Privacy Policy

About this policy

This policy explains what types of personal information are gathered by DiploFoundation, how we use and share your personal data, and your rights in relation to the personal data we hold.

It includes information on which data is gathered when you visit the DiploFoundation website or any website operated by DiploFoundation (including the Geneva Internet Platform website, https://www.giplatform.org/, the GIP Digital Watch observatory, https://dig.watch, https://righton.dig.watch/, the International Forum for Diplomatic Training website, https://forum.diplomacy.edu, diplo.us and https://humainism.ai/). This policy also applies to other websites which DiploFoundation may create or operate from time to time, under the subdomain https://name.diplomacy.edu, and any mobile applications (apps).

This policy also explains what types of personal information are gathered when you register for or attend online or blended learning courses, capacity development programmes, and other learning events, either offered exclusively by DiploFoundation or in collaboration with other partners when the administrative aspects are handled by DiploFoundation.

Information about us

This Privacy Policy applies to DiploFoundation’s (‘Diplo’ or ‘we’ or ‘us’) operations.

DiploFoundation operates from four offices:

• Anutruf, Ground Floor, Hriereb Street, Msida, MSD 1675, Malta (headquarters)
• WMO Building, 7bis, Avenue de la Paix, CH-1202 Geneva, Switzerland
• Diplo Centar, Branicevska 12a, 11000 Belgrade, Serbia
• Diplo US, 740 15th street NW, 20005 Washington, DC, USA

DiploFoundation also engages staff members based in other parts of the world.

Information collected

We collect personal data in a number of ways. The following describes what information is collected, and how it is used and stored.

As an applicant or participant of any of our online or blended learning courses, capacity development programmes, or other learning events

In order for you to apply and to take part in any of our courses, especially courses that are academically accredited, we require your personal data. We collect the data which you provide us when applying to study with DiploFoundation through the application form you complete and other enrolment documents you provide. We also collect other data which you add to your profile in our online classroom or on other platforms which Diplo may use for the running of its courses.

We may process your personal data because it is necessary for the performance of our contractual obligations to you, or in order to take steps at your request prior to entering into a contract.

The purposes for which we will use personal data (including sensitive personal data, and data related to your academic performance) are:

·        Admissions and academic matters. If the course or programme you are undertaking is accredited by the University of Malta, your personal data will be shared with the University. If it is offered in collaboration with partnering organisations, your personal data may be shared with such partners. Some of the data you provide is used to create your profile in our online classroom, which is visible to other participants, course lecturers, course coordinators, special guests, and the administrative and technical teams. Within your profile, some data will always be visible (name, surname, e-mail address, courses attended, etc.) while you may choose not to disclose other details within the classroom. We also publish some of the data on our Alumni Map, to showcase the impact and reach of Diplo’s capacity development programmes, if you grant us permission to do so. You may edit, add, and remove the data on the alumni map at any time through your classroom profile (https://learn.diplomacy.edu; under ‘My Account’).

·        Administering finance. These include fees and scholarships. Some of your personal data is shared with our bank/s in order to process payments and prevent fraudulent charges, and may be shared with our funders, especially (but not only) if your participation is partially funded by a government or an organisation.

·        Administrative purposes. We may share some of the data, in an anonymised format, for research and statistical analysis purposes, and to promote Diplo’s work in the field of capacity development.

·        We may also do so because it is necessary for the performance of our tasks carried out in the public interest, when your participation is funded (even partially) by any government or public authority.

·        We may also use your data to meet our compliance and regulatory obligations.

 Visiting our websites, downloading our apps, and using our extensions

·        This website may collect and process data that you provide to us about you, for example through filling out forms. By supplying this information, you are consenting that DiploFoundation hold and use it for the purposes for which it was provided.

·        We may also automatically collect information about your device, including where available your Internet Protocol (IP) address, operating system, and browser type, for system administration and to report aggregate information to our webmasters. This is statistical data about our users’ browsing actions and patterns which does not identify any individual and allows us to ensure that content from our site is presented in the most effective manner for you and for your device.

