Innovation Manager

Privacy Policy

July 22, 2026

The protection of your personal data is important to Compellio S.A. ("Compellio", "we", "us"). This Privacy Policy informs you about how personal data is processed when you use the Innovation Manager service ("Service") and about the rights available to you.

The following information applies to registered users and to visitors who access the Service without registering an account. The Service is delivered over the web and is accessible at https://app.innovation-manager.io.

The processing of your personal data is always carried out in accordance with the General Data Protection Regulation ("GDPR") and applicable national data-protection law, including the law of the Grand Duchy of Luxembourg.

1. Controller

The controller within the meaning of the GDPR is:

Compellio S.A.
‍
21 Rue Glesener
L-1631 Luxembourg, Luxembourg

For any question regarding this policy, or to exercise your rights, you can contact us at privacy@innovation-manager.io.

2. Definitions

This policy is based on the terminology of the GDPR. For your convenience, the main terms are explained below:

  • Personal data (or data): any information relating to an identified or identifiable natural person.
  • Usage data: information collected automatically, such as IP addresses, request metadata, and the browser and operating system used.
  • Processing: any operation performed on personal data, such as collection, storage, use, disclosure, restriction or erasure.
  • Controller: the party that determines the purposes and means of the processing. For the Service, this is Compellio S.A.
  • Processor: a party that processes personal data on the controller's behalf.
  • Recipient: a natural or legal person to whom personal data is disclosed.
  • Data subject: the natural person to whom the personal data relates.
  • User: the individual using the Service, who unless otherwise stated is the data subject; this includes visitors who do not register an account.
  • Content: material created or uploaded by users while using the Service.
  • Trackers / cookies: any technology that enables information to be stored on, or accessed from, your device.

3. Origin of the personal data

We obtain personal data in the following ways.

3.1. Information you provide

You provide personal data when you register (first name, last name and email address), when you complete optional profile information, when you submit a project or work within the Service (including content and files you upload), and when you apply to an open call through a public application form.

3.2. Data collected automatically

Certain data is generated automatically when the Service is accessed, including from visitors who do not register an account: your IP address, the information contained in system logs (which may include the browser and operating-system type and the pages accessed), and the date of your most recent login, which is used to administer and secure your account.

3.3. Data collected through integrated third-party services

To deliver and secure the Service, components provided by third parties are integrated into the application. When these load, limited technical data — in particular your IP address — is disclosed to the relevant provider. Profile images are displayed through a third-party service using a pseudonymised identifier.

4. Scope, purposes, legal bases, storage and recipients

4.1. General information

The processing of your personal data may be based on the following legal bases:

  • Art. 6 (1) lit. b) GDPR, where processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract;
  • Art. 6 (1) lit. c) GDPR, where we are subject to a legal obligation that makes processing necessary; and
  • Art. 6 (1) lit. f) GDPR, where processing is necessary for a legitimate interest pursued by us and your interests, fundamental rights and freedoms do not override that interest.

We do not profile our users, do not use analytics or advertising technologies, and do not currently collect payment or financial data through the Service.

Where we rely on our legitimate interests, we have carried out and documented a balancing assessment and concluded that our interest is not overridden by your rights and freedoms; a summary is available on request. You may object as described in section 5.

Where you provide personal data relating to other people through the Service, you are responsible for ensuring that you are entitled to do so.

4.2. Data transfers to third countries

Some of the providers we use, or the corporate groups to which they belong, are established outside the European Economic Area (EEA), including in the United States and the United Kingdom; the place of processing for each named provider is indicated in the sub-processor table in section 4.6. Where personal data is transferred outside the EEA, it is protected by appropriate safeguards, in particular the EU–US Data Privacy Framework and/or the European Commission's Standard Contractual Clauses. You can request details of the safeguard applied to a specific transfer using the contact details in section 1.

4.3. Data retention and deletion

We retain personal data only for as long as it is needed for the purposes described in this policy.

Account and project data are retained for as long as your account remains active. Because project history is kept so that collaborators retain access, data is not deleted automatically; it is deleted when you request deletion of your account and we have verified your identity. Deletion requests are handled manually, and data cannot be recovered once your account is deleted.

Detailed system logs are kept for up to 15 days and are then aggregated; logs relating to suspicious activity or errors may be kept longer where necessary for security. Records that we are required to keep by law, such as accounting records, are retained for the period required by the applicable law.

