PRIVACY POLICY (EN)
Website Name – www.ambassadormelissawells.com
Effective Date: December 17, 2025
This Privacy Policy describes how the data controller for this Website is the family and legal heirs of Melissa Foelsch Wells, residing in the State of São Paulo, Brazil, collects, uses, stores, shares, and protects personal data processed through www.ambassadormelissawells.com (“the Website”). The Website is a digital memorial created to honor the life, legacy, and humanitarian work of Melissa Foelsch Wells and aims to inspire others through her experiences, celebrate her profound contributions, and preserve historical and biographical records relevant to her career.
The Website is hosted exclusively on servers located in Brazil, specifically within Oracle Cloud’s Brazilian Datacenter, as provided by the curator. All processing of personal data complies with the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados – LGPD, Law No. 13.709/2018), in addition to relevant ethical and international standards.
- Purpose and Nature of the Website
The Website serves three primary purposes, as described by the curator:
- To inspire people by sharing the life experiences and global work of the diplomat.
- To provide a space of tribute and remembrance, inviting friends, family, former colleagues, and members of the public to contribute memories.
- To serve as a historical archive, preserving selected personal and professional materials that reflect her international career and life journey.
The Website is strictly non-commercial, and all content is presented in a respectful, historical, cultural, and educational context.
All materials on the Website are maintained to preserve the historical integrity, dignity, and authenticity of the life and legacy of Melissa Foelsch Wells. No content may be altered, distorted, or contextualized in a manner that misrepresents her actions, beliefs, or diplomatic work. The Website reserves the right to refuse, remove, or restrict any content that compromises the integrity of the memorial.
This memorial is not affiliated with the United Nations, the U.S. Government, or any government, diplomatic service, or multilateral institution. Any references to diplomatic work or the UN appear solely within the context of historical documentation.
- Categories of Personal Data Processed
The Website processes several types of personal data, all of which fall into one of the categories described below.
2.1. Personal and professional photos from the diplomat’s personal archive
The Website contains personal and professional photos taken of the diplomat, and by her, between approximately 1940 and 2001, as well as photos taken in Spain between 2001 and 2021. These images may include:
- colleagues, diplomats, local citizens;
- individuals from Uganda, the United States, and various other countries;
- children and individuals from vulnerable communities;
- people whose identity is known or unknown;
- contexts of travel, humanitarian engagement, and professional activities.
These materials are processed strictly as historical and biographical records.
2.2. Non-confidential diplomatic documents
Some non-confidential diplomatic or work-related documents may be included. Any classified, confidential, or restricted materials will not be accepted or published.
2.3. User submissions (photos, documents, stories, and memories)
The Website allows third parties to upload content for publication, subject to moderation by the family as curator, and may include:
- photographs,
- written memories or testimonials,
- documents,
- materials contributed by friends, family, or members of the public.
2.4. Technical data automatically collected
The Website uses Google Console and Google Analytics, and may include:
- IP addresses,
- browser type,
- device information,
- cookie identifiers,
- pages visited and navigation patterns.
The Website does not offer login or newsletter functionality.
- Legal Basis for Processing (LGPD)
Under the LGPD, the Website relies on the following legal bases:
3.1. Legitimate Interest (Art. 7, IX)
The Website preserves and displays personal and historical materials for cultural, educational, and memorial purposes, including materials personally created by the diplomat during her life.
3.2. Consent (Art. 7, I)
Consent is required for all user-submitted content. Uploading a contribution constitutes informed consent to process and display the material.
3.3. Historical, Scientific, or Cultural Purpose (Art. 7, §4º)
Photographs and documents preserved in the memorial reflect historical events, international contexts, and biographical information.
3.4. Legal Obligation (Art. 7, II)
When necessary to comply with judicial or administrative requests.
3.5 Posthumous Rights and Estate Protection
All personal, biographical, and image rights related to Melissa Foelsch Wells are lawfully held by her heirs, who retain authority over the preservation, representation, and respectful use of her legacy. Any unauthorized commercial use, political or propagandistic exploitation, distortion, or misappropriation of her persona, likeness, or memory is strictly prohibited and may result in legal action under applicable personality, image, and cultural heritage laws.
