Privacy Policy and Conditions of Cooperation with Readers of Oštro.si Website

We respect your privacy and protect your data by processing it safely, lawfully, fairly and in a transparent manner.

The methods of achieving the above are laid out in this document entitled Privacy Policy and Conditions of Cooperation with Readers which complies with the national and European legislation.

Oštro.si is a non-profit on-line media that exclusively pursues the public interest. Oštro.si wants to establish a two-way relationship with its readers who will be able to participate in public discussion as representatives of the public – not by publishing instant comments on social media or anonymous remarks below articles but rather by contributing their knowledge and professionalism.

Oštro.si enables all readers who wish to do so that they support the work of its editorial team either with content or financial resources. They can provide us with voluntary contributions or donations, join a membership programme or cooperate with Oštro.si editorial team by suggesting content or topics the research or investigation of which is, according to their opinion, in the public interest. In this case, they can send information, hints etc. to the editorial team.

Under certain conditions, members of Oštro.si will also be able to cooperate with the editorial team in the stage of investigation, while all our readers will enhance the quality of Oštro’s content with their contributions and help us protect the public interest.

An open and sincere alliance with our readers who wish to play a part in fostering changes in the society to the best of their abilities is, in our view, one of key building blocks for a successful and efficient operation of non-profit media. Since the non-profit media act in the public interest, they must take a proactive approach to their work by promoting media literacy, educating younger generations of journalists and paving the way for actual participation of the public in the matters of public interest.

Oštro will periodically send its newsletter to all readers who agreed to receiving it, inviting them to read the content or informing them of events and special campaigns.

Oštro, Center for Investigative Journalism in the Adriatic Region, Kotnikova ulica 28, Ljubljana, Slovenia, is a controller of personal data which it does not transfer to third parties.

The data of readers who agreed to Oštro collecting, keeping and processing their data will be used mainly to provide information on Oštro’s content and events or to call for cooperation in campaigns.

At any time during the processing of personal data, readers can demand access to their personal data or that their data is completed or rectified in accordance with the General Data Protection Regulation (hereinafter: GDPR) by sending a written request to the electronic address contact@ostro.si.

If readers think that their personal data is kept or otherwise processed in a manner that is not compliant with the applicable regulations governing the protection of personal data, they can contact the Information Commissioner of the Republic of Slovenia, Dunajska cesta 22, Ljubljana.

Please contact us at contact@ostro.si for more information.

Oštro’s newsletter

Oštro’s newsletter is periodically sent to readers who subscribe to it. Readers can subscribe on Oštro.si website and via banners on the websites of our partners and social media by entering their personal name and electronic address in the appropriate fields of the web form. After submitting their application, subscribers receive a confirmation electronic mail to the provided address.

In accordance with Article 158(2) of Electronic Communications Act, Oštro will inform newsletter subscribers via the provided electronic address of its work, events and campaigns which it will organise and call for readers’ cooperation, whereby newsletter subscribers will have the option of preventing such use of their electronic address upon receiving the newsletter or rejecting such use initially upon subscribing to the newsletter (by clicking a button).

Oštro will also process the personal data of newsletter subscribers for internal analytical and statistical purposes (referring to overriding legitimate grounds for processing it in its role of a controller).

Subscribers also have the option of independently changing the data regarding their personal name and electronic address via an on-line link in the newsletter.

Subscribers can unsubscribe at any time upon receiving the newsletter. A link “I no longer wish to receive Oštro’s newsletter.” will be available at the bottom of every electronic mail and, by clicking on it, subscribers will be able to unsubscribe from the newsletter via a dedicated web form.

Subscribers can also unsubscribe by sending an electronic mail to the electronic address contact@ostro.si. Accordingly, Oštro will stop processing the personal data of subscribers for the purpose of sending the newsletter within five days of receiving the information on unsubscription. The data of former subscribers will be rendered anonymous no later than one month following unsubscription.

When unsubscribing, the subscriber will be invited to fill out a questionnaire regarding reasons for unsubscribing which he or she can either fill out or not. Oštro will process the chosen reason in an anonymous form (without any link to the actual subscriber) for its internal and statistical purposes.

In accordance with GDPR, subscribers can demand access to their personal data, that their data is completed, rectified or deleted and that the processing of their data is blocked or restricted or they can object to the processing of their data or demand a transfer of data by sending a written request to the electronic address contact@ostro.si. If subscribers think that their personal data is kept or otherwise processed in a manner that is not compliant with the applicable regulations governing the protection of personal data, they can contact the Information Commissioner of the Republic of Slovenia.

