Privacy Policy

1. Privacy at a Glance

General Information

The following notices provide a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to personally identify you. For detailed information on the subject of data protection, please refer to our privacy policy listed below this text.

Data Collection on This Website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find the operator’s contact details in the section “Notice Regarding the Responsible Party” in this privacy policy.

How do we collect your data?

Your data is collected in part by you providing it to us. This may include, for example, data that you enter into a contact form.

Other data is collected automatically or with your consent when you visit the website by our IT systems. This is primarily technical data (e.g., internet browser, operating system, or time of page access). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure the error-free provision of the website. Other data may be used to analyse your user behaviour. If contracts can be concluded or initiated via the website, the transmitted data will also be processed for contract offers, orders, or other enquiries.

What rights do you have regarding your data?

You have the right at any time to obtain information free of charge about the origin, recipients, and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can revoke this consent at any time for the future. Furthermore, you have the right, under certain circumstances, to request the restriction of the processing of your personal data. You also have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time regarding this and other questions on the subject of data protection.

Analysis Tools and Third-Party Tools

When visiting this website, your browsing behaviour may be statistically analysed. This is done primarily with so-called analysis programmes.

Detailed information about these analysis programmes can be found in the following privacy policy.

2. Hosting

We host the contents of our website with the following provider:

External Hosting

This website is hosted externally. The personal data collected on this website is stored on the servers of the host(s). This may include, among other things, IP addresses, contact requests, meta and communication data, contract data, contact details, names, website access, and other data generated via a website.

The external hosting is carried out for the purpose of fulfilling contracts with our potential and existing customers (Art. 6 Abs. 1 lit. b DSGVO) and in the interest of a secure, fast, and efficient provision of our online services by a professional provider (Art. 6 Abs. 1 lit. f DSGVO). If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 Abs. 1 lit. a DSGVO and § 25 Abs. 1 TDDDG, insofar as the consent includes the storage of cookies or access to information on the user’s terminal device (e.g., device fingerprinting) within the meaning of the TDDDG. The consent can be revoked at any time.

Our host(s) will only process your data to the extent necessary to fulfil their service obligations and will follow our instructions with regard to this data.

We use the following host(s):

netcup GmbH Emmy-Noether-Straße 10 D-76131 Karlsruhe Phone: +49 721 / 7540755 - 0 Fax: +49 721 / 7540755 - 9 Hotline (for German customers and sales enquiries): 08000 netcup (Free of charge from the Deutsche Telekom landline network) Web: www.netcup.com Email: mail@netcup.de Commercial register: HRB 705547, Amtsgericht Mannheim

Data Processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law that ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

E-Mail Mailbox

E-mails to our addresses at chacha.charity (e.g. kontakt@chacha.charity) and messages from our contact form are received by the mail server of our hosting provider netcup GmbH (address see above) and forwarded to our mailbox at STRATO GmbH, Otto-Ostrowski-Straße 7, 10249 Berlin, Germany, where they are stored. We have concluded a data processing agreement pursuant to Art. 28 GDPR with both providers; they process your message only in accordance with our instructions. The legal bases are the same as for handling your enquiry (see section 4, “Contact Form” and “Enquiry by E-Mail, Telephone, or Fax”). We delete your message six months after our last contact with you; we keep business letters for six years (§ 147 AO, § 257 HGB), each from the end of the calendar year.

Overview: Where Your Data Is Stored

Our servers are located in Germany (Nuremberg, netcup GmbH). Our e-mail mailbox is also hosted by a provider in Germany (STRATO GmbH, Berlin). However, not all data stays exclusively in Germany: for sending e-mails we currently use a service provider based in the USA (Resend; Standard Contractual Clauses, see section 5, “E-Mail Delivery via Resend”). Payments are processed by a regulated payment service provider with a contracting entity in the EU that belongs to a US group (Stripe, see section 8). Records on the blockchain are public, retrievable worldwide and contain no names (see section 8).

3. General Information and Mandatory Disclosures

Data Protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations as well as this privacy policy.

When you use this website, various personal data is collected. Personal data is data that can be used to personally identify you. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We would like to point out that data transmission over the internet (e.g., when communicating by e-mail) may have security vulnerabilities. Complete protection of data against access by third parties is not possible.

Notice Regarding the Responsible Party

The responsible party for data processing on this website is:

Maximilian Dörr Backenfeldsteig 28 91126 Schwabach

Phone: +49 911 47466252 Email: kontakt@chacha.charity

Please direct enquiries about data protection and the exercise of your rights to kontakt@chacha.charity.

The responsible party is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g., names, e-mail addresses, etc.).

Storage Duration

Unless a more specific storage period has been stated within this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g., retention periods under tax or commercial law); in the latter case, deletion will take place after these reasons cease to apply.

Special periods at a glance: we delete enquiries sent via the contact form, quote requests and e-mails to us six months after the last contact if no contract is concluded (section 4); we delete document requests from the investors page twelve months after the request (section 4); we keep business letters for six years. We keep books, records and copies of donation receipts for ten years and booking vouchers for eight years (§ 147 AO, § 257 HGB), each from the end of the calendar year (section 8).

