CartONG is committed to respecting French and European regulations on the protection of personal data and promotes a responsible approach to data management in the humanitarian and development sectors.
We have chosen to draft a Privacy Notice comprising four main parts:
-
Our vision of responsible data management and its broad principles to explain the approach we promote.
-
A summary by category of "interlocutor" (volunteer, member, candidate for a position, subscriber to our newsletter, partner, etc.) to make the relevant information more easily accessible.
-
The legal information that we are required to communicate to you.
-
Information regarding the update of CartONG's Privacy Notice - for more transparency.
As such, if you are looking for summarized information about your specific relationship with CartONG, you can go directly to the second section of our Privacy Notice and look at the category or categories that are applicable in your case! For the contact information of our Data Protection Officer, click here.
Last update: 31/01/2020
I. Our vision of reponsible data management at CartONG
At CartONG, we believe that information management technologies, tools and methodologies can play a key role in the success of humanitarian, social and development projects. To this end, we are advocating a rights-based approach based on the "Do No Harm" principle in our sector to implement responsible data management practices and to support our partners in doing the same.
Practicing responsible data management in the humanitarian and development sectors implies taking into account the privacy, security and ethical implications of data management - whether these data are personal or sensitive due to the context of each intervention - and applying it to the different stages of the data management chain: from data collection in the field to data cleaning, processing and/or analysis, storage and deletion.
At CartONG, we treat all data responsibly, above all when it comes to personal data and sensitive personal data. If you are not familiar with the concept of personal data, we invite you to
read this short definition. Similarly, if you wish to know which personal data are considered sensitive by French and European laws, we invite you to
read this brief summary here.
Like any association, CartONG manages personal data as a "data controller" (personal data from its volunteers, members, employees, subscribers to its newsletters, direct beneficiaries, etc.). At the same time, as an H2H (
humanitarian to humanitarian) organization, CartONG manages personal data from its partners (data of populations of concern, data of its partners' employees, etc.) as a "subcontractor". CartONG is therefore double-hatted, which is quite a unique position.
• We have thought about how to apply the GDPR and the French Loi Informatique & Libertés taking into account our particular position and the sector in which we operate. In concrete terms, we have chosen a broader scope of application with regard to the obligations incumbent on the management of "personal data". Indeed, at CartONG, we also apply data protection principles and processes to aggregated data from communities (which may be used for discriminatory purposes, persecution, etc.) and to security data (given their impact on field operations) - this set has been internally renamed "data to protect".
• We practice data minimization: we collect only the data we need. In other words, we do not collect data on individuals, communities and organizations, or even on activities, if we do not have a clear reason to use them for the proper functioning of our association and for the projects we carry out in France and abroad. We encourage our partners who entrust us with their data to do the same.
• We delete data as soon as we no longer need it, and only archive it when required by law or contractual obligations.
• We practice data anonymization whenever possible and always anonymize data that we use externally, for communication purposes or in the production of resources for our partners and the sector as a whole. We encourage our partners who entrust us with their data to do the same..
• We do not use the personal data you have provided to us in a way that is incompatible with the purpose for which you provided it to us, as described in the next section. We never sell the data collected, nor do we pass it on to third parties. We do not use your data for decision-making purposes or automated profiling.
• We integrate data protection when we work with our partners, stakeholder networks, local communities (whenever possible), etc. to design and implement their projects or our own. We pay particular attention to the integration of data protection by design and by default in the solutions we design.
• When we collect data about individuals, communities or organizations, we communicate clearly the reasons for that collection and how the information will be used in order to allow for informed consent and an opt-in process.
• We strive to continually improve our data security practices to bring them up to the highest level. We provide our teams with the necessary support to meet these standards.
• We invest time and resources to actively participate in and/or organize working groups and events, as well as to produce documentation on data protection and responsible data management practices in the humanitarian and development sectors.
II. How does your Privacy Notice apply to you?
In summary, here is how our Privacy Notice applies to you based on your relationship with CartONG (categories are listed in alphabetical order).
We encourage you to also read sections 1 & 3 to better understand the vision of personal data management that we advocate at CartONG and your rights under the GDPR and the French Loi Informatique & Libertés.
If you want to learn more about the cookies used on the CartONG website and blog and by third party services (HelloAsso, MailChimp, Youtube, etc.), go to section III.7.
If you wish to contact us, please refer to section III.8.