Donations and contributions

Oštro is financed from voluntary contributions, donations, and funds acquired through public tenders and calls of various organisations.

We keep the data on natural and legal persons which transfer funds directly to Oštro’s bank account for the purposes of recording transactions.

At least once per year, Oštro.si publishes a report on acquired and spent funds, including data referring to the supporters who contribute substantial amounts for the purposes of maintaining the transparency of its operations.

The names of individuals whose voluntary contributions help Oštro to continue pursuing quality journalism will not be made public. The names of contributors will be published solely at their express request or if their overall annual contribution will exceed Oštro’s estimated monthly expenses (> EUR 7,000). Contributors can at any time permanently or temporarily withdraw their consent for the publication of their data.

The names of companies whose donations help Oštro to continue its operations will be published only if their overall donations will exceed one tenth of Oštro’s estimated monthly expenses (> EUR 700).

Oštro does not process data for any other purposes or share it with any other party.

Membership – Be our wind

Oštro also set up its own membership programme, thus inviting its readers to financially support its operations while, at the same time, becoming active members of the Oštro community. They can choose among three programmes which provide them with different membership benefits.

Readers can become our corresponding members by joining the Steady platform via Oštro. This platform is managed by Steady Media GmbH established in Berlin and processes members’ data on Oštro’s behalf pursuant to Article 28 of GDPR.

Upon joining the membership, every future member can also subscribe to Steady’s newsletter via a dedicated form. If a member chooses to receive its news, Steady Media becomes the controller for the data which are necessary to send the news, thus the member must contact Steady Media to exercise his or her rights, including as regards cancelling the subscription to newsletter.

Communication via electronic mail or in writing

Oštro provides its readers with the opportunity to co-create its content, to suggest areas of interest and to send various information, hints etc. to its editorial team.

All initiatives, information, hints etc. sent to Oštro’s main electronic addresses – contact@ostro.si and razkrinkavanje@ostro.si – should be signed with personal name of the sender. Anonymous initiatives are not welcome because Oštro does not see any reason to remain anonymous when proposing initiatives for discussing topics in the public interest, unless anonymity is necessary because an individual feels threatened. We advise to any such individual to send us information via zvizgac.si, i.e. Oštro’s portal for anonymous submission of information in the public interest (see the next section on zvizgac (whistleblower)), where you can find instructions on how to contact us in a safe and secure manner.

If senders submit information in the public interest, they will be considered a journalists’ source and protected from disclosure to third parties in accordance with national regulations and case law, unless the sender makes other arrangements with the editorial team.

Oštro will use the data solely for the purpose of contacting the sender and acquiring additional information or, if necessary, verifying the credibility of such information.

Oštro will collect, keep and process data only if readers will give their explicit consent, in which case the editorial team will keep their consent. If readers agree to it, they will receive in the newsletter the information on Oštro’s work, events and campaigns and they will be able to unsubscribe from it in a manner described in the section on Oštro’s Wire newsletter.

Safe and anonymous communication: zvizgac.si

All submissions carried out through the portal for secure and anonymous submission of information are anonymous and confidential. Zvizgac.si is based on SecureDrop, an open source whistleblower submission system that is currently considered the most reliable platform that media organizations, journalist or NGOs can install to securely accept documents from anonymous sources.

Furthermore, an established position in the case law of the European Court of Human Rights is that the right to ensure source anonymity is an integral part of a journalist’s freedom of expression, thus also making it a constituent part of the public’s right to be informed.

In 2018, the Supreme Court of the Republic of Slovenia also established the case law regarding the anonymity of journalists’ sources (judgement II Ips 61/2017 of 20 September 2018). In a court proceeding, a journalist is not obliged to disclose the identity of a journalist’s source upon the request of the opposing party because it does not involve exceptional circumstances where the public interest would clearly override the principle of protecting source confidentiality.

In addition, following a failed attempt at the prosecution of Oštro’s founder due to a supposed disclosure of classified information of the Slovene Intelligence and Security Agency, Article 260 of Criminal Code was amended. The disclosures of classified information which are indisputably in the public interest and which do not harm interest of the state are since then no longer considered a criminal offence.

Oštro does not keep, collect or process the data on persons who submit information. High standards of on-line security are expected of Oštro.si journalists and editors in performance of their duties and during their communication, while an external professional organisation occasionally carries out an examination of on-line security. All data submitted to us by our readers which will prove to be sensitive in terms of security will be protected according to the standards that apply to the protection of journalists’ sources and will not under any circumstance be disclosed to third parties.