top of page
RIL.png
Donate

PRIVACY POLICY


Last updated: 23 July 2026


1. Introduction


Refugees in Libya – APS respects the privacy, dignity and security of every person who visits this website, contacts the organisation, requests support, makes a donation, submits information, collaborates with us or otherwise communicates with us.


This Privacy Policy explains what personal data we collect through this website, why we collect it, how it may be used, how long it may be retained, with whom it may be shared and what rights individuals have under applicable data-protection law.


We recognise that some people who contact Refugees in Libya may be refugees, asylum seekers, survivors of violence, witnesses, human rights defenders or persons facing serious protection risks. Information submitted to us may therefore be particularly sensitive. Such information is handled according to the principles of necessity, confidentiality, data minimisation and restricted access.
This policy applies to the website of Refugees in Libya – APS and to personal data collected through forms, donation functions, subscriptions and other services integrated into the website.


2. Data Controller


The Data Controller responsible for the processing of personal data through this website is:
Refugees in Libya – APS
Via Vicolo Bolognetti 2
40125 Bologna BO
Italy


Italian tax code: 91466600375
Email: info@refugeesinlibya.org


Questions, requests or concerns relating to privacy and personal-data processing may be sent to the email address above.


3. Personal data we may collect


3.1 Information collected when visiting the website


When a person visits the website, the website platform and hosting infrastructure may automatically process limited technical information, including:

​

  • Internet Protocol address;

  • browser and device type;

  • operating system;

  • language and general location settings;

  • date and time of access;

  • pages visited and actions performed;

  • referring website;

  • technical logs, security information and error reports;

  • cookie identifiers and consent preferences.

​

This information is used to operate, secure and maintain the website and to understand technical performance.


3.2 Information voluntarily provided


We may collect information that a person voluntarily submits through a contact form, support form, volunteer form, partnership enquiry, email or other communication channel.


This information may include:

​

  • name and surname;

  • email address;

  • telephone number;

  • country or general location;

  • organisation or professional affiliation;

  • preferred language;

  • the content of the request or message;

  • documents, photographs, recordings or other materials voluntarily submitted;

  • any other information the person chooses to provide.

​

Only information reasonably necessary for the relevant purpose should be submitted.


3.3 Requests for support and protection


People requesting humanitarian, legal, medical, protection or referral support may provide information concerning their personal circumstances.
Depending on the request, this may include:

​

  • nationality or country of origin;

  • migration or displacement history;

  • family circumstances;

  • legal or asylum status;

  • detention history;

  • protection risks;

  • health-related information;

  • information concerning violence, exploitation, torture or other abuses;

  • copies of identity, asylum or administrative documents;

  • contact information for relatives, representatives or trusted persons.

​

Such information may include special categories of personal data under Article 9 of the General Data Protection Regulation.


Refugees in Libya processes such information only where it is necessary for the requested assistance and where a lawful basis and, where required, an additional legal condition for processing sensitive information are present.
Submitting a request for assistance does not give Refugees in Libya permission to publish the person’s identity, testimony, photograph, documents or story. Public use requires a separate assessment and, where applicable, separate and explicit consent.


3.4 Testimonies, documentation and evidence of human rights violations


Refugees in Libya documents human rights violations, conditions of detention, trafficking, interceptions at sea, border violence and other abuses affecting refugees and migrants.


Where a person submits testimony, evidence, photographs, video recordings or documents, we may process the information for purposes including:

​

  • documenting human rights violations;

  • verifying reported incidents;

  • providing referrals or support;

  • supporting advocacy and accountability efforts;

  • communicating with lawyers or authorised human rights organisations;

  • preserving evidence;

  • supporting legal proceedings, complaints or investigations;

  • cooperating with judicial or international accountability mechanisms where lawful and appropriate.

​

Information intended for documentation or accountability is not automatically made public. Decisions concerning publication are made separately, taking into account consent, safety, dignity, necessity, evidentiary integrity and the risk of retaliation.


