Privacy Policy

With this Privacy Policy, we provide information about the processing of personal data in connection with our activities and operations, including our website under the domain name soazara.org. In particular, we provide information about what personal data we process, how, for what purpose, and where. We also provide information about the rights of individuals whose data we process.

For individual or additional activities and operations, we may publish further privacy policies or other information on data protection.

We are subject to Swiss law and, where applicable, foreign law, in particular that of the European Union (EU), including the European General Data Protection Regulation (GDPR).

By decision of July 26, 2000, the European Commission recognised that Swiss data protection law ensures an adequate level of data protection. In its report of January 15, 2024, the European Commission confirmed this adequacy decision.

Table of Contents

1. Contact Details

The controller for data protection purposes is:

Wenner, Sergio
Association Soa Zara
BP 17 Ranohira
Ihosy 313, Madagascar

info@soazara.org

In individual cases, third parties may be responsible for the processing of personal data, or joint responsibility may exist with third parties. Upon request, we will gladly provide data subjects with information about the respective responsibility.

2. Terms and Legal Bases

2.1 Terms

Data subject: Natural person whose personal data we process.

Personal data: Any information relating to an identified or identifiable natural person.

Sensitive personal data: Data on trade union, political, religious or philosophical views and activities, data on health, intimate sphere or affiliation to an ethnicity or race, genetic data, biometric data uniquely identifying a natural person, data on criminal and administrative sanctions or proceedings, and data on social assistance measures.

Processing: Any handling of personal data, regardless of the means and procedures used, for example querying, comparing, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, deleting, revealing, arranging, organizing, saving, altering, disseminating, linking, destroying, and using personal data.

European Economic Area (EEA): Member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway.

2.2 Legal Bases

We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (Data Protection Act, FADP) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).

We process personal data – if and insofar as the European General Data Protection Regulation (GDPR) applies – on the basis of at least one of the following legal bases:

  • Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the performance of a contract with the data subject and for the implementation of pre-contractual measures.
  • Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data in order to safeguard legitimate interests – including the legitimate interests of third parties – provided that the fundamental freedoms and rights as well as the interests of the data subject do not prevail. Such interests include in particular the sustainable, user-friendly, secure and reliable conduct of our activities and operations, ensuring information security, protection against misuse, enforcement of our own legal claims and compliance with Swiss law.
  • Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to comply with a legal obligation to which we are subject under applicable law of member states in the European Economic Area (EEA).
  • Art. 6 para. 1 lit. e GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
  • Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
  • Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data in order to protect the vital interests of the data subject or another natural person.
  • Art. 9 para. 2 et seq. GDPR for the processing of special categories of personal data, in particular with the consent of the data subjects.

The European General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data and the processing of sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).

3. Nature, Scope and Purpose of the Processing of Personal Data

We process the personal data that is necessary in order to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner. The personal data processed may in particular fall into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data and payment data. Personal data may also constitute sensitive personal data.

We also process personal data that we receive from third parties, obtain from publicly accessible sources, or collect in the course of carrying out our activities and operations, insofar as such processing is permitted.

We process personal data, where necessary, with the consent of the data subjects. In many cases, we may process personal data without consent, for example in order to fulfil legal obligations or safeguard overriding interests. We may also ask data subjects for their consent even if such consent is not required.

We process personal data for the duration required for the respective purpose. We anonymise or delete personal data in particular depending on statutory retention and limitation periods.

4. Disclosure of Personal Data

We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties may, for example, be specialised providers whose services we make use of. Such third parties may in turn disclose personal data to other third parties.

As part of our activities and operations, we may disclose personal data in particular to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, accounting and fiduciary service providers, debt collection companies, advocacy groups, IT service providers, cooperation partners, credit and commercial information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister and subsidiary companies, organisations and associations, social institutions, telecommunications companies, insurers and payment service providers.

5. Communication

We process personal data in order to communicate with individuals as well as with authorities, organisations and companies. In particular, we process data that a data subject transmits to us when making contact, for example by post or email. We may store such data in an address book or by using comparable tools.

