Date: 25th of August 2021
With MOTUS we ask users (the “Respondents”) to take part to a study (the “Study”). Studies include the completion of questionnaires, diaries and the inclusion of sensor data. The latter includes location information. A study has an assigned duration in advance and is voluntary. Studies can offer personal feedback to the respondent.
Studies are designed and executed by the Vrije Universiteit Brussel (VUB-Belgium) and hbits CV as spin-off of the Research Group TOR of the VUB.
Your privacy is very important to us. Before we get to the details, check out our Privacy Label to see a summary of our privacy practices. Below the Privacy Label the full policy can be found.
|Collection of data|
|- Do we manage, store and process your Personal data during the Study?||Yes|
|- Do we manage, store and proces your Personal data after the Study?||No|
|- Do we use external plugins to collect, manage, store and process Study data?||No|
|- Do we collect, manage, store and process User data?||Yes|
|- Do we track your device location when you use MOTUS?||Yes, with your consent|
|- Do we track your device location when you are not using MOTUS actively?||Yes, with your consent|
|Processing of data|
|- Do we pass on your Personal data to research partners?||No|
|- Do we pass on your Personal data to commercial companies?||No|
|- Do we pass on your Study data to research partners?||Yes|
|- Do we pass on your Study data to commercial companies?||No|
|- Do we pass on your Sensor data to research partners?||No|
|- Do we pass on your Sensor data to commercial companies?||No|
|- Do we pass on your User data to research partners?||No|
|- Do we pass on your User data to commercial companies?||No|
|- Do we process Study data to aggregated information?||Yes|
|- Do we share or sell aggregate information?||Yes|
|- Do we use your Study data to apply for research funding?||Yes|
|Privacy and Control|
|- Can someone else see your data in MOTUS?||No|
|- Can you control the privacy settings in MOTUS?||Yes|
|- Can you exercise your rights under GDPR?||Yes|
|- Can you make a complaint?||Yes|
The VUB, represented by the rector, is the controller for the processing of the Personal data of respondents. The VUB has appointed a Data Protection Officer who assists the VUB in monitoring all processing of Personal data that takes place at the VUB.
MOTUS and the Services are managed by the Research Group TOR of the VUB (VUB-TOR), led by Prof. Ignace Glorieux (Ignace.Glorieux[at]vub.be; +32 2 614 81 55). The project manager is Joeri Minnen (Joeri.Minnen[at]vub.be; +32 2 614 81 49). Specific contact details may be provided for each study.
Scope and acceptance of this Privacy Statement
Collection of data
MOTUS makes it possible to collect, manage, store and process data from respondents. MOTUS receives information in a few different ways, including when you answer questions, register, track, complete or submit activities using the Services. Because the Services are used for various studies, large quantities of data are collected and managed. This may vary for each study. Only the information that is necessary in relation to the research questions is requested.
Personal data are collected, managed, stored and processed for one of the following purposes:
- Organising registrations for, invitations to and participation in Studies;
- Drawing up group profiles;
- Conducting Studies inside and outside the university and for statistical purposes;
- Contacting the winners of competitions or paying compensation in connection with a Study;
- Verifying whether confidential material provided to MOTUS respondents is being used properly.
In what follows, a distinction is made between Personal data, Study data, Sensor data and User data that MOTUS collects, manages, stores and processes with the respondent’s consent.
Much of the Personal data is used to identify respondents as individuals, to contact them in the context of studies conducted via MOTUS and to secure and provide access to our Services. These data are first name, last name, sex, date of birth, language, address (street, number, postal code, city and country), email address, telephone details (landline, mobile phone) and the push tokens of the respondent’s devices. Part can also be used as Profile information.
To make it possible to recall the details of conversations at a later time, in the context of a study communication with the respondent is also recorded.
The overarching goal of MOTUS is to capture study data on the behaviour, opinions, norms and values of respondents. This is done through having respondents independently answer questions and keep a diary, activating sensors (see further) and connecting relationships (e.g. family relationships). People’s behaviour in daily life stands central. Respondents give consent to the collection of these data.
Upon consent data can also become available via data linking. Databases may be other collected databases within MOTUS, but also administrative databases or databases that provide more context about respondents’ behaviour.
Research is only conducted on a combined dataset between pseudonymised or anonymised personal data, study data and user data such that it is not possible to identify the respondent. To use a complex term, this is called differentiated privacy. To give an even more complex explanation, differential privacy which is a system for publicly sharing information about a dataset by describing the patterns of groups within the dataset whilst withholding information about individuals in it.
Location information is being captured by our Services through the use of sensors available in the mobile application. To assess quality information on the daily life of people an accurate display of time and location is necessary. We collect and process location information when you sign up for and use the Services. Upon giving consent location tracking is active while you use MOTUS (foreground tracking) and also when you are not using MOTUS actively (background location tracking).
