Introduction

Junkipedia is a tool created by the Algorithmic Transparency Institute (“ATI”, “we”, “us”, “our”), a project of the National Conference on Citizenship. Junkipedia provides a collaborative platform for collecting, monitoring, analyzing, and responding to problematic content online. 

Junkipedia allows users to log instances of problematic content posted online such as mis- and dis- information (“Content”), create an archive of these instances and undertake research, analysis and monitoring of trends in their spread.  Junkipedia is provided for the purposes of public interest archiving, research and/or journalism (“Specified Purposes”) only. 

This Privacy Policy (“Policy”) addresses the personal data processing undertaken through Junkipedia and the Junkipedia website. This Policy does not address our other data processing operations and does not apply to software or third party applications that Junkipedia integrates. This Policy should be read in conjunction with our Terms of Use. 

This Policy is subject to regular review. Subsequent updates, including any that may be required by law, will be documented below and communicated to data subjects where required. 

Data controller

ATI is the data controller for data processed in connection with this Policy. Our details are:

National Conference on Citizenship

1920 L Street, NW

Suite 450

Washington, DC 20036

Questions or enquiries about this policy can be directed to support@junkpedia.org.

What we process and why

When users create an account with us, we collect your name and email address in order to set up and administrate your account. We may also use your details to send users account-related emails from time to time.  

When you make a submission to us or another organization operating a Junkipedia Tipline (SMS, email or other submission links where Content can be submitted by members of the public) and provide your name or contact information, Junkipedia may use this information to validate your submission and/or contact you to follow up on the submission. 

We may process your personal data to the extent that it is included in any instances of problematic content posted to Junkipedia.

As an account holder, you can also choose to grant us access to your social media and messaging accounts, allowing Junkipedia to monitor the content of public channels and accounts. Enabling this feature will only allow Junkipedia to access public content through these accounts and does not allow Junkipedia to access your messages, contacts or any other information connected to your account. Enabling this feature is optional. 

When you visit our website, we use strictly necessary cookies only in order to manage traffic and keep the website secure. Further information about this is provided in the Cookies section below. 

To the extent that a legal basis needs to be identified under applicable local, national and/or international data protection laws (“Data Protection Laws”), we process your personal data either on the basis of your consent or on the basis of our legitimate interests in operating Junkipedia as a mis- and dis-information archive for the Specified Purposes. 

Data retention

In general, we retain personal data for as long as is required to fulfill the purpose it was collected for. After that time, we delete or irreversibly anonymize personal data.  

Where personal data is collected for the Specified Purposes it may be subject to exemptions and derogations related to research, archiving and journalism under Data Protection Laws that allow it to be retained indefinitely. Safeguards including data minimization and limiting access to the personal data are instituted accordingly.

Sensitive data

We may process sensitive or “special category” data as defined under Data Protection Laws. Typically this would be limited to political opinions or philosophical beliefs. We only process this type of data in the context of submissions of Content made to Junkipedia and on the basis that this had been manifestly made public by the data subject who posted the instance. 

Opting in and out of cookies

The cookies we use on our website are all strictly necessary in order run and secure the website and therefore cannot be opted in or out of. 

Information security

We take steps to ensure that the personal data we process is kept secure and confidential and treated in accordance with this Policy and our Terms of Use. We implement technical and organizational controls to prevent unauthorized access to personal data including limiting access to account and submitter personal data to individuals responsible for administrating accounts and submissions, minimizing personal data to what is necessary for our purposes, encrypting data where possible and instituting security protocols and staff training. Through our Terms of Use and monitoring and vetting processes, we limit access, use, submissions and uploads of Content to Junkipedia strictly in line with the Specified Purposes. While we make efforts to protect personal data, information transmitted over the internet remains vulnerable to interception and for this reason, the transmission of any personal data to our website, via email to us or to Junkipedia is therefore at the data subjects’ own risk.

Data sharing and subprocessors

In administrating our website and Junkipedia, we engage certain third parties for web hosting, email management and other purposes including AWS, Heroku, Twillio, SendGrid, New Relic, and Bonsai. These third parties are engaged on terms which ensure confidentiality and compliance with applicable Data Protection Laws. A list of the processors we engage is available upon request. 

From time to time we may share Content uploaded or submitted to Junkipedia with research partners and other bodies, strictly for the Specified Purposes. To the extent required under Data Protection Laws, these relationships are supported by agreements that ensure these third parties comply with the obligations on them under Data Protection Laws. 

International transfers of data

Where we transfer data subject to applicable Data Protection Laws outside the EU or EEA, we will ensure that it is appropriately protected by entering into a transfer support mechanism with the recipient, for example the European Commission’s Standard Contractual Clauses. 

Third party platforms and websites

Our website includes links to external platforms (Facebook, Twitter and Instagram, Google and YouTube). We are not in control of the way these platforms process your personal data, so we recommend reviewing their respective privacy and cookie policies. 

Your rights

We will comply with your requests to exercise your rights in relation to your personal data to the extent possible and required under Data Protection Laws. These rights may include the right to request access to, rectification or erasure of your data, object to processing, or withdraw your consent, limit the processing of your data and the receive the data you have provided to us. 

You may also have the right to bring concerns to your national data protection supervisory authority if you feel that your personal data has been unlawfully processed. Data subjects based in the EU or UK may also lodge complaints with the supervisory authority in their jurisdiction. Relevant supervisory authority contact details are listed here.   

Please note these rights may only be available to certain data subjects, and only to the extent that any exemption or derogation does not apply to the relevant data processing activities.