PRIVACY NOTICE

Fund for Research of War, Conflicts, Support of Society and Security Development "SAFE UKRAINE 2030" ("Fund", "Safe Ukraine 2030", "we", "us", or "our") has developed and complies with this Privacy Notice identifying which types of personal data of individuals ("you", "your", or "their") we process, for which purposes and in what manner we process them. This Privacy Notice covers issues of processing personal data collected only through our website.

This Privacy Notice has been developed based on and in compliance with the principles and requirements of applicable data protection legislation ("Data Protection Legislation").

Definitions

For the purposes of this Privacy Notice, the Fund uses the terms as provided for by the Data Protection Legislation, some of which are outlined below:

Personal data. Any information relating to an identified or identifiable individual (data subject)
Cookie. A small text file that a website stores on your computer or other electronic device during you visiting the website
Processing. Any action or set of actions performed with regard to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction, including with using automated means
Controller. An individual or a legal entity that (either alone or jointly with other persons) determines the composition of personal data, purposes for which and the manner in which such personal data is processed
Processor. An individual or a legal entity that processes personal data on behalf of the controller and is authorised to do so by the controller or by law

Collection of personal data

We collect your personal data directly from you during your visit to our website for the following purposes:

providing you with the relevant information, news, and updates upon your subscription to our mailout. This processing is based on your consent provided to be part of our mailing list;
notifying you about updating this Privacy Notice. This processing is based on our compliance with a legal obligation to keep you informed on how we process your data;
maintaining statistics regarding the persons interested in Fund's activity. This processing is based on our legitimate interests to keep our records updated and to study what our users are interested in.;
and improving user experience of our website. This processing is based on our legitimate interest to provide the optimum experience for our users.

If we need to process your personal data for purposes other than outlined above, we will notify you of the same and will ask you to provide your consent prior to such processing, unless we have other legal bases for such processing.

Types of personal data

The types of personal data we may collect and further process include:

name and surname; email address; your location (country);
technical data, such as IP address, type, and version of the web browser, time of your visit to the website, etc. This data is required to improve your experience while using our website We do not collect your sensitive personal data (or data which processing is of a particular risk for tights and freedoms of data subjects) as identified by the Data Protection Legislation.

Nevertheless, if this occurs, we will ask for your explicit consent for such processing, unless there are other legal bases for such processing.

How we collect personal data

We collect your personal data through our website, in particular: when you subscribe to our mailing list; and when you use our website. We collect personal data directly from you and do not collect them from any third parties.

Legal bases for personal data processing

One of our obligations as the controller is to ensure there is a legal basis for the processing of your personal data. We have noted down these lawful bases above where we explain the purposes for processing your data.

Where we process data on the basis of consent, you can withdraw your consent at any time by emailing us at compliance@safeukr2030.org or by contacting the CEO or the authorised Fund's representative. The withdrawal of consent affects only future processing operations with regard to your personal data.

Any processing operation that took place before such withdrawal is deemed legal. Please note that, as a result of withdrawing your consent for the processing of your personal data, we may be unable to provide you with some of our services. There also may be situations when your personal data may be processed under other legal bases as identified by the Data Protection Legislation.

Use of personal data

Processing of personal data may include all or some of the following operations: recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

Transfer of personal data to third parties

The Fund may transfer your personal data to third parties when it is legally allowed (such as if we have a legitimate interest) or the applicable law requires us to do so. Personal data provided by you may be transferred to the following third parties:

contractors, service providers, and other persons that support the activities of the Fund and our website and that act as processors. Such third parties and their resources may be used, for instance, for storing your personal data;
and/or law enforcement, state, and other regulatory agencies as outlined by applicable law.

Where your data is transferred to processors, we require them to implement measures for securing your personal data by way of imposing respective contractual obligations. If we transfer your personal data to third parties other than those provided for by this Privacy Notice, we will notify you of the same within 10 business days unless we are prohibited to do so by applicable laws.

Cross-border transfer of personal data

We may transfer personal data received from you outside of Ukraine for further processing by processors. The countries where we may transfer your personal data may have a different legal protection regime compared to the Data Protection Legislation. Such a legal regime may provide for personal data protection requirements either of higher or lower level as compared to the Data Protection Legislation.