Foreground tracking is done to assess location information at the moment answers to questions are given, and when respondents register activities in their diary.
Background tracking and the processing of location information is used to build up a tentative data overview showing time, place and (if available) transport mode as necessary information in order to successfully complete a diary.
A diary length can be of various durations (a day, a few days, a week or even longer). During this period the MOTUS application might not always be used by the respondent (foreground tracking). Therefore background tracking is essential in providing a tentative data overview at the moment the respondent uses MOTUS. The tentative information is shown to the respondent and upon acceptance it becomes committed data. In the process of committing data tentative data can be corrected or supplemented. The committed data is used as Study data. The respondent stays in control of his/her own data, as the tentative data provides the respondent the necessary assistance to commit data to the dairy. The more accurate diaries are complete the higher the quality and the better personal feedback can be given back to the respondent.
The location data can also be used in interaction with a geofence. At the moment a geofence is entered, dwelled or exited the respondent can receive extra questions in relation to the specific location or region.
To protect the respondents privacy, location information is only stored during the phase when the respondent is asked to complete a task, during the period of completing a task or when interacting with a geofence.
User data are collected during respondents’ interactions with MOTUS. These User data are collected to provide a better service to respondents, but also to make it easier to contact respondents. As MOTUS is used, information is collected about when respondents use MOTUS and what devices and operating systems are used. This allows in-app messages to be sent.
Cookies are used on the MOTUS website. Cookies are small data or text files that are placed on a computer by the websites that people visit. They are widely used to make websites work more efficiently and to provide information to website administrators.
MOTUS only uses first-party cookies. These are cookies that are created and placed by employees of MOTUS. MOTUS does not use third-party cookies. No information is forwarded to others via cookies.
The first-party cookies are:
- Session cookies: these are temporary cookies that are deleted when a browser is closed. In the case of MOTUS, they coincide with the necessary cookies, and are there to allow respondents to browse the MOTUS website and make use of its features.
- Permanent cookies: these cookies remain available to a browser until they are deleted. They are there in order to recognise returning respondents and make it possible to display information that respondents have previously provided. When a cookie is able to identify a respondent as a returning visitor, information such as login data does not constantly need to be re-entered.
- Necessary cookies: these cookies are strictly necessary for browsing the MOTUS website and making full use of its features.
- Cookies that send information to MOTUS: these cookies store certain aspects of respondents’ browsing behaviour on the MOTUS website. The information that is collected concerns when and for how long a visitor uses the application, what devices the user uses to log in and register data, and what browser or browser version is used. This information is used for support and statistical purposes.
Due to the composition of the cookies and the fact that only first-party cookies are used by MOTUS, no acceptance of underlying cookies by the respondent is required.
To be able to analyse the data better, the data are also enriched with labels and further metadata information.
Transaction data are required in relation to the compensation that respondents may receive for their participation in studies. When a respondent is eligible to withdraw his or her compensation, a transaction takes place between MOTUS and the respondent. The transaction summary is retained for legal reasons and in order to demonstrate that these data and transactions are the subject of proper administration. We do not store any account information.
Children's personal data
MOTUS does not knowingly collect or solicit personal data from children under the age of 16. If MOTUS has inadvertently collected personal data from a child under the age of 16, it will remove such personal data from its archives as soon as reasonably possible. It is possible to collect personal data from children under the age of 16 directly from the parent or guardian and hence with his/her explicit consent.
Purpose of data collection
MOTUS is a research tool used for collecting study data with the aim of gaining more insight into people’s behaviour and, from the central perspective of behaviour, gaining insights into opinions, norms and values.
Research questions may originate from educational institutions, government agencies, international authorities, non-governmental organisations, non-profit organisations, public corporations and commercial companies. They may be multidisciplinary, with relevance to multiple scientific fields.
Research is only conducted on a combined dataset between pseudonymised or anonymised personal data and study data such that it is not possible to identify the respondent.
MOTUS uses Virtual Private Servers (VPSs) located in the EU that are only accessible to the project managers and the head of the IT department. The servers have been completely adapted by MOTUS employees and the database structures have been developed by MOTUS employees. As a result, MOTUS itself determines the types of data that come in and the security level.
MOTUS has maximum protection against theft, and even in the event of theft it would be almost impossible to retrieve and combine personal data, study data or user data since the information is spread across different servers. Digital keys are required to combine data. In order for data to be combined, a theft would have to take place simultaneously on different servers and in different locations, and even then, it would be difficult to assemble the data without prior knowledge. The same applies to data protection in terms of confidentiality (including against loss or negligence), but also in terms of integrity, accessibility and authenticity.
