7or - The Palestinian Observatory for Digital Rights Violations
Last Revised: [October 22, 2021]
7amleh – the Arab Center for Social Media Advancement (R.A) (“7amleh”, “Us” or “We”) operates the “7or” platform at 7or.7amleh.org (the “Platform” or “7or”). We respect the privacy of the visitors and users of the Platform (“User” or “You”) and believe that You have a right to know our practices regarding the information We may collect when You use or visit the Platform and/or use the features offered on the Platform (the “Features”).
“7or” is the first Palestinian digital rights database, which aims to better protect Palestinian digital rights by enhancing the capacity of human rights organizations and activists to advocate utilizing evidence collected by organizations and individuals in a shared, secure database. The Platform allows visitors and users like You to submit reports concerning violations of digital rights of Palestinian entities, groups or individuals on the Web (eg. freedom of expression and the right to access, use and publish digital media; freedom of assembly and participation; privacy and data protection; access and non-discrimination etc.). Any report submitted by You through the Platform as described above is referred to in this policy as the “Report”).
When You submit a Report to Us, You authorize us and entrust us with filing a claim in order to investigate and address the incident described in Your Report (the “Incident”) with the concerned authorities and/or organization (a “Claim”) that may include, among others, perpetrators who are the subject matter of your Report, such as social media platforms like Facebook, Instagram, Linkedin, Twitter etc., as well as local and/or international law enforcement agencies and advocacy organizations (the “Concerned Parties”).
- Collection of Information
You are not legally obligated to provide Us any personal information. However, we require certain information in order for You to able to use the Platform and the Features. If you choose not to provide us with such information, You may not be able to use the Platform and/or the Features (or any part thereof).
1.2.1. We collect two types of data and information when You use or view the Platform:
1.1. Non-Identifiable Information (“Non-identifiable Information” or “Anonymous data”): To put it simply, we are not aware of the identity of the User from which we collect the Non-Identifiable Information. The Non-identifiable Information We gather consists of technical information and behavioral information, including, among others, IP address, user surfing patterns, browser plugin types and versions, the pages on the Platform that you visit, the time and date of your visit, and other diagnostic data; amount and type of Reports and complaints submitted (per user, region etc,) and feedbacks.
1.3. Individually identifiable information (“Personal Information” or “Personal data”): To put it simply, if You elect to submit a Report through the Platform, we will collect Personal Information about You, which may identify You or is of a private and/or sensitive nature, as required in order to pursue, manage and handle the Report and file a Claim. The Personal Information gathered may contain, among other things, Your name, gender, date of birth, location, job title, nationality, email address, and phone number, and any other identifiable information You have provided 7amleh during the submission of any Report, including, information and data inputted by You through intake forms available on the Platform (such as, the details of the Incident).
To avoid any doubt, any Non-identifiable Information connected or linked to any Personal Information are considered Personal Information as long as such connection or linkage exists.
- Usage of Information
In general, we use Your personal data in order to operate and improve the Platform.
The Non-identifiable Information We collect is used mainly to learn about general trends of usage of the Platform, enhance the user experience on the Platform and promote its goals, and/or in order to improve the forms used to file Claims and/or reports and/or improve the Features, including for training and quality assurance purposes, and other lawful purposes. For example, We are using the Non-identifiable Information to identify the type of the device You are using when visiting and/or viewing the Platform, the operating system, as well as Your language preference and time zone. We may also use certain statistical information to promote certain features offered on the Platform. The above usage of your Non-identifiable Information may assist Us in building a better Platform and improve its user experience and efficiency.
The Personal Information is used mainly to process and handle Reports submitted by You through the Platform, and to submit a Claim to the Concerned Parties in relation to your Report, as well as follow up with such parties. It is clarified that any information You provide in Your Report, including, the Incident’s details, will be provided in full to the Concerned Party and/or the Third Party- Organizations (defined below) as provided by You. We may also use your Personal Information in order to contact You when We believe it is necessary, or as part of handling and managing your Report, among others in order to obtain additional information on the Incident You will report and to send You updates and periodic emails in connection with the Platform. In addition, the Personal Information is used to personalize the User's experience, thus improving and enhancing such User's experience, learn more about Your preferences and suggest relevant content to You.
We may also use statistical information about Incidents reported by You and/or other Users in Our static charts and/or reports in a form of aggregate data which provide general statistics about violations reported through the Platform (on an anonymous basis and without including any information that may identify You) and may also publish such static charts and reports on the Platform and/or on 7or or 7amleh’s accounts on social media platforms. We may also share statistical information about Incidents with our donors as part of Our periodic and other status and update reports to such donors.
From time to time We may engage third party service providers to perform certain functions and provide services to Us, such as hosting and maintaining our servers and the Platform, database storage and management, e-mail management etc. We may share your Personal Information and some Non-Identifiable Information with these third parties to enable them to perform such services.
When You submit your email address on the Platform, You agree to receive emails from Us. However, if at any time You decide to unsubscribe from receiving future emails from Us, You may do so by unsubscribing from Our emails list as indicated in the email You will receive (if at the time You will unsubscribe from Our email list your Report may still be in progress, unsubscribing from the emails list will likely limit or restrict our ability to handle and pursue your Report).
- Sharing the Information with Third Parties
We do not sell your personal information to third parties. When You submit a Report through the Platform, 7amleh will transfer Your Personal Information to the Concerned Parties as necessary to handle Your Report and file a Claim with such Concerned Parties. A Claim may be submitted by Us to the Concerned Party whether directly or through third party organizations engaged in advocacy and/or promotion of human rights and/or digital rights (the “Third Party Organization”). We usually do not have a contract in place with the Concerned Parties and the Third Party Organizations that governs their collection and processing of Your Personal Information in order to handle our Claim, and by submitting a Report, You entrust Us with submitting a report or a Claim with such parties on Your behalf and agree to share your Personal Information with such parties. If You do not wish that we transfer your Personal Information to the Concerned Parties and/or to Third Party Organizations, do not submit a Report.
