Friday, May 8, 2026
LIBERTIS
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LIBERTIS

Privacy Policy

This Privacy Policy explains how personal data is collected, used, stored, and protected

when you access or use the website https://libertis.net ("Website").

This document is drafted in accordance with the General Data Protection Regulation (EU)

2016/679 ("GDPR") and applicable ePrivacy rules.

1. DATA CONTROLLER

The data controller responsible for the processing of personal data is:

Company: Libertis

Email: editorial@libertis.net

The Controller determines the purposes and means of processing personal data collected

through the Website.

2. SCOPE OF THIS POLICY

This Privacy Policy applies to:

  • Visitors of the Website
  • Subscribers to newsletters or editorial communications
  • Users interacting with CMS-generated content or forms

    • It does not apply to third-party websites that may be linked from this Website.

    3. PERSONAL DATA WE COLLECT

    We limit data collection to what is strictly necessary.

    3.1 Data provided directly by the user

    We collect:

  • Email address (when subscribing to newsletters or editorial updates)

    • No additional personal data is required to use the Website.

    3.2 Data collected automatically

    When you access the Website, aggregated and non-personal technical data is collected automatically through Plausible Analytics:

  • Device type and browser family
  • Pages visited and navigation patterns
  • Referral source
  • Country-level location (derived from IP at ingestion; IP is not stored)

    • No IP addresses are stored. This data is aggregate-only and cannot be used to identify individual users.

    When you submit a subscription form, your IP address is transiently transmitted to Cloudflare for bot-protection verification via Cloudflare Turnstile. The IP is not stored by us and is not retained by Cloudflare beyond the verification request.

    4. PURPOSE OF PROCESSING

    Personal data is processed for the following purposes:

  • Providing newsletter and editorial communications
  • Delivering news updates and content distribution
  • Improving Website performance and content quality
  • Ensuring technical functionality and security
  • Analyzing aggregated usage statistics via analytics tools

    • We do not use personal data for automated decision-making or profiling that produces legal

    or similarly significant effects.

    5. LEGAL BASIS FOR PROCESSING

    We process personal data under the following legal bases:

    5.1 Consent (Article 6(1)(a) GDPR)

    Email addresses are processed based on explicit consent provided by the user when

    subscribing to newsletters or updates.

    Consent may be withdrawn at any time without affecting the lawfulness of processing prior to

    withdrawal.

    5.2 Legitimate interest (Article 6(1)(f) GDPR)

    We may process limited technical and analytics data based on legitimate interest for:

  • Website performance monitoring
  • Security and fraud prevention, including bot protection via Cloudflare Turnstile
  • Improvement of content and user experience

    • We ensure that such interests are balanced against the rights and freedoms of users.

    6. ANALYTICS AND TRACKING TECHNOLOGIES

    The Website uses Plausible Analytics to understand how visitors interact with our content and to improve our services.

    Plausible Analytics is a privacy-friendly, cookieless analytics tool. It does not use cookies, does not store IP addresses, and does not track users across sessions or devices. All data collected is aggregated and cannot be used to identify individual users.

    The data processed includes:

  • page views and navigation patterns
  • referral sources
  • device type and browser family
  • country-level location (derived from IP, which is not stored)
  • session duration

    • Since no personal data is collected or stored, this tool does not fall under the personal data definition of Article 4(1) GDPR, and no user consent is required under Article 5(3) of Directive 2002/58/EC (ePrivacy Directive).

    Plausible Analytics is operated by Plausible Insights OƜ, registered in Estonia, EU. Data is processed and stored on EU-based servers. No international transfers of personal data occur in connection with this service.

    For more information, see https://plausible.io/data-policy

    7. COOKIES AND LOCAL STORAGE

    The Website does not use cookies of any kind ā€” no analytics, tracking, or session cookies.

    The Website uses the browser's localStorage exclusively for functional purposes:

  • Interface language preference
  • Content language preference
  • Email address (stored locally to support subscription functionality, based on user consent)
  • Action token (a temporary security token used during subscription flows)

    • This data is stored locally in your browser and is not transmitted to our servers beyond its intended functional use. It does not require consent under Article 5(3) of Directive 2002/58/EC (ePrivacy Directive), as it is used solely to provide functionality explicitly requested by the user.

    8. DATA RETENTION

    We retain personal data only for as long as necessary for the purposes described in this

    Policy.

  • Email addresses: retained until the user unsubscribes
  • Analytics data: retained according to provider configuration, typically between 14 and

    • 26 months unless anonymized or aggregated

    After the retention period, data is securely deleted or anonymized.

    9. DATA SHARING AND THIRD PARTIES

    We may share personal data with third-party service providers strictly for operational

    purposes, including:

  • Email distribution platforms
  • Hosting providers and infrastructure services
  • Analytics providers
  • Security and monitoring services

    • These third parties act as data processors under Article 28 GDPR and are bound by

    contractual obligations ensuring data protection and confidentiality.

    We do not sell or rent personal data to third parties.

    9.1 Cloudflare Turnstile

    To protect subscription forms from automated abuse, we use Cloudflare Turnstile. During form submission, the user's IP address is transmitted to Cloudflare, Inc. for bot-verification purposes only. Cloudflare acts as a data processor under Article 28 GDPR. No data is shared with Cloudflare beyond what is strictly necessary for this verification.

    10. INTERNATIONAL DATA TRANSFERS

    Where personal data is transferred outside the European Economic Area (EEA), such

    transfers are safeguarded through appropriate mechanisms, including:

  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Adequacy decisions issued by the European Commission, where applicable
  • Additional technical and organizational safeguards where necessary

    • Cloudflare, Inc. is based in the United States. The transfer of IP address data for Turnstile verification is covered by the EU-US Data Privacy Framework (DPF) adequacy decision issued by the European Commission on 10 July 2023, under which Cloudflare is certified.

    11. DATA SECURITY

    We implement appropriate technical and organizational measures to ensure a level of

    security appropriate to the risk, including:

  • Access control mechanisms
  • Secure authentication and authorization practices
  • Encryption of data in transit where applicable
  • Regular security monitoring and maintenance
  • Principle of least privilege for data access
    • 12. USER RIGHTS UNDER GDPR

    Data subjects have the following rights under GDPR:

  • Right of access (Article 15)
  • Right to rectification (Article 16)
  • Right to erasure ("right to be forgotten") (Article 17)
  • Right to restriction of processing (Article 18)
  • Right to data portability (Article 20)
  • Right to object (Article 21)
  • Right to withdraw consent at any time (Article 7(3))
  • Right to lodge a complaint with a supervisory authority

    • Users may exercise these rights by contacting:

    editorial@libertis.net

    13. DATA PROTECTION PRINCIPLES

    We process personal data in accordance with GDPR principles, including:

  • Lawfulness, fairness, and transparency
  • Purpose limitation
  • Data minimization
  • Accuracy
  • Storage limitation
  • Integrity and confidentiality
  • Accountability
    • 14. CHILDREN'S PRIVACY

    The Website is not intended for individuals under the age of 16. We do not knowingly collect

    personal data from minors.

    15. CHANGES TO THIS PRIVACY POLICY

    We may update this Privacy Policy from time to time to reflect legal, technical, or operational

    changes.

    Any updates will be published on this page with a revised "Last updated" date.

    16. CONTACT

    For any questions regarding this Privacy Policy or the processing of personal data:

    Email: editorial@libertis.net