FULLER PROJECT PRIVACY STATEMENT

The Fuller Project for International Reporting, Inc. (referred to herein as “Fuller Project”, “we,” “us,” or “our”) have created this privacy statement in order to demonstrate our commitment to privacy and data protection. Your right to privacy and data security is very important and we endeavour always to comply with applicable data protection and privacy laws, including the EU General Data Protection Regulation (GDPR).

This privacy statement sets out the basis on which any personal data we collect from you, or that is provided to us, will be processed by us.

This privacy statement applies to all online systems offered by Fuller Project to the public, through our website fullerproject.org and other websites (including our official pages on social media) we operate or use to deliver our services. This policy also applies to any other processing of personal data in a context where we refer you to this privacy statement.

Fuller Project for International Reporting Belgium, a non-profit organization (vereniging zonder winstoogmerk) organized under Belgian law, registered with the Belgian Crossroads Bank for Enterprises under number 1033.115.821, is the data controller for purposes of the GDPR to which the policy refers. Our full details can be found at the end of this policy and please feel free to contact us with any questions related to it.

Please find below further information regarding the personal data you provide us and your rights in relation to the provision of such personal data. 

• Information Gathering And Usage
• Your Rights
• Security
• Opting Out
• Cookies
• Contact Details
• Changes In This Privacy Statement

INFORMATION GATHERING AND USAGE

Your personal data
We intend to give you as much control as reasonably possible over your personal data (meaning any information that relates to you as an individual and could reasonably be used to identify you). There are times when we may need to collect and process personal data from you, including in order to offer our services. 

The type of personal data we might collect from you includes:

• Identity: First name, last name, age or date of birth.
• Contact: Neighborhood, city, state, country, zip or postal code, email address, phone number or billing address.
• Usage: User interactions on the website, cookies, IP address or analytics (interaction with ads, duration of visit, traffic source, pages visited). Please note that our website includes embedded YouTube videos. When you interact with this content (e.g., by playing a video), YouTube may collect information about you, including watch history and cookies, in accordance with YouTube’s Privacy Policy. We do not control or have access to any data collected by YouTube through these embedded videos.
• Financial: Credit card information (credit card number, expiration date and code).
• Marketing and Communications: Marketing preferences, survey information, information provided by you when you contact us. 
• Technical: Information on the mobile telephone or device used to access the Fuller Project website. This might include geolocation, device information and browser type. For logged-in users, the website may deploy first-party cookies for technical or functional purposes, including to authenticate user sessions, ensure account security, and preserve individualized dashboard preferences as well as other third party tracking technologies (e.g., pixels, web beacons) as further described herein. For more information, see the section titled “COOKIES AND OTHER TRACKING TECHNOLOGIES” below.

We may collect your personal data when you: 

• Make a donation to us.
• Visit our website or register as a new user. 
• Follow or interact with us on social media.
• Subscribe to our newsletter.
• Apply for a job or internship with us.
• Read one of our articles.
• Make a request or inquiry.
• Complete a survey.

We use the information we collect from you to:

• Operate, maintain and improve the Fuller Project website via data analytics and deliver relevant website content and measure or understand the effectiveness of them, as well as for troubleshooting, testing, system maintenance, support, reporting and hosting of data.
• Communicate with you online or offline.
• Manage your Fuller Project membership, which includes new user registrations. 
• Send the newsletter to our subscribers.
• Process any donations and manage funding and sponsorships.
• Notify you about changes to our terms or privacy policy.
• Allow you to participate in surveys or competitions. 
• Manage the progress of any employment or internship applications.
• Fulfil any legal or regulatory obligations.

In some instances, we will collect personal data from you when we need this information in order to provide a service to you. In such instances, failure to provide your personal data may mean that we are not able to provide the services you requested. 

We do not perform any automated decision making activities, including profiling, where your personal data is processed by automated means in a manner which produces legal effects concerning you or that would otherwise similarly significantly affect you.

Why we process your personal data
Data protection law requires us to have a lawful basis for using your personal data. The basis we rely on depends on the type of data and how we use it.

• Legitimate interests: In some cases we will process your personal data for the purposes of legitimate interests, rather than seeking your consent. This is largely so that we can efficiently provide you with services without having to seek individual consent for everything we do. 
• Contract: We will process your personal data insofar as it is required to perform our contractual obligations or to act on your requests before a contract is formed.
• Legal obligation: We will process your personal data to meet our legal duties, including preventing fraud or money-laundering, and when required by law or a court order.
• Consent: In limited circumstances, before collecting personal data from you or sending you electronic communications, we will ask you for your consent. You may withdraw your consent at any time, by contacting us using the contact details below. 
• Public interest: We process your personal data when necessary for the performance of a task carried out in the public interest, namely the production and publication of investigative journalism that serves the public interest.