General Information on the Legal Basis for Data Processing on This Website

If you have consented to data processing, we process your personal data on the basis of Art. 6 Abs. 1 lit. a DSGVO or Art. 9 Abs. 2 lit. a DSGVO, insofar as special categories of data pursuant to Art. 9 Abs. 1 DSGVO are processed. In the event of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49 Abs. 1 lit. a DSGVO. If you have consented to the storage of cookies or to access to information on your terminal device (e.g., via device fingerprinting), data processing is additionally carried out on the basis of § 25 Abs. 1 TDDDG. The consent can be revoked at any time. If your data is required for the fulfilment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 Abs. 1 lit. b DSGVO. Furthermore, we process your data if this is required to fulfil a legal obligation on the basis of Art. 6 Abs. 1 lit. c DSGVO. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6 Abs. 1 lit. f DSGVO. The relevant legal basis in each individual case is explained in the following paragraphs of this privacy policy.

Recipients of Personal Data

In the course of our business activities, we work with various external parties. In some cases, the transfer of personal data to these external parties is also necessary. We only pass on personal data to external parties if this is necessary for the fulfilment of a contract, if we are legally obliged to do so (e.g., passing on data to tax authorities), if we have a legitimate interest pursuant to Art. 6 Abs. 1 lit. f DSGVO in the disclosure, or if another legal basis permits the data transfer. When using data processors, we only pass on personal data on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.

We currently use the following recipients: netcup GmbH (hosting) and STRATO GmbH (e-mail mailbox), both in Germany (section 2); Resend (e-mail delivery, USA; section 5); Stripe (payment processing; section 8). In addition, there are public records on the blockchain (section 8).

Revocation of Your Consent to Data Processing

Many data processing operations are only possible with your express consent. You can revoke consent that has already been given at any time. The lawfulness of the data processing carried out until the revocation remains unaffected by the revocation.

Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 DSGVO)

IF DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6 ABS. 1 LIT. E OR F DSGVO, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR THE PROCESSING SERVES THE ASSERTION, EXERCISE, OR DEFENCE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21 ABS. 1 DSGVO).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21 ABS. 2 DSGVO).

Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work, or the place of the alleged violation. The right to lodge a complaint is without prejudice to any other administrative or judicial remedy.

Right to Data Portability

You have the right to have data that we process automatically on the basis of your consent or in fulfilment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

Access, Correction, and Deletion

Within the framework of the applicable legal provisions, you have the right at any time to obtain information free of charge about your stored personal data, its origin and recipients, and the purpose of data processing, and, where applicable, a right to correction or deletion of this data. You can contact us at any time regarding this and other questions on the subject of personal data.

Right to Restriction of Processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing applies in the following cases:

• If you contest the accuracy of your personal data stored by us, we generally need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data. • If the processing of your personal data was/is carried out unlawfully, you may request the restriction of data processing instead of deletion. • If we no longer need your personal data, but you need it for the exercise, defence, or assertion of legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion. • If you have lodged an objection pursuant to Art. 21 Abs. 1 DSGVO, a balancing of your and our interests must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data may – apart from being stored – only be processed with your consent or for the assertion, exercise, or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.

SSL or TLS Encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the site operator. You can recognise an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.

When SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Objection to Promotional E-Mails

The use of contact data published within the framework of the legal notice obligation for the purpose of sending unsolicited advertising and information materials is hereby objected to. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam e-mails.

4. Data Collection on This Website

Cookies

Our websites use so-called “cookies”. Cookies are small data packets and do not cause any damage to your terminal device. They are stored either temporarily for the duration of a session (session cookies) or permanently (persistent cookies) on your terminal device. Session cookies are automatically deleted at the end of your visit. Persistent cookies remain stored on your terminal device until you delete them yourself or they are automatically deleted by your web browser.

Cookies may originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services from third-party companies within websites (e.g., cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyse user behaviour or for advertising purposes.

Cookies that are required for the execution of the electronic communication process, for the provision of certain functions requested by you (e.g., for the shopping cart function), or for the optimisation of the website (e.g., cookies for measuring web audiences) (necessary cookies) are stored on the basis of Art. 6 Abs. 1 lit. f DSGVO, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimised provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6 Abs. 1 lit. a DSGVO and § 25 Abs. 1 TDDDG); the consent can be revoked at any time.

You can set your browser to inform you about the setting of cookies and to allow cookies only on a case-by-case basis, to exclude the acceptance of cookies for certain cases or in general, and to activate the automatic deletion of cookies when the browser is closed. If cookies are deactivated, the functionality of this website may be limited.

If additional cookies and services are used on this website, you can find information about this in this privacy policy.

Server Log Files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

• Browser type and browser version • Operating system used • Referrer URL • Hostname of the accessing computer • Time of the server request • IP address

This data is not merged with other data sources.

This data is collected on the basis of Art. 6 Abs. 1 lit. f DSGVO. The website operator has a legitimate interest in the technically error-free presentation and optimisation of its website – for this purpose, server log files must be collected.