We use a
MailChimp account for our newsletters because it is an easy-to-use tool, widely used within NGOs, that allows us to track the obtainment of consent very clearly. MailChimp's servers are based in the United States but MailChimp is certified with the EU-US Data Protection Shield, as detailed in its
privacy notice. When you wish to subscribe to one of the CartONG newsletters via our website, you are redirected to a subscription page managed by MailChimp. We have activated the GDPR field for this registration form: it therefore requires your consent to record your preferences (choice of newsletters) and is built on the principle of minimal collection (only the email address and consent are required to subscribe - it is up to you to fill in the other sections, or not). You must also confirm your email address (by clicking on the link sent to your email box) to finalize your registration (this is called a double opt-in). If you do not give your consent, however, we cannot save your personal data and the request is aborted. Once registered, you can then change your preferences and/or unsubscribe at any time by clicking on the links at the bottom of any email you receive from us via MailChimp. As long as your subscription is active, your personal data is stored on our MailChimp account. These are only accessible to CartONG employees who need to use MailChimp as part of their duties, all via individualized logins. If you unsubscribe, you will no longer receive our newsletters and we will delete your information.
We use 4 social network accounts:
Twitter,
Facebook,
LinkedIn and
Youtube, although the way they work is not completely in line with our vision of responsible data management. Unfortunately, the existing alternatives have not yet reached the size that would allow CartONG to easily reach its supporters. The use of these 4 networks allows us to easily get in touch with new partners, stay informed of the latest events and news in the sector, disseminate job offers or volunteer missions, interact regularly with our community of volunteers, members, and more broadly, supporters, and to broadcast videos (tutorials, mapathon recordings, etc.). Interaction with these social networks is a personal decision. CartONG does not make it mandatory for anyone to use these tools for any reason, and allows those who do not wish to do so to stay informed via other ways (via the CartONG website, blog, newsletters, participation in public events, etc.). Once you have registered on these social networks, subscribed to our pages or "liked" our pages or publications, the personal data management rules as defined in the privacy policies of these social networks apply by default. You can view them
here for Facebook,
here for Twitter,
here for LinkedIn and
here for Youtube (Google product).
Signing up online
CartONG uses
HelloAsso to manage CartONG’s online memberships, a tool that has been designed for associations and that allows
secure online payments (SSL encryption of banking information and 3D Secure control). You can check out its
privacy policy here. When you choose to join CartONG, the first step is to fill out the
dedicated form that you access via our website. On the form, you can give your consent to be added to the
uMap of CartONG employees and members visible on the website (we only locate people by city/neighborhood, not by exact address and only your first name will appear on the map). You can also choose to subscribe to our newsletter(s) by clicking on the link for this form. Following signing up, you will receive an email invitation to our Google Group (which allows us to communicate important information, etc. -
privacy policy available here) and to Nextcloud (for access to volunteer records - see section III.4). You will also be directed to
Trello (the online project management tool we use for volunteer projects -
privacy policy available here). The information you have provided us with is stored in two places: on our HelloAsso account (accessible only to CartONG employees and Board members who need to use HelloAsso as part of their duties with individualized logins) and on a spreadsheet that is stored on CartONG managed infrastructure in a folder with restricted access (see section III.4. for more details). We keep your personal data for up to 3 years after the date of the last time you sign up as a member (as allowed by law), after which time your data is definitively deleted. As part of the process, we might send a few reminder(s) inviting you to re-join. Your data on HelloAsso is also deleted after 3 years. If you choose to make a donation at the time of your membership, you then enter the "donor" process (see below).
Signing up via form and bank transfer
If you have opted for membership by bank transfer and have completed the membership form, all your personal data is stored on CartONG managed infrastructure in the same restricted access folder mentioned above and for a similar length of time. Following your membership, you will receive the same contact email from CartONG. For your information, our financial accounts are held with Crédit Agricole des Savoie.
Members that are also members of the Board
The members of the Board of the association are members of CartONG working on a voluntary basis. For them, the process is a little different and we may store more personal data concerning them (including ID cards to be able to respond to calls for proposals, for reporting purposes, etc.). These data are stored in restricted access files and folders on CartONG managed infrastructure and are deleted when they leave the Board (the Board is elected once per year during the General Assembly). Board members are also invited to join a Google Group to facilitate internal communication.
When you participate in an event, workshop or activity organized by CartONG, we collect and process personal data about you that is required for proper implementation. Such personal data are usually provided by you (via online registration), or, more rarely, by a third party (who co-organizes or supports the activity, workshop or event). This is generally information related to your identity, contact details and/or professional situation. These data are stored securely on the tools selected by CartONG and are kept according to the legal provisions in force. In these activities, workshops and events, we do not manage sensitive data. Below you will find additional details for participants in events organized by CartONG.
Events open to the public
• We use
Eventbrite to organize our events open to the public (mapathons, etc.). As Eventbrite is a global company, personal data may be transferred outside of the EU. Eventbrite, Inc. has certified its compliance with the EU-US Data Protection Shield - see their
privacy policy for details. Eventbrite collects your consent. Your information is managed by several users, all members of the “Missing Maps” and “Maps from here & abroad” teams. When you register for a CartONG event via Eventbrite, the personal information we collect is used for event logistics. We then retain your personal data up to 3 years after the last interaction as permitted by law, after which time your data is permanently deleted. When you register for an event, you also have the option to choose to be added to a contact list for events organized by CartONG in your own city. As such, you can be re-contacted by CartONG, when a new event is organized near where you live. You can unsubscribe from this contact list at any time by clicking at the bottom of the page of the last email received.