- Diplomatic, Multilateral, and Sensitive Context Considerations
Because the diplomat worked in international settings. including diplomatic missions, humanitarian initiatives, and interactions with communities in multiple countries, the Website implements enhanced safeguards:
4.1. Disclaimer of Institutional Affiliation
The Website is not affiliated with, endorsed by, or representative of the United Nations, the United States Government, the U.S. Department of State, or any foreign government, embassy, consulate, agency, or multilateral institution. Any incidental appearance of logos, buildings, uniforms, or symbols does not imply sponsorship or endorsement and references to such institutions are purely historical.
4.2. “Do No Harm” Principle
Content will not be published or maintained if its disclosure could:
- endanger an individual,
- create political, social, or community harm,
- expose sensitive identities,
- violate humanitarian or ethical norms.
4.3. Sensitive Data Appearing Incidentally
Historical images may indirectly reveal ethnicity, religion, nationality, refugee status, or other sensitive data. Such data is processed solely for memorial and historical purposes, and removal will be granted upon request.
Certain archival photographs may depict minors in situations of hardship, trauma, displacement or humanitarian vulnerability. These images are included only when strictly necessary to portray the historical and humanitarian context of the diplomat’s work and are processed under the legal basis of historical and cultural purpose (LGPD Art. 7, §4º).
Any individual depicted may request removal at any time.
4.4 Accelerated Removal of Harmful or Illegal Content
Any content that is illegal, abusive, defamatory, threatening, discriminatory, sexually explicit, security-sensitive, or harmful to individuals appearing in the archive will be removed immediately upon identification or notification. Safety-related or humanitarian-sensitive removal requests receive priority and will be addressed within the shortest reasonable timeframe.
4.4. No Classified, Restricted, or Confidential Materials
The Website will not publish any:
- diplomatic cables,
- internal government documents,
- official internal UN reports,
- materials protected under U.S. State Department or UN confidentiality rules.
- User Submissions and Licensing
Users may contribute content for publication. By uploading any material, the contributor declares that:
- they are the rightful author or have authorization to submit the content;
- the material does not infringe any copyright or confidentiality obligation;
- the content does not originate from classified or official archives of any government or international organization;
- the contribution is free from sensitive or harmful information.
By submitting content, the user grants the Website a non-exclusive, perpetual, worldwide, royalty-free license to use and display the material within the context of the memorial.
All submissions are subject to moderation by the family of Melissa Wells, as described in the intake form.
- Moderation
As per the curator’s written statement, the family of Melissa Wells will serve as the moderator of the Website, responsible for receiving submissions and approving or declining them prior to publication. A third-party developer from the agency RAINOV will administer the backend technically but without editorial control.
Moderation may be:
- pre-publication,
- post-publication,
- or mixed, depending on the nature of the content.
Content violating this Policy will be removed.
6.1 Acceptable use and prohibited content
Where the Website offers any form of interaction – including contact forms, guestbooks, submission forms, or future comment functionalities – users must adhere to a respectful and commemorative tone consistent with the memorial nature of the Website. The following types of content are strictly prohibited:
- insults, slurs, or degrading language directed at any person or group;
- hate speech or incitement to discrimination, hostility, or violence;
- defamatory, harassing, or threatening statements;
- sexually explicit, pornographic, or suggestive content;
- content promoting racism, xenophobia, misogyny, homophobia, or any other form of prejudice;
- attempts to use the Website as a platform for political campaigning, propaganda, or ideological agitation;
- trolling, abuse, or any conduct incompatible with the respectful purpose of the memorial.
The Website may, at its sole discretion, refuse, edit, or remove any submission or message that violates these rules and, where applicable, block repeat offenders or disable interactive features to preserve the safety and dignity of all participants.
- Rights of Data Subjects
Any individual appearing in the Website may exercise the following rights:
- access their personal data;
- request correction or anonymization;
- request deletion of personal images or content;
- request restriction of processing;
- object to processing based on legitimate interest;
- revoke consent for user-submitted materials;
- request “urgent removal” in cases involving risk, dignity concerns, or vulnerability.
