Privacy Policy

Last updated: May 21, 2026

1. Overview

HUB Digital - INOV-NORTE (“we”, “us”) is committed to protecting your personal data. This Privacy Policy explains what information we collect, how we use it, and your rights under the General Data Protection Regulation (GDPR).

2. Information We Collect

We process personal data provided directly by you, generated through platform usage, or collected automatically:

Account Data: Name, email address, professional affiliation (institution/organization), and secure hashed password.
Profile Information: Public-facing biography, professional credentials, profile photo, and teaching or research interests.
Toti AI Assistant Interactions: Conversational queries, prompt history, and interactions submitted to our virtual assistant to facilitate responsive guidance.
Gamification & Progress Data: Unlocked achievements, accrued experience points (XP), current learning levels, and active login streaks.
User-Generated Content & Suggestions: Open Educational Resources (OERs), digital tools, pedagogical methods, case studies, best practices, posts, comments, associated metadata, and files uploaded through the suggestion wizards.
Usage Data: IP address, browser type, operating system details, access times, and page interaction logs.
Communications: Support queries, feedback, direct messages, and team invitations.

3. Purposes and Use of Data

Your data is used to:

Create, secure, and manage your account.
Enable the sharing, indexing, and discoverability of Open Educational Resources (OERs) and digital tools.
Provide access to courses, record progress, and track learning achievements.
Deliver the Toti AI Assistant service by processing inputs against our internal catalog and specialized language models to generate contextual answers.
Display display names, learning levels, unlocked achievements, and login streaks on public leaderboards and peer discovery sections in the community network.
Administer team collaboration, team creation, and member invitations.
Maintain website security, prevent system abuse, and comply with EU/Portuguese legal obligations.

4. Legal Basis

Data is processed under one or more of the following lawful bases:

Consent: Your express agreement when you register, modify your profile, or upload resources.
Performance of a Contract: Providing access to courses, catalog tools, and general platform functionalities.
Legitimate Interests: Platform administration, optimizing catalog search, maintaining the AI assistant, and organizing community gamification.
Legal Obligation: Compliance with applicable reporting, funding, or administrative legal mandates.

AI Service Processors: Conversational inputs submitted to the Toti AI Assistant are processed securely via API orchestration (such as Azure OpenAI). We do not share account credentials or direct personal identifiers (like emails) with these processors.
Platform Community: Content contributed via suggestion wizards (resources, tools, best practices, etc.) and selected gamification metrics (XP, level, streak) are displayed publicly to support peer discovery and academic collaboration.
Service Providers: Media uploads and files are securely stored on S3-compatible cloud providers (AWS S3) under strict confidentiality agreements.
Legal Compliance: Data may be disclosed to public authorities only if required by Portuguese or European law.

6. Cookies and Tracking

We prioritize your privacy by keeping tracking to a minimum:

Plausible Analytics: We use Plausible Analytics for website usage metrics. This is a privacy-first, cookieless, and fully GDPR-compliant analytics tool. It does not collect personal data, track individual users across devices, or store any cookies.
Functional Cookies: We use essential, functional cookies to manage active sessions (auth_session) and persist user interface preferences (NUXT_LOCALE for language settings). These cookies do not track you across other websites.

7. Data Retention

Personal data is retained only for as long as your account remains active or as required to fulfill the academic and funding reporting requirements of the INOV-NORTE initiative.
Deleted accounts will have their personal profile data permanently removed, though contributed educational resources may persist anonymously for community utility.

8. International Data Transfers

Personal data is hosted and processed within the European Union. In the event that any sub-processors (such as secure AI endpoints) require processing outside the EEA, adequate transfer safeguards (e.g., European Commission Standard Contractual Clauses) are strictly enforced.

9. User Rights

Under the GDPR, you have the right to:

Access, correct, update, or request the deletion of your personal data.
Withdraw your consent at any time without affecting prior lawful processing.
Object to processing, request restriction of processing, or request data portability.
Lodge a complaint with the Portuguese Data Protection Authority (Comissão Nacional de Proteção de Dados - CNPD).

To exercise any of these rights, contact our Data Protection Office at cip@sc.ipp.pt.

10. Children’s Data

The Platform is designed for adult educators, researchers, and higher education students. If any educational resources or community areas are accessed by individuals under the age of 18, parental or guardian authorization is required.

11. Third-Party Links

Our Platform contains links to external websites, academic resources, or third-party digital tools. We are not responsible for the privacy policies or content of external providers.

12. Security

We implement standard administrative, technical, and organizational measures (such as TLS encryption, secure database proxies, and hashed password storage) to safeguard your personal data from unauthorized access, alteration, or disclosure.

13. Policy Updates

This Privacy Policy may be revised to reflect changes in our services or legal frameworks. Substantive updates will be highlighted on the platform or sent via email notification.

14. Contact

For any questions, requests, or privacy concerns, please contact us:

Email: cip@sc.ipp.pt
Address: Edifício da Biblioteca do Politécnico do Porto, Rua Dr. Roberto Frias, 712, 4200-465 Porto, Portugal
Phone: (+351) 225 571 097
Mobile: (+351) 961 017 608