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Privacy Policy

This Privacy Policy (hereinafter — the "Policy") governs relations in the field of personal data protection for visitors to the website https://kontur.org.ua/ (hereinafter — the "Website"), which belongs to the NGO "Kontur Think Tank" (legal entity identification code 46218211, registered address: Ukraine, 04070, Kyiv, 13 Andriivska Street, Building B, Office 16), registered in accordance with the current legislation of Ukraine (hereinafter — the "Organization").

1. General provisions.

1.1. In this Policy, the following terms are used with the meanings below:

  • personal data database — a named collection of structured personal data in electronic form and/or in the form of personal data card files;
  • consent of the data subject — the voluntary expression of will by a natural person (provided they are duly informed) to grant permission for the processing of their personal data in accordance with the stated purpose of such processing, expressed in a form that makes it possible to conclude that consent has been given;
  • processing of personal data — any action or set of actions, such as the collection, registration, accumulation, storage, adaptation, alteration, renewal, use, and dissemination (distribution, sale, transfer), depersonalization, or destruction of personal data, including through the use of information (automated) systems;
  • personal data — information or a set of information about a natural person who is identified or can be specifically identified;
  • data subject — the natural person whose personal data is being processed;
  • third party — any person other than the data subject, the data controller, or the data processor;
  • cookies — small text files stored in a device's browser (computer, mobile phone, etc.) after visiting the Website, which the Website transmits to the browser. You can learn more about cookies at: https://allaboutcookies.org/.

All other terms in this Policy are used with the meaning defined by the current legislation of Ukraine, including international legal instruments ratified by Ukraine.

1.2. This Policy has been developed to inform data subjects about the procedure for processing their personal data when visiting/using the Website, and to ensure the protection of their personal data during such processing.

1.3. This Policy, as well as the Organization's activities related to the collection, processing, storage, and other lawful actions regarding personal data, is governed by:

  • the Constitution of Ukraine;
  • the Law of Ukraine "On Personal Data Protection" dated 01.06.2010, No. 2287-VI;
  • other current legal acts of Ukraine governing personal data protection;
  • international legal instruments ratified by Ukraine.

Legal relations arising for the Organization in connection with the processing of personal data of residents of foreign jurisdictions are also governed by the applicable law (including international law) and the national and international legal instruments regulating personal data protection for residents of such countries.

1.4. The Organization is the controller of the personal data processed in connection with visiting/using the Website's features. The Organization has the right to delegate 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 current legislation.

1.5. A natural person is a data subject under this Policy if they are a visitor to the Website, including if they use any of the features available on the Website, including providing the Organization with their email address and name.

1.6. The Organization guarantees that it:

  • follows good practice and regulatory requirements for personal data protection;
  • protects the rights of data subjects;
  • takes steps to prevent the risk of a breach in the security of personal data processing.

1.7. The purpose of processing personal data obtained through the operation of the Website is to enable the Organization to carry out its statutory activities.

1.8. Publishing this Policy at the link specified in Section 4.1 of this Policy serves as notice to data subjects of the identity of the Controller, the scope and content of the personal data collected in connection with visiting/using the Website, the rights of such subjects, the purpose of collecting their personal data, and the third parties to whom such personal data may be disclosed.

2. Processing of personal data.

2.1. The Organization may collect and process the following information about you:

  • information you provide to the Organization: this is information about you that you provide by using the Website and its features, subscribing to receive email updates, making a charitable contribution (donation) through the options available on the Website, communicating with the Organization through the features available on the Website, and so on;
  • information about you collected by the Website and other systems:
    • if you visit the Website, third parties may collect certain information about you and your visit, such as the type and version of your browser, the pages on the Website you visit, and your Internet Protocol (IP) address;
    • the Website may also place cookies on your device;
    • if you contact the Organization's staff through the Website or other electronic means of communication.
  • information that third parties collect about you on the Website through your actions: this is information about you that you provide to third parties (for example, Facebook, Google, Twitter) by using the social-media sharing features available on the Website, by moving from one page to another, or by viewing materials that link to (open) other platforms (websites).

