1. Data controller
The data controller for the personal data collected or generated through this website is:
- Controller: FUNDACIO DE RECERCA CLINIC BARCELONA-INSTITUT D'INVESTIGACIONS BIOMEDIQUES AUGUST PI I SUNYER (FRCB-IDIBAPS).
- Tax ID: G59319681
- Address: C/ Rossello, 149-153, 08036 Barcelona, Spain.
- Data protection contact: protecciodades@recerca.clinic.cat
2. Scope of this policy
This policy applies to personal data processed through:
- Browsing the website.
- The contact channels published on the website.
- Communications sent through the project's general email address.
- Requests for information submitted by patients, family members, researchers or healthcare professionals.
- Management of access to the private area, where individual users or credentials are used.
- Queries related to collaboration on the project or referral pathways for potential participants, without sending clinical or identifying data through these channels.
- Technical or security incidents reported by users.
Simply consulting general information about the project does not in itself involve the collection of patient data. However, the server, email, cookies and restricted-access system may give rise to the processing of personal data under the terms described in this policy.
3. Personal data processed
Depending on how the website is used, the following categories of data may be processed:
3.1. Browsing data
- IP address.
- Date and time of access.
- Browser and device.
- Operating system.
- Referring page.
- Technical and security logs.
- Information about errors or attempted unauthorized access.
3.2. Data provided through the website contact form
- First and last name.
- Email address.
- Telephone number, if provided voluntarily.
- Centre, entity or institution.
- Role or professional profile.
- Content of the enquiry.
- Any other non-clinical information voluntarily included by the user in the enquiry.
3.3. Private area user data
Where access is individualized, the following may be processed:
- First and last name.
- Professional email address.
- Affiliated centre or entity.
- Role or function within the project.
- Username.
- Access history.
- Activity and security logs.
Access credentials will be managed using appropriate security mechanisms. Passwords must not be displayed or stored in readable text.
4. Purposes and legal bases
A. Managing general project enquiries
Purpose: to answer questions about ASPIRE-AECC, its objectives, outreach materials, participating entities, centres and contact methods.
Legal basis: the data subject's consent (Article 6(1)(a) GDPR), expressed through the voluntary submission of the contact form and acceptance of the data protection information provided in it.
B. Managing requests from researchers and healthcare professionals
Purpose: to handle requests for information, potential collaboration proposals, scientific enquiries or communications related to the identification or referral of potential participants.
Legal basis: the legitimate interest of FRCB-IDIBAPS (Article 6(1)(f) GDPR) in promoting and managing scientific and professional collaboration relationships. Where the request relates to a specific contractual or pre-contractual relationship, Article 6(1)(b) GDPR may also apply.
C. Managing access to the private area
Purpose: to identify and authenticate authorized users, provide access to project documents and calendar, manage permissions and maintain repository security.
Legal basis: performance of the professional or contractual relationship linked to the project, where applicable (Article 6(1)(b) GDPR), and the legitimate interest of FRCB-IDIBAPS in controlling access and protecting restricted-access information (Article 6(1)(f) GDPR).
D. Ensuring technical security
Purpose: to prevent unauthorized access, detect incidents, retain technical records, resolve errors and protect the integrity of the website.
Legal basis: the legitimate interest of FRCB-IDIBAPS in ensuring the security of its systems (Article 6(1)(f) GDPR) and, where applicable, compliance with relevant legal obligations (Article 6(1)(c) GDPR).
E. Handling rights requests and legal obligations
Purpose: to process requests for access, rectification, erasure, objection, restriction or portability, and to respond to requests from competent authorities.
Legal basis: compliance with legal obligations applicable to FRCB-IDIBAPS (Article 6(1)(c) GDPR).
5. Health data and communications about potential participants
The ASPIRE-AECC website does not request and is not designed to collect health data from patients or potential participants through its general contact channels.
Patients, family members, researchers and healthcare professionals must not send medical reports, test results, clinical images, medical record numbers, patient-identifying data or any other health-related information through these channels.
Enquiries about possible participation or referral must be limited to requesting information about the appropriate centres and channels. Eligibility assessment, informed consent and any processing of clinical data will be carried out exclusively through the official clinical trial procedures and outside this website.
