Privacy Policy

Introduction

Why do we store and process personal data?

What data do we store and process?

Who has access to the data

Where do we store the data

How can you control the processing of your data and reduce privacy related issues

Right to Object

Detailed Information

Other Relevant Policies

Contact

Introduction

This document states the Slow Ways privacy policy for services formally operated and provided by Slow Ways CIC. In particular these are

  • the slowways.org slowways.org website and associated services and APIs,
  • the Slow Ways data distribution,
  • the Slow Ways wiki and help sites,
  • the Slow Ways mailing lists and forums.

It describes what personal information we may be gathering from you, who can see this information, and what options you have for controlling this. We value your privacy and strive to achieve a balance between the legitimate interests of the Slow Ways initiative and your interests and rights.

This document is mainly intended for Slow Ways contributors, if you are using services provided by Slow Ways CIC without contributing, section Data we receive automatically will be most relevant for you.

Slow Ways developers, contributors and related companies may (with initial permission) use the Slow Ways name and logo to set up groups or services on third-party web sites. For example, there might be a Facebook page, a Google Plus page, a Slack channel, a page on Xing or LinkedIn, a Meetup group, and so on. The privacy practices of such services are outside of Slow Ways CIC’s control and might be located in countries with different data protection rules. Data you share on these platforms cannot, therefore, be covered by this policy. Please refer to the privacy policies of those third-party services.

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Why do we store and process personal data?

The purpose of the Slow Ways initiative and Slow Ways CIC is to provide open geographic data, such as street maps, to anyone.

To fulfill the goal of distributing data that is truly open, untethered by rights of third parties and of high quality, we do not support anonymous contributions and retain additional, non-geographic, data on a legitimate interest basis (see GDPR article 6.1f ), to enable:

  • identifying all the contributions made by an account,
  • contacting the contributor in the case of questions in respect to the nature and source of the contributions,
  • detection, removal and correction of spam accounts, vandallism and violations of the rights of third parties,
  • facilitating the communication between Slow Ways contributors.
  • research and analysis on aggregate contributions to improve or prioritise Slow Ways CIC services, such as evaluating mapping efficacy, map completeness, determining if locations or mappers are disproportionately represented.

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What data do we store and process?

Data from contributions to Slow Ways

Besides the geographic data contributed (points lines, and areas with associated attributes and GPS trace data), and communications related data (diary posts and comments, the user page, changeset comments, messages) we store

  • editing session meta-data. For example comments added by the user, any version and similar information added by the editing application, which editing application and which aerial imagery layers where used.
  • user id and login name of the author of every change to an object and a timestamp when that change occured.
  • the e-mail address associated with your account,
  • any blocks the user has received and associated messages.
  • network access data (example IP addresses) for the systems and services operated by Slow Ways CIC.

Conference and Event Registration Data

Some events organized by Slow Ways CIC require prior registration to be able to participate. This data is required to verify payment of entry fees, planning of venues, catering and scheduling of talks and presentations and is visible to the group organizing the event. The processing of this data is necessary for the performance of a contract (see GDPR article 6.1b).

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Who has access to the data

We do not share email addresses associated with accounts with any third party and they are only accessible to our operations and working group personnel that have signed confidentiality agreements. User to user messages are visible to the sender and recipient, other access is limited to our operations staff and only if required for operational reasons, to enforce our acceptable use policies, to fulfil any legal obligations and most notably to prevent SPAM.

Similarly, network access data is only used for internal purposes and access is limited to operating personnel for operational and vandalism and SPAM protection purposes.

The other data is made available, depending on the use case, via the website, via the editing API and from our data dumps, to users with accounts and to the general public. Some of the non-geographic data may be available only by some methods however this is subject to change.

To reduce the distribution of the non-geographic information we offer our data dumps with and without the additional data. Entities that require and process the additional data can register with Slow Ways CIC and you can find contact information for them here: Registered data controllers. We do not contract with them and any processing of the data carried out by such entities is done on their own behalf.

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Where do we store the data

The website, API servers, databases and the servers for auxiliary services are currently located in the United Kingdom.