IP Addresses for Abuse Prevention and Logging

In addition to the server log files described above, we process your IP address in the following cases:

• Protection against abuse and overload: For requests to our application programming interface (API), in particular login attempts and guest donations, we temporarily record your IP address in order to detect and limit an excessive number of requests within a short period. This data is held exclusively in a temporary cache and automatically deleted after one hour at the latest. • We log security-relevant events (e.g. failed login attempts) together with the IP address; a daily cleanup job removes the IP address no later than 8 days after the event. • Security-relevant actions on your donation account: see the section “Security Notifications for Your Donation Account” (retention period 90 days). • Evidence log for data-protection requests and consent decisions: if you grant or withdraw a consent, or submit a data-protection request (e.g. a request for access or erasure), we log the IP address as evidence under Art. 7(1) and Art. 12 GDPR respectively. The newsletter sign-up is excluded (see section 5). The IP address is removed no later than 12 months after the respective event, regardless of whether your account still exists at that time; the entry itself remains as evidence. The consent decision itself is additionally stored with the IP address in your donation account and is only removed when your account is deleted (see the sections “Usage Analytics in Your Donation Account”, “Personalized Project Recommendations” and “Named Mention in the Annual Report”). • Backups: as part of our regular backups, IP addresses may be contained for up to 30 days beyond the periods stated above.

Legal basis is our legitimate interest (Art. 6(1)(f) GDPR) in the security, stability, and proper operation of our platform. For the evidence log, the legal basis is additionally our legal obligation (Art. 6(1)(c) GDPR) in conjunction with Art. 5(2) and Art. 7(1) GDPR to be able to demonstrate consents and data-protection-relevant actions.

Contact Form

If you send us enquiries via the contact form, your details from the enquiry form, including the contact data you provided there, will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions. We do not pass this data on to third parties. The exceptions are our processors, which deliver and store your enquiry on our behalf: our hosting provider, our e-mail provider STRATO (see section 2, “E-Mail Mailbox”) and our e-mail delivery service Resend (see section 5, “E-Mail Delivery via Resend”). Your details are delivered to our mailbox as an e-mail; we do not store them in a database (unlike document requests from the investors page, see below).

The processing of this data is carried out on the basis of Art. 6 Abs. 1 lit. b DSGVO, insofar as your enquiry is related to the fulfilment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of enquiries addressed to us (Art. 6 Abs. 1 lit. f DSGVO) or on your consent (Art. 6 Abs. 1 lit. a DSGVO) if this has been requested; the consent can be revoked at any time.

We delete the data you enter in the contact form six months after our last contact with you, including the copy in our e-mail mailbox; earlier if you ask us to delete it or revoke a consent to storage you have given. If a contract is concluded or your message is a business letter, we keep it for six years (§ 147 AO, § 257 HGB), each from the end of the calendar year. Mandatory statutory provisions remain unaffected.

Automatic Confirmation of Receipt

After you submit the contact form or the quote request, we send an automatic confirmation of receipt with a fixed text to the e-mail address you provided. It does not repeat any of your details. Our e-mail delivery service Resend sends it (see section 5, “E-Mail Delivery via Resend”). So that nobody can use the form to repeatedly write to third-party addresses, we send at most three confirmations per address per hour; for this we store only a pseudonymised hash value of the address, not the address itself, for one hour at most. The legal basis is Art. 6(1)(b) or (f) GDPR (confirming your enquiry, protection against abuse).

Quote Request (Premium)

Through the quote request form for premium features (on the pages for non-profit organisations and for companies) we collect your first and last name, your e-mail address, the name of your organisation or company, optionally your telephone number, your audience (non-profit organisation or company), the size of your organisation in ranges (“Not sure yet” is an option), the features you are interested in, and your message. Name, e-mail address, organisation, size range and message are mandatory; the telephone number is optional.

We use this information to prepare a quote for you and to contact you about it by e-mail or, if you provided a number, by telephone. The legal basis is our legitimate interest in handling business enquiries (Art. 6(1)(f) GDPR); if you enquire as an individual in your own name, it is Art. 6(1)(b) GDPR (pre-contractual measures at your request). We do not ask for consent; the form contains an information notice instead.

We do not store the enquiry in a database (unlike document requests from the investors page, see below). It is delivered to our mailbox as an e-mail (section 2, “E-Mail Mailbox”); Resend carries out the delivery as a processor (section 5). No further disclosure to third parties takes place. Here, too, we send the automatic confirmation of receipt (see above).

If no contract is concluded, we delete your enquiry no later than six months after the last contact, including the copy in our e-mail mailbox. If a contract is concluded or your message is a business letter, we keep it for six years (§ 147 AO, § 257 HGB), each from the end of the calendar year. No automated decision-making takes place.

Document Request (Investors Page)

If you request a document on the investors page (whitepaper, litepaper or pitch deck), we store your name, e-mail address, telephone number, company, optionally your note, and the document you chose. We also store the time of the request, the language of the page, the version of the notice text in the form, whether you ticked the optional box for further information, a key derived from your e-mail address (it only serves to limit repeated requests), and the number of times your download link was opened. Of the link itself we store only a hash value, not the link.

The telephone number is mandatory because we will get back to you about your request by e-mail or telephone. We send you a personal download link (valid for 7 days, at most 5 downloads) and notify our team. For the pitch deck you receive a confirmation; our team sends you the document personally. The legal basis is Art. 6(1)(f) GDPR (our legitimate interest in answering and following up on enquiries from interested parties).

