Privacy Policy — DirectDemocracyS

Version: 1.0
Date of publication: 22 September 2026
Last update: 22 September 2026
Organisation: DirectDemocracyS
European Commission PIC: 881951064
Registered international office: str. Muzicii nr. 22, postal code 410514, Oradea, Bihor County, Romania, European Union
Privacy contact: privacy_support@directdemocracys.org
Data Protection Officer (DPO): Franco-Romeo Zaccherini

1. Introduction

DirectDemocracyS considers the protection of personal data, privacy, anonymity, confidentiality, security and individual freedom to be fundamental principles of its entire system.

This Privacy Policy explains, in detail, how DirectDemocracyS collects, receives, generates, processes, verifies, protects, stores, separates, transfers, archives and, where appropriate, deletes personal data.

This Policy applies to the DirectDemocracyS system, its websites, platforms, online services, internal areas, social areas, registration systems, verification systems, communication systems, administrative systems, security systems and authorised internal groups, insofar as they process personal data.

DirectDemocracyS does not consider privacy to be merely a legal obligation. Privacy is also an architectural, organisational and democratic principle.

The system is therefore designed around several fundamental concepts:

• data minimisation;

• purpose limitation;

• confidentiality;

• security;

• privacy by design;

• privacy by default;

• separation of personal identity from operational identity;

• anonymity wherever anonymity is compatible with the user's chosen or required user type;

• controlled visibility;

• need-to-know access;

• separation of verification phases;

• use of unique codes;

• restricted access to highly sensitive information;

• limited retention on network-accessible systems;

• long-term storage only where necessary and preferably in protected environments;

• accountability;

• transparency;

• user control over voluntarily disclosed information.

DirectDemocracyS recognises that different users have different requirements.

A person who participates only as a Free user does not necessarily need to reveal their legal identity.

A person who wishes to exercise rights that require a verified identity, participate in shared leadership, become an official member or perform official or political representation may need to undergo additional verification.

The amount of personal information processed therefore depends on the user's relationship with the system, the user type selected or obtained, the activities performed and the legal or security requirements applicable to those activities.

2. Legal Entity and Data Protection Contact

For the purposes of this Privacy Policy, the relevant DirectDemocracyS entity is identified as follows:

DirectDemocracyS

European Commission PIC: 881951064

Registered international office:

str. Muzicii nr. 22
410514 Oradea
Bihor County
Romania
European Union

Privacy contact:

privacy_support@directdemocracys.org

Data Protection Officer (DPO):

Franco-Romeo Zaccherini

Requests concerning personal data, privacy, identity verification records, access to personal information, correction, restriction, deletion, objection, portability or other applicable data protection rights may be directed to the privacy contact above.

Where a specific request requires additional verification that the requester is the person entitled to receive or modify the information, DirectDemocracyS may request only the minimum additional information necessary to verify that right.

DirectDemocracyS will not request unnecessary identity information merely because a user wishes to exercise a privacy right.

3. Scope of this Privacy Policy

This Privacy Policy applies, as applicable, to:

1. visitors to public DirectDemocracyS websites;

2. Public users;

3. Test users;

4. Free users;

5. Guest users;

6. Access users;

7. Partially Registered users;

8. Verified users;

9. Members;

10. Politicians;

11. Representatives;

12. Owners;

13. Managers;

14. Responsible users;

15. Administrators;

16. SuperAdministrators;

17. Guarantors;

18. official representatives;

19. political representatives;

20. employees and collaborators, where their data are processed;

21. persons participating in identity verification;

22. persons participating in compatibility or skills verification;

23. persons communicating with DirectDemocracyS;

24. persons whose data are processed for security, legal, administrative, accounting or organisational purposes.

The terminology of user types is governed by the applicable DirectDemocracyS rules.

Not every user type has the same data requirements.

In particular, the fact that DirectDemocracyS may be able to verify a person's identity does not mean that the person's real identity is automatically visible to ordinary users.

4. Fundamental Privacy Principle of DirectDemocracyS

DirectDemocracyS follows a simple fundamental principle:

A person's identity should be known only when there is a legitimate reason to know it.

The system therefore separates, as far as technically and organisationally possible, the following concepts:

• the person's real-world identity;

• the person's DirectDemocracyS username;

• the person's email address;

• the person's telephone number;

• the person's verification codes;

• the person's compatibility information;

• the person's skills information;

• the person's identity-verification information;

• the person's public profile;

• the person's internal activities;

• the person's representative profile;

• security and administrative records.

These categories are not automatically interchangeable.

A person may therefore be known inside the operational system by a username without that username publicly revealing their real name.

5. Right to Anonymity

5.1 General principle

DirectDemocracyS recognises, wherever permitted by the user's user type and the applicable rules, a fundamental right to operate under an anonymous or non-identifying username.

For ordinary users, the username does not have to correspond to:

• the person's first name;

• the person's surname;

• their legal name;

• their address;

• their city;

• their telephone number;

• their email address;

• their date of birth;

• their employer;

• their professional identity;

• their social-media identity;

• or any other real-world identifying information.

A user may therefore participate using a username that has no obvious connection with their real identity.

The username is the person's operational identity within DirectDemocracyS.

6. How an Anonymous Username Can Be Chosen

A user may choose an anonymous username according to the applicable username rules.

Examples of privacy-preserving formats include:

6.1 A nickname

For example:

BlueMountain

provided that the nickname does not reveal information that the user does not wish to disclose and is not misleading or reserved for another role.