Our map tiles are provided by a global network of cache servers, provided and managed by ESRI, OpenStreetMap and Ordnance Survey.

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How can you control the processing of your data and reduce privacy related issues

While not required by law, we provide the following mechanism to reduce the exposure of potentially privacy related information for you.

  • you can select a non identifying login name and change it at any time you want,
  • you are not required to include personal data in diary posts, comments, email listserv, or other Slow Ways communications methods, and you may delete diary posts at any time through your account,
  • you can delete your own account or request it to be deleted (restrictions see below) and this will be conveyed to registered entities that are using our full data. Any user submitted reviews, surveys or photos submitted will remain on the site, but any personal account data including usernames and emails will be deleted.

You can further reduce exposure by not adding personal information to the map data (personal names and similar). Such information is in general not considered to be an useful addition to our data and you should refrain from adding it.

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Right to Object

You have a right to object against processing based on legitimate interests of the data controller.

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Detailed Information

GPS Trace Data

The uploading of GPS data is entirely optional and not a prerequisite for contributions to Slow Ways. If you do submit GPS data, it is uploaded in the form of individual GPX files. These are kept as raw files, as well as imported into the database. GPX files can be marked “public” by the uploader; this is completely unrelated to the option of making one’s edits “public”.

When GPS data for an area is downloaded via the API no indication is provided of which user uploaded a point, or of the timestamp that was associated with the point. Points are however returned in timestamp order. GPS data downloaded in this way will include points from traces which were not marked as public.

If a GPS trace is marked as public when it is uploaded then the raw trace may be downloaded from the web site or using an API call. In this case the user’s display name is shown (regardless of whether the user has made their edits public) and the timestamps in the GPX file will be included. Also, any additional information placed in the GPX file will still be present, e.g. waypoints with their names and/or notes entered, associated symbols, elevation data, etc. You should remove any such information from the data and trim enough information from beginning and end of the trace to obscure start and destination before uploading it if you have privacy concerns

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Email Addresses

The registered email address for an Slow Ways user account will never intentionally be published on the internet anywhere, shared with third party organisations, or revealed directly to other users. Email addresses will be used by the server to notify the user if another user has sent a message through the website, and for other system generated notifications.

Only System Administrators will have direct access to email address data associated with the Slow Ways account. It may be used by these people to contact users directly about their edits or other Slow Ways related issues.

Email addresses associated with the forum and help site accounts are stored separately from the Slow Ways user account data in the respective systems. These addresses are used for notifications and user to user communication (if enabled). These addresses are not publicly visible or shared with third parties, but may be visible to the administrators of the systems.

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Polls

Slow Ways CIC may from time to time conduct polls in order to determine the opinions of volunteers, staff users, the Slow Ways community, and others, and better to serve the members and the community, a legitimate purpose of Slow Ways CIC. Distributing polls and processing their results may require the use of personal data such as names and email addresses. Personal data gathered or used in connection with surveys will be processed in accordance with applicable data privacy laws and will be retained only as long as reasonably necessary.

Email addresses of members of Slow Ways CIC may be used to invite users to participate in polls.

If poll data are made publicly available (for instance, for analysis by the Slow Ways- or research communities at large) the data will be anonymized. If the anonymized data are organized in such a fashion that individuals might be reasonably identifiable (for instance, a group with few individuals that is identifiable with a specific geography or function) the grouping will be merged to deter identification. Further, the Slow Ways CIC Board reserves the right to exclude from public release any variables that might permit deanonymization of the data.

Anonymized poll data, which may be useful to the Slow Ways CIC in the future for comparison purposes, may be retained indefinitely in accordance with applicable data privacy laws.

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Data we receive automatically

Slow Ways CIC operates a number of services for the Slow Ways community, examples are the SlowWays.uk website, and the (future) Slow Ways API.

When you visit an Slow Ways CIC website, access any of the services via a browser or via applications that utilize the provided APIs, records of that use are produced, we collect information about your browser or application and your interaction with our website, including (a) IP address, (b) browser and device type, (c) operating system, (d) referring web page, (e) the date and time of page visits, and (f) the pages accessed on our websites.

