1. Preamble
As the Foundation processes personal data of individuals during its statutory activities and is:
The owner of personal data within the meaning of the Law of Ukraine “On Personal Data Protection” (hereinafter referred to as the Law);
Guided by the principle of transparency, which implies processing personal data based on and in accordance with current Ukrainian legislation;
Striving to ensure an appropriate level of protection for the processed personal data, this Privacy Policy regarding the processing of personal data by the Foundation has been developed and approved.
2. General Provisions
This Policy defines the general requirements for the processing and protection of personal data of individuals processed by the Foundation, either fully or partially using automated means, as well as personal data contained in card files or intended to be entered into card files, using automated or non-automated means.
2.1. This Policy defines the general requirements for the processing and protection of personal data of individuals processed by the Foundation, either fully or partially using automated means, as well as personal data contained in card files or intended to be entered into card files, using automated or non-automated means.
2.2. The Policy applies to the processing of personal data of individuals by the Foundation.
2.3. The Policy does not apply to the implementation of employment relations between the Foundation and individuals.
2.4. The Policy does not apply to the processing of data/information of legal entities, as well as data/information that are not personal data of individuals.
2.5. The Policy is developed based on the Constitution of Ukraine, the Laws of Ukraine “On Personal Data Protection,” “On Information”, “On Charity and Charitable Organizations”, other regulatory and sub-regulatory acts, as well as provisions, rules, policies, and other documents regulating the organization of the Foundation’s statutory activities.
2.6. The Policy is an integral part of the relevant transactions concluded by the Foundation with individuals, including donors and beneficiaries (recipients of charitable aid).
2.7. The owner of the personal data processed in connection with the visit/use of the Website options is the Foundation. The Foundation has the right to entrust the processing of personal data, fully or partially, to third parties based on a contract concluded in accordance with current legislation.
2.8. An individual is a subject of personal data under this Policy if they are a visitor to the Website, including if they use any options available on the Website.
2.9. The Foundation guarantees that it adheres to proper practices and regulatory requirements regarding personal data protection, protects the rights of personal data subjects, and prevents the risk of security breaches in personal data processing.
2.10. The placement of this Policy at the link [http://www.maecenas.org.ua/] serves as notification to personal data subjects about the owner of the personal data, the composition and content of the personal data collected in connection with the visit/use of the Website, the rights of such subjects, the purpose of collecting their personal data, and third parties to whom such personal data may be transferred.
3. Definitions
3.1. In this Policy, terms are used in the following meanings:
- Website: A set of data, electronic (digital) information, other objects of copyright and/or related rights, etc., interconnected and structured within the website address, accessed via the Internet address [http://www.maecenas.org.ua/].
- Personal Data Subject: An individual whose personal data is processed, including an individual who provides their personal data to the Foundation using the Website options and/or is a party to a transaction concluded with the Foundation. If a legal entity is a party to a transaction concluded with the Foundation, the personal data subject is considered to be the director or duly authorized representative of such a legal entity.
- Personal Data Processing: Any action or set of actions such as collection, registration, accumulation, storage, adaptation, modification, renewal, use, and dissemination (distribution, sale, transfer), depersonalization, destruction of personal data, including using information (automated) systems.
- Personal Data Database: A named set of ordered personal data in electronic form and/or in the form of personal data card files.
- Personal Data: Information or a set of information about an individual who is identified or can be specifically identified.
- Consent of the Personal Data Subject: Voluntary expression of the individual’s will (subject to their awareness) regarding the granting of permission for the processing of their personal data in accordance with the stated purpose of processing, expressed in a form that allows a conclusion to be drawn about consent being given.
- Third Party: Any person, except for the personal data subject, the owner, or the processor of personal data.
- Cookies: Small text files that are stored in the device browser (computer, mobile phone, etc.) after visiting the Website, and which the Website transfers to the browser. More information about cookies can be found at [https://policies.google.com/technologies/cookies?hl=uk].
3.2. All other terms in the Policy are used in the meaning defined by the current legislation of Ukraine, including ratified international regulatory acts in Ukraine.
4. Purpose of Personal Data Processing
4.1. This Policy is developed to inform personal data subjects about the procedure for processing their personal data during the visit/use of the Website, and to ensure the protection of their personal data during such processing.
4.2. The Foundation processes personal data to carry out its statutory activities, execute transactions with individuals or legal entities, particularly for receiving charitable donations from donors, providing charitable aid to beneficiaries (recipients of charitable aid from the Foundation), and fulfilling the requirements stipulated by regulatory and sub-regulatory acts, regulations, and documents specified in clause 2.5 of the Policy in the field of charitable activities of the Foundation.
4.3. Personal data may be processed for lawful purposes different from the initial purpose (derivative purpose), only if the initial purpose and the derivative purpose are closely related and only if the use of data for derivative purposes is not prohibited by current legislation of Ukraine.
5. Composition and Processing of Personal Data
5.1. To use the Website and its capabilities, the visitor must accept the terms of this Policy. The visitor has no right to use the Website and the capabilities for attracting and providing charitable aid provided by the Website in case of disagreement with the terms of this Policy.
5.2. For the implementation of the Foundation’s statutory activities, communication between the Website and the user, ensuring the possibility of support and processing of inquiries from donors or beneficiaries, the conclusion and execution of transactions with individuals or legal entities, the Foundation or third parties may process the following personal data:
- Surname, name, patronymic;
- Phone number;
- Email address;
- Taxpayer registration card number;
- Postal address;
- Scan-copy of an identity document;
- Scan-copy of the taxpayer registration card;
- Payment information;
- Scan-copies of pension certificates, disability certificates, etc.
