1. Controller
The controller of the personal data processed on the Propastop.org website is:
MTÜ EMCC
Registry code: 80548226
E-mail: [email protected]
For data protection questions and requests, please contact us at the e-mail address indicated above.
2. What data do we process?
Website technical data
IP address, technical information about the device and browser, time of visit, technical logs and data collected through cookies, if cookies are used.
Correspondence data
Name, e-mail address and other information that a person provides to us themselves.
Journalistic content
Information collected from public sources about persons who are relevant from the point of view of public interest, such as name, position, public statements and social media posts.
Tips and sources
The contact details of the person submitting a tip and the content submitted. Information related to source protection is treated confidentially.
3. Where does the data come from?
- from the person themselves, if they contact us;
- from public sources, such as websites, registers, social media, media outlets and public documents;
- from third parties who submit tips or materials;
- from the website’s technical logs and analytics tools.
If the data has not been obtained from the person themselves, we provide the relevant information in these terms. In the case of journalistic processing, separate notification of every person may not be possible or reasonable if it would undermine source protection or the independence of investigative work.
4. Why do we process data?
- to prepare, publish and archive Propastop’s journalistic and analytical content;
- to inform the public about information influence activities, disinformation and the mechanisms of propaganda;
- to handle tips, enquiries and feedback;
- to ensure the functioning and security of the website.
5. Legal bases
- Article 6(1)(f) GDPR – legitimate interest, such as security, responding to enquiries and protection of rights;
- Article 6(1)(c) GDPR – compliance with a legal obligation;
- Article 6(1)(a) GDPR – consent, for example voluntary cookies;
- Section 4 of the Estonian Personal Data Protection Act – processing of personal data for journalistic purposes.
In the case of journalistic processing, we assess three criteria: whether there is public interest in the topic, whether the principles of journalistic ethics have been followed and whether publication may disproportionately harm the person.
6. How long do we retain data?
Data is retained for as long as necessary to fulfil the purpose of processing. Technical logs are retained for a limited period, correspondence for the time necessary to resolve the enquiry, and journalistic content in the archive due to its documentary and public value.
7. To whom do we disclose data?
- to IT, hosting and e-mail service providers;
- to legal advisers where necessary;
- to authorities on the basis of a legal obligation;
- to the public, if the data is published in Propastop’s journalistic content.
We do not sell personal data to third parties. If data is transferred outside the European Economic Area, this is done in accordance with the safeguards provided for in the GDPR.
8. Cookies
Propastop.org may use cookies for the functioning of the website, security and the collection of statistics. We ask for consent for the use of non-essential cookies. Cookies can be restricted or deleted in the browser settings.
9. Your rights
Every person has the right to contact MTÜ EMCC in order to:
- receive information about the processing of their data;
- request access to their data;
- request correction of inaccurate data;
- request deletion of data;
- object to processing;
- withdraw consent where processing is based on consent.
In the case of journalistic content, submitting a request does not automatically mean the removal of an article, name, photograph or other information. Each request is assessed separately on the basis of Section 4 of the Estonian Personal Data Protection Act, taking into account public interest, journalistic ethics and possible harm. We generally respond to requests within one month.
10. Security
We apply reasonable technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure or destruction.
11. Right to lodge a complaint
If you believe that your data has been processed unlawfully, you may contact MTÜ EMCC or lodge a complaint with the Estonian Data Protection Inspectorate.
Estonian Data Protection Inspectorate | Website: aki.ee | E-mail: [email protected]
12. Changes to the terms
We may update these terms if our data processing, the technical solution of the website or the legal framework changes. The current version is always available at propastop.org.