EmpathyTool Mobile Application
Developed by MaaSLab under the Horizon Europe project InclusiveSpaces (Grant Agreement No. 101147881)
Last updated: July 16, 2025
Empathy Tool is an online Application developed by MaaSLab under the project "InclusiveSpaces", which is a Horizon Europe project supported by the European Commission under Grant Agreement No. 101147881.
The Empathy Tool is published by MaaSLab ("Owner") and for the purpose of the GDPR Act 2018 (the "Act"), the data controller is MaaSLab.
Users can download the Empathy Tool from the Google Play Store or the Apple App Store, depending on their device. Once downloaded, users can access the app by clicking the Empathy Tool icon on their mobile device. During login, users may register using existing accounts such as Facebook, Google, or Apple.
By registering with the Empathy Tool, users give their consent for their user profile data to be shared with urban planners, policymakers, and researchers. This consent enables the development of inclusive, gender-sensitive, and accessible transport solutions informed by real user experiences. The primary aim is to report and address accessibility barriers encountered by individuals with disabilities in their daily mobility.
By registering, users consent to the use of their data for the integrated purpose of supporting an EU-funded environmental and infrastructure safety initiative. Refusal to consent will result in non-usage of the application. Consent is essential and cannot be withdrawn selectively due to the application's core functionality. Users may, however, delete their account at any time.
Empathy Tool ("We") is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Empathy Tool may collect the following categories of personal data:
Complete details on each type of Personal Data collected are provided in the dedicated sections of this Privacy Policy or via specific prompts before collection. Personal Data may be freely provided by the User, or, in the case of usage data, automatically collected during use.
All requested data is considered mandatory unless otherwise stated. Failure to provide such data may result in limited or unavailable services. Users uncertain about which data is mandatory are encouraged to contact the Owner.
This section applies to all Users located within the European Union, with particular emphasis on individuals with disabilities participating at the project demonstration sites of InclusiveSpaces in Larnaka, Geneva, and Budapest. It is provided in accordance with the General Data Protection Regulation (GDPR) and, for such Users, takes precedence over any conflicting or inconsistent provisions contained elsewhere in this Privacy Policy. Comprehensive information can be found in the relevant sections of this Privacy Policy below.
The Owner of this Application implements appropriate technical and organizational security measures to protect Personal Data against unauthorized access, disclosure, alteration, or destruction. These measures comply with the General Data Protection Regulation (GDPR) and aim to uphold the confidentiality, integrity, and availability of the Data throughout the entire data lifecycle.
The Owner may process Personal Data relating to Users if one of the following applies: Users have given their consent for one or more specific purposes like when the provision of Data is necessary for the performance of an agreement with the User; processing is necessary for compliance with a legal obligation to which the Owner is subject; processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Data processing is carried out under Article 6(1)(e) of the GDPR, as necessary for the performance of a task carried out in the public interest under the EU Horizon Europe project InclusiveSpaces, with a focus on environmental protection and road infrastructure safety.
Data may be processed:
Users may contact the Owner to clarify the applicable legal basis.
Data is processed using secure IT systems and tools under contractual safeguards, following strict organizational procedures aligned with the purposes described in this Privacy Policy. Processing is carried out by the Owner.
The Empathy Tool collects and processes data to inform the development of inclusive, gender-sensitive, and accessible transport solutions. It reflects users' lived experiences and is used strictly for research, planning, and policy development in collaboration with urban planners, authorities, policymakers, and researchers—ensuring a data-driven, participatory approach to mobility planning. Data is also processed to ensure compliance with legal obligations, handle enforcement requests, protect rights, and detect fraudulent activity.
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests detect any malicious or fraudulent activity. The permissions asked are the following:
By default, this includes certain User's Data such as id, name, gender, and their locale.
Access the User's contact email address.
Provides access to the User's primary email address.
Share items on the User's behalf.
We use the information we collect to:
All information you provide to us is stored on our secure servers. Where you have chosen a password which enables you to access the app, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
In addition, we use the information we hold about you to ensure that content from our app and associated services is presented in the most effective way for your device, to fulfill any contractual obligations between us and you, to enable participation in interactive features when chosen, and to inform you about updates to our services.
Users may provide data through the Empathy Tool in various formats, including written text, images, and audio recordings. This flexibility supports user preferences and accessibility needs, in alignment with universal design principles. The application is designed to accommodate all individuals—regardless of gender, age, or disability—ensuring equitable participation in the data collection process.
Upon completing the registration phase, users can immediately begin using the Empathy Tool. To start recording daily trips, the user simply needs to grant the app permission to access their location. The application records the route and transport mode used. A key feature of the tool allows users to report areas they perceive as inaccessible. Users can choose from a predefined list of inaccessibility categories and submit a report using the format they are most comfortable with (text, image, voice or combination).
Users may edit their submitted reports within the app. Each report includes predefined inaccessibility categories and can be modified to reflect additional details or corrections after submission.
Upon registration, users can (per demonstration city):
The Empathy Tool is integrated with a secure, web-based dashboard that displays the results collected through the application. Access to this dashboard is restricted to authenticated stakeholders, who can log in to view anonymized reports and site-specific data. The web-based dashboard is accessible only to authorized, authenticated parties. Also, Data is anonymized or pseudonymized, and shared based on the principles of data minimization, purpose limitation, and transparency as outlined in the GDPR.
Empathy Tool may request the following permissions, depending on the user's device. These permissions must be granted before the respective features are enabled. Users can revoke permissions at any time through their device settings:
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users' consent. Therefore:
Upon account deletion, personal data is erased, and location-based data is anonymized and retained solely for scientific research under Article 89 GDPR. This supports the EU project's public interest goals of CO₂ reduction and accessibility improvement.
Users cannot withdraw their consent to core data processing without deactivating their account, as such data is integral to the EU project mission. This restriction is legally grounded in Article 6(1)(e) GDPR.
Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following, to the extent permitted by law:
Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. When users deactivate their account, they should be aware that they will no longer have access to the app unless they register again.
Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Users have the right to obtain the erasure of their Data from the Owner.
Users have the right to bring a claim before their competent data protection authority. However, if users have provided their explicit consent to the processing of their personal data, they may not lodge a complaint regarding that processing unless they first withdraw their consent.
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner. If users have already given their explicit consent to the processing of their personal data, they do not have the right to object unless they first withdraw their consent.
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users' request, the Owner will inform them about those recipients.
Users can deactivate their account by:
Users may re-register at any time.
Any updates or changes to this Privacy Policy will be posted on this page. Users are advised to review the policy periodically.
For any questions, comments, or requests regarding this Privacy Policy or data protection practices, please contact the Owner at the email address provided within the application (dpo@maaslab.org).