1. Preamble

 

Since, in the course of carrying out the statutory activities of the Charitable Organisation "Charitable Foundation "DroneUA" (hereinafter referred to as the "Foundation"), it processes personal data of individuals and is:

1. is the owner of personal data within the meaning of the Law of Ukraine "On Personal Data Protection" (hereinafter - the Law);

2. is guided by the principle of transparency, which provides for the processing of personal data on the basis and in accordance with the procedure provided for by the current legislation of Ukraine;

3. strives to ensure an adequate level of protection of personal data processed - this Privacy Policy has been developed and approved in relation to the processing of personal data by the Fund.

 

2. General provisions

 

1. The Policy defines the general requirements for processing and protection of personal data of individuals processed by the Fund in whole or in part using automated means, as well as personal data contained in the file or intended to be included in the file, using automated or non-automated means.

2. The Policy applies to the processing of personal data of individuals by the Fund.

3. The Policy does not apply to the Fund's labour relations with individuals.

4. The Policy does not apply when the Fund processes data/information of legal entities, as well as data/information that is not personal data of individuals.

5.  The Policy is developed on the basis of the Constitution of Ukraine, the Laws of Ukraine "On Personal Data Protection", "On Information", "On Charitable Activities and Charitable Organisations", other regulatory and by-laws, as well as regulations, rules, policies and other documents governing the organisation of the statutory activities of the Fund.

6. The Policy is an integral part of the relevant transactions concluded by the Foundation with individuals, in particular with benefactors and beneficiaries (recipients of charitable assistance).

7. The Fund is the owner of personal data processed in connection with the visit/use of the Website options. The Fund has the right to entrust the processing of personal data in whole or in part to third parties on the basis of an agreement concluded in accordance with the requirements of the current legislation.

8. An individual is a subject of personal data under this Policy if he or she is a visitor to the Website, including if he or she uses any options available on the Website.

9. The Fund ensures that it complies with good practice and regulatory requirements for the protection of personal data, protects the rights of personal data subjects and prevents the risk of a breach of personal data processing security.

10. Posting this Policy at https://www.charity.drone.ua/  is a notification to personal data subjects about the personal data controller, the composition and content of personal data collected in connection with visiting/using 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. Definition of terms

 

3.2.The following terms are used in this Policy:

• Website means a set of data, electronic (digital) information, other objects of copyright and (or) related rights, etc. interconnected and structured within the website address, accessed through the Internet address:

• personal data subject - an individual whose personal data is processed, in particular, an individual who submits his or her personal data to the Fund using the Website options and/or is a party to a transaction concluded with the Fund. If a legal entity is a party to a transaction concluded with the Fund, the head or a duly authorised representative of such legal entity shall be recognised as the subject of personal data;

• processing of personal data - any action or set of actions, such as collection, registration, accumulation, storage, adaptation, modification, updating, use and dissemination (distribution, sale, transfer), depersonalisation, destruction of personal data, including with the use of information (automated) systems;

• personal data base - a named set of ordered personal data in electronic form and/or in the form of personal data 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 is a voluntary expression of the individual's will (subject to his/her awareness) to grant permission to process his/her personal data in accordance with the formulated purpose of their processing, expressed in a form that allows to conclude that consent has been granted;

• - third parties- any person, except for the personal data subject, owner or manager of personal data;

• Cookies are small text files that are stored in the browser of a device (computer, mobile phone, etc.) after visiting the Website and which the Website transmits to the browser. More information about cookies can be found here:  https://www.charity.drone.ua/

3.2. All other terms in the Policy shall have the meaning defined by the current legislation of Ukraine, including international legal acts ratified in Ukraine.

 

4. Purpose of personal data processing

4.1 This Policy is designed to inform personal data subjects about the procedure for processing their personal data when visiting/using the Website, as well as to ensure the protection of their personal data during such processing. 

4.2. The Fund processes personal data in order to carry out the statutory activities of the Fund, to conclude transactions with individuals or legal entities, in particular to receive charitable assistance from benefactors, to provide charitable assistance to beneficiaries (recipients of charitable assistance from the Foundation) and to fulfil the requirements provided for by the regulatory and by-laws, regulations and documents specified in clause 2.5. Policy in the field of charitable activities of the Foundation.