• We also occasionally use
LimeSurvey, which is installed on our servers. We delete the data as soon as we no longer need it, and in any case within a maximum of 3 years after the last contact.
• During these activities which are open to the public, we may advise you on the use of certain third party services (such as OpenStreetMap, HOT Tasking Manager, Trello, etc.) that may involve the creation of an account. In which case, the privacy policies of these tools apply by default. The CartONG teams are at your disposal to answer any question you may have.
Associative events
For associative events, we use
Framaforms (
see their terms and conditions here) and create a dedicated form for each occasion. These forms are managed by the members of the Board of the association. They expire automatically after 6 months, at which time all personal data is deleted. Temporarily, your data will be stored on CartONG managed infrastructure (in spreadsheet format) in order to facilitate the logistics of the event (as collaboration is required between the Board and the administrative team of CartONG) but will then be deleted after the associative event in question has ended. For these associative events, we may have to create donation forms on
HelloAsso from time to time. For more information, please refer to the "Donors" section.
Other events
For other events, such as the
GeOnG forum, we may sometimes use tools other than Eventbrite, LimeSurvey and Framaforms, especially when we need more advanced features (such as session management features in parallel with registration management settings). The choice of tool is then made on a case-by-case basis, ensuring that the tool fully complies with the GDPR. In the case of the GeOnG forum, the information may be temporarily stored on a Google Sheet (more information on this aspect in section III.4.) - to which access is restricted to the organizers - in order to ensure statistical monitoring of registrations (in particular for analysis of the types of organization presented, which the registration tool cannot do). This data is then deleted after the event.
This is data that we manage as a subcontractor to other social, humanitarian or development organizations. This is a complex subject and a comprehensive summary covering all possible eventualities exceeds the scope of this document. However, a summary of key aspects is outlined below. We collect and process personal data and/or sensitive data, in the course of providing services to our partners. This data may be provided to us by the people themselves or by third parties (our partners and/or our partners' partners in the field). The personal data in question may include biographical information, contact details, information relating to employment or economic situation, or financial information. We also manage sensitive data, in particular medical data and unique identification numbers, and exceptionally other types of sensitive information. These data are used solely to provide services and develop solutions in support of our partners, for example in the context of field surveys or the development of web-based epidemiological monitoring applications. They are securely stored on the tools managed by CartONG (see section III.4. for more details) and/or those administered by our partners (such as DropBox Business, SharePoint, KoboToolbox, ArcGIS Online, etc.). The data is deleted when CartONG no longer needs it as part of the service provided.
We also process security data, community data and data concerning the types of assistance received by beneficiaries to which we apply the same management and security rules as other sensitive personal data. For more details on the reasons for this choice, please read Section I of our Privacy Notice. /div>
CartONG volunteers
In your interactions with CartONG and for the proper management of projects and other volunteer initiatives, we are required to collect and process personal data about you (name, first name, email address, technical skills, date of last interaction with CartONG, etc.). In accordance with the GDPR, we are required to obtain your consent to do so. This is why we send you a consent collection form by email before transferring your data to a folder with restricted access stored on CartONG infrastructure (see section III.4. for more details). Your data is kept for up to three years after the last contact in accordance with the legal provisions in force. We may need to store more data concerning some of the volunteers, such as those carrying out a field mission (copy of passport, etc.) for legitimate administrative management reasons (booking flights, etc.). This data is also stored on CartONG infrastructure in restricted access folders and deleted on a case-by-case basis once the volunteer assignment has been completed.
Volunteer projects
In the context of volunteer activities, we may advise you on the use of certain third party services (such as OpenStreetMap, HOT Tasking Manager, Trello, etc.) that may involve the creation of an account. In which case, the privacy policies of these tools apply by default. The CartONG teams are at your disposal to answer any question you may have.
As an applicant, the way your personal data is managed by CartONG teams will vary depending on the type of position you have applied for.
For a job, internship or consultancy
Applications are centralized via our
online form (accessible via the website). Any application sent by email is systematically deleted. The information we ask you to fill in is limited to the strict minimum necessary for the proper management of your application (ability to contact you again, CV with professional information to assess your skills for the position, etc.). As part of the recruitment process, your data is stored in 2 places: firstly, on the CartONG website (accessible to a limited number of employees) and secondly, on a Google Sheet (accessible to a limited number of employees and members of the Board of the association who need to have access to your data as part of the recruitment process in question). After completion of the recruitment process, your personal data will be systematically deleted from our website and the Google Sheet. We sometimes contact a particular candidate to request permission to keep their CV for a maximum of 2 years following the last contact. In which case, the CV is stored on CartONG infrastructure in a restricted folder and deleted once the 2-year period has elapsed. If we use an external service provider to assist us in recruitment, the personal data of the candidates is also managed according to the conditions of the service provider.