6. The website is not a clinical data management platform
The ASPIRE-AECC website is a dissemination, information and document-coordination site.
It is not used to:
- Register or directly select patients.
- Create medical records.
- Collect data from the trial's case report form.
- Manage clinical informed consents.
- Provide clinical follow-up.
- Store samples, images or medical results.
- Report adverse events.
- Replace the official clinical trial platforms and procedures.
Data relating to clinical trial participants will, where applicable, be processed in the study systems and in accordance with the specific study documentation, and not under this general website policy.
7. Recipients
The data may be accessible, where necessary, to:
- Authorized FRCB-IDIBAPS staff.
- Authorized research or project-management staff.
- Technology providers delivering hosting, maintenance, security, support or website management services.
- Public authorities, courts, tribunals or supervisory authorities where there is a legal obligation.
Providers that access personal data on behalf of FRCB-IDIBAPS will act as data processors where appropriate and will be subject to the relevant contract, instructions, confidentiality obligations and required security measures.
The funding of the project by the AECC Scientific Foundation does not in itself imply that AECC is a controller or joint controller, nor that it receives personal data obtained through this website.
8. International transfers
International data transfers, if necessary due to the use of certain technology providers, will only be carried out where there is an appropriate legal basis and adequate safeguards under the GDPR.
Where a provider processes data outside the European Economic Area, FRCB-IDIBAPS will apply, as appropriate, an adequacy decision, standard contractual clauses or another valid mechanism provided for by law.
Specific information about providers and, where applicable, relevant international transfers will be reflected in this policy or in the Cookie Policy where appropriate.
9. Retention periods
The data will be kept for the following periods or according to these criteria:
- General enquiries: for the time necessary to respond and follow up on the enquiry.
- Collaboration requests: while the request is being managed and afterwards for the period required to address potential liabilities.
- Private area access data: while the user remains authorized and linked to the project.
- Security logs: for the period necessary to investigate incidents and ensure security, in accordance with the applicable internal policy.
- Rights-exercise requests: for the time necessary to prove their processing and compliance with legal obligations.
- Data subject to legal obligations: for the periods required by applicable law.
Once the relevant periods have ended, the data will be securely deleted or blocked.
10. Data subjects' rights
Data subjects may exercise the following rights:
- Access to their personal data.
- Rectification of inaccurate data.
- Erasure of data where applicable.
- Objection to processing.
- Restriction of processing.
- Data portability where applicable.
- Withdrawal of consent, without affecting the lawfulness of prior processing.
- The right not to be subject to decisions based solely on automated processing, where applicable.
To exercise these rights, a request may be sent to:
The request must indicate the right being exercised and include the information needed to verify the applicant's identity.
If the person believes that the processing of their data does not comply with the regulations, they may lodge a complaint with the Catalan Data Protection Authority (APDCAT): https://apdcat.gencat.cat/.
11. Security
FRCB-IDIBAPS will apply technical and organizational measures appropriate to the risk to protect data against loss, alteration, access, disclosure or unauthorized processing.
In relation to the private area, FRCB-IDIBAPS will establish appropriate and proportionate security measures, including, where applicable:
- Controlled management of access credentials and, where the configuration allows, individualized credentials.
- Strong passwords.
- Protection against repeated access attempts.
- Periodic review of authorized users.
- Immediate deactivation of users who are no longer involved in the project.
- Encryption of communications via HTTPS.
- Access and incident logging.
- Backups.
- Permission restrictions according to each user's functions.
- A technical and organizational prohibition on storing clinical or patient data.
12. Minors
The website is informative in nature and is not specifically directed at minors.
Minors must not send personal data through the website's contact channels without the involvement of their parents or legal representatives where this is required.
13. Automated decisions
No decisions with legal effects on users are made solely on the basis of automated processing, nor are profiles created from the data collected on the website.
14. Links and third-party content
The website may include links, videos or resources hosted by third parties. These services may collect browsing data or install cookies in accordance with their own policies.
Third-party content or services that involve non-essential cookies or data communications subject to consent will not be loaded until the user has given that consent, where required.
15. Changes to the privacy policy
FRCB-IDIBAPS may update this policy whenever functional, regulatory, technical or processing changes occur in connection with the website.
The changes will be published in this same section and will include the date of the latest update.
Last updated: 07/09/2026