5.3. The Foundation may collect and process the following information about you:
- Information provided by you to the Foundation: This is information about you that you provide by using the Website and its options, subscribing to receive email updates, making charitable donations using the Website options, communicating with the Foundation through options available on the Website, etc.
Information about you collected by the Website and other systems:
- If you visit the Website, certain information about you and your visit may be collected. For example, technical data is needed for the operation, support, and improvement of our website. This includes: IP address, UTM parameters, geolocation, device type, and browser type, cookies, and data about your interaction with the site (session ID). The session ID includes: your interaction with the site; the name of the website from which you transitioned to our site; the features of the site you used; the pages you visited on our site; how you used our site; actions you performed on the site, if any;
- The Website uses cookies – text files that store information about visited websites in the memory of a computer or mobile device.
If you contact Foundation employees using the Website or other means of electronic communication;
- Information collected by third parties about you on the Website by performing actions: This is information about you that you provide to third parties (e.g., Facebook, Google, Twitter) using the social media sharing options available on the Website, when transitioning from one page to another, or by viewing materials that have links (open) to other platforms (websites).
5.4. How the Foundation processes your personal data depends on how you use the Website and interact with it. Some information may be provided directly by you when using the Website or in another way. Other information the Foundation may collect and process independently using automated technologies used on the Website.
5.5. The Foundation processes personal data only to the extent necessary to achieve the declared purpose(s) and to fulfil the obligations stipulated by current legislation.
5.6. The visitor is solely responsible for the accuracy of personal data when using the Website.
5.7. Legal grounds for data processing: When visiting the Website, the Foundation processes your personal data if:
- The Foundation has received your consent for such processing;
- Your personal data is necessary for the Foundation to conclude and execute a transaction with you or to take measures preceding the conclusion of a transaction;
- In cases where the Foundation has a legitimate interest in processing your personal data, and this legitimate interest does not outweigh your data protection interests or your fundamental rights and freedoms;
- In other cases defined by current legislation. In some cases, the Foundation may have a legal obligation to process your personal data or will process your personal data to form, exercise, or defend legal claims.
5.8. Methods of collecting personal data by the Foundation:
- Using automated means of processing personal data;
- Using non-automated means of processing personal data;
- Obtaining personal data when using the Website and Website options, or in any other way.
5.9. The Foundation processes the personal data of individuals using software systems (automated systems) or non-automated means.
5.10. Personal data processed by the Foundation must be accurate, reliable, and up-to-date. The Foundation must take appropriate measures to update and correct inaccurate or incomplete personal data.
6. Personal Data Protection
6.1. The Foundation uses technical and organizational measures to protect personal data from unauthorized or illegal processing, accidental loss, destruction, or damage. Such measures include, but are not limited to: firewalls, secure data storage and transmission, limited access to data, security protocols, data encryption, and other data security measures.
6.2. The Foundation ensures that personal data is processed in accordance with this Policy, and guarantees that any personal data it processes is processed based on and in compliance with current Ukrainian legislation.
6.3. The Foundation requires any third party to whom it discloses personal data to comply with adequate levels of protection and safeguards concerning personal data and to take all necessary steps to ensure the secure processing of personal data.
6.4. The Foundation does not disclose personal data to any third party, except as provided by this Policy, agreements with the personal data subject, or as required by current legislation.
7. Rights of the Personal Data Subject
7.1. Personal data subjects have the following rights regarding their personal data processed by the Foundation:
- Right to access: The right to obtain confirmation of whether or not personal data is being processed, and if so, access to the personal data and information about its processing;
- Right to rectification: The right to request correction of inaccurate personal data concerning them, and the right to have incomplete personal data completed;
- Right to erasure: The right to request the erasure of personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected or when consent has been withdrawn;
- Right to restrict processing: The right to request the restriction of processing of personal data under certain conditions;
- Right to data portability: The right to receive personal data provided to the Foundation in a structured, commonly used, and machine-readable format, and the right to transmit that data to another controller;
- Right to object: The right to object to the processing of personal data in certain circumstances;
- Right to withdraw consent: The right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
7.2. Personal data subjects can exercise their rights by contacting the Foundation via the contact details provided on the Website or through other means specified in this Policy.
7.3. The Foundation shall respond to requests from personal data subjects regarding their rights within a reasonable time frame and in accordance with current legislation.
8. Amendments to the Policy
8.1. The Foundation reserves the right to amend this Policy at any time by publishing the updated version on the Website.
8.2. The updated version of the Policy shall take effect upon its publication on the Website, unless otherwise specified in the updated version.
8.3. Personal data subjects are encouraged to periodically review this Policy to stay informed about how the Foundation is protecting their personal data.
9. Contact Information
9.1. If you have any questions or concerns about this Policy or the processing of your personal data, please contact us at:
- Mailing Address: Office 3, 28/1 Vyshhorodska St., Kyiv, 04082, Ukraine.
- Email: ukrainian@maecenas.org.ua
- Phone: +380683662323
By using the Website and its options, you acknowledge that you have read and understood this Policy and agree to its terms. If you do not agree with the terms of this Policy, please do not use the Website and its options.
