Privacy policy
Effective Date: January 7, 2025
This Privacy Policy (hereinafter referred to as the "Policy") regulates the relationship in the field of personal data protection of visitors/users to the mobile application "Charity Hero" (hereinafter referred to as the "Mobile Application", "Application") and the website https://www.charitylabfoundation.org or https://www.charityhero.live/ (hereinafter referred to as the "Website"), which belongs to the Charitable Organization "Charitable fund "Charity Lab Foundation", legal entity identification code 45589884, registered in accordance with the current legislation of Ukraine (hereinafter referred to as the "Foundation").
1. General provisions
1.1. In this Policy, the terms are used in the following meanings:
Personal data base – a named set of organized personal data in electronic form and/or in the form of personal data files;
Consent of the subject of personal data – a voluntary expression of the will of an individual (provided that he is informed) to grant permission for the processing of his personal data in accordance with the formulated purpose of their processing, expressed in a form that allows to conclude that consent has been granted;
Processing of personal data – any action or set of actions, such as collection, registration, accumulation, storage, adaptation, modification, renewal, usage, and dissemination (distribution, sale, transfer), anonymization, destruction of personal data, including with the use of information (automated) systems;
Personal data – information or a set of information about an identified or identifiable natural person;
Personal data subject – an individual whose personal data are processed;
Third party – any person, except the personal data subject, the owner or manager of personal data;
Cookies – small text files that are stored in the browser of a device (computer, mobile phone, etc.) after visiting the Website/Application, and which the Website/Application transfers to the browser. You can learn more about cookies at: https://allaboutcookies.org/.
Retention period of personal data – Personal information relating to a visitor/user of the Website/Application is stored during the use of the Website/Application and for 3 years after the last use of the Website/Application, or until the visitor/user decides to delete their user ID and all associated personal information. Personal information may also be deleted when the purpose for which it was used no longer exists.
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 designed to inform data subjects about the processing of their personal data when visiting/using the Website/Application, as well as to ensure the protection of their personal data during such processing.
1.3. This Policy, along with the activities of the Foundation related to the collection, processing, storage, and other lawful actions concerning personal data, is governed by:
· The Constitution of Ukraine;
· The Law of Ukraine "On Personal Data Protection" No. 2287-VI, dated June 1, 2010;
· Other applicable regulatory legal acts of Ukraine governing the protection of personal data;
· International regulatory legal acts ratified by Ukraine.
Relations arising in the Foundation concerning the processing of personal data of residents of foreign jurisdictions are also governed by the laws (including international law), national and international legal acts (including the General Data Protection Regulation - ‘GDPR’) that regulate the protection of personal data of residents of such countries.
1.4. The purpose of processing personal data obtained during the functioning of the Website/Application is the performance of the Foundation’s statutory activities.
1.5. The owner of personal data processed in connection with the visit/use of the Website/Application options is the Foundation. The Foundation has the right to delegate, fully or partially, the processing of personal data to third parties based on a contract concluded in accordance with the requirements of applicable legislation. The Foundation provides third parties with the minimum amount of personal data necessary to fulfil the terms of a predetermined service or transaction, and none of these third parties is allowed to use such personal data other than to provide a specific service to the Foundation.
1.6. An individual is a subject of personal data under this Policy if they are a visitor/user of the Website/Application, including if they use any options available on the Website/Application, or provide the Foundation with their email address and name.
1.7. The Foundation guarantees that:
It adheres to personal data protection laws;
It protects the rights of data subjects;
It prevents the risk of breaches in personal data security.
At the same time, the Foundation cannot fully guarantee the security of personal data and information that visitors/users of the Website/Application send through unsecured connections and protocols.
The Foundation strongly recommends taking all possible precautions to protect your personal information while on the Internet. Effective methods include changing passwords frequently, using combinations of letters and numbers when creating passwords, using a secure browser, and encrypting your email.
1.9. The Website/Application of the Foundation may contain links to third-party websites and services that are beyond the Foundation's control and are not subject to this Privacy Policy. We recommend reviewing the privacy policies posted on these (and all) websites you visit or services you use.
1.10. The publication of this Policy at the link specified in clause 4.1 of this Policy constitutes notification to personal data subjects about the Owner, the composition and content of the personal data collected in connection with the visit/use of the Website/Application, the rights of such subjects, the purpose of collecting their personal data, and third parties to whom such personal data may be transferred.
2. Processing of personal data
2.1. The Foundation collects, processes, stores, and transfers the personal data of Website/Application visitors/users solely based on their consent and only for the purposes defined in this Policy. Please do not provide any personal information that you do not wish to disclose or share with third parties for any purpose.
2.2. The Foundation may collect and process the following information about you:
Information you provide to the Foundation: this includes information about you that you provide by using the Website/Application and its options, subscribing to email updates, providing charitable assistance (donations) using the Website/Application options, communicating with the Foundation through the options available on the Website/Application, and so on;
Information about you collected by the Website/Application and other systems:
1) Usage information: data about your interaction with the Website/Application, such as button clicks, screen transitions, time spent in the Website/Application, and other statistics used to personalize your experience.
