Privacy policy of the Unbreakable Ukraine Foundation - Unbreakable Ukraine

Privacy policy of the Unbreakable Ukraine Foundation

The Foundation «Unbreakable Ukraine» Privacy Policy

Last update: October 20, 2024

 

In order to operate efficiently Unbreakable Ukraine (further referred to as “the Foundation”, “we”, “our”, “us”) has to collect and use information about people with whom it works and the pupils it provides an education to.

 

The Unbreakable Ukraine is committed to ensuring personal data is properly managed and that it ensures maintenance of ongoing compliance with current data protection legislation.

 

The Foundation will make every effort to meet its obligations under the legislation and will regularly review procedures to ensure that.

 

Contact Information

 

This website is operated by Foundation “Unbreakable Ukraine”. Registered office: Poland, str. Sw. Filipa, 25, 31-150, Krakow, Registration number 0000887569, tel: +48 797082167.

 

Data Protection Officer

 

The Foundation has appointed an internal Data Protection Officer with a dedicated email address dpo@nezlamna.org.

Contact email:

Please use the email address above to communicate any data protection inquiries you may have. Please also note that we may store any communication with us as evidence of your request and our response. 

 

How we use your personal information

 

When you undertake certain actions on our website, such as signing up for our newsletters, donating, applying for job, or browsing the website, you knowingly provide us with personal information about you.

 

Personal data we collect

The Foundation collect the following categories of personal data:

  • Website Data;
  • Donation Data;
  • Contact Data;
  • Humanitarian Aid Data;
  • Employment Data;
  • Event Data;
  • Pre-School Services Data.

Website Data

When you access and browse our Website, we are collecting certain personal data automatically. This information is collected using cookies and similar technology.

 

Cookies are small text files that we place on your computer while you visit us. The data stored in cookies uses identificators unique to your device, so we are able to identify the exact device. Please note, that you are able to customise cookies manually and disable any/all of them with your browser settings.

 

We use Consent Management Provider Cybot to collect and store your consent to use cookies and similar technology. Cybot is powered by Cybot A/S, with its legal address at Havnegade 39, 1058 Copenhagen, Denmark.

 

We collect the following categories of personal data:

 

 

Service Provider

Information

 

Category: necessary

 

We automatically enable necessary cookies to ensure smooth and uninterrupted work of our Website. The legal basis for processing your personal data is our legitimate interest in properly operating the Website. Without these cookies, we are unable to ensure the Website’s stability and safety.

 

Google Analytics, represented by Google Inc., 1600 Amphitheatre Parkway Mountain View, CA, United States

Google Analytics collects the following personal data:

 

1)     google_auto_fc_cmp_setting

Stores the user’s cookie consent state for the current domain.

Expiry: Persistent

 

2)     test_cookie

Used to check if the user’s browser supports cookies.

Expiry: 1 day

 

 

Stripe Inc., 185 Berry Street, Suite 550, San Francisco, CA, USA

Stipe will automatically collect personal data including:

1)     m

Determines the device used to access the website. This allows the website to be formatted accordingly.

Expiry: 2 years

 

2)     __stripe_mid

This cookie is necessary for making credit card transactions on the Website. The service is provided by Stripe.com which allows online transactions without storing any credit card information.

Expiry: 1 year

 

3)     __stripe_sid

This cookie is necessary for making credit card transactions on the website. The service is provided by Stripe.com which allows online transactions without storing any credit card information.

Expiry: 1 day

 

 

 

Nezlamna.org is powered by us

The information collected by Nezlamna.org includes:

1)     wordpress_test_cookie

Used to check if the user’s browser supports cookies.

Expiry: Session

 

New Relic, Inc. 188 Spear Street, Suite 1200

San Francisco, California 94105

 

New Relic will automatically collect the following information:

1)    JSESSIONID

Used to preserve users’ states across page requests.

Expiry: Session

 

Vimeo.com Inc, 555 West 18th Street New York, NY 10011 United States

 

The information collected by Vimeo includes:

1)    __cf_bm

This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website.

Expiry: 1 day

 

Category: preferences

 

We use certain personal data to allow the Website to remember information that changes the behavior or appearance of the Website, such as the language you choose or the region you are in. The legal basis for processing is your consent.

 

Nezlamna.org is powered by us

The personal information we collect for this purpose includes:

1)     GetLocalTimeZone

Holds the users’ timezone.

Expiry: Session

2)     wp-wpml_current_language

Designates the country code that is calculated based on the user’s IP address. Used to determine what language should be used for the visitor.

Expiry: Session

 

Category: statistical

 

We use statistical data to understand how you interact with our Website. The legal basis for processing is your consent.

