Privacy Policy

1. Who we are and what this policy covers

This Privacy Policy explains how Ariel Danieli, operating To120 and its Hebrew edition, עד 120, from Toronto, Ontario, Canada ("To120," "we," "us," or "our"), collects, uses, discloses, retains, and protects personal information in connection with https://twonetwenty.com and communications with us.

Ariel Danieli is responsible for the personal information under our control and is the contact for privacy questions and requests.

Privacy contact: Ariel Danieli

Email: to120ad120@gmail.com

We handle personal information in accordance with the laws applicable to our activities, including Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) where it applies. The privacy commitments in this policy, including our opt-in analytics choice, apply to visitors to both language editions regardless of whether a particular activity falls within PIPEDA. We also respect additional mandatory protections under another applicable law.

The governing-law clause in our Terms of Service does not limit a privacy regulator’s lawful authority or remove statutory privacy rights. Choosing the Hebrew edition does not make this a separate Israeli-operated service.

2. Our approach

You can browse our public election information without creating an account or providing your name. We process the technical information needed to deliver and protect the Website and, with your consent, limited information for standard website analytics.

We do not sell personal information, use it for targeted advertising, or build profiles of visitors’ political opinions. We do not use visitors’ browsing or scenario selections as polling responses or inputs to our election forecasts.

This policy covers the Website’s current informational services. It does not authorize undisclosed future activities such as advertising, paid subscriptions, or political-opinion surveys. Contacting us does not subscribe you to a mailing list or authorize promotional messages.

3. Information we collect

Information you provide directly

If you email us or otherwise contact us, we receive the information you choose to provide, such as your name, email address, message, and attachments. We use it to handle your request and maintain an appropriate record of the correspondence.

Providing this information is voluntary. Without sufficient contact details or information about your request, we may be unable to respond. Please do not send identity documents, sensitive personal information, or information about another person unless necessary and appropriate for the request. If we request additional information, we explain its purpose and the consequences of not providing it.

Donations through Ko-fi

The donation button takes you to Ko-fi, outside the Website. Ko-fi collects a supporter display name, email address, and any optional message, and makes that information available to Ariel Danieli. Ko-fi and the payment provider connected to the To120 page process the payment under their own policies; To120 does not collect card details on this Website. We use supporter information for donation administration and correspondence, not for a marketing list.

Technical and security information

When your browser connects to the Website, we and our hosting and security providers process technical information needed to communicate with your browser and operate the service. This may include your IP address, request date and time, requested page or resource, browser and device information, referring page where supplied, response status, and security or error information.

This processing supports page delivery, troubleshooting, abuse prevention, and security. Some information may appear in operational logs. It is separate from optional audience analytics and may continue when analytics is disabled. We do not repurpose operational or security logs to bypass your refusal of optional analytics.

Standard website analytics

With your consent, we use Google Analytics 4 (GA4) to understand how the Website is used and improve navigation, content presentation, accessibility, and performance.

Analytics information actually collected: page addresses and titles, visit and session information, approximate location, browser and device information, referring sources, and engagement metrics. We do not send custom party selections or coalition compositions.

An IP address may be processed when an analytics request is received. The provider’s treatment of that address, including any truncation, hashing, or storage, is described in Google’s privacy documentation; we do not receive individual IP addresses in our GA4 reports. We do not collect precise GPS location for analytics.

The analytics service uses the Google tag and first-party cookies after consent. Its privacy information is available at Google Privacy Policy. The technology inventory in Section 6 identifies any relevant cookies, local storage, or cookieless identifiers and their lifetimes.

Information is not necessarily anonymous simply because it lacks a name or has been hashed. We treat information that can reasonably be linked to an identifiable person as personal information. We use aggregate reports where practicable and do not attempt to identify individual visitors from analytics reports.

Privacy choices and preferences

We store your analytics choice in your browser's local storage as described in Section 6. The Website does not keep a server-side record of your choice.

4. Political information and interactive tools

Our Website concerns politics, but our audience analytics are not designed to discover how individual visitors intend to vote.

We do not send the parties you select, coalition combinations you construct, hypothetical voting preferences, or free-text messages to analytics providers as event values. We may count that an interactive feature was used without recording the political choices entered into it. We configure analytics page addresses and event data to exclude names, contact details, free text, and scenario-specific inputs. Any limited technical identifiers used for analytics are described in Section 3.