However, there is no such thing as a cast-iron guarantee. Should a theft, DDoS attack, loss, crash, or incident involving downtime or negligence nevertheless occur in spite of every effort, compensation may not be claimed for this, unless there has been negligence in meeting the obligations set out in the General Data Protection Regulation or GDPR. However, MOTUS warrants that data protection and security standards are continuously optimised to ensure an environment that is as efficient as possible at all times. The privacy of MOTUS respondents is the primary concern.
The VUB will not rent, sell or pass on personal data to third parties for financial gain. Data that can be traced back to individuals will only be provided to third parties if there is a legal basis or obligation for this, if the processing is necessary in order to represent the legitimate interests of the data controller or a third party, if it is necessary for the implementation of an agreement with the data subjects, or if the data subject has explicitly consented to the transfer of the data.
In accordance with the objectives of MOTUS, the personal data, study data and user data that are present within MOTUS are only available to the VUB, the Research Group TOR and the joint data controller hbits CV, a spin-off of the Research Group TOR.
The basis for data delivery is provision of study data. Data deliveries usually represent a limited part of the available study data related to the research question under consideration, and are supplemented with personal data or data derived from personal data.
The data may be made available in the exclusive or combined form of:
- Personal data
- User data
- Pseudonymised data
- Anonymised data
- Study data or a subset thereof
The VUB and hbits CV have access to all data and may combine them: personal data, study data and user data. Educational institutions and governments may submit a request for a subset of study data combined with pseudonymised or anonymised personal data, depending on the research question. NGOs, non-profits and public corporations may make similar requests, but only in combination with anonymised data. Commercial companies may only submit requests for results or statistical data, which in turn are available to everyone when they have been made public.
Personal data that are anonymised are recoded (reconstituted) in such a way that an individual cannot be identified. If an (anonymous) digital key is added so that the personal data can be made transparent again at a later time, this is referred to as pseudonymisation. Pseudonymisation would be possible, for example, if the client also needs future databases for its research question, and so wants to monitor changes in a personal profile and the combined study data.
It is important to stress that the respondent’s identity is also preserved with pseudonymisation. The database user cannot find out the respondent’s identity by means of pseudonymised personal data. The database can only be further enriched with additional study data and updates of the pseudonymised personal data with the cooperation of the MOTUS project manager. If pseudonymisation will be used in the study, the respondents will be informed and must give their consent.
Data retention period
Respondents are asked to participate in studies through MOTUS. After data collection has been completed and the databases prepared for scientific research, the personal data, study data and user data are anonymised in accordance with the law on the protection of personal data.
Study data have a maximum retention period of ten years, unless stated otherwise when information is provided about the study and with the approval of the VUB’s DPO.
If, in the context of a study, respondents need to be surveyed again at a later date, the personal data, study data and user data are pseudonymised. Respondents’ personal data are stored within MOTUS. When respondents wish to be part of BEHAVE, they agree to the transfer of personal data, study data (composite or otherwise) and user data to BEHAVE. At that point, such respondents become BEHAVE panel members. As long as respondents are members of the BEHAVE panel, the data that BEHAVE collects, manages, stores and processes will remain available to BEHAVE for an indefinite period. When a panel member leaves, the collected data are also anonymised in accordance with the law on the protection of personal data. Again, a retention period of ten years applies to this anonymous data, unless otherwise determined in consultation with the VUB’s DPO.
Rights with regard to personal data
Every individual, and hence every MOTUS respondent, has certain rights under GDPR.
The General Data Protection Regulation (GDPR), a European regulation that gives individuals far-reaching rights with regard to personal data and data protection, has been in force since 25 May 2018. In certain cases, and depending on the legal basis on which the VUB processes the personal data in question, individuals may be entitled:
- to ask what personal data about them are being kept and, if these data have been provided to the VUB by a third party, to inquire about the source of the data;
- to ask for data be rectified if it is incorrect;
- to object to the processing of their data;
- to request the transfer of their data to third parties or obtain a copy of them in a readable or machine-readable form;
- to be informed of the existence of any automated decision-making, and, if profiles are drawn up on the basis of this, to be informed of the underlying principles, importance and consequences thereof;
- if a number of conditions are met, to ask to be ‘forgotten’ by the organisation that has processed their personal data.
Compliance with privacy legislation and complaints
At a national level, the Data Protection Authority (DPA) is the authority that supervises compliance with all privacy legislation and to which complaints can be submitted about the processing of personal data. The DPA can be contacted at: Drukpersstraat 35, 1000 Brussels, or by telephone on +32 2 274 48 00, or by email at contact[at]adp-gba.be. More information about the DPA is available at www.gegevensbeschermingsautoriteit.be. An online form for complaints is available at: https://www.gegevensbeschermingsautoriteit.be/burger/acties/klacht-indienen
Information can also be obtained from and complaints submitted to the Data Protection Officer of the VUB, who can be contacted at dpo[at]vub.be.