Personuppgiftspolicy

WeMove Europe Privacy Policy: 10/04/2018

At WeMove Europe we take your privacy very seriously. We deliberately store your information exclusively on servers located in Europe, which are subject to German and European data protection regulations. We always strive to use European service providers to safeguard your privacy and safety of your data at all times. We will never sell your data, or share it with a third party without your explicit consent.

This Privacy Policy (“Policy”) sets out our data collection and processing practices and your options and rights regarding the ways in which your personal information is handled. Please read it carefully.

The provision of your personal data to us is voluntary. However, without providing us with your personal data, you will be unable to e.g. sign a petition, start a petition, participate in a campaign action, make a donation, fill in a survey, apply for employment with us or apply to volunteer with us.

1. Responsible body - data controller

The “controller” - organisation responsible for the processing of personal data collected when you visit our websites - is WeMove Europe SCE mbH, located: Planufer 91, 10967 Berlin.

2. Scope of this Privacy Policy

This Policy regulates how we handle personal data. It specifies which personal data we collect when you visit our websites, and how we use it.

Personal data means any information relating to person which allow to identify that person.

This includes information such as your name, address, telephone number or date of birth. Statistical information that cannot be directly or indirectly associated with you - such as the popularity of individual websites on our site or the number of users of a site - is not personal data.

3. When do we collect information

(1) When you give it to us directly

You may give us your personal data e.g. in order to start a petition, sign a petition, participate in another campaign action, when you share information about a petition from our websites on Facebook, Twitter and/or via email, when you apply for employment with us, when you apply to volunteer with us, when you contact us by phone, email or post, and/or when you donate money to us.

(2) When you give it to us indirectly

Your information may be shared with us by others including users of our services, independent event organisers, other fundraising entities, sponsors and supporters of our organisation and services. Your information will also be provided to us when you follow or otherwise interact with us on or via social media such as Twitter or Facebook.

(3) When you give permission to other organisations to share it with us, or it is available publicly.

(4) When you visit our websites

We use cookies to identify you when you visit our websites and to enable us to personalise your online experience (for example by remembering your details to make it simpler for you to sign a petition). Please refer to the section on Cookies (below) for details on the way our use of cookies affects your personal data.

4. What information we collect

(1) In our campaigning work:

When giving you the opportunity to participate in our campaigns, support our work in other ways and stay informed about our campaigns, we typically collect and hold the following information:

• First name, Last name,
• E-mail address,
• Postcode, Country,
• The language you speak.

 Sometimes we may request other information where it is appropriate and relevant, for example:

• Telephone number,
• Physical address,
• Your social media profile,
• Details of campaigns you have supported, topics/areas of interest to you, responses to surveys you have completed and other information when relevant to the campaign.

The legal basis for data processing is Article 6(1)(b) of the General Data Protection Regulation (EU GDPR). You can also voluntarily provide us with a comment on the campaign you would like to support, and we might publish it on our websites, elsewhere online or printed campaign materials (such as books of signatures, leaflets or banners) signed with your first name to illustrate our community’s views on the topic of the campaign, for the purpose of delivering the petition or outreach to a broader audience online..

(2) To collect donations and process financial transactions:

If you choose to support our work with a donation, we need the following information about you:

• First name, Last name,
• E-mail address,
• Postcode, Country,
• Payment details (name of the account holder, IBAN/ account number, BIC/ bank code, credit card number, name of the financial institution etc.),
• Donation amount and frequency.

The legal basis for data processing is Article 6(1)(b) of the General Data Protection Regulation.

(3) To process your employment or volunteering application:

When you apply for open positions at WeMove Europe, you yourself determine the scope of the data that you would like to submit to us as part of your application. For handling the administration of your employment and/or volunteering application, we typically collect and hold the following information:

• First name, Last name,
• E-mail address,
• Country,
• The language(s) you speak
• Telephone number (where it is appropriate and relevant, for example).

Please note that applications that you send us by email will be sent to us unencrypted. 