6.2 A country code combined with a random identifier

For example:

RO7F4K29

or another structure based on an ISO country code followed by a random combination of letters and numbers.

The country code itself does not have to identify the person's precise location.

6.3 A completely random identifier

For example:

X7Q9-M4P2-Z8

or another permitted random alphanumeric or special-character combination.

6.4 Other permitted anonymous formats

A user may use any username permitted by the applicable DirectDemocracyS username rules, provided that it does not falsely represent another person, a protected role, an official position, an administrative function or another identity.

7. What Users Should Avoid When Anonymity Is Important

A user who wishes to maintain strong anonymity should avoid usernames containing:

• their real name;

• their surname;

• their date of birth;

• their telephone number;

• their email address;

• their exact address;

• an identifiable social-media username;

• an employer-specific identifier;

• a unique professional identifier;

• a combination of information that could easily identify them.

Anonymity also depends on what the user voluntarily publishes.

A perfectly anonymous username can lose much of its protective value if the user publicly publishes enough information to identify themselves.

For this reason, anonymity is a combination of:

1. the architecture of DirectDemocracyS;

2. the username selected by the user;

3. the information voluntarily disclosed by the user;

4. the security of the user's own devices and accounts;

5. compliance with the DirectDemocracyS rules.

8. External Invisibility

DirectDemocracyS seeks to provide strong external invisibility for users who are entitled to anonymous participation.

For an anonymous user, ordinary visitors, external users and ordinary members should see the user's operational username rather than their real identity.

The objective is that a person viewing the public or ordinary internal profile should not be able to derive the user's:

• legal name;

• surname;

• home address;

• telephone number;

• personal email address;

• identity-document information;

• verification information;

• private identity-verification material.

The user's public or ordinary operational identity is therefore separated from their protected identity information.

This is particularly important for people who participate in political, social, professional, scientific, cultural or other activities and who may have legitimate reasons to protect their personal identity.

9. Internal Invisibility

DirectDemocracyS also applies the principle of internal invisibility.

Internal invisibility means that even within DirectDemocracyS, a person's real identity is not automatically available to every administrator, member, specialist, verifier, manager or other user.

Access to personal identity information is restricted according to:

• role;

• purpose;

• necessity;

• authorisation;

• security requirements;

• legal requirements;

• the particular verification activity being performed.

A person performing a compatibility test does not normally need to know the applicant's legal name.

A person performing a skills assessment does not normally need to know the applicant's legal name.

A person performing an identity verification activity receives only the information and codes necessary to perform that activity.

This separation is one of the principal mechanisms through which DirectDemocracyS seeks to protect anonymity.

10. Important Distinction Between Anonymity, Pseudonymity and Legal Identity

DirectDemocracyS uses strong technical and organisational separation between usernames and real identity.

However, the legal concept of anonymisation must be distinguished from pseudonymisation.

Where DirectDemocracyS retains protected information that could, under exceptional authorised circumstances, be used to establish a connection between a username and a real identity, that information remains personal data under applicable data protection law.

Therefore, this Privacy Policy uses the expression “anonymity and invisibility” to describe the protection experienced by ordinary users and unauthorised persons, while recognising that exceptional legally authorised access may exist.

This does not give ordinary users, ordinary administrators or unauthorised third parties a right to access the protected identity information.

11. User Control Over Visibility

DirectDemocracyS follows another fundamental principle:

Users decide what information they voluntarily make visible, to whom, when and in what manner, except where information must be processed privately for legal, security, technical or organisational reasons.

Where the platform provides a visibility option, users may determine, according to the applicable rules and technical possibilities:

• whether information is public;

• whether information is visible only internally;

• whether information is visible to a specific group;

• whether information is visible to specific authorised persons;

• whether information remains private;

• when information becomes visible;

• when information stops being visible;

• whether information is disclosed voluntarily during a specific activity.

The system does not interpret voluntary publication of one item of information as consent to publish all other information about the same person.

For example, publication of a user's username does not mean that the person's real name, telephone number, address or identity document may also be published.

12. Information That Must Remain Private

Some information is processed for technical, legal or security reasons even when it is not publicly visible.

Examples may include:

• registration email address;

• verified telephone number;

• authentication information;

• security logs;

• identity-verification records;

• identity documents;

• identity-verification videos;

• verification codes;

• administrative records;

• payment or accounting information;

• employment records;

• security information;

• incident records.

Such information is not made public merely because it exists within the DirectDemocracyS system.

13. Categories of Personal Data Processed

Depending on the user's relationship with DirectDemocracyS, the system may process different categories of information.

13.1 Account and registration information

This may include:

• username;

• password credentials in appropriately protected form;

• personal email address;

• telephone number;

• country/operator telephone information;

• account status;

• user type;

• registration date;

• account activation information;

• account security information.

A secure, non-temporary personal email address and a unique telephone number are part of the applicable registration and verification procedures.

14. Public Profile Information

A user's profile may contain information voluntarily provided by the user.

Depending on the user's settings and user type, this may include:

• username;

• profile description;

• interests;

• areas of activity;

• voluntary biography;

• languages;

• voluntary professional information;

• voluntary geographical information;

• voluntary photographs;

• voluntary contributions;

• participation information;

• public comments;

• other content intentionally published by the user.

The existence of an account does not automatically mean that all of these categories must be publicly displayed.

15. Compatibility Data

For users requesting higher-level participation or identity verification, DirectDemocracyS may process information necessary to determine compatibility with the system.

This may include:

• compatibility-test results;

• answers to compatibility questions;

• evaluation results;

• decisions of the authorised verification group;

• unique phase codes;

• procedural communications;

• information necessary to repeat or review a compatibility assessment.