4.3. Personal data may be processed for legitimate purposes other than the original purpose (derivative purpose) only if the original purpose and the derivative purpose are closely related and only if the use of data for derivative purposes is not prohibited by the current legislation of Ukraine.

 

5. Composition and processing of personal data

 

5.1. To use the Website and its features, the Website visitor is obliged to accept the terms of this Policy. The visitor has no right to use the Website and the opportunities for charitable assistance provided by the Website in case of disagreement with the terms of this Policy.

5.2. In order to carry out the statutory activities of the Foundation, to communicate between the site and the user, to provide support and processing of requests from benefactors or beneficiaries, to conclude and execute transactions with individuals or legal entities, the Foundation or third parties may process the following personal data - surname, first name, patronymic; - telephone number; - e-mail address; - taxpayer registration number (trn); - postal address; - scanned copy of an identity document; - scanned copy of a trn card; - payment information; - scanned copies of a pension certificate, disability certificate, etc.

5.3. The Fund may collect and process the following information about you:

- information you provide to the Fund: this is information about you that you provide by using the Website and Website options, subscribing to receive updates by e-mail, providing charitable assistance (donations) using the Website options, communicating with the Fund through the options available on the Website, etc. 

- information about you that is collected by the Website and other systems: 

1) if you visit the Website, certain information about you and your visit may be collected. For example, we need technical data to operate, maintain and improve our website. This includes the following data: IP address, UTM parameters, geolocation, device type and browser type, cookies and data about your interaction with the site (session ID). Session ID includes: your interaction with the site; the name of the website from which you came to our site; the site features you use; the pages you use on our site; how you use our site; the actions you take on the site, if any;

2) The Website uses cookies - text files that store information about visited websites in the memory of a computer or mobile device.

3) if you contact the employees of the Fund through 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 (for example, Facebook, Google, Twitter) using the social media sharing options available on the Website, when you move from one page to another or by viewing materials that are linked (opened) to other platforms (websites).

5.4. The way the Fund processes your personal data depends on how you use the Website and interact with it. Some of the information may be provided directly by you when using the Website or in other ways. Other information may be collected and processed by the Fund independently with the help of automated technologies used on the Website. 

5.5. The Fund processes personal data only to the extent that is sufficient to achieve the stated purpose(s) and fulfil the obligations provided for by applicable law.

5.6. The visitor is solely responsible for the accuracy of personal data when using the Website. 

5.7. Legal basis for data processing: when visiting the Website, of the Fund processes your personal data if:

1) The Fund has obtained your consent to such processing; 

2) your personal data is necessary for the Fund to enter into and perform a transaction with you, or to take measures preceding the conclusion of the transaction; 

3) in cases where the Fund has a legitimate interest to process 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 determined by the current legislation. 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 defence of legal claims.

5.8. Methods of collecting personal data by the Fund:

1) using automated means of personal data processing;

2) using non-automated means of personal data processing; 

3) obtaining personal data when using the Website and Website options or computer programmes posted on the Website;

5.9. The Fund accumulates personal data using automated means (server equipment, cloud storage, etc.) and/or non-automated means (files, archives, etc.). 

5.10. The Fund may use your personal data only for the purposes and purposes specified in this Policy and applicable law, in particular (but not limited to): 

1) to process your request (application) to the Fund made through the Website; 

2) to ensure that you provide charitable assistance (donation) using the options available on the Website; 

3) in order to implement other statutory purposes of the Fund in the manner prescribed by applicable law.

5.11. The Fund may accumulate personal data processed during your visit/use of the Website, including by entering this data into the personal data base. The storage of your personal data is carried out in compliance with the requirements of the current legislation in the field of personal data. 

5.12. Your personal data shall be disclosed only with your consent or in cases specified in this Policy and applicable law.

