Privacy policy
PRIVACY POLICY
Effective Date: 01.02.2025
This Privacy Policy (hereinafter referred to as the "Policy") governs the protection of personal data of visitors to the website sternenkofund.org (hereinafter referred to as the "Website"), which is owned by the CHARITABLE ORGANIZATION "”STERNENKO COMMUNITY” CHARITY FUND" (EDRPOU code 45778792, registered address: 04071, Kyiv, Vozdvyzhenska Street, Building 41, registered under the current legislation of Ukraine (hereinafter referred to as the "Fund")).
1. GENERAL PROVISIONS.
1.1. In this Policy, the terms are used in the following sense:
· personal data database - a structured set of personal data in electronic form and/or in the form of personal data records;
· consent of the data subject - a voluntary expression of will by an individual (with prior awareness) to allow the processing of their personal data for the specified purpose, given in a form that makes it possible to confirm consent;
· Processing of personal data - any action or set of actions such as collection, registration, accumulation, storage, adaptation, modification, updating, use, dissemination (distribution, transfer), anonymization, and destruction of personal data, including the use of automated systems;
· Personal data - information or a set of information about an individual who is identified or can be specifically identified;
· Data subject - an individual whose personal data is processed;
· Third party - any person other than the data subject, data owner, or data processor;
• Cookies - small text files stored in the browser of a device (computer, mobile phone, etc.) after visiting the Website, which the Website transmits to the browser.
All other terms in the Policy are used in the meaning defined by the current legislation of Ukraine, including international regulatory legal acts ratified in Ukraine.
1.2. This Policy is intended to inform data subjects about how their personal data is processed when they visit/use the Website and to ensure the protection of such data during processing.
1.3. This Policy, as well as the Fund’s activities related to the collection, processing, storage, and other lawful actions regarding personal data, are regulated by:
· The Constitution of Ukraine;
· The Law of Ukraine "On Personal Data Protection" of 01.06.2010 No. 2287-VI;
· Other applicable legal acts of Ukraine governing personal data protection;
· International legal acts ratified by Ukraine.
· The law (including international law), and national and international regulatory legal acts regulating the protection of personal data of residents of such countries also apply to legal relations that arise in the Fund in connection with the processing of personal data of residents of foreign jurisdictions.
1.4. The Fund is the owner of personal data processed in connection with the visit/use of the Website's features. The Fund may fully or partially entrust personal data processing to third parties under a contract in compliance with current legislation.
1.5. An individual is a data subject under this Policy if they visit the Website, including using any available features and providing the Fund with their email address and name.
1.6. The Fund guarantees that it:
· Complies with best practices and regulatory requirements regarding personal data protection;
· Protects the rights of data subjects;
· Prevents risks of data security breaches.
1.7. The purpose of processing personal data collected through the Website is to carry out the Fund’s statutory activities.
1.8. Posting this Policy via the link specified in section 4.1 of this Policy serves as a notification to data subjects about the data owner, the composition and content of the collected personal data, their rights, the purpose of data collection, and third parties to whom such data may be transferred.
1.9. The Fund takes all necessary technical and organizational measures to protect personal data from unauthorized access, loss, destruction, or alteration. This includes encryption, regular security audits, and employee training on data protection.
2. PROCESSING OF PERSONAL DATA.
2.1. The Fund may collect and process the following information about you:
· Information You provide to the Fund: This includes information provided through the use of the Website, subscribing to email updates, making charitable donations through the Website, or communicating with the Fund via Website features, etc.;
· Information collected by the Website and other systems:
1) If you visit the Website, third parties may collect certain information about your visit, such as browser type and version, pages visited, IP address;
2) The Website may store cookies on your device;
3) If you contact Fund representatives through the Website or other electronic means.
· Information collected by third parties via the Website: This includes data provided to third parties (e.g., Facebook, Google, Twitter) through social sharing features or when navigating between pages containing embedded links.)
2.2. The processing of your personal data by the Fund depends on how you use and interact with the Website. Some data may be provided directly by you, while other data is collected and processed automatically using technologies embedded in the Website.
2.3. Legal grounds for data processing: when you visit the Website, the Fund processes your personal data if:
1) The Fund has received your consent for such processing,
2) your personal data is necessary for the Fund to conclude and perform a transaction with you or to take measures before concluding a transaction,
3) in cases where the Fund has a legitimate interest in processing your personal data and this legitimate interest does not override your interests in data protection or your fundamental rights and freedoms,
4) in other cases specified by applicable law.
In some cases, the Fund may have a legal obligation to process your personal data or will process your personal data for the establishment, exercise, or defense of legal claims.
2.4. Automated processing mechanisms: The Fund and third parties may use automated information processing technologies in certain sections of the Website. The Fund uses cookies to store content and settings, which allows the Fund to process standard information that your browser sends to certain websites you visit, such as your IP address, browser type and language, as well as the site you came from, the pages you visit, and the links you click on the Website. Having such technical information helps the Foundation improve the Website.
2.4.1. Use of Cookies
The Fund uses cookies to enhance the functionality of the website, analyze user behavior, and ensure user convenience. Cookies are small text files stored on a user’s device when visiting the website. They help the Fund collect information about how users interact with the site, allowing for improvements in its performance.
