Privacy policy

The controller within the meaning of Art. 4(7) of the General Data Protection Regulation (GDPR) is:

• Martin Sellner
• Institute for Remigration
• Paulinengasse 18/5/17
• 1180 Vienna, Austria
• E-mail: contact@remigration-institute.com

No data protection officer has been appointed, as there is no legal obligation to do so (Art. 37 GDPR).

This statement is governed by the GDPR and the Austrian Data Protection Act (DSG).

Cloudflare. The Dashboard is delivered via Cloudflare Workers with static assets. The provider is Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA. Each time you access the Dashboard, Cloudflare necessarily processes connection data: your IP address, the date and time, the requested address, your browser identification (user agent) and, where applicable, the referring page (referrer). Cloudflare also uses this data to defend against attacks and abuse, and derives from your IP address the country from which the request originates.

Requests to our interface. Requests to our interface (addresses beginning with /api/) pass through a small program on Cloudflare (a Worker) that forwards them to our API. Logging (Workers Logs) is enabled for this program; the logs may contain request metadata such as IP address, user agent and referrer and are used solely for troubleshooting. All other pages are served directly by Cloudflare without passing through this program and are not logged by us.

FastAPI Cloud. Our API runs on FastAPI Cloud, provided by FastAPI Labs, Inc., 2261 Market Street STE 10109, San Francisco, CA 94114, USA. When forwarding a request, the Worker passes on the request headers sent by your browser and those added by Cloudflare. These include your IP address, your user agent and the referring page, as well as the country determined by Cloudflare. FastAPI Cloud logs incoming requests, so this information may appear in its request logs. Our API runs on servers in the USA (AWS region us-east-1, Northern Virginia).

• Purpose: secure, fast and stable delivery of the Dashboard; operation, troubleshooting and detection of abuse of the API.
• Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest lies in the reliable and secure operation of the Dashboard and its interface.

We do not use these logs for statistical purposes and do not combine them with other data.

On the "What to do?" page we show a video that is stored on Cloudflare Stream and embedded with Cloudflare's video player. The provider is Cloudflare, Inc. (see section 2). The player is only loaded when you scroll close to the video. From that point on, your browser fetches the player, the preview image and technical information about the video (for example the available quality levels) from customer-f0libhkluofgos1j.cloudflarestream.com. In doing so, Cloudflare receives your IP address, your browser identification (user agent) and the referring page (referrer), which here is the address of the Dashboard.

The video does not start automatically. Picture and sound are only transmitted when you press play. Cloudflare may record playback data, for example how long the video was played, as well as error reports from the player. We only see aggregated figures, for example views and minutes watched.

The player does not set cookies. Once playback starts, it stores an estimate of your bandwidth in browser storage in order to choose a suitable video quality (see section 7).

• Purpose: providing the video in a quality suited to your connection.
• Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest lies in making the video reliably available to you without operating our own video infrastructure.

We want to know how the Dashboard is used and want to show visitors that others are using it too. We do this without identifying anyone.

Cloudflare Web Analytics. To see which pages are viewed and how often, we use Cloudflare Web Analytics. For this purpose, the Dashboard loads a small script from static.cloudflareinsights.com that reports page views and technical loading times to Cloudflare. According to Cloudflare, the service sets no cookies, uses no local storage, does not use fingerprinting and does not store IP addresses for analytics purposes. We only receive aggregated figures, for example page views per page, country or browser type.

Traffic sources and sharing. We also count where visitors come from and how content is shared:

• When the page loads, your browser assigns the visit to a broad category (for example "X", "Reddit", "search engine" or "direct"). To do so, it evaluates the referring page, a utm_source or ref parameter in the address and, where applicable, the identification of an in-app browser, all locally on your device. The traffic-source payload contains only the broad category, not the original referring page or the user agent. Separately, requests include technical headers that may contain browser information and the Dashboard URL, as described in section 2. Reloading the page is not counted.
• When you share, copy or download a link or a graphic, we count the method (share menu, copy, download) and what was shared (the link or a specific graphic). We do not learn which app you share with.