We do not link your correspondence with browsing records to infer political opinions or use website data for political targeting. If you voluntarily discuss political views in a message to us, we use that message to address your communication, not to create a political profile. Please avoid providing such information when it is unnecessary.

These restrictions on analytics do not mean that requests made while using the Website are invisible to hosting or security providers. Their limited operational processing is described in Section 3 and is not used to build political profiles.

We do not use advertising pixels, cross-site behavioural advertising, or session-replay recordings of your visits.

5. Why we use information and how consent works

We use personal information to deliver and secure the Website, diagnose faults, respond to communications and correction requests, manage privacy choices, measure website use with consent, and meet legal obligations or address legal claims where permitted by law.

We limit collection, use, and disclosure to appropriate, identified purposes and obtain meaningful consent where required. When you request a page or send us a message, the information reasonably needed for that request is processed using the form of consent appropriate to the circumstances and applicable law. For necessary, reasonably expected, non-sensitive processing, consent may be implied where the law permits. That is not consent to unrelated or optional uses. Processing without consent occurs only where applicable law permits or requires it; a general business interest is not treated as a blanket exception to consent requirements.

Optional analytics are enabled only after you expressly choose to accept them. Visiting the Website, continuing to browse, or accepting the Terms of Service is not our basis for activating optional analytics. Rejecting analytics does not prevent access to the public Website.

You may withdraw consent, subject to applicable legal or contractual restrictions and reasonable notice where relevant. We explain any restriction or practical consequence. There is no notice period or loss of public-site access for switching optional analytics off through our privacy settings.

We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects.

6. Cookies, similar technologies, and your choices

Cookies are small files stored on your device. Local storage and similar technologies can also remember settings or support website functions. Whether a technology uses cookies does not, by itself, determine whether it involves personal information.

Storage needed to remember your privacy choice or provide a function you request is used only for that purpose. Optional analytics are disabled unless you select “Allow analytics.” You can select “No analytics” and continue using the public Website.

You can change or withdraw your choice at any time through “Analytics preferences” in the Website footer. Switching analytics off stops future optional analytics requests from that browser and attempts to remove first-party GA4 cookies. Information already sent to Google cannot be recalled by that browser action. Requests concerning retained information are addressed in Sections 9 and 10. Truly anonymous statistics may no longer be capable of being linked to you or individually removed.

You can also block or delete cookies through your browser. Browser settings alone may not stop cookieless measurement, so use our privacy settings to control our analytics. Clearing browser storage or using another browser or device may require you to set your choice again.

Technology inventory

This inventory includes cookieless measurement where used. An identifier’s expiry is not necessarily the same as the retention period for events or aggregate reports in Section 9.

7. Who receives information

The operator, authorized personnel, and service providers receive information only as needed for the purposes described in this policy and as permitted by law.

We remain accountable for personal information under our control when a provider processes it on our behalf. We use contractual or other appropriate measures to provide a comparable level of protection, restrict use to the agreed purposes, and control access, taking account of the information and risks involved.

Ko-fi and its connected payment provider handle off-site donations under their own terms and privacy notices. Their independent role does not remove our responsibility for supporter information that we receive or use. We obtain any additional consent required for a new use of that information.

We may disclose information where legally required, in response to valid legal process, or where lawfully necessary to protect rights, safety, or security. If operation of the Website is transferred, information may be transferred only with appropriate safeguards and subject to applicable law and any required notice or consent. A transfer does not authorize an unrelated use.

We may publish or share statistics that have been aggregated and anonymized so that individuals cannot reasonably be identified. We do not sell personal information or share it for cross-context behavioural advertising.

8. Processing in Canada and other countries

Our operation is based in Canada. Information you provide to us or make available through your use of the Website may be handled by us in Canada and by our providers outside Canada. Being based in Toronto does not mean that all hosting, analytics, email, payment processing, or backups are located in Canada.

Vercel currently reports a United States region for this Website's server functions and also operates a distributed delivery network. Google, Ko-fi, and the connected payment provider may process information in other locations under their own terms and privacy notices.

Information processed in another country may be accessible to that country’s courts, law-enforcement bodies, or national-security authorities under its laws. Those laws may differ from the laws where you live.