The compatibility process is separate from the identity verification process.

The objective is to evaluate compatibility without unnecessarily exposing the applicant's real identity.

16. Skills and Competence Data

Where a user requests a user type or activity requiring demonstrated skills, DirectDemocracyS may process:

• declared skills;

• qualifications;

• professional experience;

• educational information;

• evidence supplied by the user;

• documents voluntarily or necessarily provided;

• specialist assessments;

• verification results;

• skills-verification codes;

• decisions of authorised specialist or verification groups.

A person does not have to possess prestigious qualifications merely to participate in DirectDemocracyS.

However, where a person claims specific professional or specialist competence for an activity requiring verification, DirectDemocracyS may request evidence appropriate to that activity.

17. Identity Verification Data

Identity verification is a special and highly protected category of processing within the DirectDemocracyS architecture.

Depending on the procedure and applicable user type, identity verification may involve:

• real first and last name;

• date of birth where relevant;

• nationality where relevant;

• identity-document information;

• passport information;

• identity-card information;

• another accepted photographic identity document;

• photograph;

• selfie;

• live video;

• verification video recording;

• verification codes;

• verification results;

• information necessary to confirm authenticity;

• information necessary to document the outcome of the verification.

DirectDemocracyS applies the principle of data minimisation.

The system should not retain information that is not necessary for the specific purpose.

18. DirectDemocracyS Identity Verification — Three Main Phases

The current DirectDemocracyS identity verification rules establish a structured process.

The process is divided into:

1. Phase 0 — request and initial information;

2. Phase 1 — compatibility;

3. Phase 2 — skills;

4. Phase 3 — identity verification.

Identity verification is therefore not automatically the first question asked of every participant.

This is an important privacy principle.

A user can participate at lower user levels without mandatory identity verification where the applicable rules permit this.

19. Phase 0 — Request for Identity Verification

When a user requests identity verification, the system requires the information necessary to initiate the process.

The current rules require:

• a unique username;

• a unique personal email address;

• a unique telephone number.

The username remains the user's operational identity.

The fact that the system has a personal email address or telephone number does not mean that these data become visible to ordinary users.

20. Phase 1 — Compatibility Verification

In Phase 1, DirectDemocracyS verifies compatibility with the system.

A unique code is generated.

A corresponding code is provided to an authorised and randomly selected member of an appropriate verification group.

The codes are designed to separate the phases and reduce the possibility of linking information between them without special authorisation.

The compatibility verifier does not ordinarily need to know the applicant's legal identity.

The applicant is operationally identified by their username and the relevant verification code.

The result may be:

• approval;

• rejection;

• postponement;

• reassignment to another authorised group.

The user receives the result through the appropriate communication channel.

21. Phase 2 — Skills Verification

Phase 2 concerns the skills declared by the applicant.

A new unique code is generated for the phase.

An authorised verification group and/or appropriate specialists assess the information and evidence supplied.

The information may include qualifications, documents or other evidence relevant to the claimed competence.

Again, the system uses separation between phases.

The skills verifier does not automatically receive the applicant's complete real identity information merely because the person is undergoing skills verification.

The objective is to verify competence while limiting unnecessary disclosure of personal information.

22. Phase 3 — Identity Verification

Only after the preceding requirements have been completed does the applicant proceed to identity verification.

The system generates another unique identity-verification code.

The applicant receives the code.

The authorised identity-verification member receives the corresponding information necessary to perform the verification.

The verifier does not ordinarily receive the applicant's username or other unnecessary information.

The purpose is to verify the identity document and the person without unnecessarily connecting the person's operational identity to their real-world identity.

23. Identity Verification Video Call

The current DirectDemocracyS procedure uses a live video call for identity verification.

The applicant may be required to:

• demonstrate that they are physically present;

• perform simple live movements;

• show their face;

• present a valid photographic identity document;

• show the identity document separately;

• follow other security instructions necessary to establish that the person present corresponds to the document.

The call is recorded, encrypted and stored in a protected environment.

The video-verification material is not intended for ordinary public access.

24. Separation Between Username and Real Identity During Verification

One of the central privacy principles of DirectDemocracyS is that the person performing identity verification does not normally need to know the applicant's operational username.

This means that the verifier can perform the verification activity without automatically learning:

• the applicant's public username;

• their internal activities;

• their political or social participation;

• their previous activity history;

• their ordinary DirectDemocracyS relationships.

The purpose is to reduce the possibility of unnecessary linking.

After successful verification, the system may mark the operational username as verified or guaranteed without making the real identity publicly visible.

25. Identity Documents and Selfies

When an identity document or identification file is uploaded or presented:

1. it is protected;

2. it is encrypted;

3. it is processed only for the verification purpose;

4. access is restricted;

5. it is not made publicly visible;

6. access is limited to highly authorised circumstances;

7. it may be analysed by authorised technical systems and AI systems where this is part of the implemented verification process;

8. human access is restricted according to the applicable security rules.

Identity documents are among the most sensitive forms of personal information processed by DirectDemocracyS.

They therefore receive a higher level of protection than ordinary profile information.

26. AI-Assisted Identity Verification

Where DirectDemocracyS uses its Artificial Intelligence systems to support identity verification, the AI system is used as part of the security and verification architecture.

AI-assisted processing may include:

• document analysis;

• consistency checking;

• video analysis;

• comparison of relevant information;

• detection of anomalies;

• verification assistance;

• security analysis.

AI processing does not transform protected identity information into public information.