Requests can be sent to:
Email: ambassadormelissawells@gmail.com
Data Protection Officer (DPO): Christopher Stephan Wells
- Non-Commercial Use, Derivative Works, and Audiovisual Productions
8.1 Non-commercial purpose of the Website
All content made available on the Website, including photographs, videos, texts, documents, and user submissions, is provided solely for personal, educational, cultural, and research purposes. Any commercial exploitation of the content or of the persona, name, image, voice, or legacy of Melissa Foelsch Wells, including but not limited to films, series, documentaries, podcasts, books, advertising campaigns, branded content, or merchandising, is strictly prohibited unless expressly authorized in writing by the curator. her estate and legal heirs.
8.2 No derivative works without authorization
No person or entity may create derivative works based on or substantially inspired by the materials hosted on the Website. such as dramatizations, fictionalizations, AI-generated narratives, composite works, or adaptations – without prior written authorization from the estate of Melissa Foelsch Wells. Any unauthorized derivative use may result in legal action under applicable intellectual property, image, and personality rights.
8.3 Prohibition of political, propagandistic, or controversial exploitation
The name, image, voice, legacy, and memory of Melissa Foelsch Wells may not be used in connection with electoral campaigns, partisan politics, ideological propaganda, lobbying, or any campaign or communication of a politically divisive, inflammatory, or defamatory nature. The Website may not be cited, quoted, or used as a source in ways that suggest political endorsement, opposition, or alignment.
8.4 Protection against deepfakes and digital manipulation
It is strictly prohibited to create, upload, disseminate, or reference any AI-generated, deepfake, or digitally manipulated content that falsely attributes words, actions, behaviors, or positions to Melissa Foelsch Wells or to individuals appearing in the archive. Upon becoming aware of such misuse, the Website and the estate reserve the right to pursue legal measures and to cooperate with platforms and authorities to remove and prevent such abuse.
8.5 Preservation of archival integrity
The Website is committed to preserving the integrity and authenticity of the archival materials. Except for technical adjustments necessary for privacy, legibility, or preservation (such as cropping, blurring, or resolution enhancement), the content will not be altered in a way that distorts or misrepresents the historical record or the diplomat’s life, actions, or beliefs.
- Data Storage, Hosting, and Security
All data is hosted in the Oracle Cloud Datacenter located in Brazil. We implement physical, administrative, and technical safeguards to prevent:
- unauthorized access,
- accidental loss or destruction,
- misuse or unlawful processing.
Access to materials is limited to:
- the curator/moderator,
- authorized archival staff,
- the developer managing system infrastructure.
Sensitive images may be blurred, cropped, or restricted when necessary.
- International Access
Although hosted in Brazil, the Website may be accessed internationally. This external access does not constitute an international data transfer under LGPD, but we employ safeguards to prevent improper reuse, misinterpretation, or extraction of historical content.
- Sharing of Data
We do not sell personal data. We may share data only with:
- trusted technical service providers,
- the Website developer (RAINOV),
- legal or governmental authorities when required.
All service providers are bound by confidentiality.
- Retention
Historical materials, including the diplomat’s personal archive, may be preserved indefinitely due to their cultural and educational value, unless:
- an individual requests removal,
- the content presents safety risks,
- or publication violates legal or ethical standards.
User submissions are retained as long as the memorial remains active.
- Takedown Procedure
Any individual or institution may request removal of content that:
- infringes privacy,
- violates dignity,
- presents safety concerns,
- violates copyright,
- was submitted without authorization,
- or conflicts with diplomatic, humanitarian, or ethical obligations.
We will respond to all removal requests within 15 days, with expedited handling for urgent cases.
- Amendments
This Policy may be updated periodically. When updated, the Website will display a revised “Effective Date.”
- Contact
For privacy or content-related concerns, please contact:
Email: ambassadormelissawells@gmail.com
Data Protection Officer (DPO): Christopher Stephan Wells