The Bellona Environmental Transparency Center (“Bellona” or “we”) understands the importance of protection of your personal data, therefore we prepared this Privacy Policy (“Privacy Policy”) to inform you of our policies regarding the collection, use and disclosure of data when you visit our website www.bellona.org (“Website”), participate in our events, subscribe to newsletters. The Privacy Policy applies to every person who visits the Website, as well as to any actions you may take on the Website.

When processing your personal data, we comply with the requirements of the Regulation (EU) 2016/679 (General Data Protection Regulation) (“GDPR”).

Who We are?

The Website is managed and administered by Public Body the Bellona Environmental Transparency Center (legal entity code 306200975, registered office address at Kęstučio 54-6, LT-08112 Vilnius, Lithuania, e-mail ru@bellona.org).

About personal data

Personal data is any information related to a natural person that can be identified directly or indirectly. Examples of such information are name, address, phone, date of birth and various forms of recorded behaviour such as browsing habits.

For what purpose we collect and use your personal data

• To organize events

To organise events and invite you to events organised by Bellona, we will collect the following personal data on the basis of your consent: name, surname, email address, organization you represent, how you will participate in the event (live or remotely).

We may transfer this data to external data processors whose services we use for event registrations, sending information, etc.

Our partners who process data on our behalf are:

• Microsoft (365)
• Sendpulse
• Mailchimp

To deliver our publications to you, we will collect the following personal data on the basis of your consent: name, surname, email address, address.

We will process the collected personal data until you cancel your consent or until we will no longer send the publications you ordered.

We may transfer this data to our IT service providers, couriers, post offices and other data processors whose services we use to send information, etc.

• To maintain communication with you

To maintain communicate with you and inform about our activities, we will collect the following personal data based on your consent: name, position, company, email address and phone number.

We will process the collected personal data until you withdraw your consent.

We may transfer this data to our IT service providers and other data processors whose services we use to send information, etc.

• To inform about our activities

To inform you about our activities (send you newsletters) We will collect the following personal data on the basis of your consent: name, surname and email address.

We will keep the collected personal data until You withdraw Your consent.

We may transfer this data to our IT service providers and other data processors whose services we use to send information, etc.

• To conclude and perform contracts with service providers

To conclude and execute contracts with service providers for the purpose of concluding and executing the contract and for the purpose of legitimate interest, we process the following personal data: name, surname, personal identification number, date of birth, address, e-mail address, telephone number, individual activity certificate number, communication data.

We will process the collected personal during the term of the contract and for a period of 10 years after the end of the contract.

We may transfer this data to Our IT and accounting service providers.

• To ensure the functionality of the Website, administer the Website, diagnose possible malfunctions of the Website, and perform statistical analyses in order to determine your needs in relation to certain functions and to analyse how and where to make the most efficient use of the available resources

When you visit our Website, it records information about visited page on our domain, date and time of the server request, browser type and browser version, operating system used, referrer URL, host name of the accessing computer, IP address. These logs are used for possible troubleshooting. This data will not be merged with other data sources. The basis for data processing is the fulfilment of the contract or the pre-contractual measures. 

This data is processed for approximately a month after collection and later it is deleted.

Sharing of information

We do not share personal data with others, except for our partners (data processors) who need the data in order to provide services to us. Where we provide personal data, we establish individual agreements with the relevant data processors that limit their opportunity to use the information for other purposes.

We will disclose information in individual cases as imposed by law, for example to public authorities if offenses are suspected. Other cases of sharing or disclosure will require the consent of the person concerned.

Data processors who handle personal data on our behalf, are obliged to do the same. In case of breach of personal data, we are obliged to notify the Data Inspectorate and the persons concerned.

Information about Plugins used on the Website

YouTube 

Our website uses plugins from YouTube to integrate and display video content. The provider of the video portal is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. 

When you access a page with an integrated YouTube plugin, a connection to the YouTube servers is established. This tells YouTube which of our pages you have accessed. 

YouTube can assign your surfing behavior directly to your personal profile if you are logged into your YouTube account. You can prevent this by logging out beforehand. 

The use of YouTube is in the interest of an attractive presentation of our online offerings. This represents a legitimate interest within the meaning of Article 6 Paragraph 1 Letter f GDPR.  Details on how to handle user data can be found in YouTube’s privacy policy at: https://www.google.de/intl/de/policies/privacy.   

Vimeo 

Our website uses Vimeo plugins to integrate and display video content. The provider of the video portal is Vimeo Inc., 555 West 18th Street, New York, New York 10011, USA. 

When you access a page with an integrated Vimeo plugin, a connection to the Vimeo servers is established. This tells Vimeo which of our pages you have accessed. Vimeo learns your IP address even if you are not logged in to the video portal or do not have an account there. The information collected by Vimeo is transmitted to the video portal’s servers in the USA. 