The data is held in our content management system, a database at our hosting provider (section 2). Recipients are our hosting provider netcup, our e-mail mailbox provider STRATO (section 2, “E-Mail Mailbox”) and our e-mail delivery service Resend (section 5, “E-Mail Delivery via Resend”), each as a processor. No further disclosure to third parties takes place. Unlike the contact form, we therefore do store this request in a database.

We delete the request twelve months after you made it, including the notification in our e-mail mailbox; earlier if you ask us to delete it. If a contract is concluded or your message is a business letter, the longer statutory periods apply (§ 147 AO, § 257 HGB).

We send further information by e-mail only if you tick the optional box and confirm your address (Art. 6(1)(a) GDPR). Ticking the box alone does not trigger any mailing. You can withdraw your consent at any time with effect for the future. No automated decision-making takes place.

Enquiry by E-Mail, Telephone, or Fax

If you contact us by e-mail, telephone, or fax, your enquiry including all resulting personal data (name, enquiry) will be stored and processed by us for the purpose of handling your request. We do not pass this data on to third parties. The exceptions are our hosting provider and our e-mail provider STRATO, which receive and store e-mails on our behalf as processors (see section 2, “E-Mail Mailbox”).

The processing of this data is carried out on the basis of Art. 6 Abs. 1 lit. b DSGVO, insofar as your enquiry is related to the fulfilment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of enquiries addressed to us (Art. 6 Abs. 1 lit. f DSGVO) or on your consent (Art. 6 Abs. 1 lit. a DSGVO) if this has been requested; the consent can be revoked at any time.

We delete your enquiry and the related correspondence six months after our last contact with you if no contract is concluded; earlier if you ask us to delete it or revoke a consent to storage you have given. If a contract is concluded or your message is a business letter, we keep it for six years (§ 147 AO, § 257 HGB), each from the end of the calendar year. Mandatory statutory provisions remain unaffected.

Donation reservation (reserve without being charged)

If you reserve a donation, we store your name, your e-mail address, the selected project, the reserved amount, the selected payment method (card or SEPA), the language, and the time and expiry date of the reservation, where applicable your dedication, your address for a donation receipt, whether you wish to donate anonymously, and a voluntary contribution to the Supporter Pool. No amount is charged, and no payment data is collected.

We use this data solely to confirm receipt of the reservation, to send you a payment link as soon as the Supporter Pool covers the costs again, to remind you of the reservation after 14 days, and to inform you when it expires. These e-mails are service messages about your reservation and not advertising. The legal basis is Art. 6 (1) (b) GDPR.

The reservation is valid for 30 days and is non-binding. You can withdraw it at any time via the link in our e-mails. We delete your contact data immediately if you withdraw the reservation or pay the donation, and otherwise 7 days after the reservation expires. If a payment was started but not completed, we delete the data no later than 7 days after the reservation expires.

Recipients are our hosting provider and our e-mail delivery service Resend (Plus Five Five, Inc., USA) as processors; for details, including the transfer of data to the United States, see section 5, “E-Mail Delivery via Resend”. Providing your name and e-mail address is voluntary, but a reservation is not possible without them. No automated decision-making takes place.

Security Notifications for Your Donation Account

If you change or remove your password or two-factor method, or if your donation account is temporarily or permanently locked after several unsuccessful login attempts, we notify you by e-mail. These notifications are part of the account security we owe you under the donation account’s terms of use (Art. 6(1)(b) GDPR), and are also in our legitimate interest in protecting your account from unauthorised access (Art. 6(1)(f) GDPR).

The e-mail contains your e-mail address, the time, and the type of the event. If you change or remove your password or two-factor method, it also contains the IP address the change was made from.

This notification is sent only to you as the holder of the donation account. The e-mail is sent on our behalf by our e-mail delivery service Resend as a processor (see section 5, “E-Mail Delivery via Resend”). The underlying event data is stored by our identity service and automatically deleted 90 days after the respective event, unless you request earlier deletion under Art. 17 GDPR.

Where this processing is based on our legitimate interest under Art. 6(1)(f) GDPR, you have the right to object at any time for reasons arising from your particular situation (Art. 21(1) GDPR); see the section “Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 DSGVO)”. Because these notifications protect your own account, objecting means you would no longer receive alerts about security-relevant events on your account.

Usage Analytics in Your Donation Account

If you consent, we record how you use your donation account (pages viewed, clicks) using a self-hosted analytics tool on our own infrastructure; your data does not leave our infrastructure, and we do not additionally analyse the content of your donations. The legal basis is your consent (Art. 6(1)(a) GDPR).

This analysis only takes place if you have both agreed to the “Analytics” cookie category and enabled the consent in your account under “Privacy & My Data”. You can withdraw your consent there at any time with immediate effect; the lawfulness of processing carried out before the withdrawal remains unaffected (Art. 7(3) GDPR).

We log every consent decision (time, version of the consent statement, source, as well as IP address and browser identifier) as evidence under Art. 7(1) GDPR. We retain this consent log until you delete your account.

This data is not shared with third parties.

Personalised Project Recommendations

If you consent, we analyse your donation history to suggest matching projects to you. The legal basis is your consent (Art. 6(1)(a) GDPR). Without your consent, you see the same recommendations as an anonymous visitor.

