Privacy Policy
of the NGO “Techiia Fundation”
Updated: November 25, 2022
Thank you for visiting the website of the non-governmental organization “Techiia Fundation”.
NGO “Techiia Fundation” and its partners strive to always adhere to the principles of business partnership and cooperation, justification of trust, in particular, compliance with a responsible attitude to your personal data.
1 General provisions
NGO “Techiia Fundation” is the owner (controller) of your personal data for the purposes of processing described in this Privacy Policy (hereinafter referred to as the “Policy”).
The Policy contains detailed information about how and why the NGO “Techiia Fundation” (hereinafter - the “Techia Fundation” or “we”, “us”, “our”) processes your personal data, what information becomes available to us and third parties when you visit the website available under the domain https://techiia-fund.org/ and how we use, store and protect the information received.
The Policy is an integral part of the Terms of use of the Website, which are available at the link:
https://techiia-fund.org/en/terms-of-use (hereinafter – the “Terms”).
In terms of separate processing of Personal data related to the provision of the Charitable Donation to the Recipients, as well as receiving the Charitable Donation from the Benefactors, our joint-controller (co-owner) may be the Nonprofit Corporation “TECHIIA FOUNDATION”, USA.
2 Our contact details
Company name: NGO “Techiia Fundation”
Address: 02095, Ukraine, Kyiv, Knyazhy Zaton str., 16-B
E-mail: info@techiia-fund.org
Contact details of the joint-controller (co-owner):
Company name: Nonprofit Corporation “TECHIIA FOUNDATION”;
Company address: 5425 Grosvenor Blvd, Los Angeles, CA, USA, 90066.
3 The definitions we use
Capitalized words, both singular and plural, have the following meanings in this Policy:
the Applicable legislation – means the legislation in the field of protection and processing of personal data, which applies to the activities of the Website and the Techiia Fundation, in particular the Law of Ukraine “On the Protection of Personal Data” dated 06.01.2010 No. 2297- VI with subsequent amendments and additions, other current legal acts of Ukraine, including ratified international conventions, as well as (where applicable) – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation – “GDPR”) and other laws, under the scope of regulation of which the activities and / or separate processing of data of the Techiia Fundation may fall.
the Benefactor – the person who provide the Charitable Donation.
the Content – is all objects and materials without limitation placed on the Website, including information, texts, images, animations, titles, logos, banners, slogans, audio and video recordings, design, graphics, illustrations, interface, etc.
the Cookies – are small pieces of data that are stored on your device (computer, smartphone,
tablet, etc.) when you visit the Website.
the Charitable Donation – is a voluntary and free transfer by the Benefactor to the Techiia Fundation of funds and other property to achieve the goals and objectives of the Techiia Fundation.
the Data Subject – is a natural person whose Personal data is processed.
the Device – means any device that can access the Website, such as a computer, mobile phone or tablet.
the IP address – is an unique number, similar to your post address, associated with your Internet activity.
the Personal data – information about a natural person who is identified or can be specifically identified.
the Pixels – are pieces of software code that are integrated into the website code and allow tracking and analysis of User behavior (which pages are visited, which links are followed, etc.).
The Recipient – is a person who needs the Charitable Donation within the scope of the goals and objectives of the Techiia Fundation, and to whom such assistance is directly provided.
the Technical data – information that is collected by the Website when users visit it (for example, the IP address (web protocol) of the device you use, data about the web browser you use, your operating system, etc.).
the User – a person who uses the Website, including the Benefactors, the Volunteers, the Recipient, depending on the circumstances. According to the text, it can also be used as “you”, “your”.
the Volunteer – is a natural person who voluntarily carries out socially oriented non-profit activities aimed at helping to achieve the goals and objectives of the Techiia Fundation.
The Website – is a website available under the domain: https://techiia-fund.org/, on which the Techiia Fundation posts information about its activities, the Content, areas of charitable assistance (projects, tasks), and also provides an opportunity to join the charity activity.
4 Where does Techiia Fundation get data from?
Using the Website does not require registration and provision of the Personal Data that can identify you.
We receive data directly from you in the following cases:
- when you contact us through the Website;
- by contacting our address or e-mail, telephone;
- by filling out the appropriate form (questionnaire) for receiving assistance;
- when you provide Charitable Donation;
- through an application for cooperation (become the Volunteer, the Benefactor, partner);
- when contacting us with information requests.
We also process the Technical Data. Some of this data is collected automatically, for example through your web browser (such as Google Chrome, Safari, Mozilla Firefox, Opera, Microsoft Edge).
This includes the following data: IP address, geolocation (location), device and browser type, browser version, cookies and data on the User's interaction with the site (session ID). The session ID includes: your interaction with the Website; if you went to the Website by a link from another website - the address of this website; the functions of the Website used by you; viewed pages; length of stay; way of visiting our Website; date and time of visit and other diagnostic data.