(4) You can visit our websites without giving us any personal data or supporting us with a donation. In this case, we only collect and use the data that is automatically transmitted to us when using our websites.

(5) Usage data:

When you visit our websites, we temporarily store so-called usage data, which we use for statistical purposes, to improve the quality and design of our websites, and for online security purposes. We also use this information to enable access to our websites and to control and administer our systems. The legal basis for processing usage data is our legitimate interest within the meaning of Article 6(1)(f) of the General Data Protection Regulation.

The data consists of:

• the page from which the file was requested,
• the name of the file,
• the date and time of the query,
• the amount of data transferred,
• the access status (file transferred, file not found),
• the description of the type of web browser used,
• the IP address of the requesting computer

(6) Website analysis

Matomo

Using self-hosted software called Matomo, we collect non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Our purpose in collecting non-personally identifying information is to better understand how visitors use our websites. From time to time, we may release non-personally-identifying information in the aggregate, e.g., by reporting on trends in the usage of our websites.

We also collect potentially personally-identifying information like Internet Protocol (IP) addresses. We do not use such information to identify our visitors and do not disclose such information to any third parties.

Opting-out of website tracking

You may choose not to have a unique web analytics cookie identification number assigned to your computer to avoid the aggregation and analysis of data collected on this website.
To make that choice, please set your browser to advertise a Do-Not-Track header.

Polyfill.io

Polyfill Service provides snippets of code, called “polyfills”, that provide older Internet browsers some features needed to provide a consistent experience with the most modern browsers. When you load a web page which uses Polyfill Service, your browser will download any polyfills required in order to present the web page successfully in your browser. You can consult their privacy policy on their site.

5. How and why we use your data

(1) Overview

Personal data we handle will be used for the following purposes:

• Running campaigns, including petitions and other actions;
• Handling of donations;
• Personalising user interaction with our websites;
• Sending information about our campaigns by email or by other means (post, phone, sms, whatsapp and other channels);
• Information about significant changes to the Privacy Policy;
• As otherwise described in this privacy policy.

(2) Campaigning

We need your data to enable you to use all of the online services we offer which relate to our campaigning work, e.g. participate in a campaign, sign a petition, start a petition, take part in a survey or other campaign action (e.g. mail or tweet a campaign target).

To enable you to participate in a campaign, we need your name, email address, postcode and country. We use your data (signature) to note your participation in a campaign in the signature list and to invite you to agree to receive our campaign emails.

We might typically hand over the information about your name, surname and country to the petition target - that way we can prove that there is a real person behind your signature, and protect your privacy by keeping the information we share to a minimum. In some special cases, where the information about where you are located (e.g. electoral district) would be relevant to the goal of the campaign, we might also share your city or postcode with the petition target.

If you participate in a campaign, we may ask you if we may share your email address with the initiator of the campaign or with our partner organisation. If you agree, we will share your email address.

For the execution of campaigns, service providers employed by us, e.g. for sending emails or website analysis receive the necessary data for the execution of the order. The service provider may only use the data to perform the task assigned to them.

If you participate in a campaign, with your explicit consent we will use your data to keep you informed by email (or via another channel) about the work of WeMove Europe and our campaigns. You can revoke your consent to receive information at any time by unsubscribing or writing us a message to info@wemove.eu or as detailed below.

The legal basis for data processing is Art. 6 section 1 a) (for the campaign emails) and b) (for a petition signature) of the EU General Data Protection Regulation or for the European Citizens’ Initiative the EU Regulation No. 211/2011 on the European Citizens’ Initiative.

(3) Processing financial transactions

We use your data to handle the administration of any donation or other payment you make to WeMove Europe via credit/debit card, direct debit, cheque, standing order or other bank transfer.

Your data will only be passed on to third parties if this is necessary for the processing of donations. For the processing of donations, service providers employed by us (please see below) receive the necessary data for the execution of the order. The service provider may only use the data to perform the task assigned to them.

