PRIVACY POLICY

Last updated March 27, 2026

This privacy notice for Free Russians e.V. (“Association,” “we,” “us,” or “our”) explains how and why we process information when you use our services (“Services”), including the Belka mobile application (“Belka App” or “App”).

Belka is designed as a privacy‑preserving tool for polls and voting in small private groups. The system is built to minimize personal-data processing and to avoid linking a voter’s identity to their vote.

If you do not agree with this notice, please do not use the Services. For questions, contact contact@freerussians.org.

SUMMARY OF KEY POINTS

What personal information do we process? We process minimal personal information. In ordinary use, this is limited to your email address and authentication data required to access the App.

Do we process sensitive personal information? We do not process poll or voting answers as readable responses linked to a user identity. Votes are encrypted on the user’s device and handled as anonymous data. Depending on the subject of a poll, submitted data may still be considered sensitive under applicable law.

How do we process your information? We process limited account and technical data to operate the App, authenticate users, ensure security, and comply with legal obligations. Voting data is processed only in encrypted form.

Do we share your information? We do not sell or share personal data for advertising. Limited processing by infrastructure providers may occur.

What are your rights? Depending on your jurisdiction, you may have rights to access, correct, or delete your personal data.

1. CONTROLLER INFORMATION

Free Russians e.V. Email: contact@freerussians.org

We are the data controller responsible for processing your personal information under applicable data protection laws.

2. SYSTEM PRIVACY DESIGN

Belka is designed with a separation of responsibilities:

• Identity verification (if used) is handled by a registrar component
• Ballot collection and tallying are handled by the voting server

The voting server does not maintain a database linking voter identity to ballots. As a result:

• We cannot determine how a specific user voted
• Votes are processed only as encrypted data and aggregated results

3. WHAT INFORMATION DO WE COLLECT?

3.1 Personal information you provide

We collect personal information that you voluntarily provide when you:

• create an account
• sign in
• contact us

This includes:

• email address
• authentication data

If you contact us, we may also receive any information you include in your message.

3.2 Poll and voting data

When you participate in polls or votes:

• Your selections are encrypted on your device before transmission
• We do not store readable vote content linked to your identity
• The system processes encrypted ballots and cryptographic proofs required to validate and tally results

3.3 Technical data

We may process limited technical data necessary to operate the service, such as:

• IP address
• device type
• operating system
• request metadata

This data is used only for service delivery, security, and troubleshooting.

4. ON-DEVICE DATA STORAGE

The App stores certain data locally on your device to enable voting functionality. This may include:

• authentication tokens
• election credentials
• cryptographic keys used to create ballots
• ballot receipts and verification data

This data:

• is stored locally on your device
• is not transmitted in readable form to the server
• is used solely to enable participation and verification

You can remove this data by logging out, clearing app storage, or uninstalling the App.

5. HOW WE PROCESS YOUR INFORMATION

We process your information to:

• create and manage accounts
• authenticate users
• operate polls and voting workflows
• ensure system integrity and security
• respond to support requests
• comply with legal obligations

Voting data is processed exclusively in encrypted form and is not used for profiling or tracking individuals.

6. LEGAL BASES

We rely on the following legal bases under GDPR:

• Contract performance – to provide the App
• Legitimate interests – to secure and improve the service
• Legal obligations – where required
• Consent – where applicable

7. SHARING OF INFORMATION

We do not sell or share personal data with advertisers or data brokers.

We may rely on the following service providers:

• Cloud infrastructure providers (hosting and security)
• App distribution platforms (Google Play, Apple App Store)

Voting data is never shared as readable individual responses.

We may disclose information if required by law or to protect the security of the Services.

8. DATA RETENTION

We retain personal data only as long as necessary to:

• provide the service
• maintain account functionality
• comply with legal obligations

Encrypted ballots and public election data may be retained for verifiability and audit purposes.

When no longer needed, data is deleted or anonymized.

9. ACCOUNT DELETION

You may request deletion of your account and associated personal data by contacting:

contact@freerussians.org

Upon request, we will:

• delete or deactivate your account
• remove associated personal data from active systems

Some data may be retained where required for legal or security purposes.

10. SECURITY

We implement technical and organizational safeguards, including:

• encryption of voting data
• separation of identity and voting processes
• cryptographic verification mechanisms

However, no system can guarantee absolute security.

11. MINORS

We do not knowingly collect data from individuals under 18 years of age.

12. YOUR RIGHTS

You may have rights to:

• access your data
• correct your data
• delete your data
• restrict processing
• object to processing

To exercise your rights, contact: contact@freerussians.org

13. UPDATES

We may update this policy. Changes will be reflected by the updated date.

14. CONTACT

Free Russians e.V. Email: contact@freerussians.org

15. DATA REQUESTS

To access, update, or delete your data, contact: contact@freerussians.org