Where publication could identify a vulnerable person, Refugees in Libya may anonymise, redact, blur, modify or withhold identifying details.


3.5 Donations


When a person makes a donation, we may receive or process:

​

  • donor name;

  • contact details;

  • donation amount;

  • date and payment status;

  • transaction or reference number;

  • billing information;

  • information necessary for accounting, receipts or legal compliance;

  • preferences concerning recurring donations or communications.

​

Electronic payments may be processed by Wix or by another payment provider selected for the website. Refugees in Libya does not normally receive or store complete payment-card numbers, security codes or online banking credentials. Those details are processed directly by the relevant payment provider.
Information concerning bank-transfer donations may also be processed by the organisation’s bank.


The name of the active payment provider and a reference to its privacy information will be added once the online donation system has been selected and activated.


3.6 Newsletter and organisational updates


Where a person voluntarily subscribes to receive news, reports, campaign updates or organisational communications, we may process their name, email address, subscription preferences and information concerning delivery or interaction with the communication.


Subscription to organisational updates is voluntary and may be withdrawn at any time.


3.7 Applications and collaboration enquiries


Where someone applies to volunteer, work, undertake an internship, collaborate or participate in an activity, we may process:

  • identity and contact information;

  • professional and educational information;

  • curriculum vitae;

  • language skills;

  • availability;

  • motivation and areas of interest;

  • references or other application materials.

​

4. Purposes and legal bases for processing


Personal data may be processed for the following purposes and legal bases:


Operating and securing the website


Technical information is processed to provide the website, maintain its security, prevent fraud and abuse, diagnose errors and ensure the stability of the platform.


The legal basis is the legitimate interest of Refugees in Libya in operating a secure and functional website.


Responding to communications and requests


Personal data is processed to respond to enquiries, requests for information, partnership proposals, volunteer applications and other communications.
Depending on the circumstances, the legal basis may be:

​

  • taking steps at the request of the person before entering into an agreement;

  • performance of an agreement;

  • the legitimate interests of the organisation in responding to communications and conducting its activities;

  • consent where consent is specifically required.

​

Providing or coordinating support


Information submitted through a request for support may be processed to assess the request, communicate with the person, provide assistance, make referrals and coordinate with authorised professionals or organisations.
The legal basis may include consent, actions requested by the person, legitimate interests, compliance with legal obligations or, in exceptional emergencies, the protection of vital interests.


Where special-category data is involved, Refugees in Libya will rely on an applicable condition under Article 9 GDPR, such as explicit consent, protection of vital interests, establishment or defence of legal claims, or another condition permitted by law.


Human rights documentation and accountability


Information may be processed to document violations, preserve evidence, support complaints, assist legal representatives, communicate with accountability mechanisms and pursue or defend legal claims.
The legal basis may include consent, legitimate interests, legal obligations, the establishment, exercise or defence of legal claims and other lawful grounds applicable to the specific circumstances.


Processing donations


Donation information is processed to complete the donation, maintain financial records, issue receipts where applicable, administer recurring contributions and comply with accounting, tax, anti-fraud and legal requirements.
The legal basis is the performance of the donation arrangement, compliance with legal obligations and the legitimate interest in administering and protecting the organisation’s finances.


Sending newsletters and updates


Newsletter and campaign communications are sent only where the person has requested or consented to receive them.


The legal basis is consent. Consent may be withdrawn at any time.
Publication of identifiable testimonies or images


Where Refugees in Libya intends to publish a testimony, photograph, video, name or other identifying material supplied by a private individual, publication will ordinarily be based on separate, informed and explicit authorisation, unless another lawful basis clearly applies.


Consent for publication is not treated as consent for unrelated uses.
The GDPR requires controllers to identify their purposes, legal bases, retention criteria, recipients and data-subject rights when personal data is collected. 


5. No advertising, profiling or sale of personal data


Refugees in Libya does not:

​

  • sell or rent personal data;

  • trade personal data with commercial data brokers;

  • use personal data to build commercial advertising profiles;

  • use behavioural advertising cookies;

  • permit advertisers to target visitors through this website;

  • disclose support requests or testimonies for commercial advertising purposes.

