The Foundation «Unbreakable Ukraine» Privacy Policy
Last update: March 19, 2023
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. Dolina 5c, office 3, 61-551 Poznan, 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.
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: google_auto_fc_cmp_setting Stores the user’s cookie consent state for the current domain. Expiry: Persistent 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: m Determines the device used to access the website. This allows the website to be formatted accordingly. Expiry: 2 years __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 __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: 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: 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: __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: GetLocalTimeZone Holds the users’ timezone. Expiry: Session 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: _ga Registers a unique ID that is used to generate statistical data on how the visitor uses the website. Retention: 2 years _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 _gat Used by Google Analytics to throttle request rate. Retention: 1 year _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: 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: 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: 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: 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 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
| Data | Purpose | Legal Ground | Service Provider |
| First Name | To process your payment | Performance of contract | Stripe |
| Last Name (optional) | To process your payment | Performance of contract | Stripe |
| Email Address | To provide you with payment confirmation | Performance of contract | Stripe |
| Card Number | To process your payment | Performance of contract | Stripe |
| Expiry Date | To process your payment | Performance of contract | Stripe |
| CVC Number | To process your payment | Performance of contract | Stripe |
We will not have full access to your donation details. Such details as full card number, expiry date, CVC number are securely stored by PayPal.
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.
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, and governmental institutions.
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.