Privacy & Cookie Policy

1. What Clarvia.org collects

Clarvia ASBL operates Clarvia.org. We respect your privacy and use optional analytics and advertising cookies only if you choose to accept them.

Clarvia.org collects limited technical information needed to keep the website secure and working.

If you click “Accept all”, Clarvia.org also uses Google Analytics and Google Ads measurement to understand website traffic, improve our bereavement checklists, and measure donation campaign effectiveness.

We do not use advertising personalization or remarketing unless this policy and our consent banner are updated.

If you contact us for free bereavement administrative guidance or support, we also process the personal data you choose to share as described in section 5.

2. Cookies and consent

Optional Google Analytics and Google Ads cookies are disabled by default.

No optional analytics or advertising cookies are written to your device unless you click “Accept all”.

If you click “Decline / Essential only”, optional cookies remain blocked. Google may receive limited cookieless measurement signals where supported by Google Consent Mode, but analytics and advertising storage remain denied.

You can change or withdraw your choice at any time by clicking “Cookie settings” in the website footer.

3. Cookies Clarvia.org may use if you accept

Actual cookies may vary depending on your browser, consent choice, and Google’s services.

4. External donation services

Clarvia.org may link to or redirect you to external donation services, such as Stripe, GitHub Sponsors, or Open Collective.

Those services are separate from Clarvia.org and operate under their own privacy and cookie policies. Clarvia ASBL is not responsible for cookies or tracking used on external websites.

Please do not include sensitive family, health, or bereavement details in payment references or donation messages.

5. Contact and support requests

When you contact us by email or through a form for free bereavement administrative guidance or support, we process the personal data you choose to share. This may include your name, contact details, preferred language, the contents of your message, and any documents or other information you provide.

We use this information only to understand your request, communicate with you, and provide helpful assistance.

To help us respond accurately and in the appropriate language, we may use artificial intelligence tools, including large language models, to:

• translate messages;

• assist with research and information gathering; and

• prepare draft reply suggestions for review by a Clarvia volunteer.

These AI service providers act as processors on Clarvia’s behalf and under Clarvia’s instructions. We use only providers that offer appropriate data-processing agreements. Under our arrangements with them, they are not permitted to use the content you send us to train their general-purpose models.

AI tools may assist our volunteers, but a Clarvia volunteer remains responsible for the response sent to you.

Lawful basis: Clarvia’s legitimate interests under Article 6(1)(f) of the GDPR—specifically, providing the free guidance or support you requested and doing so accurately and efficiently.

Retention: We keep correspondence for as long as reasonably necessary to provide the guidance or support you requested and to maintain continuity, including where a matter remains unresolved or may require follow-up over an extended period. We periodically review requests to determine whether the correspondence is still needed. Once a matter is concluded and related follow-up is no longer reasonably expected, we delete or anonymise the correspondence unless continued retention is required by law or necessary to establish, exercise, or defend legal claims.

Access: Human access is limited to authorised Clarvia volunteers handling your request. Our contracted service providers may process the data only as needed to provide their services to Clarvia and in accordance with our instructions.

Please share only the information needed for us to help you. In particular, avoid sending unnecessary sensitive family, health, financial, identification, or bereavement details.

6. Your rights and choices

You can control cookies through your browser settings or change your preferences at any time using the “Cookie settings” link in the footer. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

Under the GDPR, you have the right to:

• access your personal data;

• correct inaccurate or incomplete personal data;

• request deletion of your personal data;

• request restriction of processing; and

• object to processing based on Clarvia’s legitimate interests.

These rights may be subject to conditions and exceptions under applicable law.

If you believe your data is handled incorrectly, you have the right to lodge a complaint with the Luxembourg data protection authority, the CNPD—Commission nationale pour la protection des données.

7. International data transfers

Some of Clarvia’s service providers, including Google and providers used to assist with contact and support requests, may process personal data outside the European Economic Area.

Where a provider in the United States is certified under the EU–US Data Privacy Framework, Clarvia may rely on that framework as the recognized transfer mechanism. Where the framework does not apply, Clarvia uses another valid transfer mechanism where required, such as the European Commission’s Standard Contractual Clauses, together with any additional safeguards required by law.

Accepting optional cookies controls whether Clarvia permits optional Google Analytics and Google Ads storage on your device. It is separate from the legal safeguards Clarvia uses for any international transfer of personal data.

8. Contact details

Clarvia ASBL, registered with the Luxembourg RCS under number F15680, is the controller of your data for Clarvia.org.

For privacy questions or to exercise your data-protection rights, please contact us using the “Contact Us” form available on our homepage at clarvia.org.

9. Changes

We may update this policy when Clarvia.org, our donation setup, our measurement tools, or the way we handle contact and support requests changes.