1.1 Who are we
We are a group of people from the Fridays for Future movement that started an European Citizens’ initiative.
We do not have a legal status as an NGO or similar besides that we are in the official process of running this ECI as an official direct democracy tool of the European Commission.
The citizens committee consists of the following persons:
- Thomas EITZENBERGER – email@example.com
- Astrid Cecilie BUDOLFSEN – firstname.lastname@example.org
- Guilhem HEULINE, Frederica GASBARRO, Janina ŚWIERZEWSKA, Alejandro MARTÍNEZ MARTINEZ, Ole MÜLLER
2. What personal data is collected?
The type of personal information that we could collect about you includes:
- Name & Title
- Date of birth
- Postal address
- Phone number
- Email address
- Other personal data required to sign the ECI
- Social Media profiles
- IP Address
- Photographs or digital images (e.g. in photos taken at FFF events)
- How we communicate with you and any preferences you may have
- Details of any contact that we may have with you
Cookies are small text files on your computer, smart phone, tablet or other device. They are made by your web-browser when you visit a website. Every time you go back to that website, your browser will send the cookie file back to the website’s server. Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences and generally improving the user experience.
Cookies help us to identify which bits of our website people are using, and help us to improve the user experience. Information supplied in cookies also allows us to measure the effectiveness of online marketing campaigns for our ECI so that we can become more efficient.
A cookie, by itself, can’t be used to identify you; we cannot and do not link it with personal information we hold about you (e.g. your name, address, email address).
3. How do we use your personal data?
We use your data for the following purposes:
- To respond to any correspondence you enter into with us.
- To keep you updated on the work that we are doing and tell you how your donations are being used.
- To ensure we act on any requests you make about how we do/don’t contact you.
- Where you sign the ECI, your personal details will be sent to the national authorities at the end of the collection phase.
- To help us analyse and understand our audience. This allows us to make improvements to our campaigning and our service to supporters.
- To allow us to verify your identity if we are required to do so, to be able to comply with laws and regulations, to protect our organisation and your personal data from fraudulent activities.
- For research and analysis, to help us to grow the movement by finding new audiences and like-minded persons who have similar interests and characteristics. Where research requires your direct involvement, participation will always be optional.
- To comply with our legal obligations and to share data with law enforcement agencies if required to do so.
4. What are the legal bases that we use to process your personal data?
Consent: We use consent to send you details on fundraising and campaigning by email and if you sign the ECI you consent that your data is sent to national authorities for verification at the end of the collection phase. As is your right, you can withdraw your consent at any time. All our fundraising and campaigning emails include an unsubscribe link.
Legal Obligation: We need to retain and use certain records to uphold the law, to satisfy legal, regulatory and compliance obligations.
Legitimate Interest: We may collect and use data where this is reasonably necessary for our legitimate interests. Such processing will be fair, balanced and will not unduly impact on your rights as an individual. For example, there may be times when it is not practical or appropriate to ask for your consent and where we are confident this will not impact on your rights.
Our legitimate interests include campaigning and fundraising to support our charitable objectives. These objectives are to stop global warming and to pioneer a world where sustainable way of living is the norm. In support of these legitimate interests we may collect or process personal data in the following ways:
- For administration and governance activities;
- To record and respond to any correspondence you enter into with us;
- To contact, by email, some very specific audiences relevant to our work;
- To record and act on your campaigning and fundraising communication preferences;
- To administer donations and other ways you support us, and update you on how your donations are used;
- To thank you for your donations;
- For research and analysis to help us understand our audience, improve our campaigning, fundraising and service to supporters, and grow the movement against factory farming;
- In certain circumstances, to undertake research on individuals before we proactively contact them;
- To better our efforts against fraud.
