I. Data Collection on Our Website
Who is responsible for collecting data on this website?
Data collected on this website is processed by the website operator. The operator’s contact details can be found in the website’s Legal Notice.
How Do We Collect Your Data?
First, your data is collected when you communicate it to us. This could, for example, be data you enter on a contact form.
Other data is automatically collected by our IT systems when you visit our website. This data is primarily technical data (for example, the browser and operating system you are using, or when you visited our website). This data is collected automatically as soon as you access our website.
What Do We Use Your Data For?
Some data is collected to ensure the proper functioning of the website. Other data can be used to analyze your user behavior.
What Rights Do You Have Regarding Your Data?
You have the right to request information about your stored data, where it came from, who received it, and the purpose for which it was collected, at any time and at no expense. You also have the right to request the rectification, blocking or erasure of this data. You can contact us at any time at the address given in the Legal Notice if you have any further questions on the subject of data protection. You also have the right to lodge a complaint with the responsible supervisory authority.
Analytics and Third-Party Tools
Please note that data transmission over the internet (e.g. communication by email) can be subject to security vulnerabilities. It is not possible to fully secure your data against third-party access.
Information About the Controller
The responsible party for data processing on this website is:
Via dei Portici 76
The controller is the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, email addresses, etc.).
Withdrawing Your Consent to Data Processing
Many data processing operations are only possible with your express consent. You may withdraw your consent at any time. An informal email making this request is sufficient. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Your Right to Lodge a Complaint With a Supervisory Authority
You have a right to lodge a complaint with the competent supervisory authority in the event of a breach of data protection laws.
Competent supervisory authority for Bolzano, Italy:
Garante per la protezione dei dati personali
Piazza di Monte Citorio n. 121
phone: (+39) 06.696771
fax: (+39) 06.69677.3785,
email: [email protected]
Right to Data Portability
You have the right to have data that we process by automated means on the basis of your consent, or related to the performance of a contract, transferred to you or to third parties. If you request the direct transfer of your data to another controller, we will do so to the extent such a transfer is technically feasible.
This website uses SSL or TLS encryption for security reasons and to protect the transmission of confidential information, such as orders or requests that you send to us as the site operator. You can recognize an encrypted connection in your browser’s address bar when it changes from “http://” to “https://” and the lock icon is displayed in your browser’s address bar.
If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
Access, Blocking, Erasure
Within the framework of applicable law, you have the right to obtain information free of charge at any time about your stored personal data, the origin of this data, the recipients of this data and the purpose for which this data is processed and, if applicable, the right to rectify, block or erase this data. You can contact us at any time at the address given in the Legal Notice if you have any further questions on the subject of data protection or how we handle personal data.
Objection to Promotional Emails
Third-party use of contact data published within the scope of legal notice regulations for sending unsolicited advertising and informational materials is hereby expressly forbidden. The operators of this website expressly reserve the right to take legal action in the event of unsolicited advertising information, such as spam emails.
Legally Required Data Protection Officer
We have appointed a data protection officer for our company:
Bernhard Binner, Data Protection Officer (TÜV)
Via dei Portici 76
a) Data Collection and Processing for Purely Information-Related Visits to Our Website
If you use our website for purely informational purposes and do not send us any other information (e.g., by e-mail or via the contact form), we only collect the data that your browser transmits to our server.
SERVER LOG FILES
When you access our website, it is necessary for technical reasons to collect, process, and use various data to ensure error-free communication between your Internet browser and our web server. During the process, the following data are automatically collected and logged in a log file up until their automated deletion:
- IP address
- date and time of the access
- time zone difference to GMT
- content of the web page
- access status (HTTP status)
- volume of data transferred
- website from which you have reached our website
- web browser
- operating system
- language and version of the browser.
We generally only collect these data in anonymized form. This is done for the purpose of intra-system technical processing (establishing a connection), system security, technical administration of the system and network infrastructure, as well as for optimizing the website and for statistical purposes. We reserve the right, however, to subsequently check the log file if there are specific grounds for suspecting unlawful use.
Only in the case of illegal attacks will we try to find out which person is behind an IP address. Otherwise, this information remains hidden from us, and we do not attempt to obtain the data of the owner of an IP address.
The processing of these data is performed on the basis of Article 6(1)(f) GDPR: It ensures the operability and security of the website and serves to improve the stability and functionality and also the technically error-free presentation and optimization of our website. Ensuring that our website is presented as reliably as possible and that it can be accessed without disruption is essential for the performance of the tasks pursued with the website.
