Journalism Development Network, Inc. (JDN), trading as the Organized Crime and Corruption Reporting Project (OCCRP), takes data protection seriously.
We collect the minimum amount of personal information about you when you use our services. This includes when you use our websites and mobile applications, our online research services including OCCRP ID and our data platform, OCCRP Aleph. This also applies when you subscribe to our newsletters, emails or membership services, when you make donations or when you complete a survey. We only collect as much as is necessary or desirable to help us serve you better.
We do not sell your personal information. We may share it with reputable third parties who provide us with online services to support our services to you. We may share it in an aggregated format to our donors or other trusted parties for statistical purposes, or in rare cases with our legal or other advisers bound by confidentiality (see section 5 for more information).
What it covers
Public facing services. It does not apply to our use and processing of personal data for journalism purposes. By accessing or using our services, you agree to the terms of this policy.
What it does not cover
Our Journalism Activities. As part of our journalistic work, we may receive, collect, process, analyze and publish personal information, which may also be shared within our OCCRP network and with other journalistic partners. This use of information is generally exempt under data protection and privacy laws. We work to ensure that this information is handled securely.
Third Party Links and Sites. This policy does not apply to third party sites or services linked to from our sites or services. We are not responsible for third party data protection practices or terms, including those of any OCCRP Member Center.
Transmission of Information to us. We do our best to protect your personal information once we receive it. We are not responsible for the security of your information during transmission to us. Such transmission is at your risk.
We may change this policy from time to time and will use our best efforts to advise you of any material changes. You may also check this page anytime. If you are not happy with a change, please notify us at firstname.lastname@example.org or cease using our services.
What personal information do we collect?
When you use our services we may collect the following categories of information:
Personal information you give us when you enter information via our services. This information may include basic personal information we ask for, or you choose to give us, such as when you:
use our research services, data services or our collaborative workspaces: your name, user type (e.g. journalist, researcher, member of the public), organization and email address.
sign up to our newsletters, emails or membership services, or make a donation: your name, organization, address, email address and phone number, and financial details if applicable;
We may retain details of any enquiry you make to us and records of any communications and correspondence with us.
We minimize the information we ask for to that which is needed to perform the relevant function or service at the time.
Personal information we collect about you when you interact with our services, such as details of your visits, the resources you access and transactions you carry out. This information may include, for example, when you:
visit our websites or mobile applications, or use our research services, data services or collaborative workspaces: data collected by the hosting server for statistical purposes, session identifiers, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone settings, language, location data, browser plug-in types and versions, screen size and other device characteristics, operating system and platform, weblogs and other communication data; or:
sign up to our newsletters, emails or membership services, or make a donation: the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone settings, language, location data, browser plug-in types and versions, screen size and other device characteristics, operating system and platform, weblogs and other communication data such as which newsletter you received or opened.
We use this data for statistical analysis for reporting to third parties in aggregated format (see section 5(c) below), for error analysis, protection against network intrusion and other attacks, and to improve the delivery of our services.
What do we do with your personal information?
We aim to use your personal information only for the purposes you would have reasonably expected when it was provided or collected.
The legal basis upon which we process your personal information depends upon the circumstances in which we collect and use that information. In most cases our processing of your personal information will fall into one of the following categories:
Consent: where you have agreed that your personal data may be used for a particular purpose or purposes, such as email updates about our work
Legitimate interests: in relying on this exemption we will determine how to process your data in a way that fits with our legitimate interests and yet is proportionate in relation to any privacy issues
Contractual necessity: where the processing of your personal information is necessary to carry out the performance of a contract with you
Legal obligation: where the processing of your personal information is necessary for us to comply with a legal obligation such as auditing of donations
Uses of your information
We will use your information to:
Newsletters and Communications: correspond or communicate with you, to let you know about our reporting and activities when you have provided us with your address or email address and your consent to receive such communications (for example, when you have signed up for our weekly newsletters)
Fundraising and Marketing: correspond or communicate with you to raise public awareness of our work and activities; to invite you to events, membership opportunities or to support our fundraising efforts; and when you have provided us with your address or email address for any reason and we consider it in our or your Legitimate Interests to do so. You can unsubscribe from or object to such communications at any time.
Deliver better and more secure services: ensure that our online content is presented in the most effective manner for you and your device; monitor network and information security for us to take steps to protect information against loss or damage, theft or unauthorized access.
Legal and administrative purposes: verify the accuracy of information that we hold about you; manage queries, complaints, or claims; prevent fraud and other criminal activities; establish and defend our legal rights.
Disclosure of your information to others.
Personal information provided to or collected by us when users access or use our services will never be sold. We may disclose your personal information to external providers of the services we offer.