How we process data in the context of our journalism
As part of our journalistic activities, we may process personal data relating to various individuals, including contributors to our work, confidential sources and persons who are the subject of our reporting and investigations.

Where circumstances permit and as appropriate in our reasonable judgment, such as when individuals voluntarily share information with us for our reporting, we may request informed consent regarding how information and contributions may be used in our published work. In such cases, we will do our best to clearly explain how we intend to use the information, including whether individuals will be identified or quoted. We recognise that sources may have different levels of comfort with how their information is used, and we work to respect those preferences whilst fulfilling our journalistic mission.

If we do not obtain prior consent, we generally process personal data for our journalism on the basis of legitimate interests in producing independent journalistic content and fulfilling our mission as a non-profit journalism organisation. We are committed to handling all personal data responsibly and in accordance with applicable data protection laws and applicable best journalistic practices and deontological principles.

For how long we keep your personal data
Fuller Project will retain your personal data only for so long as is necessary in order to fulfil the applicable purpose for which it was collected. 

The main criteria we use to determine the retention period is as follows: 

• how long we need to keep the data to fulfil the purposes for which we are using it;
• whether there are contractual or legal obligations that exist that require us to retain the data for a specific period of time;
• whether there is an ongoing legal claim that relates to any products or services we have provided or received, or that is related to your relationship with us; and
• whether the data is sensitive or special category data (as defined in applicable data protection laws), in which case we would generally apply a shorter retention period.

We will generally ensure that the period for which we store your personal data is limited to a strict minimum. For further information on how long we will store your personal data in any particular case, please do not hesitate to contact us using the contact details below.

Parties with whom we share your personal data
We may share the personal data that you provide us to our service providers, to the extent necessary for the purpose of providing services to you or another purpose identified above. This may include the provision of your personal data to third-party service providers (such as BambooHR for human resources management, Bonterra for fundraising, and Mailchimp for the distribution of newsletters), banks or other payment processors (such as Stripe and Apple Pay for online payments), accountants, cloud storage providers and external consultants such as public relations and legal advisors. We may also provide your personal data to any successor to our organization or any third party where we have your consent to do so. 

We will not sell or rent your personal data for any monetary consideration. 

Links to third-party websites or services
Our website may contain links to other websites or services. However, once you have used these links to leave our website, you should note that we do not have any control over that other website or service. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites or using such services and such websites and services are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website or services in question.

Where we store your personal data
We may transfer your personal data to, or store it in, a destination outside of Europe. This is because Fuller Project is globally active, with activities located in various jurisdictions, which uses service providers based in a number of locations worldwide. In some cases, your personal data will be stored in or transferred to jurisdictions outside of the European Economic Area (EEA) (a “third country”), where data protection laws are not as stringent as the applicable laws under the EEA regime. For example, we may from time to time transfer personal data to our affiliated not-for-profit entity in the United States of America.

Where we have to transfer your personal data to third countries, we will use appropriate approved safeguards or we will seek your explicit consent.  

For further information please do not hesitate to contact us using the contact details below.

Electronic newsletters
We offer a free electronic newsletter. Users can sign up by clicking on the “NEWSLETTER” button on the homepage and then subscribing with their email. After submitting your email, you will receive a confirmation email requiring you to opt in and verify your subscription before being added to our mailing list.

We do not spam, sell or rent email addresses, and there’s an easy unsubscribe in every email you’ll receive. Alternately you may remove your address from our mailing lists by sending an email to contact@fullerproject.org. 

California Shine the Light Law
Under California Civil Code Section 1798.83, California residents who have an established business relationship with us have the right to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes during the preceding calendar year. We do not currently disclose personal data to third parties for their direct marketing purposes. If our practices change, we will update this privacy statement and provide you with the ability to opt out of such disclosures.

YOUR RIGHTS UNDER THE GDPR

If our processing of your personal data is governed by the GDPR, you have the following rights in relation to such personal data:

Access. You may contact us at any time in order to request access to the personal data we hold about you. 

Rectification. If the information we hold appears to be inaccurate or out of date, you can ask us to correct or complete your personal data by contacting us at any time.  

Restriction. In certain circumstances, it may be possible to require us to limit the way in which we process your personal data. Such circumstances include:

• where you think the data, we hold about you is inaccurate, processing can be restricted while it is being rectified; 
• where you object to our processing, (which is being carried out on the grounds that it is necessary in the public interest or for the purposes of legitimate interests) processing can be restricted while we determine whether such grounds override your interests
• where processing is unlawful but you oppose the erasure and request restriction of your data instead; and 
• where we no longer need the personal data but you require the data in order to establish, exercise or defend a legal claim, our processing can be restricted.

Erasure. You may ask to have the information on your account deleted or removed. However, we must keep track of certain transaction information for legal compliance purposes, so we may not be able to fully delete your information in certain circumstances. 