Types of Cookies Used on the Website:
2.4.1.1. Analytical Cookies:
- These cookies are used to collect information about how users interact with the website (e.g., which pages they visit, how much time they spend on the site, and which links they click). This information helps the Fund analyze traffic and improve the website’s performance.
The Fund uses third-party analytics services to collect and analyze data about website usage. These services help us enhance website functionality and understand user needs. Below is information about the services we use and how they operate.
Google Analytics
We use Google Analytics to collect information on how users interact with our website. Google Analytics gathers data such as browser type, visited pages, time spent on the site, and other analytics data. This information helps us analyze traffic and improve the website’s performance.
- How Google Uses Data: According to the Google Analytics Terms of Use and Google’s Privacy Policy, Google limits the use and transfer of information collected through Google Analytics. You can learn more about how Google collects and processes data on the Google Analytics page.
- Opting Out of Google Analytics: You can block the use of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.
Hotjar
We use Hotjar to better understand how users interact with our website. Hotjar allows us to visualize user interactions, helping us improve our performance, user experience, and identify website functionality issues.
- What Data Hotjar Collects: Hotjar uses cookies and other technologies to collect data about user behavior and their devices. This may include data such as IP address, device type, browser information, geographic location (country), and interaction data (e.g., clicks, scrolling).
- How Hotjar Uses Data: Hotjar may reuse this data to develop and improve tools and services for us and our users.
- More About Hotjar: For more information on how Hotjar processes data, visit the Hotjar Trust Portal and Hotjar Privacy Policy.
2.4.2. Cookie Opt-Out
Users have the right to opt out of cookies, except for necessary cookies that ensure the website's basic functionality. Disabling cookies may affect website performance and limit access to certain features.
How to Disable Cookies:
1. Through Browser Settings:
· Users can configure their browsers to block cookies or notify them when cookies are being used. Instructions for popular browsers:
- Google Chrome: Settings → Privacy and Security → Cookies and Site Data..
- Mozilla Firefox: Settings → Privacy & Security → Cookies and Site Data.
- Safari: Settings → Privacy → Manage Website Data.
- Microsoft Edge: Settings → Privacy, Search, and Services → Cookies and Site Data.
2.4.2.1. Consequences of Disabling Cookies:
· Analytical Cookies: Disabling these cookies will not affect the core functionality of the website, but it may limit the Fund’s ability to analyze traffic and improve the website’s performance.
2.5. The Fund may use your personal data only for the purposes specified in this Policy and applicable legislation, including (but not limited to):
1) To process your request (inquiry) submitted to the Fund via the Website,
2) To facilitate your charitable donation using the options available on the Website,
3) To implement other statutory objectives of the Fund in accordance with applicable legislation;
4) To send emails and messages to your email address regarding promotional materials, information about the launch of charitable projects, requests, and invitations for feedback on charitable activities, website visits, etc.
2.6. The Fund may collect personal data processed during your visit/use of the Website, including by adding this data to a personal data database. Your personal data will be stored in compliance with applicable data protection laws.
2.7. Your personal data will only be shared with your consent or in cases specified by this Policy and applicable legislation.
2.8. The Fund may partially publish user data on its Website in the sections "Reports" and "Receipts."
2.9. Your personal data will be deleted or destroyed in the following cases:
· After a two-year storage period or another period defined by applicable legislation;
· Upon termination of legal relations between the data subject and the Fund, unless otherwise provided by law;
· In other cases defined by applicable data protection legislation.
2.10. The Fund does not process personal data related to racial or ethnic origin, political, religious, or philosophical beliefs, membership in political parties or trade unions, criminal convictions, or data related to health, sexual life, biometric, or genetic data, except in cases prescribed by law.
3. RIGHTS OF DATA SUBJECTS.
3.1. When visiting or using the Website, you have the right to:
· Receive information from the Fund that is not specified in this Policy regarding the processing and access conditions of your personal data or authorize a representative to obtain this information, except in cases defined by law;
· Access your personal data free of charge;
· Receive a response to your request regarding the processing of your personal data within the timeframe and in the manner defined by applicable legislation;
· Submit a reasoned objection to the processing of your personal data or request its modification or deletion if the data is processed unlawfully or is inaccurate;
· Protect your personal data from unlawful processing, accidental loss, destruction, or damage due to intentional concealment, failure to provide, or delay in providing it, as well as from the dissemination of inaccurate or defamatory information;
· Withdraw your consent to the processing of personal data;
· And also exercise other rights defined by applicable data protection legislation.
3.2. You have the right to contact the Ukrainian Parliament Commissioner for Human Rights regarding any issues related to the collection, use, storage, or other processing of your personal data. You can reach them via email at hotline@ombudsman.gov.ua.
If you have any questions about this Policy or if you receive any unsolicited electronic notifications sent by the Fund or allegedly on behalf of the Fund, please contact the Fund directly at appeal@sternenkofund.org.
4. Privacy Policy Changes.
4.1. The Fund reserves the right to review and amend the provisions of this Policy. The latest version of this Policy is available on the Website at sternenkofund.org.
