Privacy Policy

1. Information We Collect

1.1 Information You Provide

• Donations (Koha): Name (optional), email address (required for receipt), country (optional), payment information (processed by Stripe, not stored by us)
• Media Inquiries: Name, email, organization, inquiry details
• Case Submissions: Contact information, case description, supporting evidence
• Account Creation (if applicable): Email, credentials (hashed), optional profile information

1.2 Automatically Collected Information

• Analytics: Page views, referring sites, browser type, device type, general location (country-level)
• Cookies: Session management, preferences (e.g., selected currency), analytics
• Server Logs: IP addresses, access times, pages accessed (retained for 90 days for security)

1.3 Currency Selection

When you select a currency for donations, we may detect your approximate location to suggest an appropriate currency. This location data is:

• Derived from your IP address (country-level only, not precise geolocation)
• Used only to pre-select a currency in the donation form
• Not stored permanently
• Can be overridden by manual currency selection

2. How We Use Your Information

• Process Donations: Email receipts, acknowledge public supporters (opt-in only), maintain transparency dashboard
• Respond to Inquiries: Answer media questions, review case submissions, provide support
• Improve Services: Analyze usage patterns, fix bugs, enhance user experience
• Security: Prevent fraud, detect abuse, protect against attacks
• Legal Compliance: Comply with applicable laws, respond to legal requests
• Communications: Send receipts, important updates (we never send marketing emails without explicit opt-in)

3. Data Sharing and Disclosure

We Share Your Data With:

• Stripe: Payment processing for donations (subject to Stripe's Privacy Policy)
• MongoDB Atlas: Database hosting (subject to MongoDB's Privacy Policy)
• Email Service Provider: For sending receipts and communications

We NEVER:

• ❌ Sell your personal data
• ❌ Share your data with advertisers
• ❌ Use your data for tracking across other websites
• ❌ Share donor information publicly without explicit opt-in

Legal Disclosures:

We may disclose your information if required by law, court order, or to protect our rights and safety. We will notify you of such requests unless prohibited by law.

4. Data Retention

• Donation Records: Retained indefinitely for transparency and tax purposes
• Server Logs: Deleted after 90 days
• Analytics Data: Aggregated, anonymized after 12 months
• User Accounts: Retained until you request deletion
• Inquiries/Submissions: Retained for 2 years, then archived or deleted

5. Your Rights

You have the right to:

• Access: Request a copy of your personal data
• Correction: Update or correct inaccurate information
• Deletion: Request deletion of your data (subject to legal obligations)
• Portability: Receive your data in a machine-readable format
• Opt-Out: Withdraw consent for public acknowledgements anytime
• Object: Object to processing of your data

To exercise your rights, email: privacy@agenticgovernance.digital

6. Analytics and Tracking

About Umami Analytics

Umami helps us understand how visitors use our website so we can improve it. Unlike traditional analytics tools, Umami is designed with privacy at its core.

What Umami Collects:

• Page Views: Which pages you visit on our site
• Referrers: Which website referred you (if any)
• Browser Type: Your browser name (e.g., Chrome, Firefox, Safari)
• Device Type: Whether you're on desktop, tablet, or mobile
• Country: Your country based on IP address (not stored)

What Umami Does NOT Collect:

• ❌ IP Addresses: Not stored or logged
• ❌ Personal Information: No names, emails, or identifiers
• ❌ Cookies: Completely cookie-free tracking
• ❌ Cross-Site Tracking: We don't track you across other websites
• ❌ Precise Location: Only country-level, no city or GPS data

Do Not Track Support

We respect the Do Not Track (DNT) browser setting. If you have DNT enabled in your browser, our analytics will not track your visit at all.

How to Opt Out

You can opt out of analytics tracking at any time:

• Browser Console Method: Open your browser's Developer Console (F12), and run: window.umamiOptOut()
• Enable DNT: Turn on "Do Not Track" in your browser settings
• Development Mode: Analytics are automatically disabled on localhost

Note: Your opt-out preference is stored in your browser's localStorage. You'll need to opt out again if you clear your browser data.

Cookies

While Umami is cookie-free, we use cookies for other essential purposes:

Essential Cookies: Required for site functionality (session management, authentication)

Preference Cookies: Remember your settings (currency selection, language preference)

You can control cookies through your browser settings. Disabling cookies may affect site functionality.

Analytics Data Storage

Analytics data is stored on our self-hosted Umami instance running on OVHCloud servers in France (EU). All analytics data remains within EU jurisdiction and is never shared with third parties.

7. Security

We implement industry-standard security measures:

• HTTPS encryption for all connections
• Encrypted database storage
• Password hashing (bcrypt)
• Regular security audits
• Access controls and monitoring
• No storage of payment card data (handled by Stripe PCI-compliant systems)

While we take reasonable precautions, no system is completely secure. Report security issues to: security@agenticgovernance.digital

8. Children's Privacy

The Tractatus Framework is not directed at children under 13. We do not knowingly collect information from children. If you believe a child has provided us with personal data, please contact us at privacy@agenticgovernance.digital.

9. Data Location and International Operations

The Tractatus Framework is administered from Aotearoa New Zealand, but our infrastructure is hosted with OVHCloud in the European Union (France). Your data is stored and processed within the EU, benefiting from robust EU data protection standards.

Hosting and Data Residency:

• Primary Hosting: OVHCloud (France, EU) - all user data stored in EU jurisdiction
• Database: MongoDB Atlas (EU-West region, Frankfurt, Germany)
• Payment Processing: Stripe (uses Standard Contractual Clauses for EU-US data transfers)
• No Data Transfer to NZ: Your personal data is not transferred to or processed in New Zealand

GDPR Compliance:

As our infrastructure is hosted in the EU, we benefit from the protections of the General Data Protection Regulation (GDPR). EU users' data never leaves EU jurisdiction during normal operations. We comply with GDPR requirements including:

• Lawful basis for processing (Article 6)
• Data minimization and purpose limitation (Article 5)
• Your rights under Articles 15-22 (access, rectification, erasure, portability, objection)
• Privacy by Design and Default (Article 25)
• Data security measures (Article 32)

For non-EU users: Your data is processed in the EU and benefits from GDPR protections, regardless of your location. We extend GDPR rights to all users globally.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last updated" date. Material changes will be communicated via email (for users who provided email) or prominent notice on the website.

11. Contact Us

For privacy-related questions or concerns: