DEBUNK.ORG
PRIVACY POLICY
1. Why should I read this Privacy Policy?
This Privacy Policy (the ‘Policy’) describes how Debunk EU, VšĮ (hereinafter referred to as “we”, “us”, “our”) collects, uses, discloses, and stores your personal data (the “Data”) and what statutory rights do you have. We protect your personal information under the applicable data protection laws, including but not limited to the EU General Data Protection Regulation (2016/679) (‘GDPR’).
2. Who is responsible for protecting my Data?
We are: Debunk EU, VšĮ
Our entity number is: 304029116
Our address: Šturmanų str. 4-1, LT-93201 Klaipėda, Lithuania
Our e-mail address: info@debunk.org
3. Why and how do you use my Data?
3.1 To conduct disinformation research
We conduct disinformation research to defend democratic values and human rights, and to facilitate a safe public information space. This research includes information on threat actors and individuals engaged in disinformation activities.
Legal basis for the processing | The categories of Data concerned | Is the provision of Data a requirement? |
|---|---|---|
comments and articles, other information made public, activities in public groups. | ||
Legitimate interest (to research disinformation)
(Art. 6(1)(f) of the GDPR) | Name, surname, aliases, email address, telephone number, social media profiles, affiliations, connections, disinformation activities, IP addresses, resources used, positions, bot networks, location, public comments and articles, other information made public, activities in public groups | No |
3.2 To run educational media literacy campaigns and trainings
Where you register for or participate in educational media literacy campaigns and trainings run by us – including, but not limited to, trainings for institutions, schools, and professionals, online programs, and games – we will use your data to the extent necessary to provide these campaigns and trainings.
Legal basis for the processing | The categories of Data concerned | Is the provision of Data a requirement? |
|---|---|---|
Consent
(Art. 6(1)(a) of the GDPR)
Legitimate interest (to conduct training)
(Art. 6(1)(a) of the GDPR) | Name, surname, email address, telephone number, school, registration information. affiliation, represented institution, participation, evaluations, certificates, recordings of public events (in case they are recorded) | Yes. If you do not provide your Data, we will not be able to provide you with our services. |
3.3 To conduct recruitment and expert selection
When you apply for a position with us (including but not limited to employees, interns and volunteers) or may qualify as an expert in our projects, or when we reach out to you regarding a job or expert opportunity, we process your data as part of the recruitment and expert selection processes.
Legal basis for the processing | The categories of Data concerned | Is the provision of Data a requirement? |
|---|---|---|
Consent
(Art. 6(1)(a) of the GDPR)
Legitimate interest (selection of employees and experts)
(Art. 6(1)(f) of the GDPR) | Full name, e-mail address, phone number, CV, work experience, educational background, professional certifications, language skills, availability for work, references and their contact information, interviews, assessments results, any other information you provide to us | No |
3.4 To comply with research guidelines and professional standards
While researching disinformation and conducting other activities, we adhere to all applicable international guidelines and professional standards. These include, but are not limited to, research, editorial, and gender equality guidelines, among others. In some cases, to comply with these guidelines, we must collect and use limited data about our employees, researchers, experts and the individuals included in the research.
Legal basis for the processing | The categories of Data concerned | Is the provision of Data a requirement? |
|---|---|---|
Legitimate interest
(compliance with guidelines and standards)
(Art. 6(1)(f) of the GDPR) | Name, surname, gender, projects, payments, benefits, complaints, other information specified by applicable guidelines and professional standards | No |
3.5 To handle your inquiries and communications with you
We're dedicated to offering assistance and addressing any queries or concerns you may have. In order to respond to your inquiries effectively, we need to process your Data.
Legal basis for the processing | The categories of Data concerned | Is the provision of Data a requirement? |
|---|---|---|
Consent
(Art. 6(1)(a) of the GDPR)
Legitimate interest (handle communications with you)
(Art. 6(1)(f) of the GDPR) | Email address, subject of your inquiry, date of your inquiry, content of your inquiry, attachments to your inquiry, your name and (or) surname provided in your inquiry, reply to your inquiry, other information provided by you | No |
3.6 To ensure security of and improve our websites and platforms
To ensure our website and platforms remain secure and operates smoothly, we automatically collect certain technical information about your device and how you use our websites and platforms. This is a common practice designed to maintain the best possible functionality and safety while you’re browsing.
