SEEDIG Privacy Policy

Last updated: May 2020

This Privacy Policy explains what types of personal information are collected in the context of the South Eastern European Dialogue on Internet Governance (hereinafter – ‘SEEDIG’) activities, how we use and share your personal data, and your rights in relation to the personal data we hold.

It includes information on which data is collected when you visit the SEEDIG website. This policy also explains what types of personal information are collected when you register for or attend SEEDIG meetings (in situ or online), apply for and/or attend capacity development programmes, use SEEDIG-related mailing lists, etc. We use your personal data to organise and improve SEEDIG activities. By engaging with SEEDIG, you agree to the collection and use of information in accordance with this Privacy Policy.

1. ABOUT US

This policy applies in the context of activities carried out in the framework of the SEEDIG, in as much as they are coordinated by the SEEDIG Executive Committee. Please note that at the moment SEEDIG functions as a volunteer-based initiative, and it does not exist as a stand-alone legal entity. For the purpose of this Privacy Policy, every mentioning of ‘us’, ‘we’, ‘our’ means referral to the SEEDIG Executive Committee.

Information about the SEEDIG Executive Committee is available on the dedicated page.

2. COLLECTION AND PROCESSING OF INFORMATION

2.1. WEBSITE AND CREATION OF LOG FILES

The SEEDIG website may collect and process data that you provide to us about you, for example through filling out online forms, in order to participate in SEEDIG activities. Such information might include but is not limited to email address, first and last name, phone number, physical address, etc.

We may collect information about your user agent (browser) and/or device, including your IP-address for purposes of system administration and website maintenance.

Demographic and statistical information about user behaviour may be collected and used to analyse the popularity and effectiveness of our website/s, including the downloading of any content from our website (such as newsletters in pdf format). Data transmission between the user’s data processing system and our service provider’s systems is secured.

These data are also stored in the log files of our system and are not combined with other personal data of the user.

Use of the data for marketing purposes does not take place in this context.

2.2. USE OF COOKIES

Our website uses cookies. Cookies are text files that are stored by the Internet browser on the user’s computer system. If a user visits our website, a cookie may be stored on the user’s operating system. This cookie contains a characteristic string that enables a unique identification of the browser.

We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser remains identifiable even after a page change.

As a user, you are able to control the setting of cookies in your browser.

The purpose of using technically necessary cookies is to provide functions on our website that cannot be offered without the use of cookies.

The user data collected by technically necessary cookies are not used to create user profiles.

The cookies we set are deleted when the web browser is closed (session cookie). Cookies are stored on the user’s computer and transmitted to our site. Therefore, you as a user have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. However, if cookies are deactivated for our website, it may no longer be possible to use all functions of the website in full. We only use these cookies to provide you with high-quality website access services.

More details on the use of cookies are available in our Cookie Statement.

2.3. MAILING LIST

On our website, we offer the possibility to subscribe to the SEEDIG community mailing list. The data collected via the subscription form includes your email address and optionally your name. In addition, the date and time of registration as well as the IP address may also be stored.

For the successful subscription to the list, users must confirm an invitation email and agree to the use of their data as a part of the mailing list. In the invitation email further details concerning the processing of data in connection with the mailing list are explained.

If you send posts to the mailing list, we will forward this post to all other subscribers of this mailing list and will collect the content of this post in the archive of the mailing list together with the email address and name you initially subscribed with. The archive of the SEEDIG mailing list is publicly available and can be found at https://lists.rnids.rs/pipermail/seedig/. Beside this data we may also collect the metadata of the post as contained in every email, such as IP address, date and time when email was sent, email program, relay servers.

You can unsubscribe from the SEEDIG mailing list at any time by following the instructions available at https://lists.rnids.rs/mailman/listinfo/seedig.

The SEEDIG community mailing list is administered by the Serbian National Internet Domain Registry (RNIDS). RNIDS’ privacy policy is available at https://www.rnids.rs/en/credits/privacy-policy.

Personal data made available via the SEEDIG mailing list archive is stored for an indefinite period of time, for purposes related to transparency and to preserve SEEDIG’s institutional memory.

2.4. COLLECTING PROPOSALS FOR ANNUAL MEETING PROGRAMME

In preparation for SEEDIG annual meetings, we collect proposals for topics to be included in the meeting programme. This is done in a joint call run together with the European Dialogue on Internet Governance (EuroDIG). The form for submitting proposals is made available through the EuroDIG website; EuroDIG’s privacy policy is available at https://www.eurodig.org/index.php?id=16.

The data collected via the form are transferred to and processed by EuroDIG Association and the SEEDIG Executive Committee/Programme Committee/other designated groups within SEEDIG. The data also include personal data such as first name, family name, gender, affiliation, stakeholder group, country of origin, country of residence, and e-mail.

