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Minor edits to privacy policy (#1704)
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agrabeli authored Mar 4, 2025
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76 changes: 44 additions & 32 deletions content/about/privacy-policy.md
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**Last modified:** October 23, 2024

### CONTROLLER

The controller for the processing of your data is OONI ETS (hereinafter referred to as “**we**”).

If you have any question you can write us at our address Via Ostiense 131L, 00154 Roma (RM), Italy, or to the email [email protected].

We hereby inform you that we will process your data lawfully and fairly in full respect of your rights and, in particular, your privacy, according to Regulation (EU) 2016/679 (hereinafter “**Regulation**”) and other applicable laws and regulations.

### DATA

We will process the following data:

**Browsing data** - When you connect to our system, this will automatically record information that your device sends us. This information may relate to the steps taken, the IP address and MAC address from which you are connecting, the operating system and the language of your device, date and time of your connection, your position.
* **Browsing data** - When you connect to our system, this will automatically record information that your device sends us. This information may relate to the steps taken, the IP address and MAC address from which you are connecting, the operating system and the language of your device, date and time of your connection, your position.

* **Contact information and communications** - When you send us your contact details (email, etc.) and an email or other communication, we will record your contact details and communication.

**Contact information and communications** - When you send us your contact details (email, etc.) and an email or other communication, we will record your contact details and communication.
* **Data on donations made and requested gifts** - When you make donations or request gifts, we will record your identification data, contact data and payment data.

**Data on donations made and requested gifts** - When you make donations or request gifts, we will record your identification data, contact data and payment data.
* **Cookies** - When you use our services, we can send to your device one or more cookies (small text files containing a string of alphanumeric characters):

**Cookies** - When you use our services, we can send to your device one or more cookies (small text files containing a string of alphanumeric characters):

_technical cookies_, that is navigation or session cookies, strictly necessary for the operation of the site or to allow you to enjoy that content and the services that you requested,
* _technical cookies_, that is navigation or session cookies, strictly necessary for the operation of the site or to allow you to enjoy that content and the services that you requested,

_functionality cookies_, that is cookies used to activate specific functionalities of the site and a number of selected criteria (for example, the language or your preferences on the use of cookies) in order to improve the service,
* _functionality cookies_, that is cookies used to activate specific functionalities of the site and a number of selected criteria (for example, the language or your preferences on the use of cookies) in order to improve the service,

_analytics cookies_, that is cookies that allow us to understand how the site is used by users by processing information in aggregate and anonymous form,
* _analytics cookies_, that is cookies that allow us to understand how the site is used by users by processing information in aggregate and anonymous form,

_third-party cookies_, that is cookies of sites or web servers other than the one hosting our service, used, with your consent, for own purposes of such third parties.
* _third-party cookies_, that is cookies of sites or web servers other than the one hosting our service, used, with your consent, for own purposes of such third parties.

### PURPOSES AND LEGAL BASES FOR THE PROCESSING

Your personal data will be processed with the following purposes:
- to provide you with our services,
- to manage donations, gifts shipment and the relationship,
- to provide you with our services;
- to manage donations, gifts shipment and the relationship;
- to evaluate and improve our services and develop new ones, pursuing the legitimate interest in freedom of
association,
- to protect the technical functioning of our system, pursuing the legitimate interest in security,
- to fulfill legal obligations and/or comply with orders from public authorities, including the judicial authorities,
association;
- to protect the technical functioning of our system, pursuing the legitimate interest in security;
- to fulfill legal obligations and/or comply with orders from public authorities, including the judicial authorities;
- to process and diffuse statistics and graphic representations on the use of services (most visited pages, number of visitors per time slot or day, geographical areas of origin, etc.) but only in aggregate and anonymous form, pursuing the legitimate interest in freedom of association.

We will also process your personal data to inform you about our services and news on our site, pursuing the legitimate interest in freedom of association.

### DATA RECIPIENTS

We may communicate your data:
- to persons or entities who work with us and deal with phases of the processes necessary for the proper performance of our activities,
- to third parties to comply with legal obligations, to comply with orders from public authorities, including the judicial authorities, and / or to protect ours rights or third parties under law,
- to persons or entities who work with us and deal with phases of the processes necessary for the proper performance of our activities;
- to third parties to comply with legal obligations, to comply with orders from public authorities, including the judicial authorities, and / or to protect ours rights or third parties under law;
- to payment processors with whom you interact in the performance of your donation.

### TRANSFER PERSONAL DATA OUTSIDE THE EU

Your data will be transferred outside the EU. For some of the countries where your data will be transferred the Commission did not issue an adequacy decision: the transfer to these countries will be based on Standard Contractual Clauses and you can write to us to have a copy of them.

### PERIOD OF STORING

Your contact details and communications will be stored for the time necessary to meet your request and for any additional time necessary to use the data to protect your and/or our rights, and / or rights of third parties.

Your browsing data will be stored for up to 3 years.

If you are a donor, your personal data will be stored for the maximum time within which rights in relation to the donations and relationship can be asserted and (if before this deadline such rights will be asserted by you or third parties) for any additional time necessary to use the data to protect your and / or our rights, and / or rights of third parties.