Where applicable, the system must also respect the legal rights relating to automated decision-making.

A user must not be subjected to an unlawful decision producing legal or similarly significant effects solely because an automated system has produced a particular result.

Where human review, reassessment or an additional verification is required by the applicable process, the appropriate human procedure must be followed.

27. Exceptional Access to Identity Information

DirectDemocracyS applies an extremely restrictive approach to access to identity-verification data.

Identity documents, identity-verification files and recorded verification videos are stored in protected environments.

Access may be technically and organisationally restricted to a very small number of highly authorised persons.

Such access must have:

• a legitimate purpose;

• a serious reason;

• appropriate authorisation;

• traceability;

• documentation;

• accountability.

Curiosity is not a legitimate reason for accessing identity data.

A person's administrative position does not automatically give that person unrestricted access to identity information.

28. Official Representatives and Political Representatives

The privacy model is different for official representatives and political representatives because their activities require a higher degree of public or local identifiability.

For official and political representatives, additional identity verification may be required.

This can include direct, in-person verification.

The in-person process uses unique codes and mutual verification for security.

The persons participating in the specific verification activity may necessarily know each other's identity for that activity.

This is an exceptional and purpose-specific disclosure.

It does not mean that every administrator or ordinary user receives access to the person's complete identity-verification records.

29. Political Representative Profiles

Political representatives must be identifiable for the political activities they perform.

For political representative profiles, the applicable DirectDemocracyS rules require the username to contain the person's full name and surname, written according to the applicable linguistic rules.

This is an intentional exception to the ordinary anonymity principle.

The reason is functional and organisational: political representation requires identifiable representatives.

The person's protected verification records remain subject to the security and access restrictions described in this Privacy Policy.

30. Official Representative Profiles

Official representatives may use an anonymous operational username in accordance with the applicable rules.

However, official representatives must be identifiable by the people with whom they conduct their official activities.

This creates a distinction between:

• ordinary public anonymity;

• operational identity;

• local or activity-specific identification;

• protected legal identity.

The identity disclosed for an official activity may not be reused for unrelated purposes.

31. Anonymity of Other Users

For user types for which anonymity is guaranteed by the applicable DirectDemocracyS rules, the system seeks to maintain continuous anonymity.

Ordinary users should therefore be represented operationally by their username.

The system is designed so that ordinary users, ordinary members and unauthorised internal personnel cannot simply connect the username with the person's protected identity information.

This is a central privacy feature of DirectDemocracyS.

32. New-User Matching and Human Bridges

DirectDemocracyS has introduced a system under which a new user is connected or matched with an authorised official member.

The purpose includes:

• assistance;

• orientation;

• integration;

• safety;

• reduction of mistakes;

• support during the initial stages;

• human contact with the system.

The authorised member receives only the information necessary for the relevant activity.

The existence of this human connection does not automatically grant the authorised member access to the new user's protected identity information.

The matching system does not cancel the user's right to anonymity.

33. Data Generated by Communications

DirectDemocracyS may process information generated when users communicate through:

• internal messages;

• email;

• support requests;

• video calls;

• group discussions;

• administrative communications;

• verification communications;

• security communications.

The content and metadata of such communications are processed only for legitimate purposes, including:

• providing the requested service;

• security;

• moderation;

• verification;

• preventing abuse;

• resolving disputes;

• complying with legal obligations;

• maintaining the integrity of the system.

Access to private communications is restricted according to role and purpose.

34. User-Generated Content

Users may voluntarily create:

• articles;

• comments;

• posts;

• messages;

• proposals;

• documents;

• votes or voting-related records;

• specialist contributions;

• multimedia content;

• other material.

Before publishing personal information, users should consider whether the information is genuinely necessary.

A user who voluntarily publishes personal information may make themselves identifiable even when their username is anonymous.

DirectDemocracyS cannot guarantee anonymity against information that a user deliberately publishes about themselves or that they voluntarily provide to third parties.

35. Technical and Security Data

For security and operation, DirectDemocracyS may process technical information such as:

• IP address;

• connection information;

• browser information;

• device information;

• operating-system information;

• login information;

• authentication events;

• failed authentication attempts;

• security events;

• system logs;

• timestamps;

• error logs;

• fraud-prevention information;

• abuse-prevention information.

These records are not intended to become public profile information.

They are primarily used to operate, secure and protect the system.

36. Cookies and Similar Technologies

DirectDemocracyS may use cookies and similar technical mechanisms where necessary for:

• authentication;

• security;

• session management;

• functionality;

• preferences;

• technical operation;

• statistics;

• other purposes specifically disclosed to users.

The detailed rules governing cookies are contained in the DirectDemocracyS Cookie Policy.

Where consent is legally required, the appropriate consent mechanism must be used.

37. Legal Bases for Processing

Depending on the specific processing operation, DirectDemocracyS may rely on one or more legal bases recognised under applicable data protection law.

These may include:

37.1 Performance of a contract or requested service

Where processing is necessary to provide the service requested by the user or to manage the user's relationship with DirectDemocracyS.

37.2 Legal obligation

Where DirectDemocracyS must retain or process information because applicable law requires it.

This is particularly relevant to:

• accounting;

• taxation;

• employment;

• legally required records;

• security obligations;

• legally required disclosures.

37.3 Legitimate interests

Where processing is necessary for legitimate organisational, security, technical or administrative purposes and those interests are not overridden by the rights and freedoms of the person concerned.

Security, prevention of fraud, prevention of abuse and protection of system integrity may constitute legitimate interests where the applicable legal requirements are satisfied.

