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Privacy & data protection

Privacy Policy

ERA-LGBTI Equal Rights Association for the Western Balkans and Türkiye (“ERA”, “we”, “us”, “our”) is committed to ensuring a high level of protection of personal data and respecting the privacy of all individuals who interact with our website.

This Privacy Policy outlines the principles governing the collection, processing, and protection of personal data. ERA acts as a data controller, meaning that it determines the purposes and means of processing personal data.

Last updated: June 24, 2026

This policy is adopted in accordance with

  • Regulation (EU) 2016/679 — General Data Protection Regulation (GDPR)
  • Applicable national data protection legislation
  • ERA acts as data controller for personal data on this website

On this page

  1. Data Controller
  2. Scope of Application
  3. Categories of Personal Data
  4. Legal Basis for Processing
  5. Purpose of Processing
  6. Data Sharing & Recipients
  7. International Data Transfers
  8. Data Retention
  9. Data Subject Rights
  10. Cookies & Tracking
  11. Data Security
  12. Protection Against Misuse
  13. Amendments
  14. Contact & Complaints
01

Data Controller

ERA-LGBTI Equal Rights Association for the Western Balkans and Türkiye

ERA acts as the data controller, determining the purposes and means of processing personal data in accordance with applicable data protection legislation.

02

Scope of Application

This Privacy Policy applies to all visitors and users of the ERA website and governs all personal data processing activities carried out through digital interaction with the platform.

This Policy does not apply to third-party platforms or websites that may be accessed via external links.

03

Categories of Personal Data

Depending on your interaction with the website, ERA may collect and process the following categories of personal data:

  • Identification and contact data — name, email address, and other information voluntarily provided
  • Technical data — IP address, browser type and version, device identifiers, operating system
  • Usage data — navigation paths, session duration, interaction patterns
  • Communication data — records of correspondence and inquiries

ERA does not intentionally collect special categories of personal data (Article 9 GDPR).

Where such data is voluntarily provided, it will be processed only where strictly necessary and subject to appropriate safeguards in accordance with applicable law.

04

Legal Basis for Processing

Personal data is processed in accordance with Article 6 of the GDPR on the following legal grounds:

  • Consent (Article 6(1)(a)) — where the data subject has given explicit consent
  • Legitimate interests (Article 6(1)(f)) — including ensuring website security, functionality, and improvement. When relying on this legal basis, ERA ensures that such interests are not overridden by the rights and freedoms of the data subject and conducts an appropriate balancing assessment
  • Legal obligations (Article 6(1)(c)) — where processing is necessary for compliance with applicable legal obligations
  • Performance of a contract or pre-contractual steps (Article 6(1)(b)) — where processing is necessary to respond to user inquiries or to take steps prior to entering into a contractual relationship

Where processing is based on consent, such consent may be withdrawn at any time, without affecting the lawfulness of processing carried out prior to its withdrawal.

05

Purpose of Processing

ERA processes personal data for specific, explicit, and legitimate purposes, including:

  • Responding to inquiries and maintaining communication
  • Ensuring the proper functioning, security, and integrity of the website
  • Monitoring, analyzing, and improving website performance and user experience
  • Preventing misuse, unauthorized access, or security incidents
  • Complying with legal and regulatory obligations
  • Ensuring transparency and accountability in ERA’s work

Personal data will not be further processed in a manner that is incompatible with these purposes.

ERA may process personal data for internal research and statistical purposes, in accordance with Article 5(1)(b) and Recital 50 GDPR. Such processing is limited to what is necessary and proportionate, and, where feasible, is carried out using anonymized or aggregated data. These activities are designed to support evidence-based advocacy, program development, and public policy engagement, and do not result in decisions affecting individual users.

06

Data Sharing and Recipients

ERA does not sell, rent, or otherwise disclose personal data for commercial purposes.

Personal data may be shared only where necessary and proportionate with:

  • Authorized service providers (e.g. hosting, IT, analytics), acting as data processors under binding contractual arrangements
  • Public authorities where disclosure is required by applicable law

All third-party processors are engaged in accordance with Article 28 GDPR and are required to implement appropriate technical and organizational safeguards.

07

International Data Transfers

Where personal data is transferred outside the European Union or European Economic Area (EU/EEA), ERA ensures that such transfers are subject to appropriate safeguards, including:

  • Standard Contractual Clauses (SCCs) adopted by the European Commission
  • Other legally recognized transfer mechanisms under applicable data protection law
08

Data Retention

Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by law.

ERA applies the principles of data minimization and storage limitation in all processing activities and periodically reviews retention periods.

09

Data Subject Rights

In accordance with the GDPR, individuals have the right to:

  • Request access to their personal data
  • Request rectification of inaccurate or incomplete data
  • Request erasure (“right to be forgotten”)
  • Request restriction of processing
  • Object to processing based on legitimate interests
  • Request data portability
  • Withdraw consent at any time

ERA may request verification of identity prior to responding to such requests, in order to ensure data security.

Requests can be submitted using the contact details provided below.

10

Cookies and Tracking Technologies

This website uses cookies and similar technologies to:

  • Ensure proper functionality and performance
  • Improve user experience
  • Analyze usage patterns and website performance

Users may manage or disable cookies through their browser settings.

Where required, additional information will be provided through a dedicated Cookie Notice.

11

Data Security

ERA implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:

  • Protection against unauthorized or unlawful processing
  • Prevention of accidental loss, destruction, or damage
  • Controlled and limited access to personal data

Despite these measures, no system can be guaranteed to be fully secure.

12

Protection Against Misuse

Users must not:

  • Attempt to access or process personal data of other users without authorization
  • Use any data obtained through the website for unlawful or harmful purposes
  • Engage in activities that may compromise the security or integrity of the system

ERA reserves the right to take appropriate action in response to such activities.

13

Amendments

ERA reserves the right to amend this Privacy Policy to reflect legal, technical, or operational developments.

Updated versions will be published on this page. Continued use of the website constitutes acceptance of the updated Policy.

14

Contact and Complaints

For any questions or requests regarding personal data, please contact us. We will respond to your inquiry in accordance with applicable data protection law.

office@lgbti-era.org
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