Usually, such data does not give us a real possibility to identify you as a specific natural person, directly or indirectly, and is therefore not considered personal data. For example, we may use this data to calculate the percentage of visitors who access a particular feature of the Website. However, if we combine or link the Technical Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data that will be used in accordance with this Policy.
Automated processing of the Personal data, including profiling is not performed.
5 How do we process Personal Data?
Upon receipt of Personal Data, we process them in accordance with the following:
| The Purpose of the processing | The Legal basis | The Categories of personal data | The period of data storage |
|---|---|---|---|
| Provision of the Charitable Donation to the Recipients, including processing requests for the Charitable Donation | Consent | Surname, first name, e-mail, contact phone number, other information received from the Data Subject | Until the processing goal is achieved. Some data may be stored for a longer period of time determined by Applicable legislation, in particular for accounting and tax purposes. |
| Receiving Charitable Donation from the Benefactors | Conclusion and execution of the contract | Surname, first name, patronymic, e-mail, address, financial phone number, payment card data (partially) in case of online payment, payment details (in case of payment on the bank account) | During the time specified by the Applicable legislation, in particular for the purposes of accounting and tax purposes. |
| Cooperation with the Volunteers and partners | Conclusion and execution of the contract | Surname, first name, patronymic, e-mail, contact phone number; if necessary, also additional data | During the period of cooperation and up to 1 (one) year after its termination |
| Response to inquiries and appeals | Legitimate interest to develop and improve our charitable activities | Name and e-mail, other information received from the Data Subject | Until the purpose of the processing is achieved and up to 1 (one) year after the end of the communication |
| Ensuring the performance and stability of the Website's operation, the safety of its use | Legitimate interest to ensure stable operation of the Website, protection against fraud and other threats | IP address, geolocation data, device and browser type, cookies, browser data, other Technical Data | Within 6 (six) months from the day of the last visit to the Website. |
| Exploring and analysis of the Website's audience | Legitimate interest to develop and improve the Website | IP address, geolocation data, device and browser type, cookies, browser data, other Technical data, data provided by Google Analytics, Google Analytics 4, Facebook and Linkedin pixels, Hotjar statistics services. | Up to 26 months |
After the expiration of the term, depersonalized data may continue to be stored for archival and statistical purposes or in accordance with the requirements of the Applicable legislation.
Data processing with joint-controller (co-owner)
When you submit request for the Charitable Donation through the Website or receive Charitable Donation, depending on the circumstances, our partner - Nonprofit Corporation “TECHIIA FOUNDATION”, USA, may participate in the provision of Charitable Donation (see Section 1 above for more details).
In such cases, or when you make a Charitable Donation through the Website to our partner's details, we become joint-controllers (co-owners) of the Personal data to the extent necessary for these processes and process them in accordance with this Policy and for the relevant purpose as stated above.
Protection of children
We do not knowingly collect personal information from persons under the age of 18 (hereinafter referred to as “Child”, “Children”). If you become aware that a Child has provided us with the Personal data, please contact us. If we become aware of the fact of collecting Children's Personal Data without the consent of the Child's parents or other legal representatives, we take measures to delete this information.
Payment data
We will not store or collect your payment card details. This information is provided by you directly to payment systems – the Processors (defined in Section 8 of the Policy). The use of your Personal Data by payment systems is governed by their privacy policy.
6 Where and how is Personal data stored?
Techiia Fundation may accumulate the Personal data, inter alia by including this data in a personal database.
The Personal data and databases of personal data are stored at the business addresses of their owner, NGO “Techiia Fundation”: 21, Dniprovska naberezhna, Kyiv, Ukraine, 02081.
We also use the data centers of contractors who provide us with relevant services. You can get more detailed information in Section 8. Processors of the Personal Data hereto.
The Techiia Fundation takes the following technical and organizational measures to preserve the confidentiality of your data: use of anti-viruses, use of a secure data storage server, encryption of passwords, determination of the circle of persons and their level of access to the Personal data, conclusion of contracts with an obligation not to disclose the Personal data, and others.
7. Does Techiia Fundation transfer personal data to third parties?
We understand the value of Personal data and make efforts to keep it private and secure.
We do not transfer Personal Data to third parties, except when such transfer is:
- as required by legislation and only (if necessary) in the interests of national security, economic well-being and human rights;
- at the request of the Data Subject;
For example, we may disclose the Personal data if we believe it is necessary or appropriate to protect the rights, property, or safety of Techiia Fundation, our partners, or other persons. This includes sharing information with other individuals and organizations for the purpose of protecting or preventing crime.
8 Processors of the Personal data
We may engage third-party companies and/or individuals to facilitate the processing of the Personal sata on our behalf, provide services such as payment processing, data storage, assistance in analyzing how our Website is