For each day, category and country, our database stores only a counter; no record is created per visit.

Interactions and live notices. The Dashboard displays short notices such as a German flag followed by "S/o started remigration", together with totals (for example likes or visits today). When you start a simulation, tap "like", show interest in donating or download a graphic, we store an event consisting of its type, the country and the time. The event record contains no visitor IP address or visitor hash. Technical request logs are processed separately as described in section 2. A notice names the country that Cloudflare derives from your IP address; if no country can be determined (for example for an unknown address or when Tor is used), it simply says "Someone …". Small numbers are not shown exactly.

The country stored with counters and events is the one Cloudflare derives from your IP address; the IP address itself never reaches our database. Our database is operated by Neon (see section 8) and is located in Frankfurt am Main, Germany.

Pusher. So that notices appear without reloading the page, your browser opens a WebSocket connection to the Pusher Channels service. In doing so, Pusher technically receives your IP address and browser information. Messages distributed via Pusher contain activity notices and totals. Depending on the notice, they include an event identifier, interaction type, country and timestamp, and, for donations, the total donated so far. They do not contain visitors’ IP addresses or donor names or e-mail addresses. Pusher is operated by Bird B.V., Keizersgracht 268, 1016 EV Amsterdam, Netherlands. Your browser connects to Pusher's EU cluster, which is hosted in Ireland.

• Purpose: measuring the reach of the Dashboard, understanding through which channels it is found and shared, and displaying live activity and totals.
• Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest lies in improving the Dashboard, assessing the effectiveness of our public communication and offering an interactive service that shows how the Dashboard is being used, without identifying visitors. Technical connection data associated with these requests is processed as described in section 2.

Under "Help & Contact" you can write to us to get involved or to give feedback on the Dashboard. We process your name, e-mail address and message, the type of enquiry (involvement or feedback), for involvement the area concerned (for example IT, design or data), and the country from which you are writing, which Cloudflare determines and our server adds to the message.

This information is not stored in our database. Our API sends it as an e-mail via Google Workspace (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) to the mailbox dashboard@remigration-institute.com, with your address set as the reply address. The message is then kept in that mailbox.

• Purpose: handling your enquiry.
• Legal basis: Art. 6(1)(b) GDPR where you are interested in getting involved (steps taken at your request prior to entering into an agreement); otherwise Art. 6(1)(f) GDPR. Our legitimate interest lies in answering enquiries and feedback.
• Required information: name, e-mail address and message are mandatory fields. Providing them is neither a statutory nor a contractual requirement, but without them we cannot answer you and the form cannot be sent.

Donations to the project are made via the platform GiveSendGo (givesendgo.com). The donation button is an ordinary link: you leave the Dashboard only when you click it, and the donation itself takes place entirely on GiveSendGo's website. GiveSendGo is responsible for everything that happens on its platform, and its privacy policy applies. Any data you enter there is received by GiveSendGo, not by us.

To display donation progress and notices such as "… donated so far", our server retrieves only the campaign's current total and goal from GiveSendGo, roughly every two minutes. No names, e-mail addresses, amounts of individual donations or other data about donors are retrieved or stored.

• Purpose: displaying donation progress and the total donated so far.
• Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest lies in transparently showing the progress of the campaign.

We use the following browser-storage entries to remember interface settings and to support the live-notice connection and video playback:

• ifr-language (localStorage): the language you selected; kept until you delete it in your browser.
• ifr-intro-seen (sessionStorage): records that you have already seen the introduction; deleted when you close the tab.
• ifr-remigration-cta-seen (sessionStorage): records that you have already seen a highlight animation; deleted when you close the tab.
• pusherTransportTLS (localStorage): stores technical connection information so Pusher can reuse a suitable transport. The cached information is treated as expired after 30 minutes but may remain in browser storage until overwritten or deleted. It is not a visitor identifier.
• stream.estimatedBandwidth (localStorage of the Cloudflare Stream video player): an estimate of your bandwidth that the player uses to choose a suitable video quality; only created when you play the video on the "What to do?" page, and kept until you delete it in your browser. It is not a visitor identifier.