 

Google Analytics, represented by Google Inc., 1600 Amphitheatre Parkway Mountain View, CA, United States

The data we collect is anonymised and includes the following:

1)     _ga

Registers a unique ID that is used to generate statistical data on how the visitor uses the website.

 

Retention: 2 years

 

2)     _ga_#

Used by Google Analytics to collect data on the number of times a user has visited the website as well as dates for the first and most recent visit.

Retention: 2 years

3)     _gat

Used by Google Analytics to throttle request rate.

Retention: 1 year

4)     _gid

Registers a unique ID that is used to generate statistical data on how the visitor uses the website.

Expiry: 1 day

 

New Relic, Inc. 188 Spear Street, Suite 1200

San Francisco, California 94105

New Relic will automatically collect the following information:

1)     events/1/#

Used to monitor website performance for statistical purposes.

Expiry: Session

 

Vimeo.com Inc, 555 West 18th Street New York, NY 10011 United States

The information collected by Vimeo includes:

1)    vuid

Collects data on the user’s visits to the website, such as which pages have been read.

Expiry: 2 years

 

Category: marketing

Marketing cookies are used to track visitors on different web pages. This is done to show ads that are for each respective user.

 

Google Analytics, represented by Google Inc., 1600 Amphitheatre Parkway Mountain View, CA, United States

Collected information include:

1)     google_experiment_mod#

Used by Google AdSense for experimenting with advertisement efficiency across websites using their services.

Expiry: Persistent

 

Gemius by Gemius S.A., Domaniewska 48

St. 02-672 Warsaw, Poland

 

Collected information includes:

1)     Gdyn

Used in context with pop-up advertisement content on the Website. The cookie determines which ads the visitor should be shown, as well as ensure that the same ads do not get shown more than intended.

Expiry: 1 year

2)     Gtest

This cookie is set to collect information on user behavior and navigation which is used to optimize the website – The cookie also allows Google Ads and Google Analytics to compile information on visitors for marketing purposes.

Expiry: 6 days

 

 

Donation Data

 

When you wish to support our mission with a donation, we may collect certain personal data.

Please note that we allow you to donate using the PayPal link: https://www.paypal.com/donate/?hosted_button_id=96HCR9U5G2XP8.

PayPal is a third-party service provider that is deemed our data processor. This implies that it will process and store your information according to our instructions. However, PayPal is a financial institution, and it may be required to store or use your data independently. Furthermore, to make payment in PayPal you will be required to register an internal account. We will not have access to this information, it will be processed independently. We suggest you check the privacy policy of PayPal prior to providing them with your personal information.

You are also able to make a donation using the Stripe solution. Simultaneously, Stripe is deemed our data processor, however, may store certain personal data independently to comply with obligations imposed on it. You may be required to register an internal account in Stripe to conduct payment operations. We will not have access to this information, it will be processed independently. We suggest you check the privacy policy of Stripe prior to providing them with your personal information.

 

The purpose of collecting donation data is the performance of the contract.

Donation data collected

You may donate to our Foundation using PayPal, Buy Me a Coffee platform or via straight transfer using Bank Details available on the website. 

If via PayPal

Data

Purpose

Legal Ground

Service Provider

First Name

To process your payment

Performance of contract

PayPal

Last Name (optional)

To process your payment

Performance of contract

PayPal

Email Address

To provide you with payment confirmation

Performance of contract

PayPal

Card Number

To process your payment

Performance of contract

PayPal

Expiry Date

To process your payment

Performance of contract

PayPal

CVC Number

To process your payment

Performance of contract

PayPal

 

Please note that we allow donations via PayPal link: https://www.paypal.com/donate/?hosted_button_id=96HCR9U5G2XP8. PayPal is a third-party service provider that is considered our data processor. This means that it will process and store your information in accordance with our instructions. However, PayPal is a financial institution and may need to store or use your data independently from us. Additionally, you will need to register an internal account to make a PayPal payment. We will not have access to this information, it will be processed independently. We encourage you to check PayPal’s privacy policy before providing them with your personal information.

We will not have full access to your donation details. Such details as full card number, expiry date, and CVC number are securely stored by PayPal.

You may also donate to the Foundation by clicking the “Buy me a book” button on the website. “By me a book” functionality is provided by the Publisherr Inc platform. The following data will be processed:

 

Data

Purpose

Legal Ground

Service Provider

Name of Nickname (if you choose to provide it) otherwise the donation may stay anonymous

To let other users know who made a donation

Your consent

Publisherr Inc

Message (if you create it)

To share your thoughts and wishes

Your consent

Publisherr Inc

Email Address

To process your payment

Performance of contract

Publisherr Inc

Card Number

To process your payment

Performance of contract

Publisherr Inc

Expiry Date

To process your payment

Performance of contract

Publisherr Inc

CVC Number

To process your payment

Performance of contract

Publisherr Inc

Transaction ID

To prove the payment

Legal obligation

Publisherr Inc

Amount

To prove the payment

Legal obligation

Publisherr Inc

Please note that you may remain anonymous to other users if you wish so. Simultaneously, we will not have access to your donation details. Such details as full card number, expiry date, CVC number are securely stored by Publisherr Inc.

