# Privacy Policy

Controller Fairlinked — Alliance for digital fairness e.V. c/o Postflex #9498 Emsdettener Str. 10 48268 Greven, Germany

Amtsgericht Steinfurt, VR 2059

Email: hello@fairlinked.eu

1. Server logs

When you visit this website, our hosting provider (Hetzner) automatically collects and stores the following data in server log files:

• IP address (anonymised after 7 days)
• Date and time of the request
• Page requested
• HTTP status code
• Referrer URL
• Browser type and version
• Operating system

This data is processed to ensure the security and stability of the website. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in IT security). Log files are deleted after 30 days.

2. Membership application

When you apply for membership through the form on this website, we collect:

• First and last name
• Business or organisation name (if applicable)
• Email address
• Country
• Membership tier selection
• Contribution basis figures you enter (e.g. revenue, number of employees)
• Voluntary contribution estimate

This data is processed to evaluate your application, establish the membership relationship, and fulfil legal obligations under German association law (§ 58 BGB, Abgabenordnung). Legal basis: Art. 6(1)(b) GDPR (performance of a contract or pre-contractual measures) and Art. 6(1)(c) GDPR (legal obligation).

During the application process, a subset of this data is transmitted to our server at an earlier step (“lead capture”) to prevent data loss if you do not complete the form. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in preserving incomplete applications).

We retain membership data for the duration of your membership and for the legally required retention periods after it ends (up to 10 years for tax-relevant records under § 147 AO).

The application form contains a hidden honeypot field to detect automated spam submissions. No personal data is collected through this field.

3. Contact by email

When you contact us by email, we process your email address, name (if provided), and the content of your message to respond to your inquiry. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in responding to inquiries) or Art. 6(1)(b) GDPR where your inquiry relates to a contractual relationship.

We retain correspondence for as long as the subject matter requires, and for legal retention periods where applicable.

4. Newsletter and email communications

If you subscribe to our newsletter or consent to receiving updates, we process your email address and, if provided, your name. We send emails only with your prior consent. Legal basis: Art. 6(1)(a) GDPR.

You can withdraw consent at any time by clicking the unsubscribe link in any email or by writing to hello@fairlinked.eu . Withdrawal does not affect the lawfulness of processing before withdrawal.

Email infrastructure: We operate a self-hosted mailing list system (Listmonk) at list.browsergate.eu. Emails are delivered through Sweego (Sweego SAS, France), which acts as our SMTP relay and processes email addresses and message metadata for the purpose of delivery. Sweego operates under French and EU law and processes data exclusively within the European Union.

5. Google Fonts

This website loads typefaces (Open Sans, Fira Mono) from Google Fonts, a service operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

When you open a page, your browser establishes a direct connection to Google’s servers (fonts.googleapis.com, fonts.gstatic.com). In the process, your IP address is transmitted to Google. Google’s privacy policy applies to this processing: https://policies.google.com/privacy

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in consistent typography and efficient font delivery).

We are evaluating self-hosting these fonts to eliminate this data transfer.

6. Cookies

This website does not set cookies for analytics, advertising, or tracking purposes. Your browser may receive technically necessary cookies from our server (e.g. session management). These are essential for the website to function and cannot be disabled. Legal basis: Art. 6(1)(f) GDPR.

7. No analytics or tracking

We do not use any analytics tools, tracking pixels, or similar technologies. We do not track your behaviour on this website.

8. Data recipients

We share personal data only where necessary:

We do not sell personal data. We do not share personal data with advertisers.

9. International transfers

Data transmitted to Google through Google Fonts may be transferred to servers outside the EU/EEA. Google relies on Standard Contractual Clauses (SCCs) and supplementary measures for these transfers. All other processing occurs within the EU.

10. Your rights

Under the GDPR, you have the right to:

• Access your personal data (Art. 15)
• Rectification of inaccurate data (Art. 16)
• Erasure of your data (Art. 17)
• Restriction of processing (Art. 18)
• Data portability (Art. 20)
• Object to processing based on legitimate interest (Art. 21)
• Withdraw consent at any time where processing is consent-based (Art. 7(3))

To exercise any of these rights, write to hello@fairlinked.eu .

11. Right to lodge a complaint

You have the right to lodge a complaint with a data protection supervisory authority. The supervisory authority responsible for our registered office is:

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen Postfach 20 04 44 40102 Düsseldorf https://www.ldi.nrw.de

You may also contact the supervisory authority in your own Member State.

12. Changes

We update this policy when our practices change. The current version is always available at this page.

Last updated: April 6th 2026