Privacy Policy

In Open Cages we respect the privacy of everyone who visits our website or otherwise uses our services. The following document explains how we protect and use your data.

If you have any questions or concerns, please contact us at: contact@opencages.org

Last update: 24.05.2018

 

I. Administrator of Personal Data

We would like to inform that the administrator of your personal data is Open Cages Advocacy Ltd with the charity registration number 1190484. You can contact us for further details at: contact@opencages.org

 

III. Collection and Processing of Personal Data

For the purpose of pursuing various statutory objectives of Open Cages, we need to process your personal data. We always do that in accordance with the law. The legal framework for our operations can be found below:

In order to keep you informed about the actions of Open Cages, we process the following:  
  • First name,
  • Last name,
  • E-mail address,
  • City,
  • Country.
The legal basis for this is art. 6(1)(a) of the General Data Protection Regulation (GDPR), which allows us to process your data after having received your informed consent.

In order to register you as a supporting member, we process the following:  
  • First name,
  • Last name,
  • E-mail address,
  • Date of birth,
  • Phone number,
  • Postal address,
  • Your membership fee amount.
The legal basis for this is art. 6(1)(a) of the GDPR which allows us to process your data after having received your informed consent.

In order to manage our accounts, records and evidence files, we process the following:  
  • First name,
  • Last name,
  • E-mail address,
  • Date of birth,
  • Phone number,
  • Postal address,
  • Your membership fee amount.
The legal basis for this is art. 6(1)(a) of the GDPR which allows us to process your data necessary to pursue legitimate objective. In this case, the objective of Open Cages is to acquire personal data which serves to prove the provision of our services when required by authorities.

In order to collect and process applications for volunteering, we process the following:  
  • First name,
  • Last name,
  • E-mail address,
  • Phone number,
  • Postal address.
The legal basis for this is art. 6(1)(a) of the GDPR, which allows us to process your data after having received your informed consent.

In order to collect signatures on our petitions, we process the following:  
  • First name,
  • Last name,
  • E-mail address,
  • Phone number.
The legal basis for this is art. 6(1)(a) of the GDPR, which allows us to process your data after having received your informed consent.

In order to conduct recruitment and/or selection of candidates for positions offered by Open Cages , we process the following:  
  • First name,
  • Last name,
  • E-mail address,
  • Phone number,
  • Postal address,
  • Employment history and educational background.
The legal basis for this is art. 6(1)(a) of the GDPR which allows us to process your data after having received your informed consent.

 

IV. Cookies

  1. Similarly to other entities, our website uses cookies – small text files saved and stored on a user’s computer, smartphone tablet or any other device. Cookies can be read by our IT systems and systems owned by other entities providing their services to us (e.g. Facebook or Google).
  2. Cookies have many useful functions on our website. You can read about them below (if you find this explanation insufficient, please contact us):
    • Security – cookies are used for authentication of our visitors and prevent any unauthorised use of the Customer Panel. They protect your personal data against unauthorised access.
    • Website efficiency – when you visit our website, cookies remember your preferences thus helping it work smoothly and making all its functions accessible. Keeping cookies turned on allows you to browse freely through all the contents uploaded to the website.
    • Session state – cookies often save information about the ways the visitors use our website, e.g. which subpages are viewed the most. These so-called ‘session state cookies’ also allow quick error identification which helps us improve our services and make your browsing experience better.
    • Maintaining session state – when you log in to the website, cookies maintain the session state, which means that you do not have to type in your login and password every time you move to another page. This function makes browsing much more convenient.
    • Preparing statistics – cookies make it possible for us to analyse the ways our website is used (how many people visit it, how long they stay, which contents are the most popular, etc.). Thanks to this data, we can constantly improve our website and make it more user-friendly. To track user activity, we use tools provided by Google such as Google Analytics, which we not only use to report statistics, but also combine with some of the cookies to show our users customised content across Google services (e.g. Google search engine) and the rest of the web.
    • Access to social media – there is a Facebook icon on our website which allows you to like our fan page without having to leave the site. To make it possible, however, we need to use cookies supplied by Facebook.
    1. It is important to remember that a lot of cookies are anonymous – without any additional details we cannot use them to identify you.
    2. By default, your Internet browser enables cookies on your device. This is why we would like to ask you to agree to our use of cookies when you visit our website for the first time. If you want cookies to stay disabled, you can change your browser preferences– block the automatic use of cookies entirely or set notifications every time cookies are saved on your device. These changes can be made anytime.
    3. While we respect the autonomy of each person visiting our website, we feel responsible to inform users of our services that turning off or limiting our use of cookies may cause serious difficulties in browsing our website, e.g. you may be asked to re-enter your login and password every time you move to another page, it may take much longer to load a page, the functionality of the website may become limited, you may not be able to like our page on Facebook, etc.