37.4 Consent

Where consent is legally required or is the appropriate legal basis, DirectDemocracyS will request it in an appropriate manner.

Consent may be withdrawn where applicable.

Withdrawal of consent does not invalidate processing lawfully carried out before withdrawal.

38. Purpose Limitation

Personal data collected for one purpose should not automatically be reused for an unrelated purpose.

For example:

• identity-verification data are not ordinary marketing data;

• security logs are not public profile data;

• a telephone number used for verification is not automatically a public contact number;

• an identity document is not a profile photograph;

• employee records are not community-profile information.

Any new use must have an appropriate legal basis and be compatible with applicable data protection requirements.

39. Data Minimisation

DirectDemocracyS seeks to collect and process only the information necessary for each purpose.

Where a purpose can be achieved without identifying a person, anonymous or less identifying information should be preferred.

Where pseudonymisation can reduce the risk, it should be used where appropriate.

Where encryption can reduce the risk, it should be used.

Where access can be limited, it should be limited.

Where information no longer needs to remain on an accessible system, it should be removed from that accessible environment according to the applicable retention procedure.

40. Data Storage Architecture

DirectDemocracyS uses a distinction between:

1. systems accessible through the network and used for ordinary operation;

2. protected private storage environments that are inaccessible from the public network and from the Internet.

As a general operational rule, data are retained on the network-accessible platforms for approximately 7 working days, after which information that must be retained is transferred or archived according to the applicable retention category and security procedure.

This does not mean that every category of information is automatically destroyed after seven working days.

Different categories have different legal and operational retention requirements.

The seven-working-day period is therefore primarily the standard operational-access retention period on the network-accessible platforms, while legally or organisationally necessary records may subsequently be maintained in protected private storage.

41. Private Server Storage

Where information must be retained after its normal operational period, DirectDemocracyS may store it on a private server or protected storage environment that is:

• inaccessible from the public Internet;

• inaccessible through ordinary external network access;

• separated from ordinary operational systems;

• protected through access restrictions;

• accessible only to authorised personnel where necessary.

The purpose of this architecture is to reduce the attack surface and to prevent sensitive historical information from remaining continuously exposed through ordinary network-accessible systems.

42. Retention Periods

DirectDemocracyS applies different retention periods according to the category and purpose of the data.

The principal periods currently applicable are:

The exact retention period must always be interpreted together with the applicable law.

Where a law requires a longer period, the legally required period prevails.

Where no legal requirement exists, DirectDemocracyS should retain the information only for as long as reasonably necessary for the stated purpose.

43. Accounting and Tax Records

Accounting records and documents required by tax legislation are retained for approximately 10 years, where required by the applicable fiscal obligations.

The purpose is to comply with legal, accounting and tax requirements.

The longer retention of these records does not mean that they are publicly accessible.

They remain protected and subject to access restrictions.

44. Employee Data

Employee information is subject to specific retention periods determined by:

• labour legislation;

• tax legislation;

• social-security requirements;

• contractual requirements;

• employment-related legal obligations;

• applicable national or local requirements.

Employee records therefore do not have a single universal retention period.

DirectDemocracyS maintains specific retention schedules for employee information according to the applicable legal requirements.

45. Video-Surveillance Data

Where DirectDemocracyS uses video surveillance, images recorded by the surveillance system are generally removed from the network-accessible server after approximately 24–72 hours, subject to the applicable legal and operational requirements.

Where a longer retention is necessary for security, investigation, legal or organisational purposes, relevant material may be retained for up to 365 days on a private server that is inaccessible from outside and from the Internet.

Access to retained surveillance material is restricted.

Video surveillance is not intended to create a permanent public record of people's movements.

46. Marketing Data

Where DirectDemocracyS lawfully processes marketing-related information, the standard retention period is approximately 24 months from the last administrative contact, unless a longer period is required by applicable law in the relevant country or local jurisdiction.

Marketing information is not automatically retained indefinitely.

Where applicable, users may exercise the right to object to direct marketing and may withdraw consent where consent is the applicable legal basis.

47. Data Security

DirectDemocracyS applies technical and organisational measures intended to protect personal data against:

• unauthorised access;

• unauthorised disclosure;

• alteration;

• destruction;

• accidental loss;

• misuse;

• unauthorised linking;

• unlawful processing.

Depending on the system and purpose, security measures may include:

• encryption;

• encrypted communications;

• encrypted identity documents;

• encrypted video recordings;

• protected servers;

• private storage;

• network segregation;

• access control;

• role-based permissions;

• unique verification codes;

• separation of verification phases;

• restricted administrator access;

• audit records;

• authentication controls;

• backup protection;

• incident-management procedures;

• least-privilege principles;

• need-to-know access.

48. Need-to-Know Principle

A person within DirectDemocracyS should have access only to information necessary for the activity they are authorised to perform.

For example:

A compatibility verifier does not need the user's identity document.

A skills verifier does not need unrestricted access to the user's identity document.

A technical administrator does not automatically need to know a user's real name.

A member helping a new user does not automatically receive access to identity-verification records.

A user does not receive access to another user's private personal information simply because both are members.

This principle applies regardless of organisational rank, subject to exceptional and documented security or legal requirements.

49. Special Protection for Privileged Users

Administrators, SuperAdministrators, Guarantors and other privileged users may have access to systems containing more sensitive information.

However, higher organisational authority does not mean unlimited privacy access.

Privileged access should remain:

• purpose-limited;

• logged;

• authorised;

• justified;

• reviewable;

• limited to what is necessary.