Some of these data will be published automatically on the EuroDIG website to make the process of submitting issues as transparent as possible to all stakeholders. These data are: suggested issue, category, first name, family name, affiliation and stakeholder group. This data is later on also published on the SEEDIG website.

E-mail addresses are solely used to contact the issue proponents only for purposes related to their involvement in the annual meeting planning process.

We may use some of the data, in an anonymised format, for research and statistical purposes.

Personal data collected in this context is stored for the duration necessary to process it in relation to the annual SEEDIG meeting for which it was collected, but no longer than one year after the end of the meeting. By way of exception, the personal data published on the SEEDIG website (as described above) remains publicly available for an indefinite period of time, for purposes related to transparency and to preserve SEEDIG’s institutional memory.

2.5. SIGNING UP TO RECEIVE OUR SEESummary

We collect your email address when you sign up to receive the SEEsummary. By subscribing, you understand that you will receive an email at least once a month, when a new issue of the SEEsummary is published.

You can then unsubscribe at any time by clicking the link in the footer of our emails.

We use Mailchimp as a platform for enabling subscriptions. Mailchimp’s privacy policy is available at https://mailchimp.com/legal/privacy/.

2.6. VOLUNTEERING FOR SEEDIG ACTIVITIES/GROUPS

From time to time, we launch calls for volunteers/applications/nominations inviting community members to contribute to various SEEDIG activities. These include, for instance, calls for members of the Programme Committee, calls for nominations for the Executive Committee, and calls for various other working groups.

We collect expressions of interests/applications/nominations either via Typeform or via forms created directly on our website via plugins. Typeform’s privacy policy is available at https://admin.typeform.com/to/dwk6gt.

Data we collect in such cases may include but is not limited to name, email address, organisation, country, and stakeholder group. This information is only made available to the SEEDIG Executive Committee and, occasionally, to other parties such as pre-appointed (s)election committees or chairs of the working groups for which volunteers are sought.

If you are selected to be part of such groups, data such as your name, organisation, country and stakeholder group may be published on the SEEDIG website. You will be informed about this before the publication. Such data may also be further processed in the context of the group’s activities (for example, by including your name in working documents).

Your email will only be used for communicating with you on matters related to your application/expression of interest/nomination, and, if applicable, your contribution to the group’s activities.

In the particular case of elections for the SEEDIG Executive Committee, personal data may also be collected for voting purposes. For instance, we may require members of the SEEDIG community to register as voting members. In such cases, the information collected is made available to the election committee. Some of this information may also be published on the SEEDIG website, with your consent. Your email address may be used to send you the voting ballot, as part of the voting process. All these circumstances are clearly communicated to everyone involved in the process at the start of the process. Where applicable, consent for data processing is sought.

Personal data collected in these contexts is only stored for the duration necessary to process it in relation to the work of the respective SEEDIG committee or group for which you volunteered, but no longer than one year after the committee or group ceases to exist. By way of exception, the personal data published on the SEEDIG website (as described above) remains publicly available for an indefinite period of time, for purposes related to transparency and to preserve SEEDIG’s institutional memory.

2.7. APPLYING FOR CAPACITY DEVELOPMENT PROGRAMMES

SEEDIG runs multiple capacity development programmes, such as the Youth School, the Fellowship Programme, the Internship Programme and the Ambassadors Programme. As part of the application process for these programmes, we ask for personal data including but not limited to name, email address, country. The data are collected during the application process as requested in the form.

The purposes for which we will use personal data you provide via application forms include:

Selection process. The data are entered into an input form, transmitted to us and saved. For the sole purpose to decide whom we select to participate in each programme, all data from the application form will be passed on to the selection team involved in the selection process (this may include members of the SEEDIG Executive Committee, representatives of SEEDIG sponsors, SEEDIG volunteers, etc.). We do not pass on the data to any third parties. Your email will only be used for communicating with you on matters related to your application.

Participation in the programme. If you are selected to participate in one of our programmes, some of your personal data – such as your name, organisation, country and stakeholder group – may be published on the SEEDIG website. You will be informed about this before the publication. Your email will only be used for communicating with you on matters related to your participation in the programme.

Administering finances. Some of our programmes offer scholarships, and in these cases we may require additional information to be able to process payments and reimbursements (e.g. bank account numbers, addresses, etc.). Some of this data is shared with organisation(s) that manage(s) SEEDIG finances and with its/their banks. It may also be shared with our sponsors.
Administrative purposes. We may use some of the data, in an anonymised format, for research and statistical purposes.
The organisation(s) that manage(s) SEEDIG finances may also use your data to meet compliance and regulatory obligations.