2) If you visit the Website/Application, third parties may collect certain information about you and your visit, such as the type and version of your browser, the pages you visit on the Website/Application, and your internet protocol (IP) address, location at the city level and transaction information;
3) The Website/Application may also download cookies to your device;
4) If you contact the Foundation’s staff through the Website/Application or other electronic means of communication.
Information collected by third parties about you on the Website/Application through their actions: this includes information about you that you provide to third parties (e.g., Facebook, Google, X) when using the social media sharing options available on the Website/Application, navigating from one page to another, or viewing materials linked (opened) to other platforms (Website/Applications).
2.3. How the Foundation processes your personal data depends on how you use and interact with the Website/Application. Some information may be provided directly by you during your use of the Website/Application or otherwise; other information may be independently collected and processed by the Foundation through automated technologies used on the Website/Application.
2.4. Legal grounds for data processing: when visiting/using the Website/Application, the Foundation processes your personal data if:
1) The Foundation has obtained your consent for such processing;
2) Your personal data is necessary for the Foundation to conclude and execute a transaction with you or to take steps prior to concluding a transaction;
3) 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, and in other cases defined by applicable law.
In some cases, the Foundation may have a legal obligation to process your personal data, in particular to comply with legal requirements, to conduct legal proceedings, to protect its rights, to fulfil contractual obligations, to report to government authorities (customs, fiscal), or to meet financial monitoring requirements.
2.5. Automated processing mechanisms: The Foundation, along with third parties, may employ automated information processing technologies to manage data within specific sections of the Website/Application. The Foundation utilizes cookies to store content and preferences, enabling the processing of standard data transmitted by your browser to Website/Applications you visit, including but not limited to your IP address, browser type, and language, the referring Website/Application, the pages accessed, and links interacted with on the Website/Application. The collection and processing of such technical data facilitate the Foundation to optimize and enhance the Website/Application's functionality.
2.6. The Foundation can use your personal data solely for the purposes defined in this Policy and applicable law, including (but not limited to):
1) To process your request (inquiry) to the Foundation made through the Website/Application;
2) For the purpose of facilitating the provision of charitable assistance (donations) by you through the options available on the Website/Application;
3) To carry out other statutory purposes of the Foundation in the manner prescribed by applicable law;
4) For the purpose of sending emails and notifications to your email address regarding promotional materials, information on the initiation of charitable projects, requests and invitations for feedback on charitable activities, Website/Application visits, and other related matters.
2.7. The Foundation may collect personal data processed during your visit to or use of the Website/Application, including by incorporating such data into a personal data repository/database. The storage of your personal data shall be conducted in accordance with the requirements of the applicable data protection legislation.
2.8. The dissemination of your personal data is carried out only with your consent or in cases defined by this Policy and applicable law. The Foundation may also provide personal information and personal data to third parties in connection with legal matters, which includes:
· providing information if the Foundation is legally obliged to do so (e.g., subpoenas or court orders);
· in connection with the investigation, prevention or assistance to law enforcement authorities regarding suspected or known illegal activities, fraud, threats, other violations of the law or in other cases provided for by the laws of Ukraine.
2.9. The Foundation may partially publish users' data on its Website/Application in the sections "Reports", "Donations Received."
2.10. Your personal data shall be deleted or destroyed in the following cases:
· Upon the expiration of the 3-year storage period or another period defined by applicable law;
· Upon the termination of the legal relationship between the data subject and the Foundation, unless otherwise provided by law;
· In other cases defined by the applicable data protection laws.
2.11. The Foundation does not process personal data regarding racial or ethnic origin, political, religious, or philosophical beliefs, membership in political parties and trade unions, criminal convictions, as well as data related to health, sexual life, biometric, or genetic data, except in cases defined by law.
3. Rights of personal data subjects
Receive from the Foundation information not specified in this Policy regarding the processing and conditions for accessing your personal data or issue a relevant instruction to authorized persons to obtain this information, except in cases provided by law;
Access the personal data free of charge;
Receive a response to a request regarding the processing of your personal data in accordance with the procedure and within the timeframe specified by applicable law;
Submit a reasoned request objecting to the processing of your personal data, or requesting the correction or destruction of your personal data, if such data is processed illegally or is inaccurate;
Protect your personal data from illegal processing and accidental loss, destruction, or damage due to intentional concealment, failure to provide, or delay in providing it, as well as protect it from the provision of unvalidated information or information that discredits the honor, dignity, and business reputation of an individual;
Withdraw your consent to the processing of personal data;
3.2 You have the right to address questions related to the collection, use, storage, and other processing of your personal data to the Ukrainian Parliament Commissioner for Human Rights at [email protected]. If you have questions regarding this Policy, if you wish to file a complaint related to the collection, use, storage and other processing of your personal data by the Foundation, or have received any unsolicited electronic notification sent by the Foundation or allegedly sent on behalf of the Foundation, please contact the Foundation directly at [email protected]. This does not limit your right to file a complaint with the Ukrainian Parliament Commissioner for Human Rights.
3.1 When visiting/using the Website/Application, you have the right to:
4. Changes to the privacy policy
4.1 The Foundation reserves the right to review and amend the provisions of this Policy. The current version of this Policy is available on the Website at the provided link: https://www.charitylabfoundation.org
