LIBERO NETWORK SOCIETY is committed to safeguarding your privacy. Contact us if you have any questions or problems regarding the use of your Personal Data and we will gladly assist you.
Table of Contents
- Definitions used in this Policy
- Data protection principles we follow
- What rights do you have regarding your Personal Data
- What Personal Data we gather about you
- How we use your Personal Data
- Who else has access to your Personal Data
- How we secure your data
- Information about cookies
- Contact information
Personal Data – any information relating to an identified or identifiable natural person.
Content – any “content” or media such as written work, videos, photography, comments, emails, form submissions, etc.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
We/us (either capitalised or not) – LIBERO NETWORK SOCIETY
Data Protection Principles
We promise to follow the following data protection principles:
- Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
- Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
- Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
- Processing is limited with a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of data.
- We will do our best to ensure the integrity and confidentiality of data.
Data Subject’s rights
The Data Subject has the following rights:
- Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
- Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
- Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
- Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records. *see note regarding submitted Content
- Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
- Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
- Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
- Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
- Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.
In the case of submitted Content (including but not limited to story and article submissions), Content cannot be removed from the Site once published. Instead, we will honour your privacy by anonymizing any Personal Data (in accordance with the definitions in this Policy) in order to anonymize the Content. This may include removing any author picture or ‘Free from’ photo (or other personally identifiable images) and changing the Author’s name from full (i.e. John Smith) to first name and last initial (i.e. John S).
Data we gather
Information you have provided us with
This might be your e-mail address, name, billing address, home address etc – mainly information that is necessary for delivering you a product/service or to enhance your customer/donor/visitor experience with us. We save the information you provide us with in order for you to comment or perform other activities on the website. This information includes, for example, your name and e-mail address.
Information automatically collected about you
This includes information that is automatically stored by cookies and other session tools. For example, your donation information, your IP address, your donation history (if there is any) etc. This information is used to improve your donor/visitor experience. When you use our services or look at the contents of our website, your activities may be logged.
Information from our partners
We gather information from our trusted partners with confirmation that they have legal grounds to share that information with us. This is either information you have provided them directly with or that they have gathered about you on other legal grounds. See the list of our partners here.
Publicly available information
We might gather information about you that is publicly available.
Information You Choose To Submit
When you make a comment, fill out a form, submit literary work, make a donation, or engage through submitting information in any other way on this site or via direct email, we may collect certain information about you which may include such information as your name, e-mail address, gender, date of birth, and credit card number or other payment information. When you post content through the Service, your username and other Personal Information may be included in the post.
Your use of areas of our site or services that are intended for interaction with other users may reveal your username and/or personal information and may allow you to publish certain personal information about you. By choosing to use these areas, you understand and agree that anyone with access to those areas may access and forward any information about you that is contained in or that you post to those areas. As with any social networking service, you should use care when disclosing your personal information to strangers.
How we use your Personal Data
We use your Personal Data in order to:
- provide our service to you. This includes, for example, registering your account; providing you with other products, services, or information that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any services.
- enhance your donor/visitor experience;
- fulfil an obligation under law or contract;
- to further communicate with you. For example, if you reach out to us inquiring about contributing or volunteering via an online form, we will use the information provided in this form to reach out to you and respond to your inquiries and offer more information related to your inquiry.
We use your Personal Data on legitimate grounds and/or with your Consent.
On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:
- to identify you;
- to provide you a service or to send/offer you a product;
- to communicate either for sales, donation receipting, or invoicing.
On the ground of legitimate interest, we Process your Personal Data for the following purposes:
- to administer and analyse our donor/visitor base (behaviour and history) in order to improve the quality, variety, and availability of services and information offered/provided.
With your consent we Process your Personal Data for the following purposes:
- to send you newsletters (from us and/or our carefully selected partners);
- for other purposes we have asked your consent for;
- to send you automatic updates/notifications related to your donations, filled out forms, or other inquiries. For example, you may receive automatic email confirmations informing you that your donation has been processed or informing you when an inquiry form has been received by us from you..
We Process your Personal Data in order to fulfil obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We save your billing information and other information gathered about you for only as long as needed for accounting purposes or other obligations deriving from law..
We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
- the link between purposes, context and nature of Personal Data is suitable for further Processing;
- the further Processing would not harm your interests and
- there would be appropriate safeguard for Processing.
We will inform you of any further Processing and purposes.
Who else can access your Personal Data
We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience. We share your data with:
Our processing partners + tools:
- Google Analytics (website analytics and statistics)
- MailChimp (email newsletter platform)
- MailMunch (email newsletter signup forms)
- GiveWP (online donation manager)
- PayPal + Stripe (donation payment gateways)
- Zoho Mail (email service provider)
- Jetpack + WordPress (website hosting platform and tools)
- Flywheel (website hosting company)
- Anti-Spam services (including Akismet, WP-reCAPTCHA, Wordfence, Stop Signup Spam, and Cookies For Comments)
- Contact Form 7 + Flamingo (contact and submission form collection and backup plugin)
We only work with Processing partners who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.
Links to other sites
This site and our services may contain links to other websites. If you choose to visit another site by “clicking on” any type of third party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization, or representation that we are affiliated with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third-party websites. These other websites may place their own cookies or other files on your computer, collect data, or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
How we secure your data
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymizing and pseudonymizing where suitable. We monitor our systems for possible vulnerabilities and attacks. We use account and device passwords and run regular virus and malware checks..
Even though we try our best we can not guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account with us, note that you have to keep your username and password secret.
We do not intend to collect or knowingly collect information from children. We do not target children with our services.
Anyone under the age of contractual consent must have a parent or guardian offer consent on their behalf. We assume all consent received is only from individuals over the legal age of contractual consent.
Cookies and other technologies we use
A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.
- Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in or submitting comments. These cookies don’t collect any personal information.
- Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.
- Analytics cookies – these cookies are used to track the use and performance of our website and services (more below).
- Security cookies – these cookies help us block out spam, protect from malware and bots, and keep our site (and your data) safe and secure.
You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit https://www.allaboutcookies.org/.
Name: Lauren Bersaglio
Supervisory Authority (PIPEDA Only)
Office of the Privacy Commissioner of Canada
30, Victoria Street
Supervisory Authority (GDPR Only)
Email: [email protected]
Phone: +32 2 283 19 0000
Last modification was made August 07, 2018.