Your trust matters to us. Here we explain, without unnecessary jargon, what data we collect, why we collect it, how long we keep it, and what rights you can exercise at any time.
All you need to register is your email address. Your name, city, profession and interests are always optional.
Your card details never touch our servers: they're handled by Mollie.
Information that could identify a source is never shared with third parties.
Data controller
Clarionfold Press OÜ determines the purposes and means of processing connected with running the website, subscriptions, donations, the members' area, editorial and user communications, and the journalistic activity of Silere non possum.
Scope of this policy
This policy applies to the processing of personal data carried out through:
- the website silerenonpossum.com and its members' area;
- our subscription and donation services;
- editorial communications and communications sent to us by users;
- the technical activity needed to run and secure the website;
- the journalistic, editorial and publishing activity of Silere non possum.
It does not apply to third-party sites reached via links on our website. Those sites act as independent controllers and apply their own privacy policies.
What data we collect
3.1 Browsing and technical data
While you browse the site we may process data needed to keep it running, secure and properly maintained: your IP address, the date and time of access, the URLs requested, browser type, operating system, device type, server logs, and any data relating to errors, unauthorised access attempts and the prevention of abuse.
3.2 Account and members' area data
When you create an account or take out a subscription, we collect: your email address, first and last name (if provided), technical login credentials, subscription status, registration and last-login dates, and your account preferences. Where a password is set, it is stored in a form that cannot be read back; session tokens are used to keep you logged in and to secure your session.
3.3 Optional profile data
You may choose to provide further details, such as your date of birth, city, profession or editorial preferences. These fields are optional: leaving them blank does not stop you using our core services. Where a preference you provide freely might reveal religious, philosophical or political views (a "special category" of data under Article 9 GDPR), we only process it with your explicit consent and strictly for the purpose you requested.
3.4 Subscriptions, payments and donations
To manage subscriptions and donations we process: your first and last name (if provided), email address, the amount and currency, the date and time, the transaction outcome and reference, subscription status, and any data needed for receipts and tax purposes.
Payments are handled by Mollie. Full card details are never stored on our servers.
3.5 Editorial and service communications
We may send you communications about your account, subscriptions, renewals, expiry dates, payments, security, changes to the service, and editorial initiatives or fundraising campaigns. Communications that aren't strictly necessary are only sent with your request or consent; you can opt out at any time by writing to us.
3.6 Communications you send us
When you contact us by email or through a form: your contact details, the content of your message, any attachments, and the technical metadata needed to reply. Please avoid sending us data that isn't necessary, irrelevant details about third parties, or special category data, unless it's genuinely unavoidable.
3.7 Comments and user-submitted content
Where the site allows comments or other interaction: the content you post, the name or handle displayed, the date and time, your IP address and other technical security data. We may moderate or remove content that is unlawful, offensive, defamatory, abusive or spam.
3.8 Cookies, similar technologies and local storage
Your reading history and reading progress are stored only in your browser (localStorage) and are never sent to our servers. Full details on cookies and tracking are in our Cookie Policy.
3.9 Data processed for journalistic purposes
Our editorial work may involve data relating to people named in articles, investigations and documents, drawn from public sources, lawfully accessible records, press releases, public statements, archives, confidential sources and tip-offs. Processing for journalistic purposes is governed by section 11.