You can withdraw this consent at any time under “Privacy & My Data” in your account with immediate effect; the lawfulness of processing carried out before the withdrawal remains unaffected (Art. 7(3) GDPR).

Here too, we log your consent decision (time, version, source, as well as IP address and browser identifier) as evidence under Art. 7(1) GDPR. We retain this log until you delete your account.

This data is not shared with third parties.

Named Mention in the Annual Report

If you consent, we name you in our annual reports. We publish your name in the form you chose (first name and initial of your last name, or first and last name) and your tier (“Ambassador” or “Pioneer”). From this it can be seen that you have supported us with at least the amount from which the respective tier applies; we do not state the exact amount. The legal basis is your consent (Art. 6(1)(a) GDPR). Consent is voluntary; without it you keep your tier and all other benefits.

The annual report is publicly available on our website and can be found by search engines. It can also be downloaded and passed on. Your consent applies to all annual reports published from the time of your consent until you withdraw it.

You can withdraw this consent at any time under “Recognition & Badges” or under “Privacy & My Data” in your account, with effect for the future (Art. 7(3) GDPR). After a withdrawal we remove your name from the online version of the annual report, usually within 14 days. We cannot retrieve copies that have already been downloaded or printed, or copies held by third parties. The lawfulness of processing carried out before the withdrawal remains unaffected.

We log every consent decision (time, version of the consent statement, source, as well as IP address and browser identifier) as evidence under Art. 7(1) GDPR. We retain this consent log until you delete your account.

The controller is the website operator (see legal notice). Beyond the publication in the annual report, this data is not shared with third parties.

5. Newsletter

Newsletter Sign-Up and Stored Data

You can subscribe to our newsletter via several forms on our website or in the settings of your donation account. For this we need your e-mail address. Optionally, you can select topics on which we may inform you and state preferred contact channels. We do not ask for your name; as a technical display name, the newsletter system uses the part of your e-mail address before the @. Providing your e-mail address is voluntary; without it, however, we cannot send you the newsletter.

To manage and prove your consent, we additionally store the source of the sign-up (the form or page through which you signed up), the type of sign-up purpose, your language, and the time and source of your consent. We do not store your IP address in the newsletter system as proof of consent.

Double Opt-In and Proof of Consent

After you sign up, we send you a confirmation e-mail containing a link (double opt-in). You only receive the newsletter after you have opened this link. As proof of your consent, we store the time and source of the sign-up and the status and time of the confirmation. The legal basis for this proof is our legitimate interest in being able to demonstrate consent that has been given (Art. 6(1)(f) in conjunction with Art. 7(1) GDPR).

Newsletter System and Recipients

For the newsletter we use open-source newsletter software that we operate ourselves on our own server, at the same hosting provider as this website (see section 2 “Hosting”). Your newsletter data is therefore not transmitted to an external newsletter service. The public newsletter pages (confirmation, unsubscribe, preferences) are available at newsletter.chacha.charity; for the technical page request, the information on “Server Log Files” in section 4 applies.

The only recipients of your newsletter data are our hosting provider and the e-mail delivery service named below, each as a processor within the meaning of Art. 28 GDPR. Beyond that, we do not pass your newsletter data on to third parties unless we are legally obliged to do so.

E-Mail Delivery via Resend

We send the newsletter, the related confirmation e-mails and the other e-mails we send you in connection with this website and your donation account via the e-mail delivery service Resend (Plus Five Five, Inc., 2261 Market Street, San Francisco, CA 94114, USA; trading as Resend). This also includes confirmations of receipt for enquiries, e-mails about donation reservations, security notifications and the notification about messages from our contact form. The purpose is the technical delivery of these e-mails (transactional e-mails and newsletter). In doing so, Resend processes your e-mail address, the content of the respective e-mail and technical delivery data (e.g. time and delivery status) on our behalf and in accordance with our instructions. We have concluded a data processing agreement with Resend pursuant to Art. 28 GDPR; it takes effect when the Resend terms of service are accepted and includes the EU Standard Contractual Clauses.

We have the e-mails sent via Resend’s EU region. According to Resend, however, the associated account data, delivery logs and metadata (e.g. recipient address, time, delivery status) are stored in the United States. Your data is therefore transferred to a third country. The transfer relies on the European Commission’s adequacy decision for the EU-U.S. Data Privacy Framework (Art. 45 GDPR), under which Resend states that it is certified, and additionally on the EU Standard Contractual Clauses agreed in the data processing agreement (Art. 46(2)(c) GDPR). You can obtain a copy of the Standard Contractual Clauses on request at kontakt@chacha.charity. According to Resend, Resend keeps e-mail content and delivery logs for 30 days and deletes customer data within 90 days after the contract ends.

Bounces and Complaints

If the recipient’s mail server reports that an e-mail could not be delivered (bounce), or if you mark an e-mail as spam (complaint), the e-mail delivery service notifies us automatically. We record the event (type of event and the error message reported by the receiving mail server) in the newsletter system and block the address from further mailings after a permanent delivery failure (hard bounce) or a complaint. The legal basis is our legitimate interest in the reliable deliverability of our e-mails and in complying with legal requirements (Art. 6(1)(f) GDPR).