We collect applications either via Typeform or via forms created directly on our website via plugins. Typeform’s privacy policy is available at https://admin.typeform.com/to/dwk6gt.

Personal data collected in this context is only stored for the duration necessary to process it in relation to your participation in the respective SEEDIG capacity building programme for which you applied, but no longer than one year after the end of the respective programme. By way of exception, the personal data published on the SEEDIG website (as described above) remains publicly available for an indefinite period of time, for purposes related to transparency and to preserve SEEDIG’s institutional memory. Data collected for purposes related to administering finances (as described above) may be stored for a longer period of time, as required by financial regulations applicable to the entity managing SEEDIG finances.

2.8. REGISTERING FOR SEEDIG ANNUAL MEETINGS

Participants in our annual in situ meetings are asked to register, either online before the meeting, or in situ. Information we collect may include but is not limited to your name, email address, country, organisation, gender, and stakeholder group. Some of this information may be published on the SEEDIG website, if we have your consent (this consent is sought at the moment of registration).

The data you provide is made available to the SEEDIG Executive Committee. Some of the data may be made available to the organisation(s) that assist with the planning of the event, for example for the purpose of creating participant badges.

Your data may also be used for statistical purposes.

Personal data collected in this context is only stored for the duration necessary to process it in relation to the annual SEEDIG meeting for which it was collected, but no longer than one year after the end of the respective meeting. By way of exception, the personal data published on the SEEDIG website (as described above) remains publicly available for an indefinite period of time, for purposes related to transparency and to preserve SEEDIG’s institutional memory.

2.9. PHOTO AND VIDEO RECORDING DURING FACE-TO-FACE EVENTS

We usually take photographs and record video footage during our events. We share photos and videos on our website, social media, YouTube and other video-sharing websites. Such content is retained indefinitely as it constitutes a history of SEEDIG.

It is presumed that by attending our events, you by default agree that we may use, reproduce, and/or publish in any way whatsoever (without any payment being due to you) any photos and/or video/audio that may pertain to you (including your image, likeness and/or voice). This material may also be used in an event report, publication, press release, or other promotional content. Additionally, at the beginning of each event, we will notify all participants of planned filming and photography.

If you do not wish to be photographed or included in video recordings, please, inform a designated member of our team who will be introduced to participants at the respective event. Moreover, at some events of larger scale we might distribute clearly identifiable signs (red lanyards, stickers, etc.) to be permanently worn by participants who prefer to be excluded from photo and video recording at the event. Failure to do so, which resulted in you being photographed or recorded on video, removes our responsibility for any subsequent usage of such photographs and recordings.

2.10 ATTENDING OUR ONLINE MEETINGS/EVENTS

From time to time we may organise online meetings and events for purposes such as updating the community on SEEDIG activities, preparing the annual meeting, coordinating work within SEEDIG working groups, etc. For some of these events, we may require prior registration. In such cases, we collect the details you provide on the registration form; these are required only to enable us to communicate with you, and for internal statistical purposes. By registering, you are agreeing to such use of your data.

We use third party software or applications such as Webex and Zoom for our online meetings and events. When you log in, the third-party software or application may collect personal information from you. Follow the links for Privacy Policies of third party software or applications:

We may record some of our online meetings/events. The recording usually includes names of participants who attended, and a log of the public chat during the webinar or event. We normally use such recordings for internal purposes, such as taking minutes of the meetings. In exceptional cases, the recordings may be shared with meeting participants (for example, in the case of webinars held in the context of the Youth School); participants are informed beforehand of such cases.

If you have concerns about your name being shared with other participants, we suggest you use an alias when logging in.

Personal data collected in this context is only stored for the duration necessary to process it in relation to your participation in the respective SEEDIG online meeting or event, but no longer than one year.

2.11. CONTACT VIA EMAIL

We collect questions, queries, or feedback you leave, including your name, e-mail address, and telephone/mobile number (if included in your message), if you email us. We use these details to respond to the feedback/query/question you sent us. In some instances, this information is passed to a colleague in our team whom we believe can best respond or assist you.

In this context, the data will not be passed on to third parties.

2.12. ADDITIONAL THIRD PARTY SERVICES

In addition to the third party services mentioned above (Typeform, Mailchimp, etc.), we may also use other third party service providers, some of whom host and operate certain features of the website, our emailing system, and our collaborative software.

These include, for instance:

3. SHARING OF PERSONAL DATA

We may share certain personal data with members of various SEEDIG groups for the purpose of processing this information in the performance of their role. Examples include, but are not limited to, applications for our capacity development programmes being reviewed by those programmes organising teams, nominations for the Executive Committee being reviewed by an election committee, etc. We require that such groups handle personal data in accordance with our general privacy policy and with appropriate confidentiality and data protection obligations.

