Privacy Policy

1. Data controller

The data controller for personal data processed through the websites is:

Prisoners Defenders is an association established in Spain, declared of public utility by the Spanish Ministry of the Interior.

2. Purpose of this Privacy Policy

This Privacy Policy aims to inform users about how Prisoners Defenders collects, uses, retains and protects personal data that may be provided through its websites, contact channels, forms, content subscriptions, institutional communications or specific channels established within the framework of its active legal defence of human rights activity.

3. Personal data that may be processed

Depending on the channel used and the purpose of the communication, the data processed may include:

• Identifying data (name and surname).
• Contact data (email, phone, postal address).
• Professional or institutional data when acting on behalf of an entity, media outlet, organisation or institution.
• Data freely included by the user in communications, requests, messages or forms.
• Technical data necessary for browsing and website security (IP address, technical identifiers, connection data, browser functional information).
• Data related to content subscriptions.

Prisoners Defenders does not request more data than necessary.

4. Channels through which data may be collected

• Content subscriptions.
• Complaint, case or specific communication forms when available.
• Press contact.
• Emails sent to Prisoners Defenders corporate addresses.
• Telephone communications.
• Specific forms enabled on the websites for specific purposes.
• Institutional channels used by Prisoners Defenders for its objectives.

5. Purposes of processing

5.1. Handling enquiries and communications

Managing, responding to and following up on communications received by email, phone, forms or any other enabled channel.

5.2. Content subscriptions

Managing the subscription requested by the user to receive content, informational communications, updates, documents or publications from Prisoners Defenders. These communications are not commercial in nature.

5.3. Press contact

Handling requests from media outlets, journalists, entities or professionals interested in information, statements, reports or institutional content from Prisoners Defenders.

5.4. Management of complaints, cases or specific communications

Receiving, analysing, managing and following up on communications, forms, complaints, cases or information related to the active legal defence of human rights. When communications may affect persons at risk, enhanced confidentiality and data minimisation criteria will be applied.

5.5. Security and website operation

Managing technical operation, maintaining system security and preventing unlawful uses, attacks or unauthorised access.

5.6. Compliance with legal obligations and defence of rights

Complying with applicable legal obligations, responding to requests from competent authorities and preserving the legal security of the organisation.

6. Legal basis

• Consent of the data subject: when the user subscribes to content, voluntarily submits a communication or uses specific forms.
• Legitimate interest of Prisoners Defenders: to handle received communications, protect website security and carry out its institutional human rights defence activity.
• Compliance with legal obligations: when processing is necessary to comply with applicable rules or respond to legally required requests.
• Defence of rights and claims: when processing is necessary to formulate, exercise or defend claims linked to the active legal defence of human rights.

7. Processing of sensitive information

Prisoners Defenders develops activities linked to the active legal defence of human rights. In certain cases, communications received may contain sensitive, reserved or particularly delicate information. When information is received that may affect persons, sources, victims, relatives, whistleblowers, witnesses or third parties at risk, Prisoners Defenders will apply appropriate confidentiality and protection measures, including restricted access, data minimisation and non-disclosure of sensitive or at-risk sources.

8. Data retention

Personal data will be retained for as long as necessary:

• Contact data: as long as needed to handle the enquiry or communication.
• Subscription data: while the user keeps the subscription active or until unsubscription is requested.
• Data linked to human rights complaints or cases: as long as necessary for the legitimate purposes of documentation, analysis, follow-up or legal defence.
• Technical and security data: as long as needed to ensure the operation and security of the websites.

9. Recipients

Prisoners Defenders does not generally transfer personal data to third parties unless necessary for the relevant purpose, there is a legal obligation, the user has authorised it or another valid legal basis exists. Data may be processed by technical providers acting as data processors for services necessary for the operation of the websites, email, hosting, security or technical support.

10. International transfers

Prisoners Defenders may use technical services or platforms involving processing or access to data from countries outside the European Economic Area. International data transfers will be made with appropriate safeguards under applicable law, through legally recognised mechanisms.

11. Users' rights

Users may exercise the following rights:

• Right of access to their personal data.
• Right to rectification of inaccurate or incomplete data.
• Right to erasure.
• Right to object.
• Right to restriction of processing.
• Right to data portability, where applicable.
• Right to withdraw consent, where processing is based on consent.

To exercise these rights: legal@prisonersdefenders.org

12. Complaints to supervisory authority

Users may lodge a complaint with the Spanish Data Protection Agency (AEPD) if they consider that processing of their personal data does not comply with applicable regulations.

13. Security and confidentiality

Prisoners Defenders applies organisational and technical measures to protect information against unauthorised access, loss, alteration, misuse or unauthorised disclosure. Prisoners Defenders maintains confidentiality criteria regarding sensitive or at-risk sources and restricts access to information to persons or collaborators who need it for the relevant purpose.

14. Accuracy of data

The user declares that data provided to Prisoners Defenders is accurate, true and up to date, and undertakes to communicate any relevant changes.

15. Minors

Prisoners Defenders does not direct its websites at minors and does not generally request data from minors. If data relating to minors is provided in the context of a human rights communication, such data will be processed with special caution, minimisation, confidentiality and enhanced protection.

16. Non-commercial communications

Prisoners Defenders does not conduct commercial campaigns, does not sell products or services, and does not use user data for commercial purposes. Communications sent to subscribed users will be informative, institutional or documentary in nature. Users may unsubscribe by writing to legal@prisonersdefenders.org.

17. Changes to this Privacy Policy

Prisoners Defenders may modify this Privacy Policy when necessary to adapt to regulatory, technical, organisational or operational changes. The current version will be the one published at any given time on the websites.

Entry into force: April 2019 · Last revised: 25/06/2025