No Measurement of Opens and Clicks

We do not measure whether or when you open a newsletter or click links in it. Our newsletters contain no tracking pixels, and links are not redirected through a counting function.

Legal Bases at a Glance

• Sending the newsletter: your consent (Art. 6(1)(a) GDPR).

• Proof of consent, recording of the unsubscription and suppression list, handling of bounces and complaints: our legitimate interest (Art. 6(1)(f) GDPR).

Withdrawal and Your Rights Directly in the Newsletter

You can withdraw your consent at any time with effect for the future. Every newsletter contains an unsubscribe link for this purpose; in addition, a one-click unsubscribe (List-Unsubscribe) is provided in the e-mail header, which your e-mail program may display. On the preferences page at newsletter.chacha.charity, which you can reach from every newsletter, you can also:

• change your newsletter selection,

• have the newsletter data stored about you sent to you by e-mail (Art. 15 and 20 GDPR), and

• delete all newsletter data about you (Art. 17 GDPR).

You can also declare your withdrawal informally by e-mail to kontakt@chacha.charity. The lawfulness of processing carried out before the withdrawal remains unaffected. Further rights (access, rectification, restriction, complaint) are described in section 3.

Unsubscribing and Suppression List

After you unsubscribe, we record this in the newsletter system so that you do not receive further newsletters. If you choose, when unsubscribing, not to receive any newsletters in the future either, or if your address has been blocked after a hard bounce or a complaint, we additionally put it on a suppression list; signing up again with this address is then not possible. If you want to sign up again later, first delete your newsletter data (see above) or write to us. We use this data only for this purpose and do not merge it with other data. The legal basis is our legitimate interest in complying with the legal requirements for sending newsletters, which also corresponds to your interest in not being contacted again (Art. 6(1)(f) GDPR). The record and the suppression list are not limited in time. If you also want this data deleted, use the full deletion of your newsletter data (see above) or object under Art. 21 GDPR; we can then no longer ensure that no further newsletters are sent to this address if it is signed up and confirmed again.

Retention and Deletion

We store your newsletter data for as long as you are subscribed. After you unsubscribe, the data required for the record of the unsubscription, the suppression list and the proof of consent remains stored until you request full deletion.

Sign-ups that you do not complete by clicking the confirmation link are not used for mailings. We delete them automatically 14 days after your most recent sign-up.

Deleted newsletter data may remain in our backups for up to 30 days before it is deleted there as well. No automated decision-making takes place.

If you delete your donation account with us, we also delete the newsletter data for the e-mail address of that account.

Data stored by us for other purposes remains unaffected.

6. Plugins and Tools

OpenStreetMap (Impact Map)

Processing of Personal Data in Connection with the Impact Map

On the public Transparency Dashboard we embed map material from the OpenStreetMap Foundation, St John’s Innovation Centre, Cowley Road, Cambridge, United Kingdom, on the so-called Impact Map, to display project locations. The map is not loaded automatically. It only loads after you actively click “Load map” in the map area.

Data Collected

Retrieving the map tiles transmits your IP address and other data contained in the standard HTTP header (e.g. browser type, requested tile URL) to the OpenStreetMap Foundation’s servers, where they are processed.

Retention Period

We store your decision to load the map exclusively in your browser’s session storage — i.e. only for the duration of the current session. We will ask again on your next visit. For how long the OpenStreetMap Foundation retains the data transmitted when tiles are requested (e.g. in server logs), see the OpenStreetMap Foundation’s privacy policy: https://osmfoundation.org/wiki/Privacy_Policy.

Legal Basis

The Impact Map is embedded on the basis of your consent pursuant to Art. 6(1)(a) GDPR. You actively give this consent by clicking “Load map”. Without your consent, no connection to the OpenStreetMap Foundation’s servers is established.

Data Transfer to the United Kingdom

The OpenStreetMap Foundation processes the data outside the European Union, in the United Kingdom. The European Commission issued an adequacy decision for the United Kingdom on 19 December 2025 (valid until 27 December 2031).

More information on data protection at OpenStreetMap can be found in the OpenStreetMap Foundation’s privacy policy: https://osmfoundation.org/wiki/Privacy_Policy.

7. Sharing Content via Share Links

What a Share Link Is

You can share projects, your donations, impact proofs, campaigns, organisations, certificates and your status as a supporter of the Supporter Pool via a link. For this purpose we generate a random, short link (chacha.charity/share/…). It leads to a public page and to a preview image that social networks and messengers display when the link is inserted there. Links to projects, organisations, impact proofs, campaigns and certificates show public information only.

Which Data the Link Shows and on Which Legal Basis

• Without separate consent, the link shows the information that belongs to the shared content: for donations, the project, the organisation and the date of the donation; for a personal supporter link, the number of months for which you have been a supporter. The legal basis is Art. 6(1)(b) GDPR: you request the sharing function, and this information is necessary for it. • Only with your consent does the link show your display name and the amount of your donation, or your supporter tier and your total contribution to the Supporter Pool. An approximate contribution range can be derived from the tier. The legal basis is Art. 6(1)(a) GDPR. You give your consent in the dialog when creating the link; the options are unselected by default. We log every consent and every withdrawal with its time and wording in your donation account as proof (Art. 7(1) GDPR); we delete this information together with your account. A supporter link never shows your name. • If you have objected to the publication of your donations, or if you donated without an account or anonymously, we do not show a name. • On the public link to the Supporter Pool, we show the sum of contributions and the number of supporters only if enough people have contributed that no individual contribution can be derived from them (the same rule as in the public pool register); otherwise we show an amount rounded to €50 and no number.

