About this document

This document is the privacy policy of the Meeting of Communities of Free Technologies, having the following structure: it is organized to begin explaining the nature of the organization of the “Encontros de Comunidades de Tecnologias Livres” and its vision and stance on privacy, then following for the explanation of all processing of personal data from the most generic details to the most specific:

• Organization of the “Encontros de Comunidades de Tecnologias Livres”
  • Members of the organization of “Encontros de Comunidades de Tecnologias Livres”
  • Posture of the organization regarding privacy protection and setting of expectations
• Processing of personally identifiable data
  • Who processes (and has access) your personal data?
    • Entities operating infrastructure used by the organization, where processing of personal data
    • Processing of personally identifiable data by organization members
      • while visiting the website of the “Encontros de Comunidades de Tecnologias Livres”
    • Processing by members of the organization at other moments
    • Purposes of personal data processing by ANSOL
    • Processing by other infrastructure suppliers of the “Encontros de Comunidades de Tecnologias Livres”
      • GitLab while hosting the web site
• Technical information about the website
  • Vanilla Framework
  • Hugo
  • the website of the “Encontros de Comunidades de Tecnologias Livres”
• Destruction of personal data after the retention period
• Rights as a data subject
  • How you can exercise your rights as data subject
• Identification of personal data collected, legal grounds, and other information
  • Prior note
  • Detailed and specific information of the specific processing of personal data

The privacy policy was created to be applicable from the first of January 2025, having, however been updated on:

1. 20th of January 2025.

The organization of “Encontros de Comunidades de Tecnologias Livres”

The organization of the “Encontros de Comunidades de Tecnologias Livres” (ECTL) is in this document referred to as “the organization”, or simply “organization”.

The organization consists of volunteer individuals, without any kind of contractual or legal relationship between them.

The team is not a legally constituted entity, only an informal group of individuals, some who are themselves members of other communities, and others without any other membership.

Not being an legally constituted entity ECTL has no legal obligation to have a privacy policy, yet the organization decided to have one by being aligned with the values it advocates.

The organization establishes and communicates this privacy policy as follows to ensure that all visitors to the ECTL website and event attendees are informed of how we want to protect your privacy. If you have criticisms, or suggestions, please contact us on a friendly manner. We are willing to read your criticism or suggestion(s) and consider improving the document and our practices.

If you have suggestions, in addition to contact us by the contact form, you can also propose changes to the document by submitting them in the form of a merge request to the repository of our site and we promise to consider your proposal.

Posture of the organization regarding privacy protection and setting of expectations

The events of the “Encontros de Comunidades de Tecnologias Livres”, are public events, are open to all who agree to behave, according to the Code of Conduct of the “Encontros de Comunidades de Tecnologias Livres”, and when applicable also with those of the participating communities. A certain degree of publicity about the attendeed participation should be expected by all of them. However, the organization makes a considerable effort to presever the privavy of attendees in their interest and those of data subjects, and legitime interests of the organization has defined and detailed in this document. The organization will also strive to create a safe environment, and to protect the privacy of participants.

The organization avoids any processing and personal data where possible, even avoiding the processing of data described in this document, except to pursuit the the mission of the “Encontros de Comunidades de Tecnologias Livres”, such as to announce its activity and preserve the historical memory of its activity. There is no intention of obtaining financial gains with data processing, only facilitating and promoting the events and activities, to the strict extent that such data is necessary for such purposes.

The organization limits as much as possible access to the processed data and seeks to provide them with the best of their capabilities and is willing to provide additional clarification and improve their privacy protection practices.

The organization does not process individualized statistical data on participants in events and activities. But we can make statistics relating to all participants in each event and activity and to all participants in all events and activities, to better understand public participation.

The organization does not create, nor does it maintain profiles on participants in the events. There are profiles that can be generated, maintained and even made public about organizers, contributors, speakers, who run workshops, organize events and activity on behalf of the “Encontros de Comunidades de Tecnologias Livres”, or in some way in their context.

Processing of personally identifiable data

Who processes (and has access) your personal data?

The processed data, fundamentals for its processing, the purpose(s) of the processing(s) of each data, retention period, the obligation to provide the data for the purpose/fins described(s), advertising, and any additional information and notes, are in the section “Identification of the personal data collected, legal grounds, and other information”, of this document.