5.13. We use your data to carry out the statutory activities of the Fund and fulfil our obligations under the transactions concluded with you, and may transfer them to third parties in the following cases:

1) compliance with the law. We will disclose your personal data to third parties to the extent necessary to comply with a lawful request of public authorities, execution of a court decision or other requirements of legislation; 

2) to prevent illegal use of the Website or violation of the terms of use of the Website, our rules and policies; 

3) to protect the Foundation from claims of third parties; 

4) to assist in the prevention or investigation of fraud; 

5) we also transfer your personal data to third parties on the basis of a public offer for processing on our behalf, subject to technical and organisational measures to protect your personal data - for example, for processing credit cards and payments.

5.14. Your personal data is subject to deletion or destruction in the case:

- expiry of the 3-year storage period or other period determined by the applicable law; 

- termination of legal relations between the personal data subject and the Fund, unless otherwise provided by the law; 

- in other cases determined by the current legislation in the field of personal data protection; 

- you can also exercise your right to delete your data. In this case, your data will be deleted from our servers within 30 days after your request.

5.15. The Fund does not process personal data on racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, conviction to a criminal sentence, as well as data related to health, sexual life, biometric or genetic data, except in cases determined by law. 

5.16. During the period of processing of personal data and other information, the Fund has the right to depersonalise them in such a way that they lose their personal connection with you. The Fund has the right to use such depersonalised information in its statutory activities without any restrictions. 

5.17. The Fund has the right to verify the accuracy of personal data, in particular by requesting additional information from you. 

5.18. You can change your personal data by yourself by verbal or written notification of such changes to the Fund, or by making appropriate changes to the transactions concluded with the Fund in the manner prescribed by such transactions.

 

6. Rights of the personal data subjects

 

6.1. In the manner prescribed by the current legislation of Ukraine, you have the right to: 

6.1.1. to know about the sources of collection, location of your personal data, the purpose of their processing, location or place of residence (stay) of the owner or manager of personal data;

6.1.2. to receive information on the conditions for granting access to your personal data, including information about third parties to whom his/her personal data is transferred; 

6.1.3. to access your personal data;

6.1.4. receive a response on whether your personal data is processed no later than 30 (thirty) calendar days from the date of receipt of the request, except as provided by law, and receive the content of such personal data; 

6.1.5. to submit a reasoned request to the personal data controller with an objection to the processing of your personal data. The request shall be made in the manner prescribed for providing access to personal data; 

6.1.6. to submit a reasoned request to change or destroy his/her personal data by any owner and manager of personal data, if such data is processed illegally or is unreliable. The change and destruction of personal data at your request is carried out in the manner prescribed for providing access to personal data;

6.1.7. to protect your personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision of such data, as well as to protect against providing information that is untrue or defamatory of your honour, dignity and business reputation; 

6.1.8. file complaints against the processing of your personal data to the Commissioner or to the court; 

6.1.9. apply for legal remedies in case of violation of the legislation on personal data protection;

6.1.10. to make reservations regarding the restriction of the right to process their personal data when providing consent. Entering reservations may make it impossible for the Fund to fulfil its tasks; 

6.1.11. to withdraw consent to the processing of your personal data. Withdrawal of consent to the processing of personal data or exercise of the right to destroy personal data may result in limitation or impossibility of providing you with charitable assistance from the Fund. In this case, the Fund will destroy the personal data that it processes, except for the personal data that must be stored by the Fund in accordance with the requirements of the current legislation of Ukraine. Withdrawal of consent to the processing of personal data is carried out in the manner prescribed for providing access to personal data. 

6.2. If you have any questions regarding this Policy or if you had received any unsolicited electronic communication sent by the Fund or purportedly sent on behalf of the Fund, please contact the Fund directly at the following email address info.charity@drone.ua

 

7. Final provisions

 

7.1. The Policy comes into force from the date of its publication on the Website. 

7.2. The Policy is retrospective and applies to both legal relations between the Fund and the user of the Website that arose before the Policy cames into force and those that arose after its entry into force. 

7.3. The Fund has the right to change the Policy if necessary. Changes to the Policy that does not involve a change in the purpose(s) of personal data processing do not require your prior consent.

7.4. The Policy with changes that do not require your prior consent shall enter into force from the date of posting the updated version of the Policy on the Website. 

7.5. Failure to provide or incomplete provision of your consent to the processing of your personal data or other information by the Foundation may make it impossible to provide you with charitable assistance.