Receiving your personal data. You may also ask us to send you the personal data we hold on you in an electronic, structured and user-friendly format, or you may ask us to send this data to another person.  Please note that if you choose to ask us to send your personal data to you or another party, this may impact our ability to provide the products and services you requested.

Object. Where we are processing your personal data without your consent to pursue the purposes of legitimate interests, you may object to us processing your personal data. In particular, where we are using your personal data to contact you for marketing purposes, you may object to such processing at any time. 

Automated decision-making. You have the right to be informed of any automated decision-making, including profiling, used in connection with your personal data, and we will provide information about the logic we apply, as well as the significance and consequences of such processing.

The rights described above are subject to certain exceptions under data protection law. In particular, where we process personal data for journalistic purposes, some or all of these rights may be limited or restricted in accordance with Article 85 of the GDPR and applicable national laws implementing this provision, including Article 24 of the Belgian Law of 30 July 2018 relating to the protection of natural persons with regard to the processing of personal data. 

For any of the requests listed above, please contact us using the contact details below. We will make reasonable efforts to respond promptly and at the latest within one month. Our response to such requests may be limited to information under our direct control.

Complaints. If you believe that our processing of your personal data is in breach of data protection law, please reach out to us at the contact details below. You also have the right to lodge a complaint with the Belgian data protection authority.

SECURITY

Security measures
We have security measures in place to help protect against the loss, misuse, and alteration of the information under our control. While we cannot guarantee that loss, misuse, or alteration to data will not occur, we ensure that our systems adhere to reasonably security standards so as to help safeguard against such occurrences. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. We will use commercially reasonable means to protect your personal data, but we cannot guarantee its absolute security. 

Children’s privacy protection
Fuller Project does not target and its websites are not intended for children under the age of 16. Fuller Project will not knowingly collect personal data from children and will delete such data upon discovery. Where Fuller Project requires personal data pertaining to children for the purpose of providing a service, the consent of an adult with parental responsibility for that child will be required. 

OPTING OUT

If you do not wish to receive certain communications from us you may opt out by: informing us (using the contact details below) that you no longer wish to receive such communications or following the opt out instructions that we include in each of our communications with you. We will comply with such requests unless such communications from us are required by law or do not require your consent under applicable laws. Your opting out may restrict our ability to provide you with the full extent of our services.

COOKIES AND OTHER TRACKING TECHNOLOGIES

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. We use cookies and similar technologies for purposes such as remembering user preferences and settings, determining the popularity of content, inviting users to fill in surveys, delivering and measuring the effectiveness of advertising campaigns, and analyzing traffic to our Site. For example, we may also use web beacons (also referred to as pixel tags or clear GIFs), which are small pieces of code placed on a website or within the body of an email for the purpose of tracking activity on websites, or when emails are opened or accessed, and are often used in combination with cookies.

To help us understand how people use our website and make improvements, we use a service called Google Analytics. This service uses cookies to collect information about your visit, such as which pages you view, your interaction on the website, your general location, and technical details about your device and browser. You can learn more about how Google handles this information on their website: http://www.google.com/policies/privacy/partners/. If you would prefer to opt out of Google Analytics tracking, you can find more information on their website here: https://tools.google.com/dlpage/gaoptout.  In addition, and as noted above, our website includes embedded YouTube videos. When you interact with this content (for example, by playing a video), YouTube may collect information about you, including watch history and other personal information, such as identifiers, collected via cookies, in accordance with YouTube’s Privacy Policy, and may be used to facilitate or assist with marketing and advertising campaigns. We do not control or have access to any data collected by YouTube through these embedded videos. 

Please note that if your browser permits, you may configure your browser to refuse or delete cookies, or to alert you when cookies are being sent. If you choose to turn off cookies, however, some parts of the Site may not function properly. In addition, you can control the collection of information collected via cookies and other tracking technologies by adjusting your privacy settings in our cookie management tool (the persistent cookie-shaped button at the bottom left of our website screen).

Do Not Track Disclosure.  As explained above, third parties such as advertising networks, analytics providers and widget providers may collect information, including your personal data, about your online activities over time and across different websites when you access or use our services.   Currently, various browsers offer a “Do Not Track” option, but there is no standard for how “Do Not Track” should work on commercial websites.  Due to lack of such standards, our site does not respond to “Do Not Track” consumer browser settings.

CONTACT DETAILS

If you would like to get in touch with us with regards to your personal data, please email us at contact@fullerproject.org or contact us at:

Fuller Project for International Reporting Belgium
CBE 1033.115.821
Muilenstraat 1, box 2
1770 Liedekerke
Belgium

CHANGES IN THIS PRIVACY STATEMENT

This statement was last updated on February 03, 2026. If we decide to change our privacy policy, we will post those changes to this privacy statement on our website and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you by email or by means of a notice on our website home page.