 

V. Right of Withdrawal

  1. If we process your data on the basis of your informed consent, you have the right to withdraw this consent any time and in your sole discretion.
  2. If you want to withdraw your consent, please do one of the following options:
  • e-mail Open Cages directly at: contact@opencages.org,
  • unsubscribe by clicking the link at the end of the e-mail you received from us,
  • delete your comment,
  • delete your review of our services.
  1. If the processing of your data has been based on your consent, withdrawing this consent does not render our previous proceedings illegal. In other words, up until we receive your withdrawal, we have a legal right to process your data and withdrawing your consent does not affect the legitimacy of past processes.

 

VI. Sharing Personal Data

  1. Sharing your personal data is voluntary and depends solely on your decision. In some cases, however, we need parts of your data so that we can meet your expectations about the services provided by Open Cages as well as make it possible for you to support the cause.
  2. To sign petitions, appeals and pledges issued by Open Cages, sharing your first name and e-mail address is essential – without such data, we are not able to verify the authenticity of your signature.
  3. If you want to make an online donation, you have to share your first name, e-mail address and possibly some additional data required by your payment method of choice – without such data, donating online is impossible.
  4. To keep you posted on our actions and campaigns, we need your first name and e-mail address – without such data, we are not able to contact you via e-mail.
  5. To keep you posted on our actions and events taking place near you, we need your postal code – without it, we are not able to send you locally customised messages.
  6. To be able to call you about matters regarding the campaigns, we need your phone number – without it, we are not able to contact you.
  7. To become a member of Open Cages, you have to share your full name, e-mail address, phone number and postal address – without such data, we are not able to sign you up as a supporting member.

 

VII. Automated Decision-making and Profiling

  1. We would like to inform that your personal data allow us to make automated decisions, including profiling.
  2. We do not use your data to make any automated decisions about you which could affect your legal rights.
  3. The profiling we perform takes place when at least one of the following actions is being analysed – active interaction with the content posted by Open Cages, website activity, form of support (including membership fees and donations), first name and/or postal code provided voluntarily. Profiling allows us to adjust the frequency of our contact with you and send you content that fits your preferences. In case of membership fees, profiling helps us verify the list of our active supporting members and fulfil our obligations to provide information about events held by Open Cages near you.
  4. Automated decision-making is based on customising the content we provide and, in some cases, categorising our users’ profiles, e.g. in accordance with their involvement in Open Cages.
  5. Automated decision-making is compliant with the law as profiling does not take place without the user being informed about it or is essential to signing contracts with our users and performing the stipulations mentioned therein, such as determining the amount of overdue fees.
  6. Aforementioned decisions should not significantly affect your situation as they are not legally effective. The only consequences of our profiling are that you receive customised messages and your supporting member status may be changed.
  7. If you disagree with our decision, you have every right to object, e.g. by filing a complaint. In order to do that, please contact us at contact@opencages.org and provide the reason(s) why you think our decision was wrong. We will make sure that your complaint is investigated by an authorised person (such submissions are not handled by any IT systems).

