Privacy
Privacy Notice
TONEL-LA CORP. respects the privacy of visitors to its official digital platform. This Privacy Notice explains how information may be processed when you visit tonella.org, the safeguards that guide the website, and how measurement or interactive services are introduced through controlled releases.
Publication Status
Published v2.1 privacy and analytics-readiness release.
1. Scope
What this notice covers.
This notice applies to the public TONEL-LA CORP. website at tonella.org and the public pages delivered through that domain.
It does not describe separate systems, services, applications, membership processes, payment systems, or third-party platforms unless they are expressly identified in this notice.
2. Current Website Operation
The public website currently provides institutional information.
The public website currently provides institutional information, including TONEL-LA’s mission, strategic framework, programs framework, membership-readiness information, participation pathways, and accountability commitments.
At the time this notice is published, the public website does not provide active membership intake, payment or donation processing, or public forms designed to collect personal information.
3. Technical Information Required to Deliver the Website
Normal Internet delivery involves technical request information.
When you request a webpage, normal Internet communications necessarily transmit technical information such as an Internet Protocol address, browser or device information, requested URL, date and time, and related request information to the infrastructure used to deliver and protect the website.
Hosting, network, and security providers may process this technical information as necessary to deliver website content, maintain availability, prevent abuse, diagnose technical problems, and protect the website and its visitors.
TONEL-LA does not use this necessary infrastructure processing to create advertising profiles of website visitors.
4. Analytics
Privacy-conscious aggregate measurement.
TONEL-LA has selected Cloudflare Web Analytics as its approved service for privacy-conscious, aggregate website measurement under TLC 2.0 v2.1. Activation of the service is controlled separately from publication of this notice.
When active for TONEL-LA’s production website, Cloudflare Web Analytics uses a browser-based Real User Monitoring beacon to provide aggregate information about website use and performance. This may include visits, page views, page paths, referring sources, country, device type, browser, operating system, page-load timing, and Core Web Vitals.
TONEL-LA uses this information to understand the usefulness, reliability, and performance of its public digital platform. It is not authorized for advertising, cross-site behavioral profiling, session replay, keystroke recording, or the creation of individual visitor profiles.
The approved v2.1 configuration requires Cloudflare’s regional-exclusion mode for the production tonella.org hostname. TONEL-LA does not authorize production analytics collection from Cloudflare Pages preview or deployment hostnames.
5. Cookies, Browser Storage, and Similar Technologies
Cloudflare Web Analytics does not rely on analytics cookies or persistent browser storage.
Cloudflare states that its Web Analytics Real User Monitoring beacon does not store or access cookies, local storage, session storage, or IndexedDB for analytics measurement.
When active, the beacon processes page-specific performance information available through browser performance APIs. Cloudflare states that although the source Internet Protocol address necessarily reaches the Real User Monitoring endpoint as part of normal Internet request handling, that address is discarded at the nearest Cloudflare data center and is not stored in Cloudflare’s core Real User Monitoring databases or logs.
TONEL-LA does not authorize advertising cookies, cross-site tracking cookies, browser fingerprinting for behavioral profiling, or persistent analytics identifiers as part of this v2.1 implementation.
6. Information TONEL-LA Does Not Intentionally Collect Through the Current Public Website
Public intake is not active.
The current public website is not designed to collect names, email addresses, telephone numbers, membership identifiers, passwords, payment-card information, donation information, government identifiers, free-text form submissions, or other information through an active public intake process.
TONEL-LA does not authorize session replay, keystroke recording, advertising pixels, browser fingerprinting for behavioral profiling, or cross-site advertising profiles as part of the current public website.
7. Purposes of Processing
Technical processing should support delivery, security, reliability, and approved aggregate measurement.
Technical information associated with normal website requests may be processed for purposes including:
- delivering requested pages and website assets;
- maintaining website availability and performance;
- protecting the website against malicious or abusive activity;
- diagnosing failures and technical problems; and
- maintaining the security and integrity of the digital platform.
When active under the approved v2.1 controls, Cloudflare Web Analytics is used only to understand aggregate website use, reliability, and performance. TONEL-LA does not authorize it for advertising, cross-site tracking, or building behavioral profiles of individual visitors.
8. Service Providers
Cloudflare supports website delivery and approved aggregate measurement.
TONEL-LA uses service providers to operate and deliver its digital platform. These providers may process technical information on TONEL-LA’s behalf or as otherwise described in their applicable service terms and privacy documentation.
The website is delivered using Cloudflare infrastructure. Under v2.1, TONEL-LA has also approved Cloudflare Web Analytics for aggregate website-use and performance measurement on the production website, subject to the activation controls described in this notice.
For a website proxied through Cloudflare using automatic Web Analytics setup, Cloudflare loads its browser beacon from its analytics script infrastructure and sends measurement data to the website’s own Cloudflare Real User Monitoring endpoint.
9. Data Minimization
Collect only what is needed.
TONEL-LA’s website architecture follows a data-minimization principle: information should not be collected merely because it can be collected.
TONEL-LA limits website measurement to information necessary to understand aggregate site use, identify technical or performance problems, and improve the public platform.
Cloudflare Web Analytics currently does not log URL query strings, reducing the risk that information contained in query parameters becomes part of analytics reporting.
TONEL-LA does not use website analytics for advertising, individual behavioral profiling, sale of visitor information, or cross-site tracking.
10. Retention
Analytics retention is limited and documented.
TONEL-LA intends to retain website-related information only for as long as reasonably necessary for the purpose for which it is processed, subject to applicable operational, security, contractual, and legal requirements.
Cloudflare currently states that unsampled Web Analytics beacon data is retained for seven days. After that period, the data is aggregated for longer-term storage. Cloudflare currently makes Web Analytics information accessible through its Web Analytics service for the previous six months.
TONEL-LA will review these retention practices if Cloudflare materially changes the Web Analytics service or if TONEL-LA changes its analytics requirements.
11. International Processing
Cloudflare may process Real User Monitoring data through its global infrastructure.
Internet infrastructure and service providers may process information in more than one country.
Cloudflare states that Real User Monitoring data is generally processed at the nearest Cloudflare data center based on network routing and may therefore be processed in a country or region different from the visitor’s location.
TONEL-LA will continue to review applicable provider documentation, subprocessors, contractual safeguards, and relevant data-transfer considerations as part of its privacy and security governance.
12. Visitor Choices and Privacy Rights
Applicable rights depend on location and law.
Depending on where you live, applicable law may provide rights relating to personal information, including rights of access, correction, deletion, objection, restriction, or other privacy choices.
Privacy-related inquiries or requests may be submitted using the verified contact listed in Section 15.
13. Security
Privacy, security, and least privilege.
TONEL-LA applies privacy, security, and least-privilege principles to the development of its public digital platform.
No Internet service can guarantee absolute security, but website capabilities involving additional data collection will not be intentionally activated until their operational ownership, safeguards, and technical controls are reviewed.
14. Changes to This Notice
Privacy changes follow controlled release.
This notice may be updated as the TONEL-LA digital platform develops.
Material changes involving analytics, forms, membership intake, payments, donations, or other personal-information processing should be reflected in the notice as part of the controlled release that introduces those capabilities.
The effective date will identify the current published version.
15. Contact
Privacy inquiries.
Privacy-related inquiries or requests may be sent to the verified public channel above.