You agree that the Platform may collect and process Personal Information and Non-Identifiable Information in accordance with Sections 1, 2 and 3.
- Cookies & Local Storage
When You use our Platform, We may use industry-standard technologies such as “cookies” or pixels or “sessions” (or similar technologies), which store certain information on Your computer (“Local Storage”) and make the User's browsing more convenient and effortless.
“Cookies” are small files that are stored on the users' computer. A cookie is primarily used to store information about a user (or, more precisely, about the device on which the cookie is stored) during or after the user's visit to an online service. Different data can be stored within the cookies. For the purpose of analyzing the use of the Platform and for the purpose of user handling in the administration area of the Platform, the IP data of the connection owner is stored within the framework of cookies used by Us. In addition, we store Your preferred language, other personal page settings as well as the type of Your terminal device. The use of the Platform is basically possible without cookies and You may elect to prohibit the Local Storage option. Most browsers will allow the User to erase cookies from their computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if You block or erase cookies, Your online experience on the Platform may be limited and You may not be able to use some portions of the Features.
A “Session” is a small piece of data stored on your computer or mobile device by your web browser. We may use "Sessions" to identify the areas of the Platform that you have visited.
- Security & Retention of Data
7amleh takes great care in maintaining the security of Your information and in preventing unauthorized access to it through the use of appropriate technology and internal procedures, including by using a Standard Secure Socket Layer (SSL) certified encryption-based security of information on the Platform. We also take industry standard steps to ensure the website on which the Platform operates is safe. However, 7amleh does not guarantee that unauthorized access, viruses and other data security breaches will never occur.
- Third Party Sites
While using the Platform and the Features You may encounter links to third party sites and/or third party content (such as, information, applications and other services)(the “Third Party Services”). Please be advised that the Third Party Services are independent sites, and 7amleh assumes no responsibility or liability whatsoever for them with regard to privacy matters or any other legal matter, including, without limitation, the accuracy or completeness of their content. If You decide to use such Third Party Services, including, if You decide to click on a link (on our Platform) to any third party site, You do this at your own risk and responsibility. We encourage You to carefully read the privacy policies and terms and conditions of such third-party sites before using any of the features available on such sites. Such Third Party Services may use their own cookies or other methods to collect information about You.
- Social Media Plugins
- Cross Border Transfer
We may need to transfer Personal Information to countries where We (eg. our team and personnel) and/or the Concerned Parties and/or the Third Party Organizations operate. Such countries may be different from the country in which the data originated and where data protection laws may not be equivalent to, or offer the same protection as, those in your country. By using the Features and/or submitting a Report, You agree to any such transfers. Otherwise, please do not use the Features or submit a Report.
- Additional Information for Users in the EU
For the purposes of the EU General Data Protection Regulation (‘GDPR’), 7amleh is the data controller of the personal data We process about You. You can contact us via email@example.com.
We collect, store and process the personal data about you when you report an incident on our platform, which consists of your personal identification information and other information you provide us related to your enquiry. For more details please see Section 1.2. Your personal data is provided by you and we do not obtain your personal data from third parties.
The purpose for processing your personal identification information is to contact you in response to your report and to collect information on a specific incident you report; the legal basis is consent and our legitimate interest, namely documenting incidents in the field of our activities. The purpose for processing analytics of non-identifiable information is developing and improving the Platform and the Features and the legal basis is our legitimate interests in understanding how users use the Platform and making decisions on further development of the Platform.
If we transfer your personal data from the EU to other jurisdictions, we will do so by using appropriate safeguards particularly by Standard Contractual Clauses of the EU Commission (article 46(2) (c) GDPR). The personal data we collect is processed in Israel which is recognized by the European Commission in an adequacy decision as having adequate protection for personal data.
Chapter III of the GDPR gives data subjects the right to access your personal data, rectification of inaccurate data erasure of your personal data , object or restrict processing of your personal data. However, these rights do not apply with respect to aggregated analytics information that cannot be attributed to a specific user. In the circumstances where you may have provided your consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. You have the right to obtain a copy of your personal data. You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you but have the right to extend this period by two months. If we extend the response period, we will let you know within one month of your request. If you wish to exercise your rights listed above or have any concerns about our data collection practices, you can contact us by email at Report@7amleh.org.
Subject to applicable law, you have the right to lodge a complaint with your local supervisory authority. According to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.
- Children’s Privacy
7amleh does not knowingly collect or process personal data from or with respect to children under the age of 18, and you must be 18 years of age or older in order to submit a Report through the Platform. If you are a parent or legal guardian and believe that your child under the age of 18 has submitted his or her personal data or other data without your consent, permission, or authorization – please let us know immediately, and we will take steps to remove that information from our servers promptly. We cannot and will not take responsibility for misrepresentation by persons as to their age.
- Accessing, Deleting or Updating Your Personal Information
You may ask to access the personal information about You that is stored in our systems, or have us update, correct or delete such information. You may also be entitled to obtain from us the personal data you provided us (including data we obtained from other sources) in a structured, commonly used and machine-readable format, and have the right to transmit those data to another data controller. If you wish to exercise any of these rights, contact us at: Report@7amleh.org.
Should you have any inquiries, complaints or suggestions, you may contact us at Report@7amleh.org. We will do our best to resolve your issue in a timely manner.