Purposes and legal bases
We process personal data for the following purposes and on the following legal bases (Article 6 GDPR):
| Purpose | Legal basis |
|---|---|
| Running the website, browsing and technical security | Legitimate interest (Art. 6(1)(f)) |
| Registration, accounts and the members' area | Contract / pre-contractual steps (Art. 6(1)(b)) |
| Subscriptions, members' content, renewals and support | Contract (Art. 6(1)(b)); accounting/tax obligations (Art. 6(1)(c)) |
| Managing donations | At your request (Art. 6(1)(b)); legal obligations (Art. 6(1)(c)); legitimate interest (Art. 6(1)(f)) |
| Payments via Mollie (fraud prevention and security) | Contract (Art. 6(1)(b)); legal obligation (Art. 6(1)(c)); legitimate interest (Art. 6(1)(f)) |
| Optional profile data | Consent (Art. 6(1)(a)); explicit consent for special category data (Art. 9(2)(a)) |
| Service communications (account, payments, security) | Contract (Art. 6(1)(b)); legal obligation (Art. 6(1)(c)); legitimate interest (Art. 6(1)(f)) |
| Editorial communications and fundraising campaigns | Consent (Art. 6(1)(a)) or legitimate interest (Art. 6(1)(f)) |
| Responding to user enquiries and reports | Legitimate interest (Art. 6(1)(f)); contract/legal obligation where applicable |
| Protecting our rights, handling disputes, fraud prevention and authority requests | Legitimate interest (Art. 6(1)(f)); legal obligation (Art. 6(1)(c)) |
| Accounting, tax and administrative compliance | Legal obligation (Art. 6(1)(c)) |
| Analytics and advertising (Google Analytics, Google Ads) | Consent (Art. 6(1)(a)); see our Cookie Policy for details |
| Journalism, editorial work and our archive | Freedom of expression and information (Article 85 GDPR and Estonian law); legitimate interest (Art. 6(1)(f)) |
Whether you have to provide your data
You need to provide your email address to create an account, access the members' area, manage your subscription, and complete payments or donations. The data needed for payment is essential for subscriptions and donations; any data required to meet accounting or tax obligations is mandatory where the law requires it.
Providing optional profile data, and consenting to non-essential communications, is entirely up to you: choosing not to does not stop you registering, subscribing or using any of our other services.
Who we share data with
Your data may be handled by authorised staff and by external providers who, when acting on our behalf, act as data processors under Article 28 GDPR and are bound by written agreements with us:
We never sell your data to third parties or pass it on for their own independent marketing purposes.
International transfers
Your data is processed mainly within the European Economic Area or by providers based in Europe, such as Mollie B.V. (the Netherlands). Some providers (for example, Google) or their own sub-processors may process data outside the EEA. Where this happens, we only allow the transfer where one of the following GDPR safeguards is in place:
- an adequacy decision from the European Commission;
- the EU–US Data Privacy Framework, where the provider is validly certified under it;
- Standard Contractual Clauses approved by the European Commission, with any supplementary measures needed;
- another basis permitted under Articles 44 onwards of the GDPR.
How long we keep data
We keep data for as long as necessary to fulfil the purposes described above, unless the law requires us to keep it longer or we need it to protect our legal rights.
| Category | Retention period |
|---|---|
| Account data | For as long as your account is active; deleted or anonymised within 30 days of a deletion request, unless the law requires otherwise |
| Subscription data | For the length of your subscription, plus whatever period is needed to meet accounting/tax obligations and protect our legal rights |
| Payments and donations | 7 years from the end of the financial year (under Estonian accounting law) |
| Accounting and tax records | 7 years from the end of the financial year in which they were recorded |
| Non-essential editorial communications | Until you withdraw consent or object; then for a limited period to record your request and avoid sending you further unwanted communications |
| Messages you send us | As long as needed to respond, and generally no more than 24 months, unless a legal obligation or dispute requires longer |
| Technical and security logs | A limited period, generally up to 180 days, unless needed longer for an incident or an authority's request |
| Reading history (localStorage) | Stays on your own device until you clear it yourself |
| Data used for journalistic purposes | Kept in our editorial archives for as long as needed for journalistic, documentary and archival purposes |
Your rights
Subject to the limits and conditions set out in the GDPR, you can exercise the right to:
- access your data and receive a copy of it (Article 15);
- have inaccurate data corrected (Article 16);
- have your data deleted (Article 17);
- restrict how we process your data (Article 18);
- receive your data in a portable format (Article 20);
- object to processing based on legitimate interest (Article 21);
- withdraw your consent at any time, without affecting the lawfulness of processing carried out before you withdrew it;
- not be subject to decisions based solely on automated processing, in the cases covered by Article 22.
