Privacy notice grants
This privacy notice is applicable to the provision of DFF Services, such as our grant application process, meetings, or if you are a member of our Panel of Experts. Please click here, for the privacy notice applicable to visitors of the DFF website or people submitting a concept note to apply for DFF Services.
This website is owned and operated by the Digital Freedom Fund (“DFF” or “us” or “we“). DFF takes your privacy seriously and is committed to handling your personal data in a fair and secure manner. We believe it is important to inform you about which personal data we collect and how we will use your personal data.
This privacy notice applies to all personal data that is collected and used by us when you apply for a grant, pro bono support or any other type of support from us (“Services“), as well as circumstances where you express an interest in attending meetings or events held or supported by DFF (“Meetings”), and express an interest in having content hosted on DFF’s website (“Website Content”). This privacy notice also applies to the independent expert panel that may assist with the performance of aforementioned Services (“Panel of Experts“).
DFF is responsible for the collection and use of your personal data through your use of our Services or visiting the website. DFF is a non-profit organisation which supports strategic litigation to advance digital rights in Europe by providing financial support for strategic litigation and facilitating collaboration between digital rights actors.
The personal data we collect about you when you use our Services or form part of our Panel of Experts may include the following:
Personal data you provide to us in the context of our Services, Meetings, Website Content and Panel of Experts:
- Your contact details – your name, organisation, job title, postal address and other contact details, such as your telephone number and email address;
- Your personal characteristics – short biographies for you and, where applicable, all key members of your team;
- Your communication data – data that we receive if we communicate with you via email or online as well as information contained in, where applicable, concept notes, application forms, reporting documents, budgets, and self-assessment forms;
Additional personal data you provide to us in the context of our Services
- Your financial details – a bank statement, annual accounts or other documentation demonstrating the financial status of the applicant;
- Your identification data – a copy of your identity document and identity verification document;
- Your business data – personal data contained in articles of incorporation, proof of registration and/or annual accounts;
- Other information you provide to us, either voluntarily or upon our request.
Additional personal data you provide to us in the context of our Meetings:
- Your travel details – travel itinerary to and from relevant Meetings, and details about accommodation for such Meetings;
- Your identification data – a copy of the information page of your passport;
- Other information you provide to us, such as dietary requirements, either voluntarily or upon our request.
Additional personal data you provide to us when submitting Website Content:
- Your image – a personal photograph of yourself to accompany blogs and/or essays;
DFF collects and uses your personal data on a lawful basis for the purposes described below.
To take steps at the request of the data subject prior to entering into a contract
Services: DFF uses your name, email address and communication data to know who is submitting a concept note or application for Services, to make an assessment for qualification for a grant and to have a way to communicate with you. We do so on a lawful basis in order to take necessary steps at your request prior to entering into an agreement.
DFF may use the other data identified under the relevant headings above concerning Services in order to formalise and perform the agreement between you and DFF and as such provide you with the Services you requested.
Panel of Experts: If you are a member of our Panel of Experts, your contact and business details are used to ensure DFF can select the right expert for the right assignment. We do so on the basis of the performance of an agreement or in order to take necessary steps prior to entering into an agreement.
On the basis of your consent
Website Content: DFF uses the data identified under the relevant headings above concerning Website Content for the purpose of making an assessment as to whether a blog/essay is suitable for publication on DFF’s website and communicating with authors of selected content in order to provide feedback and comments with a view to publication on DFF’s website. DFF may use an author’s name, photograph, and biography for the purpose of publishing the blog/essay on DFF’s website, maintaining an archive of published content, and promoting the content on social media sites and other similar fora. We do this on the basis of the author’s consent.
Meetings: DFF may use your identification data where necessary to book flights or make other travel arrangements for you to attend our meetings. We may do this on the basis of your consent.