We may also share certain personal data with other third parties for the purpose of processing this data on our behalf and providing services to us or the SEEDIG community. These third parties may include providers that provide services such as web resource administration, hotel and other travel services (in the case of SEEDIG programmes which include financial support for travel and/or accommodation), etc. We require that such groups handle personal data with appropriate confidentiality and data protection obligations.

We also publish some personal data on the SEEDIG website, as described in the relevant sections above.

Under certain circumstances, we might be required to disclose your personal data by law or in response to valid requests by public authorities (e.g. a court or a government agency).

4. RETENTION OF DATA

The personal data of the person concerned will be deleted or blocked as soon as the purpose of storage ceases to apply, and in line with the above provisions. As a general rule, personal data published on the SEEDIG website in relation to your participation in various SEEDIG programmes or activities are stored for an indefinite period of time, for purposes related to transparency and preserving SEEDIG’s institutional memory. Nevertheless, your rights as a data subject apply in these cases.

Beyond that, storage can take place, if this is necessary to enforce our legal agreements and policies, resolve disputes and when provided by applicable laws or other regulations. The data will also be deleted if a storage period specified in the mentioned laws and regulations expires, unless there is a need for further storage of the data for the conclusion or fulfilment of a contract.

Personal data made available on the SEEDIG website with your consent is stored on secure servers of our hosting service provider – Gransy gHosting. Their privacy policy is available at https://g-hosting.rs/img/PERSONAL_DATA_PROTECTION_POLICY_SER.pdf

Personal data processed in the context of the SEEDIG mailing list is stored on secure servers of RNIDS. Their privacy policy is available at https://www.rnids.rs/en/credits/privacy-policy.

5. RIGHTS OF THE DATA SUBJECT

Users may be entitled to obtain access to information on the processing of personal data, to object to certain processing, and have their personal data rectified, deleted, or otherwise restricted in terms of processing, in each case as permitted under applicable law. Users also may be entitled to withdraw any consent given with prospective effect with respect to the processing of their personal data. Users can exercise these rights or learn more about the processing of personal information by us, by sending a request to privacy@seedig.net. Any request is subject to identity verification.

All privacy-related access requests are taken seriously, and we will respond to request(s) as soon as reasonably practicable, but in any case, within the legally required period of time. Please note that certain personal data may be exempt from such access, correction, objection, or deletion rights pursuant to local laws.

6. SECURITY OF DATA

The security of your personal data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use all acceptable means to protect your personal data, we cannot guarantee its absolute security.

Our website, emails and information/promotion materials may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s website. We strongly advise you to review the privacy policy of every website you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

7. CHANGES TO OUR PRIVACY POLICY

We may update our Privacy Policy from time to time. Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, you will be notified by email. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. We will put the ‘Last updated’ line with respective date at the top of this Privacy Policy.

8. CONTACT US

If you have any questions about this Privacy Policy, you can contact us by email – privacy@seedig.net

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COOKIE STATEMENT

This statement explains how we use cookies on the SEEDIG website.

For information about what types of personal information will be gathered when you visit the website, and how this information will be used, please see our Privacy Policy.

How we use cookies

Our website uses ‘cookies’. ‘Cookies’ are small text files that are stored on your computer or mobile device when you visit a website. They allow the website to recognise your device and remember if you have been to the website before. Cookies are widely used in order to make websites work more efficiently, as well as to provide information to the owners of websites on site usage and performance.

Some of the cookies we use are essential for site functionality. Other cookies help us to improve your website experience by providing insights into how the site is used. For example, they allow us to count the number of visitors to specific pages, and to analyse website usage patterns and trends. Other cookies enable us to improve our website.

The information we collect does not enable us to identify any website visitor personally. No individual data or personal information is stored in our cookies.

Cookies we use

Cookies may be set either by the SEEDIG website (‘first party cookies’), or by a third party website (‘third party cookies’).

Our website may use Google Analytics, which uses cookies. Google Analytics collects information such as how often users visit the site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognising you on return visits to this site by disabling cookies on your browser.

How to manage cookies

Most web browsers allow some control of most cookies through the browser settings. Depending on your browser (and the browser’s version), you can block certain cookies from being downloaded on your device, and you can clear or delete them.

To find out more about cookies, including how to see what cookies have been set and how to manage them, please, identify your browser and version, and visit http://www.allaboutcookies.org/.

Changes to our Cookie Statement

Any changes we may make to our Cookie Statement in the future will be posted on this page, and, where appropriate, you will be notified by email.

 

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