This translation is provided for information purposes only. In the event of any discrepancy, the French version shall prevail.
In accordance with the provisions of French Law No. 2004-575 of 21 June 2004 on confidence in the digital economy (LCEN), users of the WeBlame platform are hereby informed of the identity of the various parties involved in its publication, operation and funding.
The website accessible at the URL https://weblame.org (hereinafter the “Site”) is published and operated by:
WEBLAME FOUNDATION
Non-profit association governed by the French Law of 1 July 1901, RNA (Répertoire national des associations, the French national register of associations): W133039439
Registered office: 28 Boulevard de la Corderie 13007 Marseille
Represented by: Ms Marline GARCIA, President.
The association WEBLAME FOUNDATION is:
• the publisher of the Site;
• the entity responsible for the WeBlame platform;
• the entity that manages testimonies and their moderation;
• the entity acting as controller for the processing of personal data within the meaning of the GDPR (General Data Protection Regulation (EU) 2016/679);
• the entity in charge of supporting and protecting users. The WEBLAME platform is thus managed and administered entirely by the association as part of its public-interest mission: encouraging people to speak out, breaking the isolation of victims and contributing to the prevention of violence.
The company SASU WEBLAME is a société par actions simplifiée unipersonnelle (single-shareholder simplified joint-stock company under French law).
SIREN (French company identification number): 989 331 988
Registered office: 28 Boulevard de la Corderie 13007 Marseille
SASU WEBLAME does not publish the platform, does not manage testimonies and does not access any personal data of users.
Its activity is exclusively dedicated to:
• vocational training;
• raising awareness of violence and harassment in organisations;
• interventions in companies and with institutions;
• the prevention of violence in professional environments.
These activities make it possible to disseminate the knowledge and expertise arising from the work carried out by the WEBLAME project, while contributing to the prevention of violence within companies and organisations. The training activities carried out by the company are strictly separate from the missions of the platform managed by the association. SASU WEBLAME has no access whatsoever to the data of users of the platform.
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Publication director:
Ms Marline GARCIA
Contact: contact@weblame.org
The weblame.org website is hosted by Hostinger, whose registered office is located in Cyprus (61 Lordou Vironos Street, 6023 Larnaca). The server on which the website is stored is located in France, and certain backups are located in Lithuania (European Union).
The app.weblame.org platform is hosted by Hostinger. The server on which the application is stored is located in France. The application uses a Supabase database (Supabase Inc., registered office in the United States). The database is hosted in Paris, in compliance with the requirements of the GDPR.
The Site as a whole, its structure, content, databases, software, algorithms and graphic elements are protected by intellectual property law.
Any reproduction without prior authorisation is prohibited.
The WeBlame platform, its functional architecture and its mechanisms for collecting testimonies, putting co-victims in touch with one another and generating non-identifying alerts are the subject of a filing establishing proof of prior creation (dépôt d’antériorité) with the INPI (Institut national de la propriété industrielle, the French intellectual property office).
Any reproduction or imitation may constitute:
• unfair competition,
• economic parasitism,
• infringement (contrefaçon).
The platform:
• does not legally characterise the facts;
• does not name anyone as guilty;
• does not take the place of the judicial authorities.
Content remains the sole responsibility of its authors.
WEBLAME FOUNDATION (non-profit association)
Represented by Ms Marline GARCIA, President
contact@weblame.org
A. Identification data
• Surname, first name
• Email
• Telephone
• Technical logs
B. Sensitive data – Testimonies
• free-form account;
• context;
• information relating to a person implicated.
Legal basis: consent of the data subject (GDPR Art. 6(1)(a)) and explicit consent for sensitive data (GDPR Art. 9(2)(a)).
The data is used exclusively to:
• collect people’s accounts;
• identify cases of co-victimisation;
• generate non-identifying alerts;
• provide support on request;
• produce anonymised statistics.
Alerts:
• do not allow anyone to be identified;
• constitute neither an accusation nor a public denunciation.
Fundamental principle:
• separation of identity / testimony;
• encryption;
• restricted access;
• EU hosting;
• documented protocols.
Data is never:
• sold,
• rented,
• assigned.
Access limited to an authorised team.
The WeBlame platform was designed from the outset as a tool for the lasting protection of victims, based on high ethical standards, responsible governance and an approach founded on trust.
Given the particularly sensitive nature of the information entrusted by users, the publishing association, WEBLAME FOUNDATION, adopts structural commitments intended to guarantee the long-term protection of data, regardless of any economic, institutional or personal change.
7.1 No commodification of data
The WeBlame platform is not based on any business model founded on the monetisation or commercial exploitation of personal data.
Accordingly:
• no personal or sensitive data is sold, rented, assigned or exchanged;
• the testimonies submitted do not constitute a marketable asset;
• no data is transmitted to third parties for advertising, marketing or commercial purposes.
The data entrusted to the platform is processed exclusively for the purposes of protection, support and the prevention of violence.
However, the platform may produce strictly anonymised statistical analyses which in no case allow the direct or indirect identification of the data subjects or of the persons implicated.
These statistics serve only the following purposes:
• analysis of the phenomena of violence (typologies, contexts, recurrences);
• raising awareness among the public and institutions;
• contribution to research or studies;
• preparation of reports intended for public authorities or prevention bodies.
This processing is carried out in accordance with the requirements of the General Data Protection Regulation (GDPR) and the recommendations of the CNIL (Commission nationale de l’informatique et des libertés, the French data protection authority), on the basis of aggregated and irreversibly anonymised data.