If via Bank Details:

 

Data

Purpose

Legal Ground

Service Provider

Proof of payment

To proof your payment

Your consent

Your financial institution

The Foundation will only see the proof of payment information and will not store or access other personal or financial information related to payment.

Contact Data

 

When you want to contact the Foundation, we will ask you to provide the following information:

 

Data

Purpose

Legal Ground

Name

To address you correctly

Legitimate interest to assist you with your request

Email Address

To contact you back if and where necessary

Legitimate interest to assist you with your request

Content of Request

To address you correctly

Legitimate interest to assist you with your request

Attached File

To assist you properly

Legitimate interest to assist you with your request

 

Without your name and email address we will not be able to help you, answer your request or assist you with your inquiry. You may also contact us to apply for a vacant position in the Foundation. We will process the same information as stated above in this Section and the processing will be based on our legitimate interest to process your application.

Humanitarian Aid Data

We may from time to time conduct humanitarian aid activities such as the campaign for Ukrainians who were forced to leave their homes and are temporarily in Poland – “Gifts for Ukrainian children in Poland”. These campaigns may provide participants with free tickets or kits for learning and creativity.

The following information is required for humanitarian aid activities registration:

 

Data

Purpose

Legal ground

Full name

To provide you with humanitarian aid

Your consent

Age

To provide you with humanitarian aid

Your consent

Gender

To provide you with humanitarian aid

Your consent

Birth certificate (including a copy of certificate)

To provide you with humanitarian aid

Your consent

We kindly ask you to read this Notice carefully before participating in humanitarian aid activities.

Employment Data

Personal information that Foundation may process about the applicant includes:

  • Personal information the applicant provides: CV, Full Name, education and experience information, email address, phone number, references or list of third parties in order to get a reference (provided the Foundation has obtained prior consent from an applicant).
  • Personal information processed during the recruitment process: recruitment notes, cover letter, any other information that applicant provides to Foundation, including, but not limited to references provided by the applicant from their previous employment, as well as information about applicant obtained from third parties with applicant’s consent, sending inquiries to verify the availability of applicant’s data in the registers required by the Foundation’s policies and the applicable laws of the Republic of Poland, contacting third parties indicated by the applicant with the purpose of reference obtaining.
  • Personal information processed if the applicant receives and accepts employment offer: full name, сopies of the foreign and internal (domestic) passports, PESEL, bank account number, diploma with annexes (if applicable), marriage certificate (in case surname in diploma is different from one in passport), certificate from the educational institution and a copy of the student ID (in case when the applicant is pursuing their first higher education), address of residence, criminal records information, email address, phone number.

The Foundation will process you personal information for the following purposes:

  • CV processing;
  • to verify your information and conduct relevant and appropriate legally permitted pre-employment and eligibility verification checks, as well as to assess your skills, qualifications and experience;
  • to comply with local, national or international laws, obligations and legal requirements;
  • to communicate with the candidate;
  • for the selection process.

Please note that by submitting your application, you authorize Foundation to store your information for the purposes stated above.

The Foundation will store your personal information for a period of employment and longer in accordance with the labor law requirement of the Republic of Poland or Ukraine (if you have accepted an employment offer).

Legal basis for processing employment data include the following:

  • Performance of contract. This legal basis will only be used to conclude the employment contract with you.
  • Legal obligation. The Foundation will rely on legal obligations under various laws such as labor law or tax law.
  • Legitimate interest. The Foundation will rely on legitimate interest to source a suitable candidate.

 

Events Data

The Foundation can organize various types of recreation, as well as various entertaining, educational, and informative events for children (workshops, courses, etc.), not only for students of the Educational Institutions ‘First Ukrainian School’ of the Foundation Unbreakable Ukraine’, but also for students/pupils of other schools or kindergartens. For these purposes, the Foundation may collect your personal data, including:

  • Consent for recording and use of participant’s image at the event,
  • Consent for independent return of the child/participant home – only upon the parents’ request.

The Foundation may also collect other data that is objectively necessary for participation in the respective event. Such data may vary depending on the event and will be available during registration. The Foundation will process such data in accordance with this privacy policy and will not use such data for any other purposes. Please also note that participation in such events is voluntary and possible only with your consent.

Without this data we will not be able to provide you with access to the respective event.

This data will be stored during the time of the event or unless you wish to exercise your right to delete such data.