·        Demographic and statistical information about user behaviour may be collected and used to analyse the popularity and effectiveness of our website/s, including the downloading of any content from our website (such as newsletters in pdf format). Any disclosure of this information will be in aggregate form and will not identify individual users.

We use a tool called ‘Google Analytics’ to collect information about the use of this site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognising you on return visits to this site by disabling cookies on your browser.

We use ‘Microsoft Clarity’ to collect information about your use of this site.  Microsoft may collect your personal data when visiting our websites and offer appropriate opt-out choices as required by Data Protection Law. Microsoft collects or receives your personal data from us to provide Microsoft Advertising. Microsoft’s ability to use and share information collected by Microsoft Clarity is restricted by the Microsoft Clarity Terms of Use and the Microsoft Privacy Statements.

We use Google Ads Remarketing and Facebook Ads (Remarketing) to advertise DiploFoundation across the Internet, in particular on the Google Display Network and Facebook. AdWords and Facebook Ads will display ads to you based on what parts of our website you have viewed by placing a cookie on your web browser. This cookie does not in any way identify you or give access to your computer or mobile device. Google Ads Remarketing and Facebook Ads allows us to tailor our marketing to better suit your needs and only display ads that are relevant to you. Find out how Google Ads uses data and how Facebook uses your data.

If you do not wish to see ads from DiploFoundation you can opt out in several ways:

1. Opt out of Google’s use of cookies by visiting Google’s Ads Settings.

2. Opt out of Facebook’s use of cookies by visiting Facebook’s Ads Settings.

3. Opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.

·        Queries via e-mail or phone

·        We collect questions, queries, or feedback you leave, including your name, e-mail address, and telephone/mobile number, if you e-mail us or call us at any of our offices. We use these details to respond to the feedback/query you sent us. In some instances, this information is passed to a colleague in our organisation whom we believe can best respond or assist you. We do not record phone calls, unless we specifically notify you in advance.

·        Signing up to receive our newsletter/s

·        We collect your name, e-mail address, and other details you may wish to provide, when you sign up to receive DiploNews, the Geneva Digital Watch newsletter, e-mail related to our courses, e-mail related to the Geneva Internet Platform, e-mail related to our E-diplomacy project, and e-mail related to other activities or series of activities.

·        We may also collect this information, and other details that help us determine and evaluate the reach and usefulness of our publications, for any other book, publication, study, or resource that we may publish and make available on our website/s (such as the latest version of the book An Introduction to Internet Governance).

·        In addition, we may periodically send additional e-mail, which we think you may find useful (e.g. new events or activities).

·        If you have signed up for e-mail alerts, you can unsubscribe at any time by selecting the ‘unsubscribe’ link that appears in every e-mail we send.

Attending our webinars or events with online participation

·        We collect the details you provide on the registration form when you register for any of our webinars or events with online participation. These are required to enable us to communicate with you, and for internal statistical purposes. By registering, you are agreeing to such use of your data.

·        We use third party software or applications such as Adobe Connect, Webex, YouTube, or Zoom for our webinars or events with online participation. When you log in, the third-party software or application may collect personal information from you. Follow the links for Privacy Policies of third party software or applications:

We record most of our webinars and events which support online participation. The recording usually includes names of participants who attended, and a log of the public chat during the webinar or event. We upload recordings on YouTube, or other video-sharing websites. The recording may also appear on our website/s, or on third party websites. In addition, the link to the webinar recording may be sent to those who registered/attended.

If you have concerns about your name appearing on a public website or being shared with other participants, we suggest you use an alias when logging in.

Photos/videos during face-to-face events

We usually take photographs and record short video footage during our events. Occasionally, we may record the full event. We share photos and videos on our website/s, on social media, on YouTube or any video-sharing website), and our gallery on SmugMug (https://diplo.smugmug.com). Such content is retained indefinitely.

By attending our events, you agree that DiploFoundation may use, reproduce, and/or publish in any way whatsoever (without any payment being due to you) any photos and/or video/audio that may pertain to you (including your image, likeness and/or voice). This material may also be used in an event report, publication, press release, or other promotional content.