The more sensitive the data, the more restricted access should be.

50. Exceptional Access

There may be exceptional situations in which protected information must be accessed.

Examples may include:

• a serious security incident;

• suspected identity fraud;

• serious abuse;

• legal proceedings;

• a binding legal obligation;

• a serious threat to the integrity of the system;

• investigation of a serious violation of the rules;

• a legitimate request by a competent authority;

• technical recovery of critical data.

Exceptional access must not become ordinary access.

Where technically possible, exceptional access should be:

• documented;

• authorised;

• attributable to a specific person;

• limited in scope;

• limited in time;

• auditable.

51. Disclosure to Public Authorities

DirectDemocracyS may disclose personal data to competent public authorities where this is:

• legally required;

• necessary to comply with a binding legal obligation;

• authorised under applicable law;

• necessary for a lawful investigation;

• necessary to protect fundamental rights or serious security interests.

DirectDemocracyS does not interpret a general request from an authority as an automatic right to unrestricted access to all information.

The request must be handled according to applicable law and the principle of minimisation.

52. Processors and Internal Authorised Units

The effective DirectDemocracyS processing structure is intentionally limited.

The current operational environment consists primarily of:

• the DirectDemocracyS system;

• DirectDemocracyS platforms;

• DirectDemocracyS websites;

• authorised DirectDemocracyS groups and organisational units.

Authorised internal groups operate under DirectDemocracyS rules and access controls and do not automatically constitute independent external data controllers or processors merely because they are separate operational groups.

Where an external service provider or legally separate entity is actually engaged to process personal data on behalf of DirectDemocracyS, that relationship must be governed by the applicable data protection requirements and documented appropriately.

The list of actual external processors should therefore always reflect the providers actually used at the time this Policy is applied.

DirectDemocracyS does not sell or rent users' personal data.

53. No Sale of Personal Data

DirectDemocracyS does not sell personal data.

It does not rent personal information to third parties for commercial exploitation.

Personal data are not treated as a commodity.

The existence of a DirectDemocracyS account does not constitute permission for unrelated organisations to commercially exploit the user's identity.

54. International Data Transfers

Where personal data are transferred outside the European Economic Area, DirectDemocracyS applies the safeguards required by applicable data protection law.

Depending on the circumstances, these may include:

• an adequacy decision;

• appropriate contractual safeguards;

• Standard Contractual Clauses;

• additional technical measures;

• other legally recognised transfer mechanisms.

The specific transfer mechanism depends on the actual location of the receiving system and the applicable law.

DirectDemocracyS should maintain an up-to-date record of actual international transfers.

55. Data Accuracy

DirectDemocracyS seeks to maintain accurate information.

Users may be asked to correct information that is:

• inaccurate;

• incomplete;

• obsolete;

• inconsistent with the purpose for which it is used.

Where the user controls the information directly through their account, they should use the available profile-management tools.

Where the information cannot be changed directly, the user may contact the privacy team.

56. Right of Access

A person may have the right to request confirmation as to whether DirectDemocracyS processes their personal data and, where applicable, to obtain access to those data.

Access may include:

• categories of data;

• purposes;

• applicable retention information;

• recipients;

• relevant processing information;

• copies of personal data, subject to applicable legal limitations.

DirectDemocracyS may need to verify that the requester is entitled to receive the information.

This verification should be proportionate and should not unnecessarily undermine the user's anonymity.

57. Right to Rectification

Users may request correction of inaccurate personal data.

Where appropriate, DirectDemocracyS may also update information internally when an error is discovered.

Identity-verification information may be subject to specific verification procedures because changing such information can affect the integrity of the verification process.

58. Right to Erasure

Where applicable, a person may request deletion of their personal data.

However, the right to erasure is not absolute.

DirectDemocracyS may retain certain information where retention is necessary or legally required, including:

• tax records;

• accounting records;

• employment records;

• legally required documents;

• security records;

• evidence necessary for legal proceedings;

• information necessary to prevent serious fraud or abuse;

• records whose retention is required to protect the integrity of the system.

Where complete deletion is not legally possible, DirectDemocracyS should restrict processing and, where appropriate, anonymise or isolate the information.

59. Right to Restriction of Processing

Where applicable, a person may request restriction of processing, for example where:

• accuracy is disputed;

• processing is allegedly unlawful;

• the person needs the information for legal claims;

• the person has objected and the relevant assessment is pending.

Restricted data should not be used beyond the purposes permitted by applicable law.

60. Right to Object

Where the applicable legal basis permits objection, a person may object to certain processing.

This may be particularly relevant to:

• direct marketing;

• certain processing based on legitimate interests;

• other processing for which the law provides a right to object.

DirectDemocracyS will assess the objection according to the applicable legal requirements.

61. Right to Data Portability

Where the legal conditions for portability are satisfied, a person may request their personal data in a structured, commonly used and machine-readable format.

Portability generally applies only to the categories and legal circumstances defined by applicable data protection law.

62. Automated Decision-Making

DirectDemocracyS may use automated systems and AI to support certain processes.

Examples may include:

• technical security analysis;

• document analysis;

• anomaly detection;

• verification assistance;

• classification;

• system administration.

Automated processing must not unlawfully remove the rights of the person concerned.

Where applicable law grants a right not to be subject to a decision based solely on automated processing producing legal or similarly significant effects, DirectDemocracyS must respect that right and provide the safeguards required by law.

63. Exercising Privacy Rights While Remaining Anonymous

DirectDemocracyS recognises a particular difficulty created by strong anonymity.