Financial transactions carried out on our websites are handled through:

• Stripe, Inc. (“Stripe”), third party payment services provider,
• Paypal, Inc. (“Paypal”), third party payment services provider, and
• GLS-Bank (“Bank”), SEPA Direct Debit provider.

We recommend that you read Stripe’s privacy policy ( https://stripe.com/gb/privacy) and Paypal’s privacy policy (https://www.paypal.com/fr/webapps/mpp/ua/privacy-prev) prior to effecting any transaction using these providers. We will provide your personal data to Stripe or Paypal only to the extent necessary for the purposes of processing payments for transactions you enter into with us. We do not store your credit card details.

We use your data to keep our donors informed by email (or via another channel) about the work of WeMove Europe and our campaigns. You can revoke your consent to receive information at any time by unsubscribing or writing us a message as detailed below.

The legal basis for the use of your data is Article 6(1)(f) of the General Data Protection Regulation. WeMove has a legitimate interest in being in contact with our donors.

(4) Contact

You can contact us by post, email to info@wemove.eu, telephone or via direct message on Twitter or Facebook. The data you provide will only be used to process your request, e.g. provide you with the services, materials or information you have requested. Your data will only be passed on to third parties if this is necessary to process your request.

The legal basis for the use of your data is Article 6(1)(f) of the General Data Protection Regulation. WeMove has a legitimate interest in being in contact with the users of our websites and to answer any questions or send information.

(5) Campaign emails or “newsletter”

When you participate in one of our campaigns for the first time, or when you submit your data through the “Join our movement” form, we will ask for your consent to send you further emails (“newsletter”).

With your explicit consent, we will use your email address to send you personalised emails about the campaigning work of WeMove Europe (including e.g. campaign launches, other campaign actions which might require your attention or participation, fundraisers, reports on campaign developments). We might use the data you provide (e.g. the campaign you took part in, your country, your postcode) as well as information about how you interact with our emails (e.g. the language you speak, our emails you open, the links you click) to make sure the emails you receive are interesting and personalised.

The legal basis for processing data is Article 6 (1) a) of the General Data Protection Regulation (consent), which you give us by clicking on the corresponding link in the confirmation email. You receive the confirmation email after submitting your data into one of our forms when you participate in a campaign. The data will be stored for as long as your consent remains valid. You can revoke your consent to receive campaign emails at any time by unsubscribing or writing us a message as detailed below.

(6) Employment or volunteering application

To apply online for open positions at WeMove Europe, you can send us your application via email. You yourself determine the scope of the data that you would like to submit to us as part of your online application. We will use your personal data to handle the administration of your employment and/or volunteering application. The legal basis for this data processing is § 26 (1) 1) of the Federal Data Protection Act (Bundesdatenschutzgesetz n.F.) (decision on the establishment of an employment relationship). Your application data will be forwarded to and handled only by the persons responsible for the advertised position and for hiring procedures. All participants treat your application documents with the necessary care and confidentiality. After we’ve completed the selection procedure, the information you provide for the specific selection procedure and the documents sent will be deleted after six months, unless we have established an employment, volunteering or other type of contract with you.

(7) Supporter research

We may use your personal information to undertake research to gather further information about our supporters from publicly accessible sources. This might sometimes help us to get a better understanding of your background, interests and preferences in order to improve our communications and/or interactions with you, to help ensure they are targeted to be relevant and appropriate, and to provide information (sometimes through third parties, e.g. online marketing tools such as Facebook advertising or Google ads) about petitions and other aspects of our services which we consider may be of interest to you.

The legal basis for processing data is Article 14 (2) f) of the General Data Protection Regulation.

6. Cookies

Cookies are small files that are stored on the hard disk of your computer or mobile device. They allow you to store information for a certain period of time and identify your end device.

We use cookies in some areas of our websites, e.g. in order to recognize your browsing preferences, to be able to improve your browsing experience, to pre-fill signature forms for you. This facilitates navigation and makes our websites more user-friendly. Cookies also help us to identify particularly popular areas of our websites.

