Privacy Notice

1. Introduction

The International Data Reserve Association ("Association", "we", "us", or "our") is a not-for-profit association established under Swiss law, with a registered office in Baar, Zug, Switzerland.

This Privacy Notice applies to all websites operated by the Association, including:

theinternationaldatareserve.org - the Association's main website ("Main Website");

signtheact.datareserve.org - the signature campaign website for the proposed Data Savings Act ("Campaign Website").

These websites are connected: the Main Website directs visitors to the Campaign Website as part of the Association's public advocacy work. This single Notice governs personal data collected across both properties.

We are committed to handling your data responsibly and transparently, in compliance with the Swiss Federal Act on Data Protection (nFADP) and, where applicable, the EU General Data Protection Regulation (GDPR) and other applicable privacy laws.

2. Information we collect

We collect information in two ways: through forms you actively complete, and automatically through analytics technology when you visit either website.

Our websites are not directed at children under the age of 18. We do not knowingly collect personal data from anyone under 18. If you are under 18, please do not submit any information through our websites. If we become aware that we have inadvertently collected data from a person under 18, we will delete it promptly.

2.1 Newsletter sign-up in the Main Website

If you subscribe to the Association's newsletter, we collect your email address.

2.2 Signature form ("Add My Name") in the Campaign Website

If you sign the Data Savings Act declaration, we collect (i) your first and last name; (ii) your Zip code; (iii) your email address.

By signing, you may also opt in to receive campaign updates. You may unsubscribe at any time.

2.3 Co-Sponsor request form in the Campaign Website

If your organization submits a co-sponsorship request, we collect: (i) organization name and type; (ii) contact person's name and role/title; (iii) email address; (iv) website URL (optional).

2.4 Analytics data in both websites

Both websites use PostHog, a third-party analytics service, to collect information about how visitors interact with the sites. PostHog may collect: (i) pages visited and navigation patterns; (ii) approximate geolocation derived from IP address; (iii) device type, browser, and operating system; (iv) referring URLs and session duration.

This data is collected through cookies placed on your device (see Section 5 for full details). PostHog's privacy policy is available at https://posthog.com/privacy.

2.5 Support and direct communications

If you contact us directly by email or through any contact form, we will collect your email address and the content of your message in order to respond to you.

3. Purpose and legal basis for processing

For each processing activity below, we identify the primary legal basis and, where applicable, an alternative basis that applies depending on the specific circumstances. Identifying more than one basis does not mean we rely on all of them simultaneously; it reflects the fact that the same activity may occur in different contexts.

3.1 Newsletter

Your email address is used to send you the communications you requested (Association updates, news, and publications).

Primary legal basis: consent, given at the time of subscription. You may withdraw your consent at any time by clicking the unsubscribe link in any email or by contacting us directly. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Alternative basis: legitimate interest in maintaining communication with individuals who have expressed interest in the Association’s mission, to the extent permitted by applicable law.

3.2 Campaign signature

Your name, Zip code, and email address are used to record your public support for the Data Savings Act.

Primary legal basis: consent, given at the time of signing.

By signing the declaration, you acknowledge that your first name, last name, and Zip code may be included in a public record submitted to Washington, D.C., as part of the formal campaign. Your email address will not be made public. If you do not wish your name to appear on a public record, please do not submit the signature form.

For the specific act of submitting the compiled signature record to public authorities, an additional legal basis applies: processing necessary for the performance of a task carried out in the public interest, given the civic and policy nature of the campaign.

If you opted in to campaign communications at the time of signing, your email address will also be used to send you campaign updates. Legal basis: consent. You may unsubscribe at any time.

3.3 Co-sponsor request

Organization and contact details are used to evaluate and respond to co-sponsorship requests.

Primary legal basis: legitimate interest in identifying and communicating with potential institutional partners.

Alternative basis: performance of a contract or pre-contractual steps taken at the request of the organization, to the extent that the co-sponsorship involves a formal agreement.

3.4 Analytics

Analytics data is used to understand how visitors use our websites and to improve their performance.

Primary legal basis: legitimate interest in operating effective and well-functioning websites.

Where required by applicable law (including for visitors in the EU/EEA), the legal basis is consent, which will be sought before any analytics cookies are placed.

3.5 Support

Your email address and message content are used to respond to your inquiry and provide any assistance requested.

Primary legal basis: legitimate interest in handling communications addressed to us.

Alternative basis: performance of a contract, where the inquiry relates to an existing relationship (e.g., a co-sponsorship arrangement or a formal campaign participation).

3.6 Aggregated and anonymized data

We may use any data in anonymized or aggregated form, from which no individual can be identified, for any lawful purpose, including publishing reports or statistics about the campaign and sharing such reports with co-sponsors, partners, and the public. Such use does not constitute processing of personal data.