If a person uses an entirely random username and DirectDemocracyS does not publicly connect that username to their real identity, the system may not be able to determine whether a person making a request is genuinely the account holder.

In such cases, DirectDemocracyS may request reasonable proof of control over the relevant account or another proportionate verification mechanism.

The purpose is not to destroy anonymity.

The purpose is to prevent one person from obtaining another person's private information.

DirectDemocracyS should therefore seek to verify entitlement without collecting unnecessary additional personal data.

64. Data Breaches and Security Incidents

DirectDemocracyS maintains procedures for identifying, containing, investigating and responding to security incidents.

Where a personal-data breach occurs, DirectDemocracyS will assess:

• what happened;

• what information was affected;

• which users may be affected;

• the level of risk;

• what containment measures are required;

• whether notification to a supervisory authority is legally required;

• whether affected persons must be informed.

The applicable notification deadlines and procedures are determined by law.

65. Privacy by Design

Privacy is incorporated into the DirectDemocracyS architecture from the beginning rather than added only after a system has been developed.

Examples include:

• anonymous usernames;

• separation of username and identity;

• unique verification codes;

• separate verification phases;

• random selection of verifiers;

• restricted access to identity documents;

• encrypted verification videos;

• private storage;

• limited network exposure;

• role-based access;

• need-to-know access;

• limited retention;

• separate representative profiles;

• controlled visibility.

The objective is to reduce the amount of personal information that any individual person can access.

66. Privacy by Default

Where a user has not actively chosen to make information public, the system should apply the most privacy-protective setting reasonably available.

This means that private information should not become public merely because a user has created an account.

The default should be:

minimum necessary visibility, unless greater visibility is deliberately chosen or required for the user's activity.

67. Security Does Not Cancel Privacy

DirectDemocracyS recognises that security and privacy must work together.

Security procedures may require processing personal information.

However, security is not a general justification for unlimited access.

The appropriate approach is:

• collect only what is necessary;

• use it only for a legitimate purpose;

• protect it;

• restrict access;

• record exceptional access;

• retain it only as long as necessary;

• remove or archive it appropriately.

68. Privacy and Democratic Participation

DirectDemocracyS distinguishes between:

1. the right to participate;

2. the right to anonymity;

3. the right to verified identity;

4. the right to shared leadership;

5. the right to collective ownership;

6. the responsibilities of official representation;

7. the requirements of political representation.

These rights and responsibilities are not identical.

A person does not lose their general right to privacy merely because another person chooses to become an official or political representative.

At the same time, a person who voluntarily requests a role requiring verified identity must accept the additional verification requirements applicable to that role.

69. Privacy and Collective Ownership

Collective ownership is one of the reasons for the identity-verification requirements applicable to official members.

Where the rules require a verified and guaranteed identity for official membership, the identity verification exists to establish eligibility for that specific legal and organisational function.

It does not mean that the person's identity becomes publicly available to every other member.

Verification of eligibility and public disclosure of identity are two different concepts.

70. Privacy and Shared Leadership

Similarly, binding participation in shared leadership may require a verified identity.

The verification exists to ensure that the person exercising the corresponding rights is a real, eligible and uniquely identified participant.

The underlying identity remains protected from ordinary users unless the applicable role requires public identification.

71. Privacy and the Different User Types

DirectDemocracyS uses different user types because not every activity requires the same level of verification.

The general principle is:

Higher responsibility may require higher verification, but higher verification does not automatically mean unrestricted public disclosure.

A Free user may remain anonymous where the rules permit.

A Verified user may have a verified identity while still operating publicly through a username.

An official member may have additional rights and responsibilities while their real identity remains protected from ordinary users.

A political representative must be identifiable because political representation requires it.

72. Children and Age-Related Processing

Age-related processing is governed by the applicable DirectDemocracyS participation rules and by the law applicable to the relevant user.

Where age verification is required for a specific service or legal obligation, DirectDemocracyS processes only the information necessary for that purpose.

No unnecessary age-related information should be made public.

73. Third-Party Websites and External Services

DirectDemocracyS may contain links to external websites or services.

When a user leaves a DirectDemocracyS platform and accesses an external service, that service may have its own:

• Privacy Policy;

• Cookie Policy;

• Terms of Service;

• data-processing practices.

DirectDemocracyS is not responsible for processing performed independently by an external website outside the DirectDemocracyS system.

Users should therefore review the privacy information of external services before providing them with personal data.

74. User Responsibility for Personal Disclosure

DirectDemocracyS provides strong privacy architecture, but no system can protect a user from every form of voluntary disclosure.

A user may unintentionally identify themselves through:

• photographs;

• documents;

• writing style;

• personal stories;

• location information;

• employment information;

• social-media links;

• external websites;

• unique personal events;

• communication with people who already know their identity.

Users who require strong anonymity should therefore avoid voluntarily publishing combinations of information that make identification easy.

75. Relationship Between the Username and the Personal Data

The username is the primary operational identifier within DirectDemocracyS.

For an anonymous user, the username should not reveal the person's legal identity.

Protected information such as:

• name;

• surname;

• identity-document information;

• telephone number;

• personal email;

• verification records;

must not automatically be inferred from the username.

Where the technical architecture permits, identity information and operational information should be maintained in separate logical and technical environments.

76. Special Protection of Identity-Verification Servers

Identity-verification data and other particularly sensitive information may be stored on servers inaccessible from the public network.

This architecture is intended to provide an additional security layer.

The fact that information exists on a private server does not eliminate the obligation to protect it.