For an unsolicited application
Applications are centralized via our
online form (accessible via the website). Any application sent by email is systematically deleted. The information we ask you to fill in is limited to the strict minimum necessary for the proper management of your application (ability to contact you again, CV with professional information to assess your skills for the position, etc.). In the case of an unsolicited application, your data is only stored on the CartONG site (accessible to a limited number of employees). We try to regularly look at unsolicited applications. If your profile interests us, your CV can be shared with team members for review and we can contact you. If this does not result in a recruitment, your personal data will either be deleted from the site or - after your agreement - your CV may be stored on our infrastructure in a restricted access folder for a period of 2 years following the last contact. At the end of this period, it is then deleted.
For civic service positions
Civic service applications are centralized on the Civic Service Platform. Only employees involved in the recruitment of civic service volunteers have access to it. As long as your account is active, CartONG continues to have access to your personal information, and is not able to proactively delete it.
During recruitment (all categories)
We may ask you for additional information, ask you to take one or more tests to check your skills and record interviews for the rest of the recruitment team to view. We only record interviews with your consent. Documents, tests and videos are stored temporarily on our infrastructure. We remove them at the end of the recruitment process.
CartONG does not purchase data on potential donors. We therefore only collect data provided to us by the individuals themselves.
Online donation
CartONG uses
HelloAsso for online donation management, a tool that has been designed for non-profit associations and that allows
secure online payments (SSL encryption of bank information and 3D Secure control). You can check out its
Privacy Policy here. When you choose to make a donation to CartONG, the first step is to fill out the
dedicated form that you access via our website. Once you have made your donation (thank you very much!), your information is stored in our HelloAsso account (first name, last name, email address, donation amount, donation date, etc.) accessible only to employees and members of the Board who need to use HelloAsso to complete their mission at CartONG. If you have chosen to donate online, HelloAsso also manages your tax receipt. We keep your personal data for up to 3 years after the last donation made as permitted by law, after which time your data is permanently deleted. Tax receipts are stored for 6 years and then deleted.
Donation by cheque or bank transfer
If you have chosen to make a donation by bank transfer or by cheque using the form provided for this purpose, all your personal data is stored on our infrastructure in a file with restricted access and for a similar length of time as mentioned above. Our administrative team is then in charge of generating a tax receipt. This document is stored in paper form at our head office in Chambéry and in electronic form on CartONG infrastructure in a restricted access folder and kept for a period of 6 years in accordance with our legal obligations. For your information, our financial accounts are held with Crédit Agricole des Savoie.
From the moment the recruitment is finalized until the departure of our employees (understood here in the broadest sense: employees, interns & civic service volunteers), we collect and process a certain amount of personal data on our employees, necessary for the fulfilment of our obligations as an employer (drawing up the contract, declaration to the “Santé au Travail”, payroll management, etc.). Our employees' personal data is stored on CartONG infrastructure in restricted access folders and on a Google Contract Tracking Sheet accessible to a limited number of employees. We may need to retain employee personal data for several years in order to meet legal or contractual obligations, or to establish, exercise or defend legal rights - even after an employee has left the association. In this case, the data is transferred to an intermediate archiving system on CartONG infrastructure until it is permanently deleted. Internally, we use several work tools such as
Toggl to facilitate our accounting processes and budget tracking by partner and
Teamwork Projects to manage our projects. We also use subcontractors and third-party tools for human resources and recruitment management to which we may transmit personal data (Sylae, Elisa civic service platform, etc.). Employees are informed about the management of their personal data through an annual electronic communication.
Because of our position as a H2H organization working in support of other organizations, we may occasionally come into contact with the personal information of employees of our partners, the personal information of candidates for a position at our partners’ organizations or a roster. We ask our partners to send us information through secure channels. The information is stored on the infrastructure of our partners. We do not process any sensitive data in this context.
We store a very limited amount of personal data related to our partners, only in order to meet contractual obligations and to facilitate the partnership relationship. This information is stored on CartONG infrastructure in restricted access folders (see section III.4. for more details). We may need to retain this personal data for several years in order to comply with legal or contractual obligations (including reporting or auditing), or to establish, exercise or defend legal rights.
When you contact us via the online contact form on the CartONG website, we receive an email with the email addresses linked to this form (see section III.6.). All the pages of the website and the blog that allow the entry of personal data are under the https protocol. However, we cannot guarantee the security of your personal computer or of the Internet in general, and any online communication is at the user's own risk (including on the CartONG website). Emails sent to CartONG's generic email addresses (info[at]cartong[dot]org, partnerships[at]cartong[dot]org, etc.) are accessible by a very restricted list of our staff who have a legitimate work reason to access them and are able to respond appropriately. Emails received via the generic email addresses may occasionally be forwarded to other staff members or members of the Board so that we can provide the sender with a relevant response.