  • ​

Information collected for humanitarian, advocacy, documentation, legal, administrative or donation purposes is not repurposed for advertising.


6. Whether providing data is mandatory


Providing personal data is generally voluntary.
However, some information may be necessary for Refugees in Libya to:

​

  • respond to a request;

  • assess a support enquiry;

  • process a donation;

  • issue a receipt;

  • consider a volunteer or collaboration application;

  • comply with legal obligations.

​

Where necessary information is not provided, it may not be possible to complete the requested service or respond fully.
People should not submit unnecessary identity documents, medical records or highly sensitive information through an ordinary contact form.
Where secure communications are necessary, Refugees in Libya may direct the person to a more appropriate communication channel.


7. Recipients of personal data


Personal data may be accessed or received only where reasonably necessary by:

​

  • authorised members, staff or volunteers of Refugees in Libya;

  • website-hosting, technical and information-technology providers;

  • Wix.com Ltd. and relevant Wix service providers;

  • email and communication-service providers;

  • payment providers and banking institutions;

  • accountants, auditors and administrative advisers;

  • legal representatives and authorised human rights organisations;

  • medical, humanitarian or protection organisations where a referral has been requested or authorised;

  • judicial authorities, public authorities or international accountability mechanisms where required or lawfully justified;

  • security or fraud-prevention service providers.

​

Access within Refugees in Libya is restricted according to role, responsibility and necessity.


Information concerning support cases, witnesses or survivors is not made available to the entire organisation merely because it has been submitted to Refugees in Libya.


Wix acts as a service provider for the website and maintains a Data Processing Agreement covering the processing of data belonging to visitors of Wix-hosted websites. Wix may also use authorised subprocessors for platform operations and service delivery. 


8. Sharing information for referrals


Where a person asks Refugees in Libya to make a referral, relevant information may be shared with an appropriate lawyer, humanitarian organisation, medical provider, protection organisation, international body or other trusted recipient.
Only information reasonably necessary for the referral should be shared.


Where possible, the person will be informed before their identifiable information is transferred. In urgent cases involving immediate danger, vital interests or serious safeguarding risks, information may be handled according to the circumstances and applicable law.


9. International transfers


Because Refugees in Libya works across several countries and uses international digital service providers, personal data may in some circumstances be processed outside Italy or the European Economic Area.


Where a transfer occurs, Refugees in Libya and its service providers will rely on a lawful transfer mechanism, such as:

​

  • a European Commission adequacy decision;

  • Standard Contractual Clauses;

  • contractual and organisational safeguards;

  • an applicable legal derogation;

  • explicit consent where legally appropriate.

​

Wix states that visitor information is initially processed by Wix.com Ltd.  in Israel and may subsequently be processed by Wix entities or subprocessors in other countries. Wix states that it uses adequacy decisions, contractual safeguards and Standard Contractual Clauses where required. 


10. Data retention


Personal data is retained only for as long as reasonably necessary for the purpose for which it was collected, subject to legal, safeguarding, evidentiary and accountability requirements.


The following general criteria apply:

​

General enquiries


Ordinary contact and collaboration enquiries will generally be retained for up to 24 months after the last substantive communication, unless continued retention is necessary because a relationship, project, dispute or legal obligation remains active.


Volunteer or application information


Unsuccessful applications will generally be deleted within 12 months, unless the applicant agrees to longer retention or the information remains relevant to an ongoing selection process.


Newsletter information


Subscription information will be retained until the person unsubscribes or withdraws consent. Limited information may be retained afterwards where necessary to record and respect the request not to receive further communications.


Donations and accounting information


Donation, transaction and accounting records may be retained for up to 10 years, or for another period required under applicable tax, accounting or civil law.


The Italian Data Protection Authority gives ten years as an example for records connected with contractual and accounting relationships under Article 2220 of the Italian Civil Code. 