 

VIII. Recipients of Personal Data

  1. Like the majority of organisations, we use services provided by third parties that often require us to share your personal data. For that reason, your personal data may be processed by the following entities:
  • Adobe Systems Incorporated
  • Atlassian Corporation Plc.
  • Dropbox, Inc.
  • Facebook, Inc.
  • Flickr
  • Google LLC
  • Hetzner Online GmbH
  • OVH
  • Salesforce.com, Inc.
  • Slack Technologies, Inc.
  • Soneta sp. z o.o.
  • Starlit Accounting sp. z o.o.
  • Tresorit AG
  • TYPEFORM SL
 
  1. In addition, it may happen that, on the basis of the applicable law or a decision issued by a competent authority, we have to share your data with other public or private entities. Thus, it is very difficult for us to predict who may request your personal data. However, we would like to ensure our users that every request is thoroughly examined so that your data is not accidentally shared with anyone who is unauthorised.
  2. We never sell or rent your personal data or any details regarding our website visits and traffic patterns.

 

IX. Sharing Personal Data with Third Countries

  1. We would like to inform that, in accordance with the statutory activities of Open Cages and/or provision of its services, we may share your personal data with entities outside the European Economic Area.
  2. The GDPR introduces certain limitations to sharing personal data with third countries as they do not adopt European laws and may therefore compromise the safety of the personal data of European citizens. For that reason, each administrator of personal data is obliged to identify the legal basis of every share.
  3. In our case, your personal data may be shared with the USA and/or Switzerland.
  4. The processors of personal data whose services we use are all participants in the EU-US Privacy Shield program created for the purposes of sharing data between the European Union and the USA
  5. In relation to our cooperation with entities participating in the Privacy Shield program, we would like to inform that when sharing your personal data with the USA and Switzerland we do not employ any protective measures specified by the GDPR, including binding corporate rules or standard contractual clauses.
  6. In case of sharing your personal data with third countries which, according to the European Commission, do not meet minimum requirements of the personal data protection, we share your data only after having received your explicit and voluntary consent. Considering the circumstances, however, we cannot guarantee that your personal data will be sufficiently secured. Sharing your data with any third country always poses certain risks.
  7. If you feel concerned about our ways of sharing your data, we are more than happy to provide further explanation on our privacy policy.

 

X. Period of Storage of Personal Data

  1. In accordance with the applicable law, we do not process your personal data indefinitely. We do that for as long as it is necessary for us to achieve our objective (e.g. carry out a recruitment process). After that period, your personal data are permanently removed or destroyed.

 

XI. Rights of Data Subjects

  1. We would like to inform that you have the right to:
  • access your personal data,
  • correct your personal data,
  • delete your personal data,
  • limit the processing of your personal data,
  • object the processing of your personal data,
  • transfer your personal data.
 
  1. We respect your rights resulting from the provisions on the protection of personal data and do our best to utilise them.
  2. Nevertheless, we would like to emphasise that these rights are not absolute and can therefore be legally overruled. If it happens that we reject your request, we can ensure that we do so only after having analysed your case thoroughly, and when such rejection is imperative.
  3. When it comes to your right to object, you are legally entitled to object to the processing of your personal data on the basis of the legitimate interest of the Administrator of Personal Data (described in point III) and in relation to your particular situation. However, in accordance with the applicable law, we may refuse to accept your objection if we succeed to prove either of the following:
  • There are reasonable grounds for processing your data, which take precedence over your interests, rights and freedoms;
  • There are grounds for establishing, vindicating or defending our claims.
 
  1. Moreover, you always have the right to object to the processing your data for our marketing purposes. We will stop processing your data in this way immediately after having received your objection.
 
  1. You can exercise your rights by:
  • e-mailing Open Cages directly at: contact@opencages.org,
  • unsubscribing by clicking the link at the end of e-mail your received from us.

 

XII. Right to Lodge a Complaint

If you believe that your personal data are not being processed in accordance with the applicable law, you may lodge a complaint with the President of the Personal Data Protection Office.

 

XIII. Final Provisions

  1. In the absence of specific provisions in this Privacy Policy, the provisions of on the protection of personal data are applicable.
  2. If you have agreed to receive our electronic messages, we will e-mail you about any changes in this Privacy Policy.
  3. This Privacy Policy takes effect on May 25th, 2018.

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