We store personal data related to our service providers only in order to meet contractual and legal obligations (payment of invoices, etc.). This information is stored on CartONG managed infrastructure in restricted folders and for some of them on a Google Sheet to which a limited number of employees have access (see section III.4. for more details). We may need to retain this personal data for several years in order to comply with legal or contractual obligations (including reporting or auditing), or to establish, exercise or defend legal rights.
This paragraph is a summarized version of section III.6 - for more details, please refer to it.
• We use
WordPress for our blog and
Drupal for our website because they are open source solutions and we are able to easily manage them internally or with the help of trusted third party service providers who have been with us since the creation of these two resources. It is useful for CartONG to know how the
website and the
blog are used by visitors. To do so, we use the
Matomo Cloud service which allows us to record statistics (more details in section III.6.) These statistics are recorded anonymously and are only accessible to CartONG. If you perform a personally identifiable action via third party services on our website or blog - for example, by subscribing to our
MailChimp newsletter (more information on this in Section II.1.) or by making a non-anonymous donation via
HelloAsso (more information on this in Section II.8.) - your browsing habits may be recorded by these third party services in a way that is attributable to you. If you wish to obtain more information on this point, we invite you to read section III.8. on the management of cookies. However, please note that CartONG does not deposit any advertising cookies and that all third-party cookies are blocked by default on the website and blog.
• The personal data that you have communicated to CartONG through the website (via online forms) are, unless you request otherwise, processed and stored by our association and therefore used by the employees, trainees and civic service volunteers concerned as well as the members of the Board - when relevant. They can be, on occasion, processed and/or accessible by CartONG's subcontractors (in the sense of
article 4.8 of the GDPR) in a strictly supervised manner. The length of time during which personal data is kept depends on the purpose for which it is to be used. We do not use your data for decision-making purposes or automated profiling.
• All the pages of the website and the blog that allow the entry of personal data are under the https protocol. However, we cannot guarantee the security of your personal computer or of the Internet, and any online communication is at the user's own risk (including on our website). Please do not hesitate to inform us of any signs that may indicate a lack of security.
III. Legal information that we are required to provide you with, according to the GDPR & the French Loi Informatique & Libertés
This section of the Privacy Notice details how we collect, use and process personal data at CartONG as Data Controller in addition to your rights as defined by the GDPR and the French Loi Informatique et Libertés.
We collect and manage several types of personal data depending on your relationship with CartONG. We may collect and manage personal data related to the following categories of people:
• Subscribers to our newsletters: for more details, please refer to section II.3.
• Members: for more details, please refer to section II.3.
• Beneficiaries and/or participants in our activities: for more details, please refer to section II.4.
• Volunteers: for more details, please refer to section II.6.
• Applicants: for more details, please refer to section II.7.
• Donors: for more details, please refer to section II.8.
• Employees (broadly understood): for more details, please refer to section II.9.
• Partners: for more details, please refer to section II.11.
• Persons having contacted CartONG: for more details, please refer to section II.12..
• Subcontractors (individual consultants, firms, etc.): for more details, refer to section II.13.
• Website and blog users: for more details, please refer to section II.14.
For your information, we also manage data from our partners as a subcontractor. For more information on this subject, please refer to:
• Section II.5. for the beneficiaries (including communities) of our partners' activities
• Section II.9. for applicants to our partner organizations (or roster)
• Section II.10 for our partners' employees
The categories of personal data that we may manage, for the purposes described below (III.2.), include:
• Identity information (surname, first name, biographical information, nationality, identity documents, etc.).
• Contact information (email address, postal address, phone number, etc.)
• Information related to professional activity and access to the labor market in France
• Economic and financial information (including history of donations, memberships, etc.)
• Web connection data (technical data relating to equipment and browsers, etc.)
• Internet data (cookies, navigation data, etc.)
• Communication preference (for newsletters)
We manage sensitive data as an employer to fulfill our legal obligations. We may - very occasionally - manage sensitive personal data in other cases, mainly when the person in question has chosen to provide us with this information (for example: information related to accessibility constraints in order to organize a job interview on our premises, communications where the person has included sensitive data on his or her own initiative, etc.). We do not use this data for purposes other than those for which it was provided. We do not collect sensitive data about our members, volunteers or donors, as well as users of our website and blog. As a general rule, we discourage people who come into contact with CartONG from emailing us sensitive data unless absolutely necessary.
We collect and manage this personal data for the following purposes:
• To administer our website and blog
• To answer questions, requests for information, etc., and to manage requests for access to personal data
• To communicate with our supporters via the newslettersn
• To receive and manage donations
• To manage memberships and resulting contributions
• For human resources and recruitment management
• For the management of volunteers and volunteer activities, and of associative events
• For the management of activities, workshops and events organized by CartONG
• In order to enable the completion of the services we offer
• To manage our relationships with our partners
• To comply with our legal and/or contractual obligations (including in the case of audits or controls)
• To establish, exercise or defend legal proceedings
CartONG processes these personal data on a legal basis. The legal basis on which we will rely will depend on the circumstances in which we collect and use your personal data. The legal basis for our processing operations is always one of the following:
• On the basis of your unambiguous consent to use your data in a certain way (e.g. to communicate with you via our newsletter).