General: DFF may also use your email address for information purposes, if you have decided to sign up for our newsletter. This includes for example, informing you on new content on our blog or calls for applications. We may also use the information referred to above in the section ‘Personal data we collect’ in order to respond to queries about our work or enquiries about recruitment that we receive by email or other forms of online communication. We may do this on the basis of your consent.
You can withdraw your consent at any time. In order to do so, please see the section ‘Your rights’ below.
In pursuit of legitimate interests
Meetings: DFF uses the data identified under the relevant headings above concerning Meetings for the purpose of organising and formulating an agenda for the relevant meeting. DFF may use this data for arranging travel and accommodation for you to attend the meeting, and to ensure your access and dietary needs can be met during the meeting. DFF may also use this data for the purpose of evaluating the meeting in order to help improve future meetings. We do this for the purpose of pursuing our legitimate interest in providing useful field-building meetings.
For compliance with legal obligations
Services: In the context of our Services, your identification and financial data is used to verify your identity and to verify the ability to receive funds from us and assess any likelihood of financial mismanagement. We do so on the basis of our legitimate interest to prevent financial mismanagement or fraud, or if applicable to comply with a legal obligation to which we are subject.
General: All the information referred to above in the section ‘Personal data we collect’ may be used to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations. We would do so on the basis of compliance with a legal obligation to which we are subject.
We retain your personal data for as long as required to satisfy the purpose for which they were collected (for example, for the time necessary to provide you with our services), unless a longer period is necessary for our legal obligations or to defend a legal claim. The copy of your identity card is deleted as soon as we have verified your identity and signed the identity verification document.
Our website contains links to third party websites, for example to Twitter. If you follow these links, you will exit our website. While these third party websites are selected with care, DFF cannot accept liability for the use of your personal data by these organisations. For more information, please consult the privacy statement of the website you are visiting.
For the purposes described in this privacy notice, we may share your personal data on a need to know basis with colleagues due to their function within DFF. We also engage third parties to facilitate or assist us with the delivery of our Services and Meetings, or to perform other services in relation to these activities. We may share your personal data on a need to know basis with these third parties. In addition, information about you, including personal data, may be disclosed as part of any merger, sale, transfer of DFF’s assets, acquisition, bankruptcy, or similar event.
We will take steps in accordance with applicable legislation to keep your personal data accurate, complete and up-to-date. You are entitled to have any inadequate, incomplete or incorrect personal data corrected (that is, rectified). You also have the right to request access to your personal data and to obtain a copy of it as well as additional information about the processing and to request us to erase the personal data we hold about you.
The following rights apply to European residents in addition to the above:
- Right to restriction: you have the right to obtain a restriction of processing, for example in case we no longer need your personal data in view of the initial purposes, but they are required by you for the establishment, exercise or defense of legal claims;
- Right to object: you have the right to object to our processing of your personal data which is based on our legitimate interests. We will no longer process your personal data upon your request, unless we have compelling legitimate grounds for the continuation of the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims;
- Right to withdraw consent: in cases where we rely on your consent for using your personal data, you can withdraw such consent at any time by sending an email to: firstname.lastname@example.org, or by using the unsubscribe button provided for in every newsletter we send;
- Right to data portability: under circumstances, you have the right to have your personal data transmitted to another data controller in a structured, commonly used and machine-readable format;
- Right to lodge a complaint: in case you have a question or complaint about how we process your personal data, you can send an email to email@example.com. Alternatively, you could consider to lodge a complaint with a supervisory data protection authority.
For further information regarding your rights, or to exercise any of your rights, please contact us through the details provided below.
If you have any questions regarding the processing of your personal data or this privacy notice, please contact DFF via firstname.lastname@example.org or via the below postal address:
Digital Freedom Fund
Nieuwezijds Voorburgwal 104-108
1012 SG Amsterdam
This privacy notice is dated August 2019. We may change this privacy notice from time to time. If a fundamental change is involved that requires us to inform you about this, or if the change is in any other manner relevant to you, we will ensure that information is provided to you well in advance of the change actually taking effect.