7.2 Lasting protection in the event of legal or ownership changes
In the event of any change in the legal structure, funding model, governance or institutional organisation of the platform, the following principles shall remain mandatorily applicable:
• maintenance of an equivalent or higher level of data security and protection;
• no possibility of using the data in a manner contrary to the interests of users;
• strict compliance with the original purpose of the project: protection, prevention and support for victims.
Any structural transformation must guarantee the continuity of the ethical commitments set out in this policy.
7.3 Mechanism ensuring continuity of protection in the event of a change of governance or incapacity of the founding management
Given the highly sensitive nature of the data entrusted to the platform, a specific legal mechanism has been provided for in advance in order to ensure the continuity of its protection independently of the natural persons involved in managing the project.
In the event of a change of governance, organisational change, long-term incapacity, cessation of duties or any situation affecting the founding management of the platform:
• the management of the platform and of the data shall remain governed by specific legal and notarial provisions;
• responsibility for the continuity of the system shall be entrusted to one or more persons or entities designated in advance for their competence and ethical commitment;
• no assignment, transmission or exploitation of the data may take place in contradiction with the principles set out in this privacy policy.
This mechanism is intended to ensure that the protection of users and the integrity of the data are guaranteed on a permanent basis, independently of any natural person.
7.4 Principle of ring-fencing data
The data entrusted to WeBlame is regarded as ring-fenced.
Accordingly, it may never:
• be used for purposes unrelated to the protection of victims;
• be made public in an identifying form;
• be exploited outside the strict framework defined by this privacy policy.
The platform recognises that the testimonies submitted are particularly sensitive aspects of people’s lives, involving the safety, dignity and sometimes the personal integrity of the data subjects.
The lasting protection of this data therefore constitutes a fundamental and permanent commitment.
Where a testimony concerns a minor, an enhanced level of protection is applied.
No public exposure is possible.
Referral to specialist organisations
Subject to explicit agreement, priority contact with a partner association may be offered in order to ensure:
• urgent assistance;
• specialised support;
• referral to the competent authorities.
Testimonies may be retained for a long, non-predetermined period in order to enable the subsequent identification of co-victims.
The data is:
• encrypted,
• pseudonymised,
• separated,
• traceable.
Retention is based exclusively on explicit consent.
Users may request erasure or restriction at any time.
Given the particular nature of the information entrusted to the platform, WEBLAME applies an enhanced retention policy designed to protect victims, witnesses and the minors concerned.
Categories of data concerned
This policy applies in particular to:
• testimonies from victims;
• testimonies from witnesses;
• data relating to violence suffered or witnessed;
• data concerning minors;
• health data that users may choose to provide;
• supporting documents provided voluntarily;
• identification data necessary to secure the system.
Retention of testimonies
Testimonies are retained in order to enable the subsequent identification of possible victims or witnesses of the same perpetrator.
This long-term retention is justified by the reality of violence: many victims only come forward several years, or even several decades, after the events.
Data is retained solely within the scope of the purposes defined by WEBLAME:
• protection of victims;
• identification of repeat offending;
• secure contact between the people concerned;
• support for victims;
• compliance with legal obligations.
Testimonies concerning minors
Where a testimony concerns a minor, an enhanced level of protection is applied.
The data is subject to:
• strictly limited access;
• enhanced monitoring;
• particular care with regard to its use and retention.
No identifying publication or dissemination is possible.
Where the information provided gives reasonable grounds to believe that a minor is exposed to a current danger or to a serious risk of the violence being repeated, WEBLAME makes the reports or disclosures provided for by law to the competent authorities or child protection bodies, without waiting for a match. To date, this reporting procedure applies only to situations falling under French jurisdiction; it is not implemented for situations that occurred outside France.
Health data
Some victims may choose to provide medical or psychological information in order to document their testimony.
This information is considered particularly sensitive data.
Accordingly:
• it benefits from an enhanced level of security;
• access to it is limited to authorised persons only;
• it is not used in any way other than as necessary for the purposes of the system.
Security and encryption
Data entrusted to WEBLAME is protected by several complementary security mechanisms:
• data encryption;
• separation between identification data and testimonies;
• access restrictions;
• traceability of data consultations;
• hosting within the European Union;
• documented security protocols.
Even in the highly unlikely event of unauthorised access to the servers, the encrypted data would remain unusable without the appropriate authentication mechanisms and security keys.
Judicial requests
WEBLAME does not transmit any data to third parties except in the cases provided for by law.
Any request for disclosure of data is subject to prior verification of its legal validity.
Any transmission of information may only take place within the framework of:
• a judicial request;
• a court decision;
• an applicable legal obligation.
Archiving and erasure
Users may exercise their rights in accordance with the GDPR.
Any request for erasure, restriction or rectification is examined on a case-by-case basis, taking into account:
• applicable legal obligations;
• the legitimate interests in protecting victims;
• any need to preserve certain data in connection with ongoing or future legal proceedings.
WEBLAME’s constant objective is to reconcile respect for users’ rights with the lasting protection of victims and the prevention of violence.
The internal system only analyses self-reported factual information.
It:
• makes no accusation;
• reveals no identity;
• requires consent before any contact is arranged.
Objective: to break the isolation of victims and facilitate voluntary support.
WeBlame is an intermediate tool between individual silence and recourse to the courts.
The platform pursues exclusively the objectives of:
• protection,
• prevention,
• support,
• making it safe to speak out.
It never constitutes a public register of accusations.
• access
• rectification
• erasure
• withdrawal of consent
contact@weblame.org
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