Send requests to [email protected] with "PRIVACY" in the subject line. For security reasons, we may ask you for information to verify your identity.
Limits on your rights
We may limit these rights where necessary and proportionate to protect freedom of expression and information, our journalistic activity, the confidentiality of our sources, the security of the site, fraud prevention, legal obligations, and the rights of Clarionfold Press OÜ or of others.
For data relating to accounts, payments, subscriptions, donations and editorial communications, your rights remain fully exercisable under the ordinary rules of the GDPR, subject only to any limits arising from legal obligations.
Processing for journalistic purposes
Silere non possum is an independent international online daily (ISSN 3125-5205) published by Clarionfold Press OÜ. In the course of our journalism, we may collect, verify, process, store and publish personal data where necessary to inform the public about facts, official acts, statements, documents and matters of public interest.
This processing complies with the GDPR, with Article 85 GDPR, and with Estonian law (the Personal Data Protection Act, IKS), which together balance data protection against freedom of expression and freedom of information. Some information (under Articles 13-14) and some of your rights may be limited where providing them would compromise our journalistic purpose, our fact-checking, the confidentiality of our sources, or the public's right to be informed.
Requests for correction, right of reply or updates to published content should be sent in line with the process set out in our Impressum, and should include: the URL of the content, your identity, the reason for the request, the specific parts you are disputing, any supporting documentation, and your proposed wording.
Protecting our sources
Protecting our journalistic sources is a fundamental principle of Silere non possum's editorial work. Information that could identify a source is handled with enhanced confidentiality measures and is never disclosed to third parties.
We may limit access, disclosure, correction, deletion or other operations on data where necessary to protect the confidentiality of our sources and our journalistic activity.
Children
This site is not specifically directed at children. Under Estonian law, for information society services a child's own consent is valid from the age of 13; below that age, consent from a parent or legal guardian is required. We do not knowingly collect data from children under 13 without such authorisation and, if we become aware that we have, we take reasonable steps to delete it, unless the law requires us to keep it or there is an overriding public interest in the journalism concerned.
Data security
We use appropriate technical and organisational measures to guard against unauthorised access, loss, destruction, alteration or disclosure. These include:
- HTTPS encryption and access controls;
- individual login credentials and secure password storage;
- protected session tokens, regular backups and technical updates;
- security monitoring and access limited to authorised staff only;
- agreements with our providers and confidentiality measures for editorial data and sources.
No system can guarantee absolute security. If a breach occurs, we carry out the required assessments and, where necessary, make the notifications required under the GDPR.
Automated decisions and profiling
We do not make decisions based solely on automated processing that produce legal effects or similarly significantly affect you (Article 22 GDPR). The site uses statistical cookies (Google Analytics) and advertising cookies (Google Ads): both are only activated with your consent and are covered in detail in our Cookie Policy, which also links to Google's own privacy information. Interest-based advertising does not produce legal or similarly significant effects on you.
Making a complaint to a supervisory authority
If you believe your rights have been infringed, you can lodge a complaint with the relevant supervisory authority. For Clarionfold Press OÜ, the lead authority is:
You also retain the right, in the cases provided for by the GDPR, to complain to the supervisory authority in your own country of residence, place of work, or the place where the alleged infringement occurred. If you are based in the United Kingdom, this means you can contact the Information Commissioner's Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF; ico.org.uk; helpline 0303 123 1113.
Changes to this policy
We may update this policy to reflect changes in the law, our technology, our organisation or our editorial practice. The current version is always published on this page, together with the date it was last updated. If we make substantial changes that affect the rights of registered users, we will let them know by email or with a notice on the site.