• members of the organization who are simultaneously administrators of the ETCL, who are involved in the administration of their necessary technical means and/or in the organization of the “Encontros de Comunidades de Tecnologias Livres”,
• by representatives of entities operating infrastructure used by the organization.

Entities operating infrastructure used by the organization, where processing of personal data

Data transference by the organization, and even by transference that occurs while using public infrastructure of the organization by the data subject.

• ANSOL - Associação Nacional para o Software Livre (NIPC: 513661174).
• GitLab B.V. e GitLab, Inc.

Processing of personally identifiable data by organization members

Some members of the organization, for purposes related to the realization of the events and activities of the “Encontros de Comunidades de Tecnologias Livres”, have access to personal data processed by the organization, and may conduct some data processing for the necessary purposes and described below. The organization seeks to limit its elements with access, to a strict minimum and necessary for the purpose in question and informs members of the need to protect the data and privacy of the subjects, and only use them for the purposes identified in this document (a time when the data were collected if the legal basis for the processing is consent).

While visiting the website of the “Encontros de Comunidades de Tecnologias Livres”

By the simple act of visiting the “Encontros de Comunidades de Tecnologias Livres” web site, the personal data proccessing that occurs is made by the entity that hosts the web site, and further information regaring that data processing is provided on the topic: “Processing by other infrastructure suppliers of the “Encontros de Comunidades de Tecnologias Livres””, no further personal data processing occurs by the organization.

If while visiting the web site of “Encontros de Comunidades de Tecnologias Livres”, you fill any form included withing the web site, the data that you submit will be processed.

Processing by members of the organization at other moments

In general, the data entered in the forms of the website of the “Encontros de Comunidades de Tecnologias Livres”, can be processed for various purposes, as described below, always and only if necessary for the following purposes:

1. validate entries in events,
2. logistics of events (e.g. for the preparation of space for the proper amount of participants, ensuring the safety and comfort of all),
3. preparation to offer gifts and custom offers, or not customized if there is need of organization to plan capacity,
4. organization of social events that require capacity planning,
5. feeding preparation,
6. promote the event, including in future editions,
7. ensure a public memory of the event,
8. statistical purposes on participation in the event.

The organization doesn’t track individuals about any specific data subject statistics only general aggregated statistics about the entire group of atteendees.

As mentioned above, the information specifies about each data is described in the section “Identification of the personal data collected, legal grounds, and other information”.

Purposes of personal data processing by ANSOL

As an entity providing technical infrastructure to the organization of the Meeting of Communities of Free Technologies, the organization transfers data to ANSOL processes data to ensure technical means for its collection, storage and other forms of processing carried out by members of the organization. Do not do so for any other purposes that ensure the operationality, security of the technical means used by the organization.

ANSOL offers the ECTL team, a Nextcloud instance used for all forms in which all types of data submitted by users are collected, namely:

1. The contact form
2. The exercise form of personal data rights
3. The forms listed on the registration listing page

Processing by other infrastructure suppliers of the “Encontros de Comunidades de Tecnologias Livres”

GitLab while hosting the web site

The “Encontros de Comunidades de Tecnologias Livres” website is hosted in the infrastructure of GitLab B.V. using the GitLabs Pages service, and GitLab B.V. carries out some personal data processing. To learn more how GitLab does processing, what data, and for which purposes, then read their Privacy Policy, but we note the following uses, which we think are relevant to visitors of pages lodged with GitLabs Pages:

• Understand how your services are used and how they can improve them,
• To improve service safety,
• To detect abuse,
• To exercise your terms of use,
• To comply with legal obligations,
• To protect the rights of visitors and to ensure protection and ownership of GitLab or third parties,
• For the purposes for which the visitor gives informed consent.

In addition, we also recommend visiting and reading the website page of GitLab B.V. regarding compliance with the General Privacy Protection Regulation and also the Privacy team page.

GitLab B.V. is a company in the Netherlands.

Technical information about the website

The following technical information additional to the fact that you are staying in the GitLab Pages service and using Nextcloud Forms running in an instance of ANSOL Nextcloud may be relevant to technically understanding the website of the Communities’ Free Technologies Meetings operates, including how your data is processed:

Vanilla Framework

The “Encontros de Comunidades de Tecnologias Livres” website uses a version hosted by Canonical of the Vanilla Framework, a CSS framework, used on the website to define the visual appearance of web pages.