Legal basis for the processing | The categories of Data concerned | Is the provision of Data a requirement? |
|---|---|---|
Legitimate interest
(security and improvement of our Website)
(Art. 6(1)(f) of the GDPR) | IP address, log-in information, browser type and version operating system and platform, type of device, a unique device ID, mobile network information, mobile operating system and the type of mobile browser you use, screen resolution, use and interaction information | No |
3.7 To send newsletters, provide other communications and display adds
When you or the entity you represent have used our services, consented to receive communications or adds, or when we have a legitimate interest to inform you about our activities, we will send you our newsletters, provide other communications with information about these activities, or display personalized online advertisements to ensure that the content you see is relevant to your interests.
Legal basis for the processing | The categories of Data concerned | Is the provision of Data a requirement? |
|---|---|---|
Consent (Article 6(1)(a) of the GDPR)
Customer relationship
(Article 81(2) of the Law on Electronic Communications of Lithuania)
Legitimate interest
(direct and other marketing)
(Article 6(1)(f) of the GDPR) | Name, surname, email address, affiliation, telephone number, preferences, interests, IP address, advertising IDs, browsing information, device information, cookie information, online behaviours, and interactions with previous advertisements | No |
3.8 To manage our social media profiles
By engaging with us through messaging, following our pages, or interacting with our posts on social media, you agree that your limited data will be processed by us.
Legal basis for the processing | The categories of Data concerned | Is the provision of Data a requirement? |
|---|---|---|
Consent
(Art. 6(1)(a) of the GDPR) | Name and surname provided in your social media profile, email address, messages, message information, attachments, comments, shares, reactions, other interactions and additional Data provided | No |
3.9 Fulfilment of statutory duties and the establishment, exercise, or defense of legal claims
If you enter into a contract with us, we'll keep your Data for as long as the law requires. This helps us protect our legal rights, just in case. We also need to hold onto some of your information for legal stuff like accounting and record-keeping. And, on the off chance you're involved in a legal case where we're also a party, we'll use your Data specifically for that case.
Legal basis for the processing | The categories of Data concerned | Is the provision of Data a requirement? |
|---|---|---|
Legal obligation
(Article 6(1)(c) of the GDPR)
Our legitimate interest to defend our rights and interests
(Article 6(1)(f) of the GDPR) | Name, surname, address, IDs, personal identification numbers, social security numbers, payments, legal documents, contracts, communications, procedural documents, annexes, court documents, investigation information, criminal convictions and offenses, other Data provided or mandated | When the processing of your Data is required under applicable laws, providing this Data becomes a legal necessity. If you are unable to provide this Data, unfortunately, we will not be in a position cooperate with you. |
4. How long do you store my Data?
We will not retain your Data for longer than is necessary for processing purposes outlined above, except when required by law, which may necessitate an extended retention period.
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The data shall be stored within the time limits set out in the Index of General Document Retention Periods approved by the Chief Archivist of Lithuania.
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We will retain other Data for 10 years, unless needed for compliance with statutory obligations or public or our legitimate interests.
5. Where do you collect my information from?
We collect most of the information from you. Where needed for the above purposes, we collect the information from various sources:
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Public records databases (such as company registries and regulatory filings) and other publicly accessible data;
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Private or commercially available sources, social media and other online platforms;
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Institutions and entities engaged in disinformation research, research partners;
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State institutions and agencies.