Recipients

The page and the preview image are public. Anyone who knows the link can access them without signing in. If you or others insert the link in social networks or messengers, their operators retrieve the preview image and store it according to their own rules. On our side, only our hosting provider (section 2) processes the requests; we do not use analytics or tracking services on share pages.

Accessing a Link

When a link is opened, we only set a technically necessary cookie for your language setting (Section 25(2) no. 2 TDDDG). To protect against overload and automated scraping, we briefly process your IP address in order to limit the number of requests per minute (Art. 6(1)(f) GDPR); it is discarded after one hour at the latest. Otherwise, the information in section 4 applies to server logs. For each link we only count the total number of views, without reference to persons; we do not count views by search engines and link previews.

Retention Period

• Links to donations are valid for up to 12 months from creation. • A personal supporter link has no expiry date and remains valid as long as you are a supporter. It shows your tier and your total contribution for no longer than 12 months after your consent; after that we hide them until you consent again. • Links to public content (e.g. projects) do not expire. • We keep the record of an expired or deactivated link (code, reference to the shared content, time and wording of your consent) as proof of your consent for three years (Art. 7(1), Art. 6(1)(f) GDPR) and delete it afterwards.

Withdrawal and Deactivation

You can withdraw your consent at any time with effect for the future and deactivate links at any time in your donation account under “Shared links”; for a supporter link you can also hide the tier and the total contribution individually there. If you donated without an account, you can only deactivate your link in the browser tab in which you created it (the management key is stored in your browser’s session storage; Section 25(2) no. 2 TDDDG); after that, an e-mail with the link to kontakt@chacha.charity is sufficient and we will deactivate it without delay. If you delete your account, we deactivate your links automatically. Changes take effect within a few minutes. The lawfulness of the display up to the withdrawal remains unaffected. We cannot recall preview images and copies that third parties (e.g. social networks) have already stored. Your further rights (access, erasure, objection) are set out in section 3.

8. Donations, Payments and Public Records

Donation and Payment Processing

When you donate, we process the donation amount, the project you chose, the time, the payment method and the payment status, as well as your e-mail address (for confirmation and receipt). We process your name and address only if you provide them, for example for a donation receipt for tax purposes; providing them is voluntary. You can donate with a donation account or as a guest. The legal basis is Art. 6(1)(b) GDPR; we meet our bookkeeping and record-keeping obligations on the basis of Art. 6(1)(c) GDPR.

Address in your donation account: You can optionally store an address in your donation account. We only use it to prefill the form when you request a donation receipt for tax purposes with an address. You can change or delete it in your profile at any time. The legal basis is your consent (Art. 6(1)(a) GDPR). The address printed on an issued donation receipt is kept separately for the statutory retention periods (see “Retention of Booking and Receipt Data”).

The payment is processed by our payment service provider Stripe (Stripe Payments Europe, Ltd., Ireland, as the contracting entity within the EU). You enter your payment details, such as card number or IBAN, directly with Stripe; we do not store them. We transmit to Stripe the amount, the currency, your e-mail address and, where applicable, your name, as well as internal reference numbers (donation, account and project IDs). Stripe processes this data on our behalf; for its own legal obligations, such as fraud and money-laundering prevention, Stripe is responsible itself, and Stripe’s privacy notice applies to that extent. Stripe belongs to a US group, so data may also be transferred to the USA; the basis is Standard Contractual Clauses (Art. 46(2)(c) GDPR) and, where applicable, the EU-U.S. Data Privacy Framework.

Retention of Booking and Receipt Data

We keep books, records and copies of donation receipts for ten years, booking vouchers for eight years and business letters for six years (§ 147 AO, § 257 HGB; Art. 6(1)(c) GDPR), each from the end of the calendar year. This includes donation bookings, donation receipts for tax purposes and the cash ledger of the Supporter Pool (see “Supporter Pool: Public Pool Register”). After the respective period has expired, we anonymise the personal references, in the Supporter Pool ledger for example the link to the account and the donation; we are currently setting up the deletion routine this requires, and until then the references remain. If you delete your account earlier, we remove or anonymise your personal data unless a statutory retention obligation prevents this; the booking data themselves remain until the period has expired.

Public Donation Overview (Donation Register)

In the project views and in the public register we show every completed donation by default so that anyone can see where donations go. We publish the donation as an amount range (not the exact amount), the day (not the time of day), the label “Anonymous donation”, and a reference number (tracking ID). We do not publish your name, your e-mail address, your account identifier or a location.

The legal basis is our legitimate interest in transparency about the use of funds (Art. 6(1)(f) GDPR). We have weighed the interests: the publication is limited to what is needed to make donations traceable (range instead of amount, day instead of time, no name, no location), and you can object to it at any time.