We remain accountable for information under our control that is transferred to providers for processing and use the safeguards described in Section 7. A transfer for processing does not authorize a new purpose. We provide appropriate notice and obtain any additional consent or implement any specific transfer safeguard required by applicable law.

You may contact our privacy contact for information about relevant provider arrangements, subject to lawful confidentiality restrictions. We do not treat using the Website as blanket consent to any foreign processing or future use.

9. Retention and security

We keep personal information only for as long as reasonably necessary for its identified purpose and applicable legal requirements.

Specific records may be retained longer when necessary and lawful for a security incident, legal obligation, privacy request, or legal claim. They are restricted to the relevant purpose. Information is deleted or genuinely anonymized when no longer needed. Truly anonymous aggregate statistics may be retained longer because they no longer identify individuals.

We use reasonable technical and organizational safeguards appropriate to the information and risks, including controlled access and suitable protections provided by our service providers. No internet transmission or storage system is completely secure.

Where PIPEDA applies and a breach of security safeguards creates a real risk of significant harm, we report it to the Privacy Commissioner of Canada and notify affected individuals as soon as feasible, as required by that law. We maintain required breach records and make any other notifications required by applicable law. We also follow other applicable reporting requirements where they apply.

10. Your privacy requests and rights

You may ask us whether we hold personal information about you, request access to it, ask how it has been used or disclosed, challenge its accuracy or completeness, and request an appropriate correction. You may also ask us to stop a particular use, delete information, or withdraw consent. We assess requests under applicable law and the commitments in this policy.

Where PIPEDA applies, rights of access, correction, and withdrawal of consent are subject to the conditions and exceptions in that law. There is no unconditional promise that every record can immediately be erased, or that data portability or every foreign statutory right applies to every visitor. We delete or anonymize information that is no longer needed and honour any additional mandatory rights, including deletion or other rights, under another law that applies to the processing concerned.

To make a request, contact to120ad120@gmail.com. We may ask for proportionate information to verify your identity and locate the relevant records, using that information only as needed for the request. We do not collect unnecessary additional information merely to re-identify genuinely anonymous records.

We ordinarily aim to respond within 30 calendar days. For access requests governed by PIPEDA, the 30-day response requirement applies subject only to legally permitted extensions and the required notice. We comply with any different deadline required by another applicable law. We explain any refusal or limitation and available recourse as required. Access is provided at minimal or no cost where PIPEDA applies; any permitted charge is communicated in advance in accordance with the law.

You may raise a concern with Ariel Danieli at the privacy contact above. You may also contact the Office of the Privacy Commissioner of Canada about matters within its jurisdiction, or another privacy regulator or competent court where applicable law permits. You do not have to contact us first where the law permits a direct complaint or proceeding. We do not require you to waive statutory rights to use the Website.

11. Children and external websites

The Website is a general-audience information resource and is not specifically directed at children. We do not knowingly seek sensitive personal information or political preferences from children.

For processing that requires consent, we seek consent from a parent or legal guardian where a child cannot provide meaningful consent. As our operating policy, we require parental or guardian consent before knowingly collecting optional analytics or other consent-based personal information from a child under 13. For older minors, we consider their capacity to understand the nature and consequences of the processing and any additional legal requirements. We do not request a date of birth merely to read public content.

A parent or guardian who believes we hold information about a child that we should not hold may contact us. We assess the concern and delete or otherwise handle the information appropriately under applicable law.

Links to external websites are governed by those sites’ privacy practices. If we introduce embedded third-party content that collects visitor information, we explain that processing and obtain any consent required by applicable law or the privacy choices we offer before the content loads.

12. Changes, language versions, and contact

We may update this policy to reflect changes in our services, practices, or legal obligations. The updated version shows its effective date. We provide prominent notice of material changes and obtain new consent where required before introducing a new purpose or materially different processing.

Changes do not retroactively authorize uses for which consent or another lawful authorization was missing.

The English and Hebrew versions describe the same practices and are intended to have the same meaning. A translation difference does not authorize additional processing or reduce the protections we have promised. Please report any discrepancy so we can correct it. The language in which you read this policy does not determine which mandatory privacy laws apply.

For questions or requests, contact Ariel Danieli at to120ad120@gmail.com.