You can view the source code of the Vanilla Framework your [GitHub repository(https://github.com/canonical/vanilla-framework)], and you can consult Canonical’s privacy policy.

Hugo

The website of the Encontros de Comunidades de Tecnologias Livres, are a set of web pages generated and maintained with the generator of static pages, Hugo.

You can see Hugo’s source code in your repository.

The website of the “Encontros de Comunidades de Tecnologias Livres”

The instance of Hugo that runs in the GitLab Pages service in which the website of the “Encontros de Comunidades de Tecnologias Livres”, is hosted resorts to the image of the official “registry” of GitLab’s online accommodation service to create a container that runs the website.

The source code of the “Encontros de Comunidades de Tecnologias Livres” website is available for consultation and free study at the git repository.

Destruction of personal data after the retention period

Members of the organization will destroy the data stored in Nextcloud instance and any local copies they have, after the maximum data retention period of 6 months.

Rights as a data subject

The rights of persons data subjects are defined in the legislation.

For more information about your rights, visit the (Portuguese) National Data Protection Commission website.

How you can exercise your rights as data subject

To exercise your rights as a data subject, use the form we created specifically for this purpose.

Identification of personal data collected, legal grounds, and other information

Prior Note

Some of the personal data does not have to be true, and the importance of its truthfulness may vary with the purpose intended, and with the relationship between the subject, the purpose and the organization. The organization tries to clarify in each case of use the necessity, and context to allow the data subject to make a free and informed choice about the processing of their data.

Detailed and specific information of the specific processing of personal data

Personal data	Legal foundation and purpose	Retention Period	Is this data mandatory	Will the data be made public	Extra Notes
- name - nickname - user provided unique id code	- legitimate interest of the organization in informing participants about members of the organization in order to ensure direct contact points of participants for safety purposes - the organization’s legitimate interest in informing the general public about the promoters and managers of activities to motivate public participation in events - legitimate interest of the organization in identifying the registration of the data subject for activities in which this type of identification is relevant/necessary	- Indefinitely for those who direct activities and members of the organization, - legitimate interest of the organization in preserving the historical memory of events and activities, - 6 months for all others	Mandatory when field on the form is mandatory	- published for members of the organization, and for those who direct activities (presentations, workshops, social events, etc…) - private for all others	- Free choice of the data subject to the use either: name, or public nickname in the case of a member of the organization, or direct activity, but for all other data can be either true, or false, provided that during the event it is intended, the identification is probably unique and allows to validate/identify the registration, - must allow participants to identify the data subject before the organization for safety purposes like any suspected violation of the code of conduct, - if the data provided by the data subject doesn’t allow the organization or the entity maniging the event space, to return lost goods, this is exclusively the responsibility of the data subject - the data can be corrected
Biographic Data from: - speakers - who direct workshops, events and activities	- the organization’s legitimate interest in informing the public about the promoters and managers of activities to motivate public participation in events - consent in the case of contributors to the organization other than members of the organization to publicize their contributions - legitimate interest of the organization in preserving the historical memory of events/activities	indefinitely published on the website and on the history of the public git repository of the website of the “Encontros de Comunidades de Tecnologias Livres”	- Mandatory for members of the organization - optional for contributors to the organization - obligatory for speakers, for whom to direct workshops and events and activities	this data will be public	These can be very diverse, but it is at the discretion of data subjects which
Email address	- legitimate interest of the organization in contacting the members of the organization, contributors, speakers, of whom to promote and direct workshops, events and activities, and of those in being contacted by the organization for reasons related to the relationship with the organization - consent for all other cases	- indefinite for the case of organization, contributors, speakers, of whom to promote and direct workshops, events and activities - 6 months for the remaining cases	- obligatory for members of the organization, contributors, speakers, those who promote and direct workshops, events and activities, and those to be contacted by the organization for reasons related to the relationship with the organization - optional for the remaining cases	the reason why the organization does not publish e-mail addresses on the site is to avoid complications in the execution of the right to correct and erase the data, related to the possible need to rewrite the history of the git repository of the website
Phone number	- legitimate interest of the organization to contact for the purposes of organizing events in order to ensure coordination, communication of decisions of the organization, provision of information to the subject necessary for its participation, with: - speakers - who direct workshops and events and activities	6 months	Mandatory when the field on the form is set as mandatory	it won’t be made public