Privacy policy

The Charitable Organization “The Charitable Foundation “An Indomitable Spirit”, whose place of business is in Ukraine, with address Khmelnytsky highway, bldg. 82, office 4.1, Vinnytsia, 21036, Ukraine, (hereinafter referred to as the “Foundation” or “The Charitable Foundation “An Indomitable Spirit”,) may be the controller of your data as it is provided under Directive 95/46 / EC (General Data Protection Regulation, Official Journal of the European Union L 119 May 4, 2016) (hereinafter referred to as GDPR).
The Foundation values and respects your privacy and is committed to protecting your rights on personal data.
This privacy policy (hereinafter referred to as the Policy) explains the way the Foundation uses and protects your personal data submitted to us and your rights regarding privacy. The Policy was last updated on August 2022. The Foundation retains the right to make changes to the Policy and update it in correspondence with the legislation in force at any time by amending this page. In order to review current amendments, it is necessary to check the content of this page.

The personal data collected by the Foundation for further processing may include:
• Contact details including emails, postal addresses, fax and phone numbers
• Information used to create your online account including username, password, security question, and answer
• General information including your name, job title/position and employing company title
• Purchase and customer service history
• Financial details including payment information, billing address, and payment card details (i.e., card number, expiration date, and security code), bank account information, financial statements, income, and credit score
• Technical information including IP address, operating system, web browser, and other technology on the devices that you use to access websites of the Foundation
• Location data including data derived from your IP address, country, and zip code
• Any other information which you may provide to the Foundation.

The Foundation may collect your personal data as follows:
• Via contact forms (the Foundation collects information when you log in of complete application or inquiry forms on the websites of the Foundation)
• Via emails, phone calls or letters (the Foundation collects information when you communicate directly with its contacts)
• Via personal interactions (the Foundation collects information when you interact with its employees directly)
• Via automated technologies (the Foundation collects information automatically via technology tools such as cookies or similar)
• Via third parties (the Foundation may collect information from publically available sources, from other companies and service providers within the limits permitted by law).

The Foundation collects your personal information in the course of its business for the following purposes:
• To provide you comfortable place of work, giving you challenging tasks
• To provide aid and assistance for those who need them
• To provide and administer information, services, and/or propositions to you
• To perform the contractual obligations that are binding us
• To communicate about and administer our initiatives, services, events, programs, and promotions (such as by sending alerts, promotional materials, newsletters, and other marketing communications)
• To create, administer and communicate with you about your account (including any purchases and payments)
• To perform data analytics including market research, trend analysis, financial analysis, and donators segmentation
• To fulfill our legal and regulatory requirements including establishing, exercising or defending legal claims
• To process, evaluate, and respond to your requests, enquires, applications or complaints
• To manage and administer relations between you and the Foundation
• To prevent and detect fraud and other legal offenses
• To ensure network and information security
• To host, maintain and improve our marketing communications website
• To verify your identity, protect against and prevent fraud and other unlawful activities, unauthorized transactions
• To maintain and enhance the safety and security of products, services, websites, network services, information resources and employees of the Foundation.
Additionally, the Foundation may use your personal data for direct marketing. This means, that the Foundation may send you marketing communications about initiatives, events, services, publications, humanitarian and political updates, courses, and surveys and to display content that we believe may be of interest to you based on your personal data. The Foundation will obtain your consent for the processing of your personal information for direct marketing purposes, where required by applicable law.The Foundation should only contact you for mentioned marketing purposes in accordance with our legitimate business interests or where you have explicitly expressed your consent to this. Your agreement for using your personal data is optional. A refusal to provide your agreement for your personal data usage should not affect your rights for visiting and using the websites of the Foundation and/or the quality of services and/or products provided by the Foundation. Simultaneously, if you choose not to provide the Foundation with certain information, the Foundation may not be able to offer you certain products and services, and you may not be able to access certain features of the Foundation websites.
The Foundation may employ a relationship management tool (if legally permissible) in order to strengthen relations between personnel of the Foundation and its current and/or potential donators and/or partners. The information submitted by you to the Foundation is exploited to assess, analyze and improve the services and the regular work performed by the Foundation.

Processing of your personal information as described hereof by the Foundation, in general, is based on the following items
• Your consent
• Performance of a contract with you or a relevant party
• Legitimate interests of the Foundation
• Compliance with legal obligations of the Foundation
You are entitled to request the Foundation not to use your personal data for marketing communications by sending a relevant email at privacypolicy@indomitablespirit.com.ua
The websites of the Foundation may comprise inviting you to provide your personal data including the “Contact Us” form and contact email addresses. These facilities purpose is apparent due to the fact that you provide your personal data directly and the Foundation is to use that information for mentioned purposes.
The websites of the Foundation may use Google Analytics service, a web-based tool for analytics, tracking, and reporting on the manner in which the website is used, in order to improve it.