Since collecting data for the provision of the web pages and storing data in log files are absolutely necessary for the operation of our web pages, there is no opt-out option here. You can only prevent this data processing by not using our services.
In some cases, our webpages use “cookies”. Cookies do not cause any damage to your computer and do not contain any viruses. The purpose of cookies is to make our website more user-friendly, functional and secure. Cookies are small text files that are stored on your computer and saved by your browser. You can access the cookie settings anytime and change your preferences.
Most of the cookies we use are so-called session cookies. They are automatically deleted at the end of your visit. Other cookies remain stored on your device until you delete them. These cookies make it possible to recognize your browser the next time you visit our website.
You can set your browser so that you are informed about the placement of cookies and only allow cookies in individual cases, exclude the acceptance of cookies generally, or just for certain cases, and activate the automatic deletion of cookies when closing your browser. Disabling cookies may limit your ability to use some of the functions of this website.
b) Other Functions and Offers on Our Website
In addition to informational use of our website, we offer various functions and services that you can use if you are interested, such as our abortion test and pregnancy test, a contact form, a forum and a comment function. This usually requires the processing of further personal data.
ABORTION TEST AND PREGNANCY TEST
For the online abortion test and the online pregnancy test, you may voluntarily provide us with personal data, e.g., first and last name, health data, data on your sex life, and data on your current mental health.
The collection and storage of these data only takes place if you have given us your express consent to do so in accordance with Article 6(1)(a), Article 9(2)(a) GDPR. You can revoke your consent at any time by notifying us via e-mail. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.
We store this data until the purpose for which the data was collected has been fulfilled.
If you send an inquiry using the contact form, your details from the contact form, including the contact details you provided there, will be stored for the purpose of processing the inquiry and in the event of any follow-up questions. We will not share this data without your consent.
The data entered in the contact form is therefore processed exclusively on the basis of your consent (Art. 6 (1)(a) GDPR). You may withdraw your consent at any time. An informal email making this request is sufficient. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
We will retain the data you provide on the contact form until such time as you request its erasure, withdraw your consent for its storage, or the purpose for its storage is no longer applicable (e.g. after completely processing your inquiry). Any mandatory statutory provisions, especially those regarding mandatory data retention periods, remain unaffected.
Registration on Our Website
You may register on our website in order to use additional features on the site. We only use data you have entered in connection with the use of the respective service or offering for which you have registered. Mandatory information requested during registration must be provided in full. Otherwise, we will reject the registration.
We use the email address provided during registration to inform you of significant changes, for example related to the scope of resources offered or modifications that are required for technical reasons.
Data provided during the registration process is processed on the basis of your consent (Art. 6(1)(a) GDPR). You may withdraw your consent at any time. An informal email making this request is sufficient. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Data collected during registration will be stored by us for as long as you are registered on our website and will be erased thereafter. This has no effect on statutory retention periods.
Comment Function on Our Website
For purposes of operating the comment function on our website, information on the time you write the comment, your email address and, if you do not post anonymously, the username you have chosen will be stored, in addition to your comment.
Storing IP Addresses
Our comment function stores the IP addresses of those users who submit comments. Since we do not check comments on our site before posting them, we need this data in order to be able to take action against the author in the event of legal violations, such as insults or propaganda.
Subscribing to Comments
As a website user, you can subscribe to comments following your registration. You will receive a confirmation email to verify that you are the owner of the email address provided. You can unsubscribe from this function at any time via a link provided in the informational email. Data entered when subscribing to comments will be erased in such cases; however, we will retain this data if you sent it to us for other purposes and elsewhere on the website (e.g. newsletter subscription).
Retention Period for Comments
Comments and the associated data (e.g. IP address) are stored and remain on our website until content to which the comment relates has been completely deleted or the comments have to be deleted for legal reasons (e.g. offensive comments).
Comments are retained on the basis of your consent (Art. 6 (1)(a) GDPR). You may withdraw your consent at any time. An informal email making this request is sufficient. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
If you have given your consent, this website uses Google Analytics 4, a web analytics service provided by Google LLC. The responsible entity for users in the EU/EEA and Switzerland is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google").
Scope of Processing
In Google Analytics 4, the anonymization of IP addresses is activated by default. For the purposes of IP anonymization, your IP address will be shortened by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be transferred to a Google server in the United States and shortened there. According to Google, the IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.
