Privacy Policy
Thank you for visiting the Lebanese National Anti-Corruption Commission (NACC or Commission) website (the “Website”) and reviewing our Privacy Policy. The Commission is committed to protecting your privacy and securing the personal information made available to us when accessing our Website. This Privacy Policy describes what information is made available to the Commission, what information the Commission collects, how that information is used, and how such information is stored.
Legal Basis
This Privacy Policy is established in compliance with Law No. 81 dated October 10, 2018 relating to “Electronic Transactions and Personal Data” in Lebanon. Data protection and privacy principles protected in international best practices (such as Convention 108+ and the European General Data Protection Act) have also been considered when drafting this Privacy Policy.
Information and Data Collected Automatically
1- If you merely browse through our Website, without engaging in interactions such as filling in forms, we or a contractor operating on our behalf will automatically collect, process, and store certain fundamental information. This automatic data collection is conducted through the latest version of WordPress CMS, which powers our Website, and Google Analytics, a tool we utilize for gathering web statistics. The type of information collected includes, but is not limited to:
• Log Information: This includes details such as your Internet Protocol (IP) address, browser type and version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, and other standard web log information;
• Device Information: We may collect information about the device you are using to access our Website, including the type of device, its operating system, and mobile network information.
• Cookies and Similar Technologies: Our Website utilizes cookies and similar technologies to distinguish you from other users, which helps us provide you with a better browsing experience and allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive.
• Analytics Information: Through Google Analytics, we collect data about the usage and interaction on our Website. This data helps us understand how visitors engage with our site, allowing us to enhance user experience and optimize our services.
• Location Information: Your geographical location may be determined through your IP address and other geolocation services.
The Commission primarily collects this information for statistical analyses and technical improvements to the website. The Commission does not collect or use information for commercial marketing purposes.
2- If you fill in any forms, in addition to the above basic information, we, or a contractor operating on behalf of the Commission will automatically collect, process and store the data contained in any of those forms.
Please note that some of the information you may provide could be subject to the Access to Information Law [Add hyperlink to the law.]
Personal Information Provided Voluntarily
Accessing information on our website does not necessitate providing any personal information. However, if you decide to share personal information, such as sending a message to an email address displayed on this website, or through a search request, we will use that information solely to respond to your message or fulfill the intended purpose of the communication. Any voluntarily provided information will be handled and safeguarded in accordance with the current privacy policy regulations.
Please note that some of the information you may provide could be subject to the Access to Information Law [Add hyperlink to the law.]
We encourage you to exercise caution when voluntarily sharing sensitive information, as internet communications may not always be completely secure from interception. If your message contains sensitive data or personal information, it is advisable to share it with the Commission via postal mail or in-person at the NACC offices.
When Is Your Data Collected
The Website collects information when:
(i) You visit and use the Website;
(ii) You create an account to fill in the Asset Declaration Forms;
(iii) through website analytics services and other technologies;
(iv) You send us an email or contact us through any other method.
Retention and Storage of Data
The data collected through the Website is hosted by NACC. The equipment and main server are placed within the premises of the NACC data center and are encrypted pursuant to high security measures.
Your personal data will be retained for as long as necessary to (i) fulfill the purposes for which is has been retained, (ii) enhance user experience and use of the Website, (iii) comply with legal obligations, (iv) resolve disputes, and (v) enforce legal agreements and policies.
Usage Data for internal analysis purposes will generally be retained for up to 5 years, after which the data shall be anonymized and only used for statistical purposes, except when this data is used to strengthen the security or to improve the functionality of the Website, or when a legal obligation justifies retaining this data for a longer period.
Disclosure of Personal Data
Some of the personal information you share on the Website might be disclosed for validation and authentication against existing databases hosted by the relevant parties who can help with such validation and for the purpose of processing your request regarding either your Assets Declaration, Complaint for Access to Information or whistleblowing a corruption information.
We will not disclose your personal data to third parties who are not authorized (by law, by contractual obligation, or for any legitimate interest) to process them. We will ensure that this Privacy Policy will be regularly updated to include any third party which might have access to your personal data for any purpose.
Data that is not personal and that cannot be used to directly or indirectly identify you, may be shared and accessible by the public for their information and use. For instance, public dashboards displaying metrics of interest to the public (e.g., proportion of households below the poverty line) may be made available to the public without disclosing any personal data.
Security
To maintain website security and guarantee uninterrupted service for all users, NACC’s digital infrastructure, along with systems managed by external contractors for the Commission, utilizes software tools to scrutinize network activity. This is to detect any unauthorized efforts to add or modify data, or actions that might harm the system. Users of these systems inherently agree to this oversight. They should be aware that if this oversight uncovers signs of potential misuse or illegal actions, the findings could be shared with the relevant legal authorities. Any unauthorized actions to add or modify data on these systems are not allowed and could result in legal consequences.
Links to External Sites
The Commissions’ website may contain links to websites created and maintained by other public or private organizations. We provide these links as a facility to visitors to our website. When you follow a link to an external site, you are leaving the Commission’s website and are subject to the privacy and security policies of the external site.