Further we may operate user interaction tracking software that will generate additional records of user activity, for example Piwik.

Services that use Geo-DNS or similar mechanisms to distribute load to geographically distributed servers will potentially generate a record of your location at a large scale.

These records are used or can be used in the following ways:

  • in support of the operation of the services from a technical, security and planning point of view.
  • as anonymised, summarised data for research and other purposes. Such data may be offered publicly via our (future) API or other channels and used by 3rd parties.
  • to improve the Slow Ways dataset. For example by analysing searches for missing addresses and postcodes and providing such data to the Slow Ways community.

The data collected on the systems will be accessible by the system administrators and the appropriate Slow Ways CIC working groups, for example the Data Working Group. No personal information or information that is linked to an individual will be released to third parties, except as required by law.

The above mentioned data is processed on a legitimate interest basis (see GDPR article 6.1f ).

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Third party provided services and data

Third party services providing content linked to via or third party JavaScript files utilised by Slow Ways CIC provided sites are not covered by this policy and you will need to refer to the respective service providers for more information. Using these services will typically transmit at least your Internet address and browser information to the operators.

These are specifically Google, Mailchimp, Eventbrite, Zoom, ESRI, Ordnance Survey, Inkscape, Paypal, and Stripe.

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Communication via Slow Ways CIC provided Systems

The Slow Ways community uses a number of channels for public and inter-personal communication. Some of the systems are operated and controlled by third parties and can be located in countries other than the UK. You will need to refer to the respective service providers for more information.

These 3rd party operated systems are:

  • Mailboxes for Slow Ways CIC e-mail addresses are provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043. USA
  • Mailchimp, Eventbrite, Zoom, Twitter, Instagram and Facebook
  • Slow Ways Organisation and source code repositories on private Github
  • Website code and systems Amazon AWS 

By using those systems that are provided by Slow Ways CIC, for example the messaging system on Slow Ways.org, you agree to your communications being intercepted by Slow Ways CIC system managers when necessary to address operational issues, to enforce our acceptable use policies, most notably to prevent SPAM, and to fulfil any legal obligations.

You should be aware of the above when communicating sensitive information and you should employ encryption to protect your communications content.

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Account Removal

You can delete your own account or request your account to be removed and we will honor such requests as far as possible.

If you have not actively contributed to the initiative we will not retain any records, user page, diary posts and similar will be removed.

If you have contributed your account will be renamed to user_USERID and contributions and changeset comments will be retained with this name, diary entries and your user page will be removed. Since we do not allow anonymous edits we will non-publicly retain your email address in case you need to be contacted with respect to your contributions.

You can unsubscribe yourself from any mailing lists, however you need to realize that personal copies held by the recipients of any mails you sent to the lists and the archives on lists.slowways.org can not be removed.

In your request for account removal you need to identify all accounts that are affected as we do not have information on which accounts belong to which Slow Ways user id.

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Cookies

Numerous Slow Ways CIC operated services use cookies to store information on your login and site navigation state. We also use cookies and similar technologies to recognize and improve your use of our websites. You may delete cookies from your computer, and most browsers provide the option to block them. If you block cookies placed by us (first party cookies), you will not be able to access parts of Slow Ways CIC websites and services that require a login. However, your access to our websites will not be affected if you disable cookies placed by third parties. You can view our cookie policy for more information.

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Other Relevant Policies

As well as privacy issues, users and contributors must also be aware of the Slow Ways terms and conditions. This includes disclaimers. We also have an Acceptable Use Policy covering various types of server usage.

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Contact

If you have questions or concerns with respect to this policy, please contact Slow Ways CIC via our Contact channels.

If you believe that we hold information that would allow us to correct, amend, or delete inaccurate information about you or if you believe that information about you has been processed in violation of this privacy policy please email us at [email protected]. Note that you may change your username, email associated with your account, and ‘home’ location through your account without contacting Slow Ways CIC.

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