Third parties who transmit data to us about other persons are legally obliged to ensure the data protection of those data subjects independently. In particular, they must ensure that they are permitted to transmit such data and that the transmitted data is accurate.

We use selected services from suitable providers in order to enable and improve communication with individuals and other communication partners. With such services, we may also manage and otherwise process the data of data subjects beyond direct communication, for example in connection with orders, services, projects and resource planning.

6. Data Security

We take appropriate technical and organisational measures to ensure data security appropriate to the respective risk. Through our measures, we ensure in particular the confidentiality, availability, traceability and integrity of the personal data processed, although we cannot guarantee absolute data security.

Access to our website and our other digital presence is secured by transport encryption (SSL / TLS, in particular via the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn against visiting a website without transport encryption.

Our digital communication is subject – like all digital communication in principle – to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We have no direct influence on the corresponding processing of personal data by intelligence services, police authorities and other security authorities. We also cannot rule out that a data subject may be specifically monitored.

7. Personal Data Abroad

We process personal data in principle in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular in order to process it there or have it processed there.

We may export personal data to all countries on Earth and elsewhere in the universe, provided that the law there ensures adequate data protection in accordance with a decision of the Swiss Federal Council and – if and insofar as the GDPR applies – also in accordance with a decision of the European Commission.

We may transfer personal data to countries whose laws do not ensure adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or other suitable safeguards. Exceptionally, we may export personal data to countries without adequate or suitable data protection if the specific legal requirements under data protection law are met, for example the explicit consent of the data subjects or a direct connection with the conclusion or performance of a contract. Upon request, we will gladly provide data subjects with information about any safeguards or supply a copy of any safeguards.

8. Rights of Data Subjects

8.1 Data Protection Claims

We grant data subjects all claims in accordance with applicable law. In particular, data subjects have the following rights:

  • Access: Data subjects may request information as to whether we process personal data concerning them and, if so, what personal data is involved. Data subjects also receive the information necessary to assert their data protection claims and to ensure transparency. This includes the personal data processed as such, but also, among other things, information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data.
  • Rectification and restriction: Data subjects may have inaccurate personal data corrected, incomplete data completed, and the processing of their data restricted.
  • Opportunity to state one’s own point of view and human review: In the case of decisions based exclusively on automated processing of personal data that produce legal effects concerning them or significantly affect them (automated individual decisions), data subjects may state their own point of view and request review by a human being.
  • Erasure and objection: Data subjects may have personal data erased (“right to be forgotten”) and object to the processing of their data with effect for the future.
  • Data release and data transfer: Data subjects may request the release of personal data or the transfer of their data to another controller.

We may postpone, restrict or refuse the exercise of data subjects’ rights within the legally permissible framework. We may inform data subjects of any requirements to be met for the exercise of their data protection claims. For example, we may refuse access in whole or in part with reference to confidentiality obligations, overriding interests, or the protection of other persons. We may also, for example, refuse the deletion of personal data in whole or in part, in particular with reference to statutory retention obligations.

We may exceptionally provide for costs for the exercise of rights. We will inform data subjects in advance of any such costs.

We are obliged to identify data subjects who request access or assert other rights by appropriate measures. Data subjects are obliged to cooperate.

8.2 Legal Remedies

Data subjects have the right to enforce their data protection claims through legal proceedings or to file a report or complaint with a data protection supervisory authority.

The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

European data protection supervisory authorities are organised as members of the European Data Protection Board (EDPB). In some member states of the European Economic Area (EEA), data protection supervisory authorities are structured federally, particularly in Germany.

9. Use of the Website

9.1 Cookies

We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data stored in the browser. Such stored data does not have to be limited to traditional text-based cookies.

Cookies may be stored temporarily in the browser as “session cookies” or for a defined period as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a defined storage duration. Cookies make it possible in particular to recognise a browser on the next visit to our website and thereby, for example, measure the reach of our website. Permanent cookies may also, for example, be used for online marketing.

Cookies can be fully or partially disabled, restricted or deleted at any time in the browser settings. Browser settings often also allow automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively request – at least where and insofar as required by applicable law – explicit consent to the use of cookies.