Our suppliers and service providers
We may disclose your information to our third-party service providers, agents, subcontractors and other organizations for the purposes of providing services to us or directly to you on our behalf. We are committed to selecting providers that have a proven track record of respecting user rights and data privacy to the best standards of their industries. We can not assume liability for data protection breaches by our third party service providers.
Such third parties may include internet service providers; hosting, email and content providers; administrative services providers; payment processing companies (which process your debit/credit card securely if you purchase goods or services from us).
When we use third party service providers, we only disclose to them personal information that is necessary for them to provide their service.
Legal and other advisers. In rare cases, we may share your personal information with our legal or other advisers bound by confidentiality.
Data anonymization and use of aggregated information. Your personal information may be converted into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from it. We may use this data for analytical and research purposes, in reporting to donors, contributors, and partners, and in our public appeals and annual report.
Retention of Personal Information. We keep personal information for as long as necessary to ensure we can deliver our services.
What are cookies? Cookies are text files of limited size deposited by the browser and stored on your device (computer, tablet, smartphone …) when you visit a website. Only the setter of a cookie can read it. A cookie does not identify you directly, but it does recognize your browser or device.
- Technical reasons: To improve your experience by saving data about your preferences, your device or your browsing session, to provide you with the services on our websites.
- Audience measurement reasons: To learn about the device you are using to access our services and about your language preferences, to measure audiences on different sections of our websites and services, to measure user interactions with different parts of our website and services, and to understand how we can improve our services to better serve you. We do not store any personally identifiable information for these purposes.
Issuers. On most OCCRP services, cookies and local storage are issued and set by OCCRP. On some of our services we also use audience measurement cookies set by trusted third-party partners: Google (Analytics, Optimize and Tag Manager), and Microsoft (Clarity). In addition, some videos on our website are provided via YouTube embed frames. These frames may set audience measurement cookies which are used by YouTube.
Your cookie preferences. Cookies are set when you arrive and navigate around our websites and services.
When you first visit our websites, you may see a cookie preferences window which explains which cookies we use on this website. Using the settings in this window, you can opt in or out of the cookies we use for some services. We will store these preferences for all your future visits, by setting a cookie on your device. You can also adjust these settings at any time by clicking here: change my cookie preferences.
In addition, in some locations on our services we embed external content from third-party providers who set their own cookies and may process your data, for example YouTube videos. In these locations you can choose to accept the data-processing by the third party, and doing so will give you access to the third-party content. These locations will be clearly marked, and if you do not want consent to the third party’s conditions, you can simply refrain from clicking on these components, and no third party cookies will be set.
Blocking essential cookies. Some of the cookies that we set are essential to the features you use on our services. Using the cookie preferences window you will be informed about these cookies, but you won’t have the option to opt out. This might include cookies that remember your language or cookie preferences, and cookies that are set by our third-party search provider (Google).
You can block these cookies by changing the settings for your browser, however this may stop you from accessing some of our services correctly. You can block cookies using the following instructions for your browser:
We operate globally. We may transfer your personal information internally or to third parties, into or out of your country of residence, from the country from where you provided the information or from where the information was collected. This may include into or out of the United States of America (US) or the European Economic Area (EEA).
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information.
You can request the following by emailing email@example.com.
Accessing your personal information. You can ask for a copy of the personal information that we hold about you. We may not provide you with this if it concerns other individuals or if we have another lawful reason to withhold that information, such as for journalism purposes.
Correcting, updating, erasing or restricting processing of your personal information. You may request this in certain circumstances and there may be situations where this is not possible.
Withdrawing your consent where we rely on your consent to process your personal information. You may also withdraw your consent or object to receiving any direct marketing by unsubscribing on any email we send you or emailing firstname.lastname@example.org. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
Objecting to our use of your personal information and automated decisions made about you. Where we rely on legitimate interests as the legal basis for processing your personal information, you may object to that use. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
Who we are and contact details
Journalism Development Network, Inc. (JDN) is a non-profit company registered in the State of Maryland, United States of America (US). We also have a representative office in Bosnia and Herzegovina. You can contact us at:
Journalism Development Network, Inc.
4401A Connecticut Ave NW 321
Washington DC 20008-2358
United States of America
JDN is the data controller and in some cases processor for your personal information. We have appointed a data privacy manager to oversee privacy and data management at JDN. Please contact them at the above addresses if you have any queries about this policy, or wish to make any related requests or updates.
You may also have the right to make a complaint at any time to the relevant supervisory authority. We would, however, appreciate the chance to deal with your concerns directly before you do so.
OCCRP's work is made possible through public and private funding from a range of institutions and the generosity of individual supporters.