We use different types of cookies. We use permanent cookies for better user guidance and individual service presentation. We also use so-called session cookies, which are automatically deleted when you close your browser. You can set your browser to inform you about the placement of cookies. This makes the use of cookies transparent for you. Important: If you do not accept cookies, you may not be able to use certain features of our websites.

The processing is carried out on the basis of Art. 6 (1) f) of the General Data Protection Regulation. It’s in our legitimate interest to optimise or enable user guidance and adapt the presentation of our website.

7. Third party websites

We link our websites directly to other sites. For example, on our page you will find links to Facebook, Twitter or YouTube. This Privacy Policy does not cover external websites and we are not responsible for the privacy practices or content of those sites. We encourage you to read the privacy policies of any external websites you visit via links on our websites.

8. Data retention

In general, unless still required in connection with the purpose(s) for which it was collected and/or is processed, we remove your personal information from our records five years after the data it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure, we will remove it from our records at the relevant time.

In the event that you ask us to stop sending you campaigning/fundraising/other electronic communications, we will keep your name on our opt-out list to ensure that you are not contacted again.

9. Service providers

WeMove Europe uses service providers to provide certain services and to process your data (e.g. denial of service attacks protection) (order processing in accordance with Art. 28 of the General Data Protection Regulation). The service providers process the data exclusively on the instructions of WeMove Europe and have been obliged to comply with the applicable data protection regulations. All contractors have been carefully selected and will only have access to your data to the extent and for the time required to provide the services.

Please note that some countries outside of the European Economic Area (“EEA”) have a lower standard of protection for personal data, including lower security requirements and fewer rights for individuals. We strive to only work with providers in the EEA who offer the best privacy protection. However, in some cases we might work with service providers outside the EEA and may transfer and/or store personal data collected from you to and/or at a destination outside the EEA. If we transfer and/or store your personal data outside the EEA we will take reasonable steps to ensure that the recipient implements appropriate measures to protect your personal data.

10. Data security

We endeavour to ensure that there are appropriate and proportionate technical and organisational measures to prevent the loss, destruction, misuse, alteration, unauthorised disclosure or of access to your personal information.

In addition to securing the operating environment, we use a state-of-the-art encryption method when transporting your data over the Internet. You can recognize this by the fact that the lock symbol in the address bar of your browser is closed and the address line starts with https://

Otherwise than as set out in this Privacy Policy, we will only ever share your data with your informed consent.

For highly sensitive informations (such as the ones collected for a European Citizen Initiative according to specific legal requirements, that might e.g. include your ID number), we also encrypt the data before storing it.

11. Your rights

As a user, you have the right to request information about what data about you is stored by us and for what purpose it is stored and processed. In addition, you may ask that we correct incorrect data, or request to have your data deleted (data which is no longer necessary to be stored). You have the right to data portability. You also have the right to complain to a supervisory authority about the data processing taking place. You have the right of appeal to a supervisory authority if you believe that the processing of data concerning you violates data protection regulations. The right of appeal may be exercised in particular before a supervisory authority in the Member State where you are living, working or where the infringement is suspected to occur.

12. Children

The WeMove Europe websites are not directed at persons under 16 years of age. Therefore, if you are under the age of 16, you may not use the WeMove Europe websites or enter your personal data on our websites.

We do not knowingly collect data from persons under 16. If you are a parent of a person under 16 and you become aware that your child is using our websites, please contact us at the contact details listed below and arrange for the data in question to be removed.

13. Policy amendments

We keep this Privacy Policy under regular review and reserve the right to update from time-to-time by posting an updated version on our websites, not least because of changes in applicable law. We recommend that you check this Privacy Policy occasionally to ensure you remain happy with it. We will notify you of significant changes to our privacy policy by email.

14. Contact

Please contact our Data Protection Officer if you have any queries or concerns whatsoever about the way in which your data is being processed.

Email: dpo@wemove.eu

Address: WeMove Europe SCE mbH

Planufer 91, 10967 Berlin,

Germany