6. Who do you share my Data with?
Where necessary for the purposes set out above and subject to applicable laws, we share Data with the following Data recipients:
Data recipients or categories of Data recipients | Third Country | ID |
|---|---|---|
Microsoft Corporation (LinkedIn) (Social media service provider) | EU/ US | |
Meta Platforms, Inc. (Social media service provider)
| EU/ US | |
State institutions, supervisory authorities, law enforcement authorities, and courts.
| EU / Worldwide | |
Providers IT tools and resources
| EU / Worldwide | |
Professional advisors (lawyers, bankers, auditors, insurers, and others | EU / Worldwide | |
Research partners, consortiums, institutions and entities engaged in disinformation research | EU / Worldwide
|
7. What are my rights?
Subject to conditions, limitations, and exceptions established by statutory data protection provisions, you have the rights listed below:
My right | When this right is applicable to me? |
|---|---|
Right to withdraw consent | where the processing is based on consent, as explained in Section 3 of this Privacy Policy, and you seek to withdraw it at any time. |
Right to lodge a complaint | where you want to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the data protection laws. |
Right to object | where the collection and use is based on a task carried out in the public interest or in the exercise of official authority vested or legitimate interest, including profiling, as explained in Section 3 of this Privacy Policy, or where you object to the collection of your personal data for direct marketing purposes. |
Right to data portability | where you seek to receive the data you have provided in a structured, commonly used and machine-readable form or to transmit those data to another controller, the processing is based on consent or on a contract and is carried out by automated means. |
Right to erasure (‘right to be forgotten’) | - when personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- when you withdraw consent on which the processing is based and there is no other legal ground for the processing;
- when you object to the processing and there are no overriding legitimate grounds for the processing, or you object to the processing for direct marketing purposes;
- where the personal data have been unlawfully processed;
- where the personal data have to be erased for compliance with a legal obligation;
- where the personal data have been collected in relation to the offer of information society services directly to a child and subject to a consent. |
Right to restriction of processing | - where the accuracy of the personal data is contested by you;
- where the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
- where we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims;
- where you have objected to processing.
|
Right to rectification | when you seek to obtain from us the rectification of inaccurate personal data concerning you.
|
Right of access | when you seek to obtain confirmation as to whether we collect or otherwise process personal data concerning you, and, where that is the case, access to the personal data and the information about the data processing. |
8. Do you engage in automated individual decision-making, including profiling?
No, we do not make decisions based solely on automated processing, including profiling, which would produce legal effects concerning you.
9. Cookies and similar technologies
The cookies and similar technologies listed below are used to save information or to access information that is already stored on your devices. A cookie is a small piece of data saved by the Website on your computer or mobile device. Cookies facilitate the website's ability to remember details about your visit, thereby simplifying future visits and enhancing the site's utility for you. Additionally, other technologies, such as unique identifiers for identifying your browser, app, or device, pixels, and local storage, may be employed for similar purposes..
Purpose | Cookie | Description | Third party? | Duration of operation |
|---|---|---|---|---|
_fbp | Used by Meta to deliver a series of advertisement products such as real time bidding from third party advertisers | No | 3 months | |
_gcl_au | Used by Google AdSense for experimenting with advertisement efficiency across websites using their services | No | 3 months | |
svSession | Identifies unique visitors and tracks a visitor’s sessions on a site | No | 1 year 1 month | |
Targeting | IDE | This cookie is set by Doubleclick and carries out information about how the end user uses the website and any advertising that the end user may h | Yes | 1 year |
_ga | This cookie name is associated with Google Universal Analytics. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. | No | 1 year 1 month | |
Analytics | _ga_NZX3JGWHMT | This cookie is used by Google Analytics to persist session state. | No | 1 year 1 month |
ssr-caching | Indicates how a site was rendered | No | 13 Seconds | |
XSRF-TOKEN | This cookie is written to help with site security in preventing Cross-Site Request Forgery attacks. | Yes | Session | |
hs | Used for security reasons | No | Session | |
Necessary to provide service | bSession | Used for system effectiveness measurement | No | 30 minutes |
10. How can I manage cookies and similar technologies?
Most browsers give you the ability to manage cookie settings, including the use of cookies, and to delete cookies and browsing history. This applies to browsers such as Chrome, Firefox, Internet Explorer, and Opera.
11. Can this Policy be amended?
We may amend this policy unilaterally from time to time. Any such amendments will be effective immediately upon publication, therefore please visit our https://www.debunk.org/ regularly for the latest version of this Policy.