected via the Up2Circ  website will be kept by TUTECH within the website back-end and shared through Microsoft SharePoint\OneDrive for project duration and will be deleted after end of the project. All project partners will keep personal data relevant for project documentation in their own file management systems for 5 years after final payment, to allow for possible external audits as required by Grant Agreement, and ensure deletion of all personal data after this period. The Up2CIrc website contents will be kept live for minimum 5 years after final payment of the project and maintained by TUTECH to support sustainability of the project outputs. Personal Data processed for applications and evaluation in the Open Call process will be kept for up to 5 years after final payment.

What rights you have over your data

If you have an account on this site, filled out one of our forms, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Do you have questions about our privacy policy or do you want to use your rights to delete or inform about data protection issues? Then please contact:  or the Coordinator’s DPO:

Matomo Tracking

This page uses Matomo, that offers “Ethical Stats” for us to know more about the visits on our page. We have to write reports and we need some statistics to do so. We respect your privacy and we use all possibilities to reduce the amount of data. We do not collect personal data such as IP address and we delete the data frequently after 6 months. If you think that is not enough you have the possibility to opt out in the following paragraph. Please note that this paragraph is translated automatically to the language your browser is using.

You may choose to prevent this website from aggregating and analyzing the actions you take here. Doing so will protect your privacy, but will also prevent the owner from learning from your actions and creating a better experience for you and other users.

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