How your data is processed
This notice applies to the “Response”, “Readiness”, “Conversation”, “Invitation” and “Notification” forms, to the confirmation email, the automatic reply and subsequent correspondence about the project.
In short
- We do not sell data or pass it to third parties for their own purposes
- We do not publish your text — in full or in fragments — without separate consent
- We do not show ads or use advertising or analytics trackers
- We do not pass your free text to language models or use them to assess your position
- We do not make automated decisions about you
- We do not send news without a separate tick in the form
Below is the full version. It is longer, but written in the same language: if any point is unclear, that is our mistake, and you can write to the same address about it.
Who is responsible for the data
The controller of personal data is Roman Voronkov, acting within the independent project “The Political Unmanifest”. At the current stage, the project has no legal entity.
Dedicated channel for data questions: [email protected]. This address is used for requests for access, rectification, erasure, restriction of processing, data portability and withdrawal of consent.
No separate data protection officer has been appointed: the scale and nature of the processing do not require one.
This address is a working channel, not a formality: emails sent to it are read and answered within the time limits set out in the “Your rights” section.
What data is collected
“Response” form
Name, email, country of residence, age group, type of message, free text and consent ticks.
“Readiness” form
Name, email, country of residence, age group, working languages, chosen direction, priorities for change, possible contribution, formats and time for participation, professional experience or a link to a profile, additional context. Citizenship is given only if you wish.
“Conversation” form on the exhibition page
Name, email, country, type of enquiry, institution name and role if you provide them, and the text of the message.
“Invitation” form on the school page
Name, email, country, type of enquiry, field, institution or role if you provide them, and the text of the message.
“Notification” form on the book pages
Email and the chosen edition language. This form collects nothing else.
Age
The forms are intended for people aged 18 and over. Age is not verified: you confirm it with a tick in the form and by choosing an age group, and the project relies on that statement. Verification would require documents — that is, collecting far more sensitive data than the data the form exists for. If the content of a message, subsequent correspondence or a request from a parent or guardian makes it clear that a record was submitted by a minor, it is deleted and the correspondence ends.
Service data
Form language, response number, date and time, working status, interaction history and the version of the consent text in force at the time of submission.
Protection against abuse
The application temporarily stores irreversible hashes of the network address and email to limit submission frequency. The network address itself is not stored in the responses database.
The data source is always the same — you. The project does not obtain information about you from other sources and does not supplement it with data from external databases.
Why, and on what legal basis
Replying to a message and continuing the dialogue
Consent — Article 6(1)(a) GDPR. Where your answer may reveal political or philosophical views, explicit consent under Article 9(2)(a) is additionally required.
Readiness profile and task matching
Consent — Articles 6(1)(a) and 9(2)(a) GDPR. Matching is done manually by a person, not by an algorithm.
Notification of an edition’s release
Consent — Article 6(1)(a) GDPR. The person chooses the edition language they want to hear about. Exactly one email is sent, on the day that edition is published. The address is deleted immediately after sending and is not used for anything else.
Anonymized and aggregated analysis
A separate, optional consent. Refusing it does not prevent you from submitting the form and does not affect the reply.
Occasional messages about the projects’ progress and tasks
A separate, optional consent, marked by the fourth item in the form. Without it, we contact you only regarding your own message. You can unsubscribe via the link in any email.
Protecting the forms from spam and abuse
Legitimate interests in the security of the service — Article 6(1)(f) GDPR, with data minimization and a short retention period.
Confirmation of receipt
A technical email sent in response to your own action. It is not a subscription or marketing.
A collective reply to accumulated messages is formulated in general terms. Your text is not reproduced verbatim and is not published without separately requested consent.
Address confirmation
The forms require confirmation that you own the address given. This protects people from messages being sent in their name from someone else’s email.
- After you click “Send”, the record is saved with the status “unconfirmed” together with the message text — so that it is not lost if the email is delayed.
- An email arrives at the given address with a link valid for 48 hours.
- The text of your message is not included in that email — in case the address was entered incorrectly or belongs to someone else.
- Until confirmed, the record is not processed in substance.
- Unconfirmed records are deleted automatically within 48 hours.
If you received such an email but did not send anything, you need not do anything: the record will be deleted. Abuse can be reported to [email protected].
Automatic reply and no automated decisions
The automatic email is chosen based on the form language and the structured answer options. Free political text is not passed to language models and is not used for automated assessment of your position.
The automatic reply only confirms receipt and the response number. It does not mean approval, refusal, a promise of a personal reply, cooperation or a specific role.
No decisions that significantly affect a person are taken automatically. No profiling within the meaning of Article 22 GDPR is carried out; all substantive work with messages and profiles is done by a human.
Who may have access to the data
The project’s author and future team members
Only to the extent necessary for their role, and after being granted separate access.
Website hosting service
Hosting the website, storing the database and logs, and running the private dashboard. The database was created with the European Union jurisdiction specified.
Brevo
Only at the moment an automatic confirmation is sent. Name, address, language, response number and a short deterministic text are transmitted. The full text of the response, age group, country and citizenship are not transmitted. Personal tracking of opens and clicks is disabled for the recipient.
Proton Mail
Working correspondence from project addresses — once such communication has started.
Data is not sold, published or shared with other project participants without a separate basis or consent.
Responses and the database are physically stored in Cloudflare D1 with the European Union jurisdiction specified: records are kept on servers in EU countries and are not moved outside the EU.
Providers’ privacy policies: Cloudflare · Brevo · Proton
International processing
Providers may process data outside your country of residence. In particular, the current hosting does not guarantee that data is located in a chosen region, and Proton operates under Swiss jurisdiction.
Where applicable, processing and transfers rely on data processing agreements and safeguards provided by law.
Do not send information through the forms that is not needed for the dialogue or possible participation. This includes data about other people, information about health, immigration status and any circumstances whose disclosure could create a risk for anyone.
Retention periods
- A response and related working history — until consent is withdrawn, but no longer than 24 months after the last substantive interaction.
- Address for an edition release notification — until the chosen edition is released; deleted immediately after the email is sent. If the edition is not released within 24 months, the address is deleted without sending.
- Unconfirmed records — no more than 48 hours.
- Technical rate-limiting hashes — no more than 48 hours.
- Records found to have been submitted by a minor — deleted immediately once this becomes known.
- Mail logs — the minimum practically necessary period; certain service records of providers may be kept under their mandatory security and accounting rules.
With separate consent, answers may be used for statistical and analytical analyses. Only aggregated results are released, prepared so that re-identification of a participant by reasonably likely means is ruled out: name, address, free text and record identifier are removed from the sample, individual-level rows are not published, and rare categories are merged. Until then, the data remains personal and is subject to the general retention periods.
Your rights
You can request access to your data, a copy, rectification, erasure, restriction of processing and data portability; withdraw consent at any time; and object to the processing of technical data based on legitimate interests. Withdrawing consent does not make processing carried out before it unlawful.
Write to [email protected] from the address given in the form and, if possible, state the response number. To protect your own data, reasonable identity verification may be required. A reply is provided without undue delay and usually within one month.
You may also lodge a complaint with a data protection supervisory authority — in your country of residence, place of work or place of the alleged infringement.
Security and changes
We use HTTPS, server-side field validation, submission rate limiting, a private dashboard with login and an allow-list of addresses, separate storage of secrets and working access statuses.
No measure eliminates risk entirely, which is why the amount of data collected is deliberately limited. This is the main protection, not an add-on to the others.
If purposes, fields, providers or retention periods change significantly, the notice will be updated before the new processing begins and, where required, new consent will be requested. Previous versions are available on request.