Vimeo can assign your surfing behavior directly to your personal profile. You can prevent this by logging out beforehand. 

Details on how to handle user data can be found in Vimeo’s privacy policy at: https://vimeo.com/privacy.

X (former Twitter) plugin 

Our website uses functions of the X (former Twitter) service. The provider is X Corp., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.  

When you use X (former Twitter) and the “Repost” function, websites you visit are linked to your X (former Twitter) account and published in your X (former Twitter) feed. Data is transmitted to X (former Twitter). We have no knowledge of the content of the transmitted data or how this data is used by X (former Twitter). Details can be found in X’s privacy policy: https://twitter.com/privacy. 

You can change your privacy settings on Twitter: https://twitter.com/account/settings.

Google Web Fonts 

Our website uses web fonts from Google. The provider is Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. 

By using these web fonts, it is possible to present you with the representation of our website that we want, regardless of which fonts are available to you locally. This is done by retrieving the Google Web Fonts from a Google server in the USA and thereby passing on your data to Google. This is your IP address and which page you visited on our website. The use of Google Web Fonts is based on Art. 6 Para. 1 lit. f GDPR. As the operator of this website, we have a legitimate interest in the optimal presentation and transmission of our website. 

The company Google is certified for the US-European data protection agreement “Data Privacy Framework”. This data protection agreement is intended to ensure compliance with the level of data protection applicable in the EU. 

Details about Google Web Fonts can be found at: https://www.google.com/fonts#AboutPlace:about and further information in Google’s data protection regulations: https://policies.google.com/privacy/partners?hl=de.

Cookies and other tracking technologies

The setting of cookies that are necessary to carry out electronic communication processes or to provide certain functions you require (e.g. remember the language of the website) is based on the legitimate interest to ensure that our services are technically error-free and seamless. If other cookies are set (e.g. for analysis functions), they will be treated separately in this Privacy Policy. 

We use the Google Analytics service for overview and statistics about the use of our websites. This is done via a program code (script) embedded in all our webpages. This program code sends information to Google Analytics about date, time and page. In addition, information about the device used (such as mobile / PC, operating system, and browser version) is recorded. This information is used for aggregated statistics and does not identify individuals.

We can use codes in links on newsletters and other mail. These track which links were clicked and are used for aggregate reporting, but do not identify individuals.

Security of personal data

We use appropriate security measures to protect personal information that is under our control from unauthorized access. Data processors who handle personal data on our behalf, are obliged to do the same. In case of breach of personal data, we are obliged to notify the Data Inspectorate and the persons concerned.

Your rights as data subject

• Access and rectification

You have the right to request access to personal data we have about you in a convenient electronic format. You also have the right to demand that personal data we have about you is correct. If you notice errors in the personal data we have about you, please contact us at ru@bellona.org.

• Revocation of your consent to data processing 

Some data processing operations are only possible with your express consent. You can revoke the consent you have already given at any time. An informal notification by email is sufficient to revoke your consent. The lawfulness of the data processing carried out until the revocation remains unaffected by the revocation. 

• Right to data portability 

You have the right to have data that we process automatically based on your consent or in fulfillment of a contract handed over to you or to third parties. It is provided in a machine-readable format. If you request the data to be transferred directly to another person responsible, this will only be done if it is technically feasible. 

• Right to information, correction, blocking, deletion 

At any time, within the framework of the applicable legal provisions, you have the right to free information about your stored personal data, the origin of the data, its recipients, and the purpose of the data processing and, if necessary, a right to correct, block or delete this data. In this regard and if you have any further questions on the subject of personal data, you can contact us at any time using the contact options listed in the legal notice. 

To exercise your rights, you can contact us at any time at the contact email address ru@bellona.org. We have the right to ask you to provide proof of your identity before we can exercise your right(s). Please be informed that the exercise of your rights may depend on the conditions for the exercise of a specific right set out in the legislation, and therefore, in the case of specific grounds set out in the legislation, we have the right to refuse to grant your request for the exercise of a specific right on the grounds stated in the legislation.

Responses to your requests for the exercise of your rights shall be provided promptly, but at the latest within 30 calendar days from the date of receipt of such request. This period may be extended by two further months where necessary, considering the complexity and number of the requests. Within one month from the date of receipt of the request, we will inform you of such extension, together with the reasons for the delay. Requests for the exercise of rights shall be executed free of charge. We have the right to request a reasonable fee if your requests are manifestly unfounded, repetitive, or excessive.

Right to complain

If you believe that the processing of your personal data by the Bellona violates data protection legislation, you have the right to lodge a complaint with the State Data Protection Inspectorate (L. Sapiegos g. 17, LT-10312, Vilnius, vdai.lrv.lt).

Changes to the Privacy Policy

The Bellona reserves the right to make changes to the Privacy Policy on an ongoing basis. We are obliged to notify you of any significant changes in the policy by changing the “Last published date” on this document.

Last Published 08/02-2024