This storage is strictly necessary to provide the function you requested (your language, no repeated overlays, playing the video) and therefore does not require consent under § 165(3) of the Austrian Telecommunications Act 2021 (TKG 2021). Any further processing is based on Art. 6(1)(f) GDPR.

Apart from the video on the "What to do?" page (section 3), the Dashboard does not load external fonts (fonts are served from our own server), external map services, embedded third-party content or captchas.

We use the following service providers as processors and have concluded data processing agreements with them in accordance with Art. 28 GDPR.

• Cloudflare, Inc., USA: delivery, security, forwarding to the API, web analytics, video playback (Cloudflare Stream).
• FastAPI Labs, Inc., USA: operation of the API (FastAPI Cloud).
• Neon LLC (a Databricks, Inc. company), USA: database, stored in Frankfurt am Main, Germany (AWS eu-central-1).
• Bird B.V., Netherlands: live notices (Pusher Channels; Pusher is a Bird company).
• Google Ireland Limited, Ireland: sending e-mail and the mailbox (Google Workspace).

GiveSendGo is not a processor; it is itself responsible for processing donations.

Links to other services (for example GiveSendGo, X, Telegram, Instagram, save-europe-act.com and the Institute's website) transmit data to those providers only when you click them, and their privacy policies then apply.

Some service providers are based outside the European Union or may process data there:

• Cloudflare is certified under the EU-U.S. Data Privacy Framework (adequacy decision, Art. 45 GDPR); in addition, Cloudflare's data processing agreement contains standard contractual clauses.
• FastAPI Labs operates FastAPI Cloud in the USA; our API runs on servers there. Transfers are based on standard contractual clauses (Art. 46(2)(c) GDPR); we have not been able to establish a Data Privacy Framework certification.
• Neon stores our database in Frankfurt. For any access from the USA, Neon relies on the Data Privacy Framework and standard contractual clauses.
• Pusher (Bird B.V.) is based in the Netherlands; the connection is handled in Pusher's EU cluster in Ireland. Where Bird engages sub-processors (including affiliates) outside the EEA, it relies, according to its data processing agreement, on the Data Privacy Framework or standard contractual clauses.
• Google: Google LLC is certified under the Data Privacy Framework; Google Workspace additionally uses standard contractual clauses.

You can obtain a copy of the safeguards referred to above by contacting us at the address given in section 1.

Statutory retention obligations remain unaffected.

Vis-à-vis the controller, you have the right to:

• access (Art. 15 GDPR),
• rectification (Art. 16 GDPR),
• erasure (Art. 17 GDPR),
• restriction of processing (Art. 18 GDPR),
• data portability (Art. 20 GDPR),
• object, on grounds relating to your particular situation, to processing based on Art. 6(1)(f) GDPR (Art. 21 GDPR).

Because we store no identifiers for visits and interactions, we are generally unable to attribute such data to a person (Art. 11 GDPR). We can, however, respond to requests concerning contact messages. Please write to contact@remigration-institute.com.

You have the right to lodge a complaint with a data protection supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement (Art. 77 GDPR). The authority competent for us is:

• Austrian Data Protection Authority (Österreichische Datenschutzbehörde)
• Barichgasse 40–42, 1030 Vienna, Austria
• Telephone: +43 1 52 152-0
• E-mail: dsb@dsb.gv.at
• Website: https://www.dsb.gv.at

We will update this privacy statement when the Dashboard or the legal situation changes. The date of the current version is shown on this page.

This privacy statement is available in several languages. In case of discrepancies between language versions, the English version prevails.