4.4. Security measures

We apply appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration and loss. These include access controls on a need-to-know basis, encryption of personal data in transit, and further technical and organisational security measures. Where we engage service providers, we conclude data-processing agreements with them as required by Art. 28 GDPR. We keep our security measures under review.

4.5. Detailed information on the processing of personal data

For each processing activity we set out the data concerned, the purpose, the legal basis and the storage period, together with the providers involved. The specific providers named below are listed, with their place of processing, in the sub-processor table in section 4.6.

4.5.1. Registration and account management
  • Data concerned: first name, last name, email address, and technical data.
  • Purpose: to create and administer your account and to provide the Service.
  • Legal basis: Art. 6 (1) lit. b) GDPR.
  • Storage period: for as long as your account is active; deleted on verified request (see 4.3).
  • Providers involved: hosting and email-delivery providers, and the profile-image display provider.

Providing your name and email address is necessary to create an account; if you do not provide it, we cannot create your account or provide the Service.

4.5.2. Projects, content, collaboration and real-time features
  • Data concerned: project descriptions, answers to defined questions, uploaded files and other content (which may themselves contain personal data, including personal data relating to third parties); and, for real-time features, IP address, browser information and session data.
  • Purpose: to enable you to work within projects, to make content available to collaborators in the same project, to produce the outputs you request, and to provide real-time features such as notifications and comments.
  • Legal basis: Art. 6 (1) lit. b) GDPR.
  • Storage period: as set out in 4.3.
  • Providers involved: hosting provider and the real-time-features provider.
4.5.3. Open-call applications
  • Data concerned: the information submitted through a public application form, which may be provided before an account is created.
  • Purpose: to allow the organisation that publishes the open call to review the application and decide whether to accept or reject it.
  • Legal basis: Art. 6 (1) lit. b) GDPR (performance of a contract and steps taken at your request prior to a contract).
  • Storage period: as set out in 4.3.
  • Providers involved: hosting provider; the organisation that publishes the open call, which reviews the application.

The organisation that publishes a given open call is identified on the application form at the point of submission.

4.5.4. Optional profile information
  • Data concerned: location and social-media or contact identifiers, relating to community features that have been discontinued. These fields are optional and are not required to use the Service.
  • Purpose: to display optional profile information where a user has provided it.
  • Legal basis: Art. 6 (1) lit. f) GDPR.
  • Storage period: as set out in 4.3; removed if you delete the information or your account.
  • Providers involved: the provider of the maps-based location-suggestion field.

The Service uses Google Maps features and content to provide location suggestions. When you interact with these features, your data is processed by Google in accordance with the Google Privacy Policy (https://policies.google.com/privacy).

4.5.5. Technical operation, delivery and security
  • Data concerned: IP address, system logs, technical data and limited security signals.
  • Purpose: to operate and deliver the Service, to keep it secure and available, and to prevent abuse, fraud and spam.
  • Legal basis: Art. 6 (1) lit. f) GDPR.
  • Storage period: logs as set out in 4.3.
  • Providers involved: content-delivery and anti-abuse providers; and, as categories, infrastructure and server-management, system-monitoring and incident-alerting providers.
4.5.6. Support and issue handling
  • Data concerned: account data, technical data and, where necessary, limited content.
  • Purpose: to provide technical support and to resolve incidents and defects.
  • Legal basis: Art. 6 (1) lit. f) GDPR.
  • Storage period: for as long as necessary to handle the matter.
  • Providers involved: as categories, email and support services, and incident-alerting and issue-tracking providers.

4.6. Recipients

4.6.1. Sub-processors

We share personal data with service providers acting as our processors, and only as needed to provide, secure and support the Service. The providers below are engaged as processors under data-processing agreements.

  • Hetzner Online GmbH
    • Purpose / service: Hosting and backend infrastructure
    • Personal data: All personal data stored in the Service
    • Data processsing location: EU (Germany)
  • Amazon Web Services, Inc.
    • Purpose / service: Transactional email delivery and system backups
    • Personal data: Email-delivery data; backup data
    • Data processsing location: Data in the EU (Germany); provider established in the United States
  • Cloudflare, Inc.
    • Purpose / service: Reverse proxy, content delivery, traffic optimisation and protection against automated abuse
    • Personal data: IP address; browser and device information; interaction signals
    • Data processsing location: Worldwide; provider established in the United States
  • MessageBird UK Limited
    • Purpose / service: Real-time features (notifications, comments)
    • Personal data: IP address; browser information; session data
    • Data processsing location: EU (Ireland); provider established in the United Kingdom

In addition, we use processors in the following categories, whose specific identities are available on request: infrastructure and server-management services (United States); email and support services (European Union and the United States); system monitoring (servers in the European Union, with a group entity in the United States); incident alerting (Germany); and issue tracking and bug resolution (European Union data residency, with a group entity outside the EEA).