During your website visit, your user behavior is recorded in the form of "events". Events can be:
- page views
- first visit to the website
- start of the session
- your "click path", interaction with the website
- scrolls (whenever a user scrolls to the bottom of the page (90%))
- clicks on external links
- internal search queries
- interaction with videos
- file downloads
- seen/clicked ads
- language setting.
The following are also recorded:
- your approximate location (region)
- your IP address (in shortened form)
- technical information about your browser and the terminal devices you use (e.g., language setting, screen resolution)
- your Internet service provider
- referrer URL (via which website/advertising medium you came to this website).
Purposes of the Processing
On behalf of the operator of this website, Google will use this information for the purpose of evaluating your anonymized use of the website and compiling reports on website activity. The reports provided by Google Analytics are used to analyze the performance of our website.
Recipients of the data are/could be:
- Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (as processor according to Article 28 GDPR)
- Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
- Alphabet Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
It cannot be ruled out that US authorities may access the data stored by Google.
In addition, your approximate location (region) will be transmitted to 1000plus-Profemina gGmbH for the purpose of providing regional and completely anonymous information about assistance to women seeking advice in the context of appeals for donations.
Transfer to Third Countries
Insofar as data are processed outside the EU/EEA, and there is no level of data protection corresponding to the European standard, we have concluded EU standard contractual clauses with the service provider to establish an appropriate level of data protection. The parent company of Google Ireland, Google LLC, is based in California, USA. A transfer of data to the USA and access by US authorities to the data stored by Google cannot be ruled out. The USA is currently considered a third country from a data protection perspective. You do not have the same rights there as within the EU/EEA. You may not be entitled to any legal remedies against access by the authorities.
The data sent by us and linked with cookies are automatically deleted after 14 months. Data which has been stored for the required period of time is automatically deleted once a month.
The legal basis for this data processing is your consent pursuant to Article 6(1)(a) GDPR.
You can revoke your consent at any time with effect for the future by calling up the cookie settings and changing your selection there. The legality of the processing carried out on the basis of the consent until the revocation remains unaffected.
You can also prevent the storage of cookies from the outset by configuring your browser software accordingly. However, if you configure your browser to reject all cookies, this may restrict functionalities on this and other websites. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) by Google and the processing of this data by Google by
a) not giving your consent to the setting of the cookie; or
b) by downloading and installing the browser add-on to disable Google Analytics HERE.
We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on our websites. This service is provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”).
reCAPTCHA is used to check whether the data entered on our website (such as on a contact form) has been entered by a human or by an automated program. To do this, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis starts automatically as soon as the visitor accesses the website. To perform this analysis, reCAPTCHA evaluates various information (e.g. IP address, how long the visitor has been on the website, or mouse movements made by the user). The data collected during the analysis is forwarded to Google.
The reCAPTCHA analyses run completely in the background. Visitors to the website are not informed that an analysis is taking place.
If you have consented to the use of Google reCAPTCHA, the legal basis for data processing is this consent. According to Article 6(1)(a) GDPR (Consent), this consent constitutes the legal basis for the processing of personal data as it may occur during the collection by Google reCAPTCHA.
We also have a legitimate interest in using Google reCAPTCHA to optimize our online service and to make it more secure. The corresponding legal basis for this is Article 6(1)(f) GDPR (Legitimate Interests). Nevertheless, we only use Google reCAPTCHA if you have given your consent.
You can revoke your consent at any time with effect for the future by going to the cookie settings and changing your selection there. The legality of the processing carried out on the basis of the consent until the revocation remains unaffected.
We would like to point out that according to the opinion of the European Court of Justice, there is currently no adequate level of protection for data transfer to the USA. The data processing is essentially carried out by Google reCAPTCHA. This may result in data not being processed and stored anonymously. Furthermore, US government authorities may be able to access individual data. It is also possible that this data may be linked to data from other Google services where you have a user account.
Our website uses plug-ins from YouTube, which is operated by Google. This YouTube website is operated by YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA.
A connection to the YouTube servers is established if you visit one of our pages equipped with a YouTube plug-in. The YouTube server is then informed about which of our pages you have visited.
If you are logged into your YouTube account, you allow YouTube to associate your surfing habits directly with your personal profile. You can prevent this by logging out of your YouTube account.