4. Data Security

We take reasonable technical and organizational measures to protect your personal data against unauthorized access, loss, alteration, or disclosure. These measures are proportional to the nature of the data we hold, which is limited to email addresses, names, Zip codes, and analytics data.

No method of transmission over the internet is completely secure. While we strive to protect your data, we cannot guarantee absolute security. In the event of a personal data breach that poses a risk to your rights, we will notify the relevant authorities and, where required, affected individuals, in accordance with applicable law.

5. Cookies

A cookie is a small file saved on your device when you visit a website. It allows the site to recognize your browser the next time you visit, or to track how you navigate through the pages.

Both of our websites use an analytics tool called PostHog, which places cookies on your device to help us understand how visitors use our sites - for example, which pages are visited most, how long people stay, and what type of device they are using. We use this information only to improve our websites.

PostHog places the following types of cookies:

1. Visitor identification cookie (duration: 1 year): Saved on your device for up to one year. It assigns an anonymous identifier to your browser so that, if you return to the site, PostHog can recognize you as a returning visitor rather than a new one. It does not contain your name or any directly identifying information.
2. Session cookies (duration: until you close your browser or persistent in localStorage): These are temporary cookies that exist only while your browser is open. They help PostHog understand how you move through the site within a single visit - for example, whether you opened the site in multiple tabs. They may be deleted automatically when you close your browser or, depending on how our websites are configured, saved in your browser's localStorage, which allows it to persist between sessions even if you clear your cookies. You can remove localStorage data through your browser settings.

These cookies are present on both websites. One of the cookies is set on the shared domain ".datareserve.org", which means it is recognized by both theinternationaldatareserve.org and signtheact.datareserve.org.

No cookie contains your name, email address, or any information you entered into a form.

You can refuse or delete cookies at any time through your browser settings. This will not prevent you from using either website or submitting any form.

If you are based in the European Union or another region where your consent is required before analytics cookies are placed, we will ask for your permission before setting any cookie.

6. Data Sharing and Third Parties

We do not sell or rent your personal data.

We may share data only in the following limited circumstances:

1. PostHog: visitor behavior data from both websites is processed by PostHog under their own privacy policy (posthog.com/privacy);
2. Service providers: companies that assist us in operating our websites or delivering communications, engaged under appropriate data processing agreements;
3. Campaign record: names and Zip codes of signatories may be submitted to public authorities or institutions as part of the formal campaign record, as described in Section 3.2;
4. Co-sponsors and institutional partners: we may share aggregated, non-identifying reports or statistics with co-sponsors and partners in connection with the campaign;
5. Legal obligations: where disclosure is required by applicable law or valid legal process.

Our websites may contain links to third-party websites. This Notice does not apply to those sites. We encourage you to review the privacy policies of any external sites you visit.

7. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Notice:

1. Newsletter email: retained until you unsubscribe, after which it will be removed promptly;
2. Campaign signature data: retained for the duration of the campaign and any subsequent formal submission;
3. Co-sponsor inquiry data: retained until the request is resolved and for a reasonable period thereafter for correspondence records;
4. Support communications: retained for as long as necessary to resolve your inquiry and for a reasonable period thereafter;
5. Analytics data: retained in accordance with PostHog's data retention settings, configured to the minimum necessary period.

8. Your Rights

Depending on your location, you may have the following rights with respect to your personal data:

1. Right of access: request a copy of data we hold about you;
2. Right to rectification: request correction of inaccurate data;
3. Right to erasure: request deletion of your data, subject to any overriding legal obligations;
4. Right to object: object to processing based on legitimate interests or carried out in the public interest;
5. Right to restrict processing: request that we limit how we use your data in certain circumstances;
6. Right to withdraw consent: unsubscribe or opt out at any time;
7. Right to lodge a complaint: with the data protection authority in your country of residence.

To exercise any of these rights, please contact us:

The International Data Reserve Association
Baar, Zug, Switzerland
theinternationaldatareserve.org
Support contact: info@internationaldatareserve.org
Privacy contact: privacy@internationaldatareserve.org

9. International Data Transfers

The Association is based in Switzerland, which is recognized by the European Commission as providing an adequate level of data protection.

PostHog may process data on servers located outside Switzerland or the EEA. Where this occurs, PostHog relies on appropriate transfer mechanisms (such as Standard Contractual Clauses) in accordance with its own policies.

If you are located in the United States, please be aware that your data may be transferred to and processed in Switzerland or other jurisdictions with different data protection rules than those applicable in your state. By using our websites or submitting any form, you acknowledge this transfer.

10. Changes to this Notice

We may update this Privacy Notice from time to time. Changes will be posted on both websites with a revised effective date. For significant changes, we will notify subscribers by email where practicable.

Your continued use of our websites after a revised Notice has been posted constitutes your acknowledgment of the changes. We encourage you to review this page periodically.