A complete, up-to-date list of our sub-processors, including those referred to above by category, is available on request at the contact details in section 1.

4.6.2. Independent controllers and other recipients

The Service relies on the third parties to offer location-suggestions, load required scripts and assets, and display profile images. The recipients below act as independent controllers, and are responsible for their own processing under their own privacy policies.

  • Google Ireland Limited
    Google LLC

    • Purpose / service: Maps-based location-suggestion field (Google Maps Platform)
    • Privacy policy: https://policies.google.com/privacy
    • Personal data: Usage data (disclosed on asset load); location-query data (disclosed on user interaction)
    • Legal basis: Legitimate Interests (Art. 6 (1) lit. f) GDPR)
  • Google Ireland Limited
    Google LLC

    • Purpose / service: Delivery of required scripts and assets
    • Privacy policy: https://policies.google.com/privacy
    • Personal data: Usage data (disclosed on asset load)
    • Legal basis: Legitimate Interests (Art. 6 (1) lit. f) GDPR)
  • Cloudflare, Inc.
    • Purpose / service: Delivery of required scripts and assets (cdnjs)
    • Privacy policy: https://www.cloudflare.com/privacypolicy
    • Personal data: Usage data (disclosed on asset load)
    • Legal basis: Legitimate Interests (Art. 6 (1) lit. f) GDPR)
  • Volentio JSD Limited
    • Purpose / service: Delivery of required scripts and assets (jsDelivr, BootstrapCDN)
    • Privacy policy: https://www.jsdelivr.com/terms/privacy-policy
    • Personal data: Usage data (disclosed on asset load)
    • Legal basis: Legitimate Interests (Art. 6 (1) lit. f) GDPR)
  • Automattic Inc.

4.7. Cookies and similar technologies

The Service uses only cookies and similar technologies needed to operate and secure the application: session and authentication cookies, used to keep you logged in and to maintain your session, and security cookies, used to protect the Service against automated abuse and to record that a security check has been completed. These cookies are necessary to run and secure the Service, so we rely on our legitimate interests (Art. 6 (1) lit. f) GDPR) to set them; you can object as described in section 5. We do not use advertising, marketing or web-analytics cookies.

5. Your rights

If you wish to exercise any of the rights below, please contact us at privacy@innovation-manager.io or support@innovation-manager.io. Requests are free of charge and are answered as soon as possible and in any event within one month, a period that may be extended by two further months for complex or numerous requests. We may need to verify your identity before acting, and requests that require the deletion of data are handled manually.

5.1. Right to confirmation

You have the right to obtain confirmation as to whether personal data concerning you is being processed.

5.2. Access (Art. 15 GDPR)

You have the right to obtain information about the personal data we hold about you, and a copy of that data.

5.3. Rectification (Art. 16 and Art. 19 GDPR)

You have the right to obtain the rectification of inaccurate personal data concerning you and to have incomplete data completed.

5.4. Erasure / Right to be forgotten (Art. 17 and Art. 19 GDPR)

You have the right to obtain the erasure of personal data concerning you where one of the grounds provided for by law applies.

5.5. Restriction of processing (Art. 18 and Art. 19 GDPR)

You have the right to obtain the restriction of processing where one of the conditions provided for by law is met.

5.6. Data portability (Art. 20 GDPR)

You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and, where technically feasible, to have it transmitted to another controller.

5.7. Objection (Art. 21 GDPR)

You have the right to object, on grounds relating to your particular situation, to processing based on our legitimate interests (Art. 6 (1) lit. f) GDPR). Where you object, we will no longer process the data concerned unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.

5.8. Complaint to a supervisory authority

You have the right to lodge a complaint with a supervisory data protection authority. For Luxembourg, the Commission Nationale pour la Protection des Données (CNPD).

6. Validity and changes to this policy

This Privacy Policy is currently valid and has the status July 2026 (Version 11.0). We may amend it where we further develop the Service, or where legal or regulatory requirements change; prior versions remain accessible. Further details concerning the collection or processing of personal data may be requested from us at any time using the contact details in section 1.

Your personal data may also be used by Compellio for the establishment, exercise or defence of legal claims, and may be disclosed where we are required to do so at the request of public authorities.