YouTube is used with the goal of making our website more attractive. This represents a legitimate interest within the meaning of Art. 6(1)(f) GDPR.
When using the donation form at https://www.profemina.org/en-us/support-profemina , the data entered is transmitted to the payment provider Payrexx.
Payrexx is a service provided by Payrexx AG, Burgstrasse 20, 3600 Thun, Switzerland. We have entered into a data processing agreement with Payrexx to ensure adequate protection of personal data transmitted to Payrexx for processing.
This data is not stored on the donation website itself. The data is stored and managed by Payrexx. The payment processing runs via a protected SSL connection and is managed by Payrexx. For payment processing, Payrexx collaborates with several reputable payment providers for payment processing and has entered into corresponding data processing agreements with these providers. After submitting the form and confirming payment, you will receive a receipt and be notified by email.
With the consent of the donors, we use the email address provided to stay in contact. This consent can be revoked at any time without providing reasons.
The legal basis for the processing of the data is Article 6(1)(d) GDPR, insofar as it concerns the processing of the donation. If the donor has given consent, the legal basis is Article 6(1)(a) GDPR. If a donation receipt is issued, we are obliged to store the corresponding data in accordance with the applicable tax laws. In this case, the legal basis for the storage is Article 6(1)(c) GDPR.
Further information on data protection at Payrexx can be found at https://payrexx.com/en/gtc.
II. Data Protection Information for Our Counseling Services
1. Information on joint controller functions according to Art. 26 (2) Sentence 2 of the General Data Protection Regulation (GDPR)
Profemina International Impresa Sociale S.r.l. (Via dei Portici 76, 39100 Bolzano, Italy), Pro Femina e.V. (Bergstr. 114, 69221 Heidelberg, Deutschland) and Ponto do Apoio à Vida (Calçada da Tapada, 143; 1300 - 541 Lisboa, Portugal) 114, 69221 Heidelberg, Germany) and Ponto do Apoio à Vida (Calçada da Tapada, 143; 1300 - 541 Lisboa, Portugal) act as joint controllers for the processing of personal data of women seeking counseling according to Art. 26 GDPR and have concluded an agreement to this effect.
(1) Competences and responsibilities with regard to the processing activities
In their internal relationship, the competences and responsibilities with regard to the processing operations are divided between the joint controllers as follows:
a) Profemina International is responsible for the processing of personal data relating to the use of digital counseling services (digital counseling).
b) If individual counseling takes place by direct (e.g. telephone) contact following digital counseling, Profemina International and Pro Femina e. V. shall be responsible for any counseling services provided in the German language. Ponto do Apoio à Vida and Profemina International are responsible for counseling provided in Portuguese.
c) Profemina International, in turn, is responsible for other processing operations, i.e., in particular for the optimization of counseling services.
(2) Competences and responsibilities with regard to the provision of information to data subjects
a) Profemina International and Pro Femina e. V. ensure the fulfillment of the obligations to provide information as set out in Art. 13 and 14 of the GDPR in the German language.
b) Ponto do Apoio à Vida is responsible for the fulfillment of these obligations to provide information in Portuguese.
(3) Competences and responsibilities with regard to the exercise the rights of data subjects
a) Profemina International and Pro Femina e. V. are responsible for processing data subject requests and exercising data subjects’ rights as set out in Art. 15-21 GDPR in the context of German-language counseling services.
b) Ponto do Apoio à Vida and Profemina International are responsible for counseling services in Portuguese.
c) Profemina International, in turn, is responsible for processing data subject requests regarding counseling services in other languages (e.g., English, Italian, French, Spanish).
c) Data subjects may assert their rights under the GDPR against any of the controllers, regardless of the language in which the counseling service is provided. The controllers shall promptly notify each other about any data subject requests and provide each other with all information necessary for the implementation of data subject rights.
Bernhard Binner, Data Protection Officer (TÜV)
Via dei Portici 76
The main purpose of the processing of data is for the purpose of counseling pregnant women in need or women who fear they may be pregnant.
We offer counseling services for following circumstances: Counseling and assistance for women who are in emotional or material need due to their current or feared pregnancy. This consultation and support may also be provided via email, phone or internet-based exchange platforms.
For all purposes, personal data is processed based on your consent under Article 6(1)(a) and Article 9(2)(a) of the EU General Data Protection Regulation in relation to your health data.
Personal data is never disclosed to unauthorized persons.
Data is only published with the explicit consent of the woman who received counseling.