We take necessary measures to secure your personal data and do not transfer your personal data outside of Ukraine to persons that did not introduce proper security and protection measures for personal data.

If your personal data are transferred outside of Ukraine, this will be done under one of the following legal bases:

a transfer is made to companies based in the member states of the European Economic Area or the signatories of the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data;
you provide your explicit consent for the transfer; we are required to transfer your personal data for the performance of a contract with you for your benefit;
a transfer is performed to protect your vital interests; a transfer is required to protect the public interest or fulfil legal requirements (e.g., in case of a legitimate request from foreign law enforcement authorities).

Retention of personal data

We retain Personal Data for as long as reasonably necessary to fulfil the purposes it was collected for and consistent with applicable law, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. The criteria used to determine our retention periods include, without limitation, consideration of the following:

your withdrawal of consent for the processing of personal data, unless we have other legal bases for the processing of your personal data;
legal requirements of the countries where the processing of your personal data takes place (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them);
necessity in light of our legal position such as in regard to applicable statutes of limitations, litigation or regulatory investigations (for example, storage of your personal data may be necessary for settling potential disputes during the statute of limitation).

Upon the expiration of the retention period, we erase your personal data.

Security of your personal data

The Fund ensures the implementation of proper technical and organisational measures to secure and protect the processing of your personal data. Confidentiality requirements apply to the persons involved in the processing of your personal data on our behalf (employees, processors, other persons).

Your data subject rights

Your data subject rights include:

right to know about the sources of collection and location of your personal data, the purpose of their processing, location of the data controller/processor or empower other persons to get this information;
right to obtain information about conditions for providing access to your personal data, in particular, information about third parties, which your data is transferred to;
right to access your personal data held by us;
right to obtain information on whether your personal data is being processed and the content of such data within 30 calendar days;
right to object to processing;
right to correction (rectification) and right to erasure;
right to protect your personal data from illegal processing and accidental loss, destruction, damage, as well as from provision of information that is inaccurate or discrediting honor, dignity and business reputation;
right to apply to the Ukrainian Parliament Commissioner for Human Rights or a court with claims regarding the processing of your data;
right to use remedies in case of violation of data protection regulations;
right to restrict processing when providing your consent;
right to withdraw consent;
right to know the logic of automatic processing if applicable;
right to protect yourself from automated decision-making (if applicable) that has legal consequences for you;
right to lodge a complaint with a supervisory authority; and right to data portability.

In case you need to execute your data subject rights, you can apply to us with the relevant request by contacting us at compliance@safeukr2030.org. We are entitled to request confirmation of your identity to protect your personal data from loss. We process such requests within 1 month. Upon the results of such processing, we decide whether to satisfy or reject the request. We also notify you of the positive or the negative outcome of your request with a relevant explanation of the latter.

Tracking technologies

Our website also collects information via cookies, pixels, and tags, such as your IP address, the date and time you access our Services, the pages you have accessed while visiting the Website, and the Internet address from which you accessed the website. Some cookies exist only during a single session, and some are persistent over multiple sessions over time. We use these technologies to remember user preferences, maximise the performance of our website, measure the effectiveness of our advertisement and to personalise online content. You may refuse or delete cookies. If you refuse or delete cookies, some of our website functionality may be impaired. Please refer to your browser’s settings to learn more about how to manage cookies and the use of other tracking technologies.

We may also use Google Analytics to better understand how you use our website in order to improve your user experience. You can familiarise with how Google Analytics processes your data here.

Contact details for requests and complaints

If you have questions with regard to this Privacy Policy or you wish to send a request/complaint to execute your data subject rights, please use the following email address: compliance@safeukr2030.org.

You also can send your requests/complaints in writing to the below address. However, we cannot guarantee a fast response to such written requests/complaints: 14A Ihorivska str., Kyiv, 04070, Ukraine

Updates of the Privacy Notice

We will update this Privacy Notice in case of any amendments to the Data Protection Legislation or changes to the personal data processing activities. We will notify you of any updates to the Privacy Notice through our website and by email.