2.2. How the Organization processes your personal data depends on how you use and interact with the Website. Some information may be provided directly by you while using the Website or by other means; other information may be collected and processed by the Organization independently, through the automated technologies used on the Website.

2.3. Legal grounds for processing: when you visit the Website, the Organization processes your personal data if

  • the Organization has obtained your consent to such processing,
  • your personal data is necessary for the Organization to conclude and perform an agreement with you, or to take steps prior to concluding such an agreement,
  • the Organization has a legitimate interest in processing your personal data, and that legitimate interest is not overridden by your interests in data protection or your fundamental rights and freedoms, or
  • in other cases defined by current legislation.

In certain cases, the Organization may have a legal obligation to process your personal data, or may process your personal data to establish, exercise, or defend legal claims.

2.4. Automated processing mechanisms: The Organization and third parties may use automated information-processing technologies to process information in certain sections of the Website. The Organization uses cookies to store content and settings, which allows the Organization to process the standard information your browser sends to certain websites you visit, such as your IP address, browser type and language, the site you arrived from, the pages you visit, and the links you click on the Website. Having this technical information helps the Organization improve the Website.

2.5. The Organization may use your personal data only for the purposes defined by this Policy and current legislation, including (but not limited to):

  • to process your request (inquiry) to the Organization submitted through the Website,
  • to enable you to make a charitable contribution (donation) through the options available on the Website,
  • to pursue the Organization's other statutory purposes in the manner defined by current legislation;
  • to send emails and messages to your email address relating to promotional materials, information about the launch of charitable projects, requests and invitations to provide feedback on charitable activities, visits to the web resource, and so on.

2.6. The Organization may accumulate the personal data processed in the course of your visiting/using the Website, including by entering this data into a personal data database. Your personal data is stored in compliance with the requirements of current legislation on personal data.

2.7. Your personal data is disclosed only with your consent or in cases defined by this Policy and current legislation.

2.8. The Organization may partially publish user data on its Website in the Reporting/Contributions section.

2.9. Your personal data is subject to deletion or destruction upon:

  • the expiry of a 2-year storage period or another period defined by current legislation;
  • the termination of the legal relationship between the data subject and the Organization, unless otherwise provided by law;
  • other cases defined by current personal-data-protection legislation.

2.10. The Organization does not process personal data concerning racial or ethnic origin, political, religious, or philosophical beliefs, membership in political parties or trade unions, criminal convictions, or data concerning health, sex life, biometric data, or genetic data, except in cases defined by law.

3. Rights of data subjects.

3.1. When visiting/using the Website, you have the right to:

  • receive from the Organization information not covered by this Policy regarding the processing of, and the conditions for granting access to, your personal data, or to instruct persons authorized by you to receive such information, except in cases defined by law;
  • free access to your own personal data;
  • receive a response to a request concerning the processing of your personal data, in the manner and within the timeframe defined by current legislation;
  • submit a substantiated request objecting to the processing of your personal data, or requesting that your personal data be corrected or destroyed, if such data is processed unlawfully or is inaccurate;
  • protection of your personal data from unlawful processing and accidental loss, destruction, or damage resulting from deliberate concealment, failure to provide it, or untimely provision, as well as protection from the disclosure of information that is inaccurate or damaging to a natural person's honor, dignity, and business reputation;
  • withdraw your consent to the processing of personal data; and exercise any other rights defined by current legislation on personal data protection.

3.2. You have the right to raise questions related to the collection, use, storage, and other processing of your personal data with the Ukrainian Parliament Commissioner for Human Rights (the Ombudsman), who can be reached at hotline@ombudsman.gov.ua.

If you have any questions about this Policy, or if you have received any unwanted electronic notification sent by the Organization or purportedly sent on the Organization's behalf, please contact the Organization directly at kontur.thinktank@gmail.com.

4. Changes to the privacy policy.

4.1. The Organization reserves the right to review and amend the provisions of this Policy. The current version of this Policy is published on the Website at: https://kontur.org.ua/