5. When and how do we collect your data?
We collect your data when you contact us directly, or interact with us via a third party, to:
- Make an enquiry to us
- Sign up to receive emails
- Take part in a campaign
- Make a donation
- Engage with us on social media
- Volunteer for us by fundraising or campaigning
- Attend an event
- Connect with us online
- Sign the ECI
In certain circumstances, we will conduct our own research and gather information that is available within the public domain. There is a certain amount of publicly available information from sources such as social media, published articles and news channels. We would use this information to improve our communications and fundraising approaches.
6. Markerting (Campaigning and fundraising)
As a charity we communicate with individuals to encourage participation in our campaigns and to raise money to fund our work. We send campaigning and fundraising communications in a variety of ways:
BY EMAIL: We will only communicate for campaigning and fundraising purposes if you have given us your consent for us to do so. As is your right you can withdraw your consent for any method of communication at any time. All our campaigning and fundraising emails include an unsubscribe link, and you can also contact us via email@example.com.
BY SOCIAL MEDIAL ADVERTSING: If you are a social media user, we may use tools provided by the leading social media platforms, such as Facebook, to reach individuals likely to engage with and respond to our campaigns. If you have participated in our campaigns and haven’t opted out, we may contact you via social media advertising. We may also use your profile anonymously, and in conjunction with many other profiles, to identify audiences that are also likely to engage with our campaigns and thereby help us achieve our charitable mission and objectives.
In order to improve the performance of our campaigns, we use conversion tracking to measure the outcome and improve the return on investment of Facebook Ads, for example, by reporting on the actions that audiences take after viewing those ads. We add a tracking pixel or cookie to our website and then track these conversions back to ads we are running on Facebook. No personal information is contained in or collected as a result of using pixels. To opt out of remarketing pixels and technologies, visit Facebook’s ad preferences page here.
7. How long do we keep your data?
Your data is retained for as long as is necessary for the purpose that it was collected for. We are obliged to keep certain data to fulfil certain legal obligations and matters of record keeping e.g. financial records which we are required to keep for 6 years. Any data that is retained is minimised to ensure that we are keeping only that which is required. We will securely delete all data when it is no longer required.
8. Sharing your data
We will not sell or swap your personal data; and it is our policy never to pass on your personal details to other organisations for their use, except when we have your express permission to do so or when the law requires it.
There may be a need to disclose your personal data upon request to regulatory and government bodies as well as law enforcement agencies.
9. Children & Vulnerable Individuals
NB – Parents and Guardians should be aware that, owing to the nature of our work, images on our websites or used in our communications may be considered unsuitable for children.
10. Your Rights
We want to ensure that your rights are upheld when we use and store the information you give to us.
10.1 Accessing the Information that we hold on you – Subject access request
You can request a copy of the information that we have on you. This will be free of charge in most cases. Please let us have details of the personal data you want to see and proof of your identity. You can send an email to firstname.lastname@example.org
10.2 Erasing your personal data from our records
Simply let us know and we will delete your details from our database. This will mean that all records of you will be erased. Please note, for legal reasons we may be required to keep certain information e.g. in the case of financial details, where we are duty bound to keep these on file for 6 years.
As the data submitted to the ECI is strongly encrypted, you need to provide the unique signature id that has been shown at the end of the signature process to us so that we can remove your signature.
10.3 Opting out of all marketing (campaigning and fundraising) communications
We will stop all campaigning and fundraising communications, or communications via a specific channel, on request. If you have given us consent you can withdraw your consent at any time. We aim to update your record within 28 days.
11. How we keep your data safe?
We are committed to keeping your data safe. Your personal data is stored on a secure network and we regularly monitor our systems for vulnerabilities. Access to your data is closely monitored; it is only accessible by staff, volunteers and contractors who are bound by appropriate policies and procedures to protect your information.
We will review the policies and procedures of any third parties that we deal with, and ensure they are compliant with data protection laws.
Your personal data for the ECI is stored strongly encrypted on a different server, located in Germany at Hetzner company.Section ColumnHeading
12. How to contact the data manager
If you wish to contact us regarding privacy / data security:
Thomas Eitzenberger email@example.com