Private storage must therefore also be subject to:

• access controls;

• authentication;

• encryption where appropriate;

• monitoring;

• authorisation;

• backup security;

• retention rules;

• deletion procedures.

77. Backup Copies

Backups may contain personal data because they are necessary to restore system availability and integrity.

Backups should be protected with security measures appropriate to the data they contain.

Backup copies should not be treated as an excuse for indefinite retention.

Where data are deleted according to the applicable retention schedule, the deletion process should also consider backup cycles and technical limitations.

78. Data Concerning Security Investigations

Where DirectDemocracyS investigates serious violations, fraud, identity misuse, abuse or security incidents, it may temporarily process additional information.

Such information may include:

• account activity;

• technical logs;

• communications;

• verification records;

• reports;

• evidence;

• incident records.

Access is restricted to authorised persons.

The information must not be used for unrelated purposes without an appropriate legal basis.

79. Data Concerning Disciplinary Procedures

Where the DirectDemocracyS rules provide for sanctions, a disciplinary or security process may require processing information necessary to:

• identify the relevant account;

• establish the facts;

• protect other users;

• document the decision;

• provide appropriate procedural safeguards;

• respond to appeals;

• comply with legal requirements.

Disciplinary records remain subject to confidentiality and retention rules.

80. Confidentiality of Internal Groups

DirectDemocracyS operates through specialist, security, administrative, legal, verification and other internal groups.

Membership in an internal group does not grant unlimited access to all personal data.

Each group should receive only the information necessary for its authorised activity.

Information received for one activity must not be redistributed to another group unless there is a legitimate reason and appropriate authorisation.

81. Confidentiality Obligations of Authorised Members

Persons authorised to access protected personal information must respect confidentiality.

They must not:

• disclose identity information without authorisation;

• copy protected documents for unrelated purposes;

• publish private information;

• connect anonymous usernames with real identities for personal reasons;

• use protected information for harassment;

• use protected information for commercial purposes;

• use verification information to obtain personal advantages.

Violations may result in the sanctions provided by DirectDemocracyS rules and, where applicable, legal consequences.

82. Human Bridges and Privacy

DirectDemocracyS may use human bridges between users and authorised members, and between humans and Artificial Intelligence systems.

The existence of a human bridge does not automatically authorise disclosure of the user's protected personal information.

The bridge should receive only what is necessary to perform its specific role.

Where an AI system is involved, personal data must also be protected according to the applicable privacy and security requirements.

83. Artificial Intelligence and Personal Data

DirectDemocracyS may use Artificial Intelligence systems as part of its technological architecture.

This may include ddsAI, allddsAI or other authorised AI systems where applicable.

AI may assist with:

• verification;

• analysis;

• classification;

• security;

• translation;

• moderation;

• information organisation;

• technical operations;

• detection of anomalies;

• other authorised activities.

AI systems do not automatically receive unrestricted access to personal data.

The same principles apply to AI processing as to human processing:

• necessity;

• purpose limitation;

• minimisation;

• confidentiality;

• access control;

• security;

• retention limitation;

• accountability.

Where AI processing is not necessary, personal data should not be provided merely because the technology is available.

84. No Generalised AI Access to Private Identity

The existence of an AI system inside the DirectDemocracyS ecosystem does not create a general right for that AI system to access all identity information.

Highly sensitive identity data remain protected.

Access should be technically restricted to the specific AI function for which processing is authorised.

85. Data Retention and the Right to Privacy

DirectDemocracyS recognises that retaining personal information creates risk.

For this reason, the system follows a two-level approach:

Operational storage

Data remain on ordinary network-accessible systems for approximately seven working days as a general operational period.

Protected storage

Information that must be retained for legal, security, accounting, employment, verification, historical, administrative or other legitimate reasons may be transferred to protected private storage.

This separation reduces the continuous exposure of historical information.

86. Review of Retention Periods

Retention periods should be reviewed periodically.

If information is no longer required, it should be:

• deleted;

• securely destroyed;

• anonymised where appropriate;

• or isolated where legal retention still applies but operational access is no longer necessary.

The fact that storage is inexpensive does not constitute a justification for indefinite retention.

87. Local, National and European Legal Requirements

DirectDemocracyS operates from Romania and within the European Union while potentially interacting with users and activities in multiple jurisdictions.

Different legal systems may impose different retention, employment, accounting, tax, security, marketing or other requirements.

Where applicable law requires a different period from the general DirectDemocracyS retention period, the legally required period applies to the relevant processing activity.

The system therefore maintains category-specific retention requirements rather than treating all data identically.

88. Marketing and Communications

Marketing communications are subject to applicable law.

Where consent is required, communications will be sent only where valid consent exists.

Where another legal basis is applicable, DirectDemocracyS will comply with the requirements governing that basis.

Users may unsubscribe or exercise applicable objection rights.

Marketing information is normally retained for approximately 24 months from the last administrative contact, unless a longer legally required period applies.

89. Administrative Communications

Administrative communications are different from marketing.

They may be necessary for:

• account security;

• registration;

• verification;

• password recovery;

• important rule changes;

• legal notices;

• system maintenance;

• security incidents;

• user-requested services.

Because these communications may be necessary to operate the relationship with the user, they may not always be subject to the same opt-out rules as marketing.

90. Changes to This Privacy Policy

DirectDemocracyS may update this Privacy Policy when:

• the system changes;

• technology changes;

• legal requirements change;

• new user types are introduced;

• verification procedures change;

• retention rules change;

• new services are introduced;

• security requirements change.