Support requests


Information concerning a support or protection request will be retained for as long as necessary to manage the request, provide follow-up, protect the person, document the assistance given and meet applicable legal or safeguarding obligations.


Closed support files will be periodically reviewed and deleted, anonymised or restricted when continued identification is no longer necessary.


Human rights documentation and legal evidence


Documentation connected with serious human rights violations, litigation, judicial proceedings, accountability processes or the preservation of evidence may need to be retained for an extended period.


Such material may be retained for as long as reasonably necessary to:

​

  • preserve evidentiary integrity;

  • support an investigation or legal proceeding;

  • pursue or defend legal claims;

  • protect witnesses, survivors or affected communities;

  • meet requests from competent legal or accountability bodies.

​

Retention will be subject to periodic review, restricted access and appropriate security measures.


Consent records
Records demonstrating consent or withdrawal of consent may be retained for as long as necessary to demonstrate compliance and resolve possible disputes.


11. Security and confidentiality


Refugees in Libya applies reasonable technical and organisational measures designed to protect personal data from:

​

  • unauthorised access;

  • unlawful disclosure;

  • accidental loss;

  • alteration;

  • destruction;

  • misuse.

​

Measures may include:

​

  • access restrictions;

  • account and password protection;

  • secure website connections;

  • limited user permissions;

  • confidentiality obligations;

  • data minimisation;

  • secure storage;

  • redaction or anonymisation;

  • periodic review of stored information.

​

No website, email system or online transmission can be guaranteed to be completely secure. For this reason, people should avoid transmitting unnecessary sensitive information through ordinary web forms or unencrypted email.


12. Children


This website is not directed primarily at children.
However, Refugees in Libya may receive information concerning children in connection with family, protection, detention, migration or humanitarian cases.
Information concerning a child will be handled with particular care and according to the child’s best interests, safety and dignity.


Where consent is legally required, Refugees in Libya will consider the child’s age, capacity, circumstances and the authority of the parent, guardian or responsible adult. Information identifying a child will not be published merely because it was submitted through a support request.


13. Automated decision-making


Refugees in Libya does not use information collected through this website to make decisions based solely on automated processing that produce legal or similarly significant effects on individuals.


Requests for support, collaboration and referrals are assessed through human involvement.


14. Rights of individuals


Subject to the conditions established by applicable law, individuals may request:

​

  • confirmation of whether their personal data is being processed;

  • access to their personal data;

  • correction of inaccurate or incomplete information;

  • deletion of personal data;

  • restriction of processing;

  • objection to processing based on legitimate interests;

  • portability of information they provided, where applicable;

  • withdrawal of consent at any time;

  • information about recipients or categories of recipients;

  • information concerning applicable international-transfer safeguards;

  • review of a decision based solely on automated processing, where applicable.

​

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.


A request may be sent to:


info@refugeesinlibya.org 


Refugees in Libya may request information reasonably necessary to confirm the identity of the person making the request and protect personal data from unauthorised disclosure.


Under the GDPR, the normal response period is one month, although it may be extended in legally permitted circumstances where a request is particularly complex. 


15. Right to lodge a complaint


A person who believes that their personal data has been processed unlawfully may lodge a complaint with:


Garante per la protezione dei dati personali


The Italian Data Protection Authority


The person may also contact the competent supervisory authority in another European Union or European Economic Area country where they live, work or believe an infringement occurred.


16. External websites and social-media platforms


The website may contain links to social-media accounts, partner organisations, news articles, reports, donation providers or other external websites.
Refugees in Libya is not responsible for the privacy practices of independent external websites. Visitors should review the privacy information provided by those services.


Where external content is embedded directly into the website, such as a video or social-media post, the external provider may process technical information or place cookies. Non-essential content should be subject to the visitor’s cookie choices where technically possible.


17. Changes to this Privacy Policy


This policy may be updated when:

  • the website changes;

  • a new form, donation system or service is introduced;

  • legal or regulatory requirements change;

  • a new service provider is appointed;

  • organisational data-processing practices change.

​

bottom of page