Privacy notice

Last updated November 28, 2023

This privacy notice for NGO Promote Ukraine and its projects such as Ukraine Leads Network, hereinafter mentioned as "Promote Ukraine," "we," "us," or "our", describes how and why we might collect, store, use, and/or share ("process") your information when you use our website ("Website"). Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Website. If you still have any questions or concerns, please contact us at info@promoteukraine.org. 1. WHAT INFORMATION DO WE COLLECT? Personal information you disclose to us We collect personal information that you voluntarily provide to us when you register on the Website, express an interest in obtaining information about us or our projects, when you participate in activities of Promote Ukraine, or otherwise when you contact us. Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and may include the following: names phone numbers email addresses mailing addresses usernames passwords job titles contact preferences contact or authentication data Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information: information revealing political opinions health data financial data information revealing religious or philosophical beliefs information revealing race or ethnic origin All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. Information automatically collected We automatically collect certain information when you visit, use, or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website, and other technical information. This information is primarily needed to maintain the security and operation of our Website and for our internal analytics and reporting purposes. Like many organizations, we also collect information through cookies and similar technologies. The information we collect includes: Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Website which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity on the Website (such as the date/time stamps associated with your usage, pages, and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings). Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information. Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt-out, you may not be able to use certain aspects of the Website. 2. HOW DO WE PROCESS YOUR INFORMATION? We process your personal information for a variety of reasons, depending on how you interact with us, including: To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order. To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Website. To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more. To protect our Website. We may process your information as part of our efforts to keep our Website safe and secure, including fraud monitoring and prevention. To identify usage trends. We may process information about how you use our Website to better understand how they are being used so we can improve them. To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you. To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm. 3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION? If you are located in the EU or UK, this section applies to you. The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information: Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. If you wish to do so, please contact us at info@promoteukraine.org. Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to: Send users information about special offers and discounts on our products and services Develop and display personalized and relevant advertising content for our users Analyze how our services are used so we can improve them to engage and retain users Support our marketing activities Diagnose problems and/or prevent fraudulent activities Understand how our users use our products and services so we can improve user experience Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved. Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person. 4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? We may need to share your personal information in the following situations: Partnership organisations. We may share or transfer your information in connection with, or during projects with our partners, other NGOs. Government institutions. We may share your information with governmental institutions with whom we work on certain projects. 5. HOW LONG DO WE KEEP YOUR INFORMATION? We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. 6. HOW DO WE KEEP YOUR INFORMATION SAFE? We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment. 7. DO WE COLLECT INFORMATION FROM MINORS? We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@promoteukraine.org. 8. WHAT ARE YOUR PRIVACY RIGHTS? In some regions (like the EEA, UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us via email to info@promoteukraine.org. We will consider and act upon any request in accordance with applicable data protection laws. If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html. Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us via email to info@promoteukraine.org. However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by contacting us via email to info@promoteukraine.org. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. Account Information If you would at any time like to review or change the information in your account or terminate your account, you can: Log in to your account settings and update your user account. Contact us using the contact information provided. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements. If you have questions or comments about your privacy rights, you may email us at info@promoteukraine.org. 9. DO WE MAKE UPDATES TO THIS NOTICE? We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information. 10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE? If you have questions or comments about this notice, you may email us at info@promoteukraine.org or send a letter by post to: Promote Ukraine NGO Boulevard Emile Jacqmain 81 1000 Bruxelles 11. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU? Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please submit a request via email at info@promoteukraine.org.