• Necessity to take the necessary steps prior to the conclusion of a contract or the execution of a contract (e.g. for recruitment, human resources management and the management of persons and organizations performing services on behalf of CartONG).
• Necessity to comply with legal requirements incumbent upon us (e.g. to comply with regulatory obligations and employment law, applicable as an employer).
• Necessity for our legitimate interests (e.g. to manage donations, to manage volunteers, for fraud prevention, etc.). We will only rely on this legal basis once we have identified the purpose (i.e the legitimate interest) and assessed that the processing is necessary for that purpose.
We employ a variety of organizational and technical measures to ensure the security of your personal data and to prevent unauthorized access, use or disclosure. Electronic data and databases are stored on secure computer systems and we monitor who has access to the information and regularly review the list of persons requiring access (see III. 4 for details). In addition, our staff receive training on data protection and we are continually working to improve the data protection procedures that all employees (including interns, regular consultants and civic service volunteers) are required to follow when processing your personal data. In the event of a breach of personal data, we have put in place a protocol to ensure compliance with the provisions in force in the GDPR.
At present, CartONG has not systematized encryption measures and adapts them according to the degree of sensitivity of the data and the risk of exposure. Our approach is primarily based on the principle of minimization (collecting as little personal data as possible). We use the open source tool
Bitwarden to manage usernames and passwords. On the security side, we use
AVG Internet Security to fight against viruses and malwares, and to secure our email exchanges and online payments. Finally, to transfer personal data securely, we use the following tools depending on the context:
Framadrop,
Firefox Send,
Tresorit send and
KPN Secure file.
CartONG's head office is located in France. All paper documents are stored in France and can transit within the European Union on an ad hoc basis.
With regard to the electronic storage of personal data, we have several tools at our disposal. First, we use
Nextcloud to store documents and data that may contain confidential, personal or sensitive information hosted on servers that we control. Indeed, we use
OVH,
Scaleway and
Online by scaleway servers, which allows us to have our data hosted within the European Union. We use three third-party services to distribute and differentiate our production, backup and testing infrastructure. When we need to collect information from others, we use
LimeSurvey (installed on our servers) or
Framaforms. We also frequently use
Framadate to organize meetings in a simple way. The general terms and conditions of Framaforms and Framadate are available
here.
At the same time, we use personal
Google Drive accounts for non-sensitive personal information, while trying to limit its use to the bare minimum. As we are an organization working with many people remotely (internally or with our partners), real-time collaboration on documents is a key part of the way we work, and we are still working to implement an open source solution that offers the same level of functionality.
Note: we use Google's email services but plan to stop doing so and use only
1&1 Ionos' email services (see below), and we have scheduled a switch to Google Drive Pro in the near future to enhance the security of the data stored on Google Drive.
We ensure that personal data is kept only as long as necessary, in accordance with the purposes of use detailed above as well as applicable laws. We may need to retain your personal data for a number of years in order to meet legal or contractual obligations, or to establish, exercise or defend legal rights. When your personal data is no longer required for these purposes, it will be deleted.
We maintain direct control over as many processes as possible and never sell or give your personal data to third parties. If necessary, your personal data may be transmitted internally to the Board (this is the case, for example, for membership and volunteer information), and externally to our authorized third party service providers (individual consultants, external firms) or to third party tools and services used for the purposes mentioned in section III.2. We carefully select and review authorized third parties and verify their privacy and security policies. These authorized third parties may be engaged in, among other things, the processing of donations, the processing of pay slips, the sending of newsletters or the services and projects carried out as part of our mission (see section II for more details). Some of CartONG staff as well as staff working for such third parties may also access and process your personal data within the strict scope of their professional responsibilities or contractual obligations. We may also be required to disclose or process your personal data as part of a regulatory audit to which we may be subject from time to time.
Some of our third party service providers and the third party tools and services we use may transfer data outside of the European Union. We then take appropriate steps to ensure that the data remains in jurisdictions with adequate protection of personal data. Where this is not possible, we select service providers and choose trusted third party tools and services with adequate safeguards to protect the data transferred, for example through standard contractual clauses or cross-border agreements. For more information on transfer guarantees linked to a particular transaction, please contact us.
For the purposes of submitting a funding application, responding to a request for proposal, writing a funding report or external communication, we may share aggregated information (such as the number of people who attended an event, the number of visitors to our website or blog in a given year, or the number of members of CartONG), which is no longer considered personal information.
Daily communication tools
We use
1&1 Ionos for email communications. For everyday communications, our teams make extensive use of
Skype messaging (for non-personal data) and we recommend the use of
Signal for sending personal and/or sensitive information. When it is not possible to use Signal, we sometimes use
WhatsApp or
Skype with the necessary safeguards (encryption, deletion of data after sending, etc.). Finally, we also exchange messages via
Messenger (linked to our Facebook account) and Twitter messaging, when supporters choose to contact us via these tools. We use different video call/conference software (
Skype,
Cisco Webex, etc.).