### RIGHTS

We remind you that, according to the Regulation, you are entitled:
- to obtain access to your personal data according to Article 15 of the Regulation,
- to obtain the correction of your personal data according to Article 16 of the Regulation,
- to obtain the erasure of your personal data according to Article 17 of the Regulation,
- to obtain restriction of processing of your personal data according to Article 18 of the Regulation,
- to object to processing of your personal data based on point (f) of Article 6(1) of the Regulation according to Article 21 of the Regulation,
- the portability of your personal data according to Article 20 of the Regulation,
- to obtain access to your personal data according to Article 15 of the Regulation;
- to obtain the correction of your personal data according to Article 16 of the Regulation;
- to obtain the erasure of your personal data according to Article 17 of the Regulation;
- to obtain restriction of processing of your personal data according to Article 18 of the Regulation;
- to object to processing of your personal data based on point (f) of Article 6(1) of the Regulation according to Article 21 of the Regulation;
- the portability of your personal data according to Article 20 of the Regulation;
- to lodge a complaint with the Italian Privacy Authority according to Article 77 of the Regulation.

### EFFECTS OF FAILURE TO PROVIDE DATA TO THE CONTROLLER

Communication of browsing data and/or contact information and communications is not mandatory, but if you do not provide them you will not be able to browse the site, and/or contact us.

If you are a donor, the provision of your data is a legal and contractual obligation: you have the obligation to provide your personal data and if you do not provide them to us you will not be able to make the donation, receive the gift and / or manage the contractual relationship.

### ABOUT COOKIES

You can control and / or delete the cookies as you like - to learn more, please visit the website [http://www.allaboutcookies.org/](http://www.allaboutcookies.org/).

You can select which cookies to enable through the appropriate procedure provided below, as well as delete cookies already on your device and set most browsers to block its installation.

Most browsers allow you to:
- view the cookies and delete them individually,
- block third-party cookies,
- block cookies for particular sites,
- block the installation of all cookies,
- view the cookies and delete them individually;
- block third-party cookies;
- block cookies for particular sites;
- block the installation of all cookies;
- delete all cookies when you close your browser.

For more information on how to set preferences on the use of cookies through your web browser, you can look at the relevant instructions:
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- [Safari](https://support.apple.com/kb/PH17191?locale=en_US&viewlocale=en_US)

If you choose to remove or not to enable:
- technical cookies, you may not be able to use the site, to view the contents and make use of its services,
- technical cookies, you may not be able to use the site, to view the contents and make use of its services;
- the other cookie (functionality, analytics and/or third-party cookies), certain services or certain features of the site may not be available or not work properly and you could be forced to change or manually enter some information or preferences each time you visit the site.

Cookies will be stored for up to two years.

### THIRD PARTY SERVICES THAT INSTALL COOKIES
We use the following services that use cookies to process your data.

We use the following services that use cookies to process your data:

#### Donorbox.org
Donorbox service provided by Rebel Idealist Inc. that uses cookies and allows Rebel Idealist Inc. to collect, store and process data on the use of the service according to the terms of its [Privacy Policy](https://donorbox.org/privacy),
Donorbox service provided by Rebel Idealist Inc. that uses cookies and allows Rebel Idealist Inc. to collect, store and process data on the use of the service according to the terms of its [Privacy Policy](https://donorbox.org/privacy).
#### Recaptcha.net
Recaptcha service provided by Google inc. / Google Ireland Limited that uses cookies and allows Google inc. / Google Ireland Limited to collect, store and process data on the use of the service according to the terms of its [Privacy Policy](https://policies.google.com/privacy?hl=it),
Recaptcha service provided by Google inc. / Google Ireland Limited that uses cookies and allows Google inc. / Google Ireland Limited to collect, store and process data on the use of the service according to the terms of its [Privacy Policy](https://policies.google.com/privacy?hl=it).
#### Stripe.com
Stripe service provided by Stripe Inc. that uses cookies and allows Stripe Inc. to collect, store and process data on the use of the service according to the terms of its [Privacy Policy](https://stripe.com/it/legal/cookies-policy),
Stripe service provided by Stripe Inc. that uses cookies and allows Stripe Inc. to collect, store and process data on the use of the service according to the terms of its [Privacy Policy](https://stripe.com/it/legal/cookies-policy).
#### Shopify.com
Shopify service provided by Shopify Inc. that uses cookies and allows Shopify Inc. to collect, store and process data on the use of the service according to the terms of its [Privacy Policy](https://www.shopify.com/legal/privacy),
Shopify service provided by Shopify Inc. that uses cookies and allows Shopify Inc. to collect, store and process data on the use of the service according to the terms of its [Privacy Policy](https://www.shopify.com/legal/privacy).
#### Google.com
Google service provided by Google inc. / Google Ireland Limited that uses cookies and allows Google inc. / Google Ireland Limited to collect, store and process data on the use of the service according to the terms of its [Privacy Policy](https://policies.google.com/privacy?hl=it).
Google service provided by Google inc. / Google Ireland Limited that uses cookies and allows Google inc. / Google Ireland Limited to collect, store and process data on the use of the service according to the terms of its [Privacy Policy](https://policies.google.com/privacy).

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