For cookies used for performance and reach measurement or for advertising, a general objection (“opt-out”) is possible for numerous services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance), or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

9.2 Logging

For each access to our website and our other digital presence, we may log at least the following information, provided that such information is automatically determined or transmitted to our digital infrastructure during such access: date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual subpage of our website accessed including amount of data transferred, the last webpage accessed in the same browser window (referrer).

We log such information, which may also constitute personal data, in log files. This information is necessary in order to provide our digital presence in a sustainable, user-friendly and reliable manner. The information is also necessary in order to ensure data security – including by third parties or with the help of third parties.

9.3 Tracking Pixels

We may integrate tracking pixels into our digital presence. Tracking pixels are also referred to as web beacons. Tracking pixels – including those from third parties whose services we use – are usually small, invisible images or scripts formulated in JavaScript that are automatically retrieved when our digital presence is accessed. With tracking pixels, at least the same information as in logging in log files can be recorded.

10. Social Media

We are present on social media platforms and other online platforms in order to communicate with interested persons and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).

The general terms and conditions (GTC), terms of use, privacy policies and other provisions of the individual operators of such platforms also apply. These provisions provide information in particular about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right of access.

For our social media presence on Facebook, including the so-called Page Insights, we are – if and insofar as the GDPR applies – jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights in order to provide our social media presence on Facebook effectively and in a user-friendly manner.

Further information about the nature, scope and purpose of data processing, information on the rights of data subjects, and the contact details of Facebook as well as Facebook’s data protection officer can be found in the Facebook Privacy Policy. We have concluded the so-called “Controller Addendum” with Facebook and have in particular agreed that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the relevant information can be found on the page “Information on Page Insights” including “Information on Page Insights Data”.

11. Third-Party Services

We use services provided by specialised third parties in order to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner. Among other things, such services enable us to embed functions and content into our website. In the case of such embedding, the services used collect, for technically mandatory reasons at least temporarily, the IP addresses of users.

For necessary security-related, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymised or pseudonymised form. This includes, for example, performance or usage data in order to be able to provide the respective service.

We use in particular:

11.1 Digital Infrastructure

We use services from specialised third parties in order to make use of the digital infrastructure required in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.

We use in particular:

11.2 Audio and Video Conferencing

We use specialised services for audio and video conferencing in order to communicate online. For example, this enables us to hold virtual meetings or conduct online classes and webinars. Participation in audio and video conferences is additionally subject to the legal texts of the individual services, such as privacy policies and terms of use.

Depending on your personal circumstances, we recommend muting the microphone by default when participating in audio or video conferences and blurring the background or using a virtual background.

We use in particular:

11.3 Online Collaboration

We use third-party services in order to enable online collaboration. In addition to this Privacy Policy, any directly visible terms of the services used may also apply, such as terms of use or privacy policies.

11.4 Map Material

We use third-party services in order to embed maps into our website.

12. Website Extensions

We use extensions for our website in order to make use of additional functions. We may use selected services from suitable providers or use such extensions on our own digital infrastructure.

We use in particular:

13. Performance and Reach Measurement

We try to measure the success and reach of our activities and operations. In this context, we may also measure the effect of references by third parties or examine how different parts or versions of our digital presence are used (“A/B testing” method). Based on the results of performance and reach measurement, we may in particular fix errors, strengthen popular content, or make improvements.

For performance and reach measurement, the IP addresses of individual users are recorded in most cases. In this case, IP addresses are generally shortened (“IP masking”) in order to follow the principle of data minimisation through the corresponding pseudonymisation.

Cookies may be used in performance and reach measurement, and user profiles may be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our digital presence, information on the size of the screen or browser window, and the – at least approximate – location. In principle, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual third-party services for which users are logged in may possibly assign the use of our online offering to the user account or user profile of the respective service.

14. Final Notes on this Privacy Policy

We may update this Privacy Policy at any time. We will provide information about updates in an appropriate form, in particular by publishing the current Privacy Policy on our website.