Website & blog
We use
WordPress for our blog and
Drupal for our website because they are open source solutions and we are able to easily manage them internally or with the help of trusted third party service providers who have been with us since the creation of these two resources. The website maps are managed by
CARTO (previously CartoDB) and
uMap. It is useful for CartONG to know how the
website and the
blog are used by visitors. To do so, we use
Matomo Cloud which allows us to collect statistics:
• To find out how many visitors per day visit the website and the blog and which contents are most read
• To know the sources of traffic
• To find out which items on our website are downloaded (e.g. PDF, detailed form, reports, short articles)
• To identify the elements that cannot be found, i.e. the 404s, so that they can be corrected.
• To identify the types of operating systems and browsers used so that we can design our website accordingly
• To identify the time of day when our website is most used in case we want to do synchronizations and repairs (which result in our website being temporarily down).
These statistics are recorded anonymously and are only accessible to CartONG for less than 13 months. However, we keep the aggregated data indefinitely and use it both internally (for example, we will report the number of annual visitors to our site at the General Assembly in the presence of Board members and all other CartONG members) and externally (for example, in the context of reporting to one of our donors).
If you perform a personally identifiable action via third-party services on our website or blog - for example, by subscribing to our
MailChimp newsletter (more information on this in Section II.1.) or by making a non-anonymous donation via
HelloAsso (more information on this in Section II.8.) - your browsing habits may instead be recorded by these same services in a way that is attributable to you. If you wish to obtain more information on this point, we invite you to read the following section (III.8.) on the management of cookies.
On the website, you can also freely communicate personal data to CartONG, through online forms in order to interact with the association, to register for an event, to receive information about the association or its publications, to apply for a job, to exercise your rights under the GDPR and the French Loi Informatique et Libertés, etc. On the blog, it is also possible for you to communicate to CartONG your personal data by using the "comment" function. These data collections through webforms are limited to the strict minimum. For example, each form clearly indicates the data that is strictly necessary to achieve the purpose (such as your email address and your consent if you subscribe to CartONG newsletters). If you have to communicate to CartONG personal data of third parties, make sure to inform them beforehand and ask for their consent.
The personal data that you have communicated to CartONG through the website and the blog are, unless you request otherwise, processed and stored by our association and thus used by the employees, interns and civic service volunteers concerned as well as the members of the Board - whenever relevant. They can be on occasion processed and/or accessible by CartONG's subcontractors (in the sense of
article 4.8 of the GDPR) in a strictly supervised manner. If, exceptionally, a communication to third parties is planned, it will be carried out on the basis of your free, informed and explicit consent. The length of time personal data is kept depends on the purpose for which it is to be used. Under no circumstances do we use your data for decision making or automated profiling.
All the pages of the website and the blog that allow the entry of personal data are under the https protocol. CartONG is committed to protecting the personal data processed through its website and its blog to the highest level. However, we cannot guarantee the security of your personal computer or of the Internet, and any online communication is at the user's own risk (including on our site). Please do not hesitate to inform us of any signs that may indicate a lack of security.
Other types of communication
For other third party tools and services used for communication purposes, please see Section II. of our Privacy Notice.
List of cookies we use on the website and blog and their purpose
• Under no circumstances can CartONG identify you from a cookie.
• We use cookies that are technically essential to the proper functioning of the website and blog, i.e. linked to the CMS, template, authentication or hosting. Their use does not require your consent since they are purely functional, and are therefore enabled by default. You may object to them and remove them using your browser settings, however your user experience may be negatively affected as a result.
| Name of the cookie |
Purpose |
Retention period |
Used on |
| has_js |
Determines if your browser accepts javascript or not.
|
Session |
cartong.org |
| rc::c |
Helps distinguish between humans and robots. Cookies from Google allow us to offer you reCAPTCHA protection which protects the website against spam and other types of automated abuse. This cookie stores an identifier that helps identify the recurring user's device. This identifier is used for targeted ads. |
Session |
cartong.org |
|
PHPSESSID
|
Keeps the configuration of user settings through page requests. |
Session |
blog.cartong.org |
• We use cookies related to the operation and storage of visitor preferences. Their use does not require your consent since they are purely functional, and are therefore enabled by default. You may object to them and remove them using your browser settings, however your user experience may be negatively affected as a result.
| Name of the cookie |
Purpose |
Retention period |
Used on |
| Tarteaucitron |
Keeps track of consent settings in relation to cookies. |
12 months |
cartong.org & blog.cartong.org |
• We do not use cookies for audience tracking and analysis. To get statistics on the website and the blog, we opted for the
Matomo Analytics (formerly Piwik) Cloud. The software is configured not to deposit audience measurement cookies on your computer, tablet or phone and, similarly, not to save complete IP addresses in order to preserve the anonymity of online users. Since we need a limited number of statistics for our website and blog (see section II.6. for more details), we realized that we could obtain these statistics without enabling cookies on Matomo Analytics: we therefore chose to disable them in line with our vision of responsible data management.