If you do not wish for your photograph to be taken, please inform a member of our Team during the event.

How data is used

Personal information provided to DiploFoundation by you will only be used for the purposes stated when the information is requested. We will therefore never share or process your information other than for the purpose for which it was provided to us; such data will not be provided to other organisations without your permission.

We may however disclose your personal information to third parties if we are under a duty to disclose or share such information in order to comply with any legal obligation. Unless otherwise indicated, information provided will be kept for as long as is necessary to fulfil the purpose for which it was collected.

Personal information collected and/or processed by DiploFoundation is held in accordance with the provisions of the Data Protection Act, Chapter 440 of the Laws of Malta, and with the EU’s General Data Protection Regulation.

How data is stored

Information which you provide to us will ordinarily be stored on our secure servers located within the European Economic Area (EEA). Some information may be stored on servers in Belgrade, Serbia (the location of one of our offices). Information may be processed by staff operating outside the EEA who work for DiploFoundation or for our contractors. We also work with third party contractors, some of whom host and operate certain features of the website, our e-mailing system, and our collaborative software. These include:

Information that we collect from you may therefore be collected in or transferred to a destination outside the EEA. We will take all reasonable steps necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

How ‘cookies’ are used

Most of our websites use ‘cookies’. ‘Cookies’ are small text files that are stored on your computer or mobile device when you visit a website. They allow the website to recognise your device and remember if you have been to the website before. Cookies are widely used in order to make websites work more efficiently, as well as providing information to the owners of websites on site usage and performance.

For more detailed information on the use of cookies on our website/s, please refer to our Cookie Statement.

Your rights

As an individual whose personal data is processed by DiploFoundation, you have:

The right to be informed

Transparency is a key requirement of data protection law. You have the right to be informed about the collection and use of your personal data. This privacy notice is designed to provide you with the information needed to allow you to see how and why your personal data is used when visiting this website.

The right to access the data we hold on you

You also have the right to ask for the personal data that we have about you to increase your awareness of and allow you to verify the lawfulness of the processing. To protect your privacy we may ask you to verify your identity.

The right to have your data rectified if it is inaccurate

If you believe that personal data we hold on you is inaccurate or misleading then you have the right to request that it is rectified.

The right to erasure (in limited circumstances)

In some circumstances, you can ask for your personal information to be deleted, for example, if:

·        your personal information is no longer needed for the reason it was collected in the first place;

·        you have removed your consent for us to use your information (where there is no other legal reason for us to use it);

·        there is no legal reason for the use of your information.

Please note that we cannot delete your information where:

·        we are required to have it by law, or by the University of Malta;

·        it is necessary to perform our obligations, such as to our funders or partnering organisations.

The right of data portability (in limited circumstances)

·        Where you have provided your personal data directly to us and it is processed by automated means and is done so on the basis of your consent, then you will have the right to obtain and reuse your personal data in an electronic format for your own purposes across different services.

The right to object to direct marketing

·  You have an unconditional right to object to direct marketing at any time. As noted within this Privacy Policy, we will not send you direct marketing without your consent and you can withdraw your consent at any time by selecting the ‘unsubscribe’ link within each e-mail.

The right to object to processing of your personal data

·        Processing is the term under data protection law that describes all uses of your personal data. This will include the collection, sharing, storage, retention, and destruction of your data.

·        You have the right to object to any aspect of our processing of your personal data. If you would like to exercise your right of access in relation to information held on you by DiploFoundation, e-mail us at diplo@diplomacy.edu

Changes to our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, you will be notified by e-mail.

Contact

Any queries or concerns should be sent by e-mail to diplo@diplomacy.edu or addressed to Management, DiploFoundation, Anutruf (Ground Floor), Hriereb Street, Msida, MSD 1675, Malta.

Should you wish to report a complaint or if you feel that DiploFoundation has not addressed your concern in a satisfactory manner, you may contact the Office of Information and Data Protection Commissioner:

Email: idpc.info@idpc.org.mt

Address: Floor 2, Airways House, High Street, Sliema, SLM 1549, Malta.

Version  27 April 2020