last updated: May 2018
For the purposes of this policy, t*point defines the term “User” as an entity with which t*point has an established relationship, the term “Listing” as a data set describing an initiative or organisation added on t*point associated to a user account and the term “Visitor” as an individual that visits our front-end website (for example www.t-point.space).
Any information stored on t*point’s platform is treated as confidential. All information is stored securely and is accessed by authorized personnel only. t*point implements and maintains appropriate technical, security and organisational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.
2. Collection and use
The following sections cover the specifics of each of the two groups from which data is collected: website Visitors and Users.
2.2 Website Visitors
If you are a Visitor to our website only, and not a user of our platform, then this section is relevant for you.
By visiting this website, you consent to the collection and use of your Personal Data as described herein. If you do not agree with the terms set out herein, please do not visit this website. If required by applicable law, we will seek your explicit consent to process Personal Data collected on this website or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your Personal Data, the use of this website may not be possible.
Such Personal Data may comprise your IP address, first and last name, your postal and email address, your telephone number, your job title, data for social networks, your areas of interest, interest in t*point products, and certain information about the company you are working for (company name and address), as well as information as to the type of relationship that exists between t*point and yourself.
t*point gathers data about visits to the website, including numbers of Visitors and visits, Geo-location data, length of time spent on the site, pages clicked on or where Visitors have come.
2.2.1 Purpose of processing personal data
t*point uses the collected data to communicate with Visitors, to customize content for Visitors, to show suitable ads to Visitors, and to improve its website by analyzing how Visitors navigate its website.
2.2.2 Sharing personal data
t*point may also share such information with service vendors or contractors in order to provide a requested service or transaction or in order to analyze the Visitor behavior on its website.
2.2.3 Cookies/Google Analytics
188.8.131.52 Session Cookie
Session cookies are temporary. They allow website operators to link the actions of a visitor during a browser session. A browser session starts when a visitor opens a browser window and finishes when they close it. Once you close the browser, all session cookies are deleted.
Examples of how we use session cookies:
- To improve the usability of our site
- To route the visitor to the most available web server
- Allowing visitors to sign in to the website as a registered user
184.108.40.206 Google Analytics
You may also prevent the collection of any data (including your IP address) generated by the cookie and related to your use of the website as well as the processing of this data by Google by using the link below
to download and install the available browser plugin.
220.127.116.11 Specific cookies
|COOKIE NAME||COOKIE USE|
|PHPSESSID||The cookie identifies the browser session and also enables the user to sign in to t*point as a registered user.|
|_ga||Google Analytics long term cookie, with a validity of 2 years. Gathering data about visits to the website, including numbers of visitors and visits, length of time spent on the site, pages clicked on or where visitors have come from.|
|_gid||Google Analytics short term cookie, with a validity of 24 hours. Gathering data about visits to the website, including numbers of visitors and visits, length of time spent on the site, pages clicked on or where visitors have come from.|
|_gat_gtag_[ID of website]||Identification code of website for tracking visits|
|euCookie||Tracks if a user has seen and accepted the cookie banner|
|surbma-gdpa||Tracks if a user has consented to be tracked via Google Analytics|
2.2.4 Links to other sites
In order to provide services to its Users, t*point collects certain types of data from them. This section will describe how this data is being collected and used by t*point. Data entered or transferred into t*point by Users such as texts, questions, contacts, media files, etc., remains the property of the User and may not be shared with a third party by t*point without express consent from the User.
2.3.2 Collection of User data
During a User’s registration and later on t*point’s online directory of trans* initiatives, they provide information such as a username, email and other relevant data. This information is used by t*point to identify the User and provide them with support and services.
t*point Users can at any time access and edit, update or delete their contact details by logging in with their username and password to t*point’s platform. t*point will not retain User data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.
2.3.3 Collection of listing data
Listings (initiatives and places) are data sets that describe initiatives or organisations offering help, information or culture for and about trans* and gender variant people.
Listings are created and managed by Users. All listings are public and available to any visitor of t*point, be it businesses, organizations, and individuals. It is the User’s responsibility to ensure that the collection and publication of a listing’s data is done in accordance with applicable law, a high moral standard and the privacy of any person connected to the listing. t*point will not process Personal Data for other purposes or by other means than instructed by its Users.
Listing data includes data from organisations, individuals or groups uploaded, transferred or manually entered by a t*point User into the listing for the purpose of making this information available to any t*point visitor.
This data may include, contact information such as name, address, telephone or mobile number, email address.
Required data points for any listing are:
Type of initiative
field of activity
Furthermore, t*point offers optional fields:
Contact details (phone, email, website, twitter, facebook, video, special offers)
Projects the organisation or initiative is interested in
Pictures / Logo
All of the information shared in a listing is always public.
The purpose of collecting Personal Data as part of a listing will vary depending on the listing, as set up by t*point’s Users. As t*point provides directory services to a wide group of customers and businesses, the purpose may vary greatly. For Users in the EEA, or for Users providing listings of initiatives or organisation in the EEA, the User will be the “controller”, as defined in the Directive and the GDPR. The purpose will consequently be defined by t*point’s User.
2.3.4 Data Processing
For Users with accounts, all processing of Personal Data is performed in accordance with privacy rights and regulations following the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the Directive), and the implementations of the Directive in local legislation. From May 25th, 2018, the Directive and local legislation based on the Directive will be replaced by the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR), and t*point’s processing will take place in accordance with the GDPR.
t*point processes Personal Data both as a Processor and as a Controller, as defined in the Directive and the GDPR:
The t*point entity which you as a User entered an agreement with when using t*point’s platform, will be the Controller for User data, as outlined above in “Collection of User data” section. For Respondent data, as outlined in the “Collection of Respondent data” section, the User will be the Controller in accordance with Directive and GDPR, and t*point will be the Processor. t*point adheres to the Directive of 1995 and the GDPR from May 25th, 2018. Consequently, t*point processes all data provided by its Users with accounts in its European Data Region, in the European Economic Area (EEA) only. All data collected by t*point Users in listings will be stored exclusively in secure hosting facilities provided by Hetzner. All hosting is performed in accordance with the highest security regulations. All transfers of data internally in the EEA is done in accordance with this data processing agreement.
3. Retention and deletion
t*point will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. For listing data, t*point’s Users have control of the purpose for collecting data, and the duration for which the Personal Data may be kept. For listing data, Users with an active account will therefore have the responsibility to delete data when required. When a user’s account is terminated or expired, all Listing Data collected through the platform and associated with the user’s account will be deleted, as required by applicable law. Listing entries can be assigned to another user prior to account deletion in order to keep the listing data available on the platform.
4. Acceptance of these Conditions
5. Our Legal Obligation to Disclose Personal Information
We will reveal a user’s personal information without his/her prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to t*point or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose personal information when we have good reason to believe that this is legally required.
7. For Further Information
If you have any further questions regarding the data t*point collects, or how we use it, then please feel free to contact us by email at: email@example.com.