• We do not use advertising cookies.
• The CartONG website and blog rely on several services offered by third party sites These include Youtube (video viewing), Dailymotion (video viewing) and Prezi. These cookies may be indispensable or functional to the service they offer or may be necessary for audience measurement. These cookies are only deposited if you give your consent. When you first visit to a page with one or several cookies, a banner informs you of the presence of these cookies and invites you to make a choice as to whether you consent to them or not (so as to use the service in full). The cookies are only stored on your computer, phone or tablet if you give your consent. You can, at any time, get more information about them and configure your settings - either to accept or refuse them - by going to the "
Cookies" menu located in the footer of the website (accessible at the bottom of each page). You will be able to indicate your preference either globally for the site, or service by service. In addition, no plug-ins are installed for our social network accounts - Facebook, Twitter & LinkedIn - on the website and blog. They therefore do not deposit cookies on your computer, tablet or phone.
• Third party cookies are deposited by Mailchimp (used for the management of CartONG's newsletters) when you click to access the registration page in order to save your communication preferences. As the page in question is not hosted on our website, it is impossible for us to block the cookies in question from our "
Cookies" menu (see below). If you are concerned about this, we encourage you to delete these cookies after you have subscribed to our newsletter(s) (see below to learn how to do so).
How to manage or refuse these cookies?
• All cookies on the website and blog - except for the so-called functional cookies that are enabled by default (see above) - can only be placed on your computer, tablet or phone if you choose to allow them. You can therefore choose to keep them blocked or even delete those already installed (if you had previously authorized some of them). Please be aware, however, that this may make your visit to our website or blog less user-friendly and pleasant.
• To accept or block cookie settings, go to the "
Cookies" menu at the bottom of the page..
• As a general rule, you can configure your browser so that cookies are stored on your computer or, conversely, so that they are rejected, either systematically or according to their originator. In addition, you can configure your browser so that you are offered the option of accepting or rejecting cookies from time to time - before a cookie is likely to be stored. The configuration of cookies depends on your browser and is described in the help menu of your browser, which will tell you how to change your cookie preferences. You will find below links to user manuals for the main browsers:
Firefox -
Chrome -
Explorer -
Safari -
Opera -
iOS. If you want to erase all cookies left by websites you have visited, you can find programs online that allow you to delete cookies or manage their deletion via your browser's instructions (see above). For more information on cookies, you can go to on the
CNIL website.
We want to make sure that you keep control of your personal data. Part of this process is to make sure you understand your legal rights, which are as follows:
1. the right to be informed of the personal data we store about you (via this Privacy Notice);
2. the the right to access (i.e., obtain a copy of) the personal information we store about you;
3. the the right to have any inaccurate information we have about you corrected;
4. the the right to have your data deleted;
5. the the right to limit the processing of your data;
6. the the right to object to the use of your data;
7. the the right to personal data or "portability request" to retrieve the personal data we hold about you in the context of processing operations based on consent and on the basis of the performance of a contract.
Please note, however, that the rights of deletion, limitation of processing and objection are not absolute. For example, CartONG may be required to retain certain personal information for legal obligations. Likewise, any limitation in processing could affect the services provided by CartONG (receipt of information, access to events, etc.). We also would like to inform you that you can define directives concerning the fate of your data after your death, in accordance with the French Loi Informatique et Libertés.
Contact CartONG
The Data Protection Officer (or DPO) is your main contact person. In accordance with the French and European regulations in force, you can exercise your rights of access, rectification, deletion, limitation of processing, right of opposition and portability by contacting the DPO in writing at: CartONG – A l’attention du DPO - 23 boulevard du musée - 73000 Chambéry (France). If you wish to get in touch by email, please write to: dpo[at]cartong[dot]org.
Please do not attach or enclose a copy of your ID to your email or postal mail. We will tell you how to share this information securely at a later time, if necessary.
Contact the CNIL
If you are dissatisfied with the way your personal data or your requests under the GDPR or the French Loi Informatique et Libertés are processed, you can file a complaint with the CNIL online, or by sending them a letter to the following address: CNIL - 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07 (France).
IV. Updading the Privacy Notice
Our Privacy Notice will be updated to ensure that it remains current and adequately reflects how and why we use your personal data. We therefore invite you to consult it regularly. In the event that the Privacy Notice is changed, the date and nature of the change will be clearly indicated on this page. In the event that the change would have a significant impact on the processing of your personal data, we will contact you to inform you of the changes and, where appropriate, obtain your consent.
Updates
- Update made on 31/01/2020 to add the tables detailing the cookies that we use on the website and blog.
- Publication on 13/12/2019.
English 
Français