We show the exact amount, the actual payment fee and a link to your Digital Donation Receipt only if you have expressly consented for that individual donation (Art. 6(1)(a) GDPR). The option is not pre-selected and is also open to guests without an account. You can withdraw your consent at any time with effect for the future: via the link in the e-mail you receive after your donation, in your account at the respective donation, or by e-mail to kontakt@chacha.charity. The register then usually shows the donation as a range again within one minute. We log the giving and the withdrawal of consent with time, text version and source as proof (Art. 7(1) GDPR). The log contains neither your name nor your IP address, belongs solely to the respective donation and is kept together with it. The exact amount is publicly retrievable in the blockchain entry of your donation; the consent covers only the display in the register (see “Record on the Blockchain”). Your Digital Donation Receipt remains in place; it contains neither a name nor an e-mail address.

Objection under Art. 21 GDPR: you can object to the publication of your donations at any time. To do so, write to us at kontakt@chacha.charity and state the reference number (tracking ID or the number shown in the register) of one of your donations, or the e-mail address you donated with. If you donated with an account, we hide all your current and future donations and your Supporter Pool contributions from the register and the public donation ledger. If you donated as a guest, we hide all donations you have made so far with the same e-mail address; for later donations, please write to us again or donate with an account. Currently we record the objection this way; we will add a way to declare it yourself in your account. The amounts remain included in overall totals, for example the total amount of a project, because no individual donation can be read from them.

Supporter Pool: Public Pool Register

The public pool register shows how the Supporter Pool covers payment and platform costs. All figures are subject to the qualification “according to pool bookings”, because the pool is not yet an account of its own. We publish the pool balance and overall totals exactly. Anyone who retrieves these values at short intervals can draw conclusions about individual donations from the changes; we will reduce this risk further before real funds flow. As long as fewer than ten people have contributed in total, we publish the balance and totals only rounded to 50 euros. Everything else that could be traced back to individual contributors or individual donations we publish only from a minimum size of ten: we show contributions from supporters and grants by source and month only if at least ten people contributed to them. We show costs and the platform subsidy per day or month only if at least ten donations stand behind them; otherwise we combine several days or show no value. We show the total platform subsidy only rounded to 50 euros as long as fewer than ten donations have been subsidised, and averages per donation only rounded to 10 cents as long as fewer than ten donations underlie them. We do not list the fee of an individual donation one by one in the public history. To count people, for contributions without an account we use a pseudonymous value derived from the e-mail address; only the number is published. We show platform costs only as a monthly total. They are paid exclusively to companies (for example for hosting, licences and service providers), not to individuals.

The legal basis for these aggregated figures is our legitimate interest in transparency about the funding of the platform (Art. 6(1)(f) GDPR). They contain no names, and no individual contributions can be read off the figures per source, month and day (for the exact overall totals, see above).

We show individual contributions only with your express consent (Art. 6(1)(a) GDPR), then with amount and day but without a name. We do not offer this consent yet; individual contributions therefore currently do not appear individually. Consent is voluntary and not pre-selected. You can withdraw it at any time with effect for the future, by e-mail to kontakt@chacha.charity and, once we offer it, in the settings of your account. We log every consent decision (time, version of the consent statement, source, as well as IP address and browser identifier) as evidence under Art. 7(1) GDPR. We keep this consent log until you delete your account.

If you have objected to the publication of your donations (see above), your pool contributions also do not appear individually. Amounts from people who have objected remain included in the pool totals; the totals name no individuals. We keep the cash ledger of the Supporter Pool as a book for ten years (see “Retention of Booking and Receipt Data”).

Record on the Blockchain

To document a donation, we may write an entry in a public blockchain network (Solana network, currently the test network). The entry contains the tracking ID, the project identifier, the exact donation amount in cents, the payment fee and a pseudonymous value (donor hash). We calculate the pseudonymous value from the e-mail address, the project and the amount using a secret key that only we know; for donations without an e-mail address it contains no personal reference. Names and e-mail addresses are not stored on the blockchain. The same applies to the publicly retrievable details of your Digital Donation Certificate (amount, project, organisation, date, tracking ID, pseudonymous value). The exact amount and the tracking ID are publicly retrievable in the blockchain entry of your donation; your consent to the display in the register does not change this. We will revise this design before moving to the main network.

The pseudonymous value is not anonymisation. For us it remains personal data, because we can recalculate it from your data for as long as we store it. For third parties without our key it cannot readily be attributed; with additional knowledge, for example if someone knows the amount, project and time of your donation, a link to you can nevertheless arise. We therefore do not describe the entries as anonymous. They are publicly retrievable worldwide, including from countries outside the EU, and cannot technically be changed or deleted. If you request the deletion of your data (Art. 17 GDPR), we delete the data stored with us and the link to you to the extent legally permitted; statutory retention obligations remain unaffected. We cannot remove the public entry itself.

The legal basis is Art. 6(1)(b) GDPR insofar as the Digital Donation Receipt and the Digital Donation Certificate are part of our service to you, and otherwise our legitimate interest in a verifiable record of donation flows (Art. 6(1)(f) GDPR).

Exchange Rate Lookup for Network Costs

To convert network costs into euros, our servers retrieve the publicly available daily rate from Kraken. No personal data about you is transmitted in the process.