Data is not transmitted to countries outside of the EU or EEA (third countries).
The personal data of women who received counseling will be erased when the purpose for which the data was collected no longer applies, unless erasure is prevented by legal or contractual storage obligations. If the data cannot be erased, the data will be made unrecognizable for further processing and restricted.
The storage period and/or erasure deadline of the data of women who received counseling are determined by the data type.
You have the following rights in relation to your personal data:
(1) Right of access: You may obtain confirmation from us as to whether or not personal data concerning you is stored by us. Such confirmation may be obtained free of charge.
This right of access is limited or not granted if and to the extent that such access may disclose confidential information or information subject to professional secrecy.
(2) Right to rectification: If your personal data, stored by us, is inaccurate or incomplete, you have the right to obtain the rectification of this data at any time.
(3) Right to erasure: You have the right to obtain the erasure of your personal data if and to the extent that your data is no longer needed for the purposes for which it was collected or, where processing is based on your consent, if you withdraw your consent. In this case, your personal data may no longer be processed and must be removed from our IT systems and databases.
(4) You do not have a right to erasure if:
- your data may not be erased or must be processed for compliance with a legal obligation;
- processing your data is necessary for the exercise, establishment or defense of legal claims.
(5) Right to restriction of processing: You have the right to obtain the restriction of the processing of your personal data.
(6) Right to data portability: You have the right to receive the personal data you provided to us in a structured, commonly used and machine-legible format, and have the right to have this data transmitted to another controller. This right is only granted if:
- you provided your data to us on the basis of your consent or a contract between you and Pro Femina is concluded;
- processing is carried out by automated means.
(7) Right to object to processing: If your data is processed on the basis of a balancing of interests, you may object to this processing at any time.
You may exercise any of the data subject rights described above against us by submitting your request by email or mail to the data protection officer specified above.
(8) Right to Lodge a Complaint with a Data Protection Supervisory Authority
You have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data infringes on data protection law. Our competent data protection supervisory authority is:
Supervisory Authority für Bolzano, Italy:
Garante per la protezione dei dati personali
Piazza di Monte Citorio n. 121
Phone: (+39) 06.696771
Fax: (+39) 06.69677.3785,
E-Mail: [email protected]
Supervisory Authority for Rhein-Neckar county, Germany:
State Comissioner for Data Protection in Baden-Württemberg
P.O. Box 10 29 32, 70025 Stuttgart
Königstr. 10a, 70173 Stuttgart
Phone: (+49) 0711 615541-0
Fax: (+49) 0711 615541-15
E-Mail: [email protected]
Supervisory Authority for the metropolitan area of Lisbon, Portugal:
CNPD - Comissão Nacional de Proteção de Dados
Av. D. Carlos I, 134, 1º
Phone: (+351) 213 928 400
Fax (+351) 213 976 832
E-Mail: [email protected]
We use the messaging service WhatsApp from WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, to offer and provide counseling to people who contact us in German or Portuguese. For this purpose, we usually use the “WhatsApp Business API" version. Sometimes we also use WhatsApp's standard version.
Communication takes place via end-to-end encryption (peer-to-peer), which prevents WhatsApp or other third parties from gaining access to the communicated content.
Your data will only ever be used to respond to your request via WhatsApp. We will not disclose it to third parties.
WhatsApp does, however, obtain access to metadata that arises in the course of the communication process (e.g., sender, recipient, and time).
The legal basis for communication via WhatsApp is your consent if you have granted such consent (Art. 6 para. 1 letter a DSGVO). This consent can be revoked at any time, affecting any future dealings.
If communication via WhatsApp is necessary for the fulfillment of a contract or for the implementation of pre-contractual measures that take place at the request of the data subject, the legal basis is Article VI paragraph 1 letter b DSGVO. If the legal requirements are met, WhatsApp may be used based on our legitimate interest in communicating as quickly and effectively as possible with women seeking advice, interested parties, and other business and contractual partners (Article VI paragraph 1 letter f DSGVO).
The communication content exchanged on WhatsApp will be stored by us until the purpose for storing the data no longer applies (e.g., after the processing of your inquiry has been completed), until you revoke your consent, or until you request us to delete it. Mandatory legal provisions, in particular legal retention periods, remain unaffected.
Furthermore, a right to deletion does not exist for such information required for the assertion, exercise, or defense of legal claims.
Updated on July 15, 2022