The Foundation is entitled to use your personal data only in correspondence with the requirements of the current legislation in force, including but not limited to
• where it is necessary for legitimate business purposes of the Foundation provided it does not override your rights and freedoms
• to perform a contract such as providing you with services or products
• to comply with legal and regulatory obligations including establishment, exercise or defense of legal claims
• where the Foundation has received your unequivocal consent
The Foundation should provide you with full details of the information requested and reasons for its collecting, while you obtain an opportunity to consider carefully whether you wish to give such consent. The Foundation keeps your personal data only for as long as it is necessary for the purposes of its collecting, in order to provide you with services and/or products, for legitimate business interests, in accordance with a contract, and where it is required or allowed under the law.
The Foundation shall not share your information with any third parties, except for the cases when a direct and explicit consent to this was provided by you, and when it is legally permitted to do so in accordance with conditions stated hereof and/or in accordance with contractual arrangements agreed between you and the Foundation.
The websites of the Foundation may contain links to third-party websites including but not limited the websites of Foundation partners. These websites are owned and managed independently from the websites of the Foundation and have their own separate privacy policies. Any personal data that you provide to these websites will be governed under the terms and conditions of the privacy policy of that particular websites.
You are entitled to contact representatives of the Foundation to obtain more detailed information on the specific mechanism used by the Foundation for your personal data processing.
The Foundation applies appropriate physical, electronic and managerial security measures in place to protect against the loss, misuse or unauthorized access to your personal data. The Foundation uses network access control technology to limit access to the systems on which personal data is stored and monitors all hazardous circumstances to negate possible vulnerabilities and attacks. However, as the transmission of information via the internet is not completely secure, the Foundation cannot guarantee the complete security of your information transmitted to the websites of the Foundation.
The Foundation accepts the fact that the information you provide may be confidential and should not sell or otherwise make your personal data commercially available to any third party.
The Foundation does not use the personal data to make automated decisions.

You have the right (subject to certain exceptions) to:
• access, correct, delete, update, rectify or restrict your personal data
• object to use and processing of your personal data or withdraw consent that you have previously given
• request the transfer of your personal data to you or a third party
• submit any requests about the use and processing of your personal data
The Foundation may ask for further information from you in order to prove your identity before disclosing any personal data to you. This security measure is aimed to ensure that personal data is not disclosed to any person who has no right to receive it. The Foundation may also contact you to ask for further information in relation to your request.

If you have any queries in relation to the Policy, please contact us at:
E-mail
privacypolicy@indomitablespirit.com.ua
Address
Khmelnytsky highway, bldg. 82, office 4.1, Vinnytsia, 21036, Ukraine
If you currently receive marketing information from the Foundation which you would not prefer to receive in the future, please email us at privacypolicy@indomitablespirit.com.ua
If you would like to a) access certain personal data we maintain about you, b) request that we update, correct, amend, erase or restrict your personal data, or c) exercise your right to data portability, please email us at privacypolicy@indomitablespirit.com.ua, stating your will. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal data that we maintain. Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response.

European General Data Protection Regulation:
This Privacy Notice takes into account the requirements set out by the European Data Protection Regulation (GDPR). In case you are a European citizen, the following rights specifically apply to you:
* According to Art. 15 GDPR you can request information about your personal data processed by us.
In particular, you may obtain information about the purposes of processing, the categories of personal data, the categories of recipients to whom your data have been or will be disclosed, the planned storage period, the existence of a right to correction, deletion, restriction of processing or objection, the right to lodge a complaint with a supervisory authority, the origin of your data, if not collected from us, about transfer to third countries or international organizations, and the existence of automated decision-making, including profiling and, where applicable, meaningful information about the logic involved.
• According to Art. 16 GDPR you can immediately demand the correction of incorrect data or the completion of your personal data stored with us.
• According to Art. 17 GDPR, you may request the deletion of your personal data stored by us, provided that the processing is not necessary to exercise the right to freedom of expression and information, to fulfil a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims.
• According to Art. 18 GDPR, you can request the restriction of the processing of your personal data if you contest the accuracy of the data, if the processing is unlawful, if we no longer need the data and if you refuse their deletion because you need to establish, exercise or defend legal claims. You are also entitled to the right under Art. 18 GDPR if you have objected to the processing in accordance with Art. 21 GDPR.
• According to Art. 20 GDPR, you may request that the personal data you have provided us with be received in a structured, current and machine-readable format or you may request that it be transmitted to another person responsible.
• According to Art. 7 para. 3 GDPR you can withdraw your consent at any time. As a consequence, we are no longer allowed to continue the data processing based on this consent for the future.
• According to Art. 77 GDPR, you have the right to complain to a supervisory authority. You can contact the supervisory authority of your habitual residence, place of work or place of the alleged infringement.

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