Privacy Policy

Code Victorian (“we”, “us”, “our”) is committed to protecting your personal data. This privacy policy explains how we collect, use, store, and protect information in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and applicable national data protection laws.

I.Data Controller

The data controller is Code Victorian, headquartered in Brussels, Belgium. For all data protection enquiries, contact our Data Protection Officer at dpo@codevictorian.com.

II.Data We Collect

We may collect the following categories of personal data:

• ✦Identity data: name, country of residence, nationality
• ✦Contact data: email address, phone number, postal address
• ✦Financial data: payment details (processed securely via third-party payment processors; we do not store card details)
• ✦Petition data: name, country, and signature status (displayed publicly with your consent)
• ✦Technical data: IP address, browser type, device information, cookies (see Cookie Policy below)
• ✦Communication data: messages sent via our contact forms or email
• ✦Membership data: membership tier, payment history, event attendance

III.Legal Basis for Processing

We process your data on the following legal bases under GDPR Article 6:

• ✦Consent (Art. 6(1)(a)): petition signatures, newsletter subscriptions, marketing communications, non-essential cookies
• ✦Contract (Art. 6(1)(b)): membership services, donation processing, store purchases
• ✦Legitimate interest (Art. 6(1)(f)): website analytics (anonymised), fraud prevention, internal administration
• ✦Legal obligation (Art. 6(1)(c)): financial record-keeping, electoral compliance reporting

IV.How We Use Your Data

Your data is used to: process petition signatures; manage membership accounts; process donations and purchases; send campaign updates (with your consent); organise events; respond to enquiries; comply with legal obligations; and improve our website and services.

V.Data Sharing & Transfers

We do not sell your data. We may share data with: trusted service providers (email: Mailerlite; payments: secure payment processor; analytics: Google Analytics with IP anonymisation); legal authorities when required by law; and EU institutions when submitting petition signatures. Where data is transferred outside the EU/EEA, we ensure adequate safeguards under GDPR Chapter V (Standard Contractual Clauses or adequacy decisions).

VI.Data Retention

We retain personal data only as long as necessary for the purposes collected: petition signatures for the duration of the campaign plus 12 months; membership data for the duration of membership plus 24 months; financial records for 7 years (legal requirement); contact form messages for 12 months; website analytics data (anonymised) for 26 months.

VII.Your Rights (GDPR)

Under GDPR, you have the right to:

• ✦Access: request a copy of your personal data
• ✦Rectification: correct inaccurate or incomplete data
• ✦Erasure: request deletion of your data (‘right to be forgotten’)
• ✦Restriction: limit how we process your data
• ✦Portability: receive your data in a structured, machine-readable format
• ✦Objection: object to processing based on legitimate interest or direct marketing
• ✦Withdraw consent: at any time, without affecting prior lawful processing
• ✦Lodge a complaint: with your national data protection authority

To exercise any of these rights, contact dpo@codevictorian.com or use our contact form (select “Data Subject Request”). We will respond within 30 days.

VIII.Cookie Policy

We use cookies in compliance with GDPR and the ePrivacy Directive. No non-essential cookies are loaded until you provide explicit consent via our cookie banner (opt-in model).

You can manage your cookie preferences at any time by clicking “Manage Cookies” in the site footer or clearing your browser cookies.

IX.Security

We implement appropriate technical and organisational measures to protect your data, including SSL/TLS encryption, access controls, regular security audits, and data minimisation practices. Our hosting infrastructure is located within the EU.

X.Changes to This Policy

We may update this policy from time to time. Significant changes will be communicated via email (for members and subscribers) and prominently displayed on our website. The “last updated” date at the top reflects the most recent revision.