The legal basis for processing Event data is your consent.

Pre-School Services Data

The Foundation may also organize a First Grade Preparation Group to conduct educational and cognitive activities for students. For these purposes, the following personal data may be collected:

Full name of the child, age, address, contact details, health features (e.g. allergies or others), parent’s full name, passport details, address, Pesel for parents and kids.

The legal basis for processing personal data stated above will be a performance of contact. Therefore, such personal data will be stored either until this contract is terminated by the parties or until the relationship with the Foundation is terminated.

Sharing your personal information

 

We are not selling or swapping your personal information. However, we may share your personal information with our national partners who help us with raising money. We may also share your personal information with our employees, payment institutions, governmental authorities of the Republic of Poland and Ukraine (including the Ministry of Education of Poland and Ukraine and their departments), Child Social Protection Authorities, our partner educational institutions that have licenses for educational activities and cooperate with the Foundation in education programs. Such transfers will be based on parental explicit consent or legal obligation imposed on us.

Mainly, your personal data will not be shared outside the European Union, however, some third-party providers may be located in the United States. Transfer of your personal data to those third-party providers is safeguarded with additional security measures, namely Standard Contractual Clauses. These clauses were adopted by the European Commission and aimed to safeguard transfers of personal data to countries with inadequate levels of data protection.

Rights of Data Subjects

 

According to the applicable data protection legislation you may have the following data protection rights:

 

right to access:

 

You are able to ask the Foundation whether it processes your personal data. If so, you may request access to your personal data that the Foundation stores about you. Inter alia, you may request the following:

 

the purposes for collecting personal information about you;

 

categories of personal information collected;

 

who receives your personal information or categories of such recipients;

 

how long we are going to store the information about you and if not possible criteria to determine the storage period;

 

when your personal information was obtained not from you directly, the source where it was obtained;

 

the existence of either profiling activities or automated decision making based on your personal information. Where such activities are performed, we should also inform you about the importance, and expected consequences of them;

 

a copy of your personal information processing.

 

right to rectification:

 

You have the right to correct inaccurate (for example, old or incorrect) personal information about you.

 

right to erasure or the right to be forgotten:

 

Under certain circumstances you have the right to request the erasure of your personal information. This right only applies to the data available at the time of request.

 

Request to erase of personal information is possible when:

 

personal information is no longer needed for the purposes it was primarily collected or processed;

 

when you have already withdrawn your consent for processing your personal data, and we do not have other legal ground to process it;

 

when your personal data is processed under legitimate interest and you object to such legal ground. Moreover, there is no overriding legitimate interest to proceed to process your personal data;

 

your personal information was unlawfully processed;

 

when your personal data has to be erased due to legal obligation.

 

right to restrict processing:

 

You may ask the Foundation to stop processing your personal information when certain conditions are met. These conditions apply when:

 

you have reasonable doubts that your information is accurate, and we are verifying the accuracy of such information;

 

your personal information was unlawfully processed;

 

the purpose of your personal information collection no longer exists, but you wish to store it longer to defend a legal claim.

 

right to data portability:

 

You have the right to reuse your personal data for your own purposes. You will also be able to transfer your personal information from one IT environment to another in a safe and secure way, when:

 

the processing is based on your consent or needed for the performance of a contract with you;

 

the processing is made only electronically, without any paper-based files included.

 

right to object:

 

You have the right to object to the processing of your personal information at any time. This allows you to prevent us from processing your personal information. This right applies only when one of the following conditions are met:

 

your personal information is used for direct marketing purposes;

 

the processing is based on our legitimate interest;

 

we are performing tasks carried out for the public interest or by governmental authority;

 

your personal information was processed for either research or statistical purposes.

 

right not to be subject to automated decision making and profiling:

 

We do not use any of your personal information for profiling or make decisions solely by automated means.

 

right to lodge a complaint with a supervisory authority:

 

You have a right to lodge a complaint with a data protection authority in a country you reside, permanently live, work, or in a country where data protection infringement takes place.

 

Children and Parents’ Rights

 

An adult with parental responsibility can access the information about their child, as long as the child is not considered to be sufficiently mature to access data personally. They must be able to prove their parental responsibility and Unbreakable Ukraine is entitled to request relevant documentation as evidence of the requestor’s identity. The Foundation has the right to ask the child if they object to the release of information to the parent in a case where the child is deemed mature enough to make such a decision. Please note that our website is not intended to be used by children, but by their parents instead.

 

We may receive the information about children and will process it with utmost care and store it separately from other data in a safe place.

 

Changes to this Policy

 

We will revise and update this policy regularly. We thus encourage you to visit this Policy page from time to time to keep up to date with any changes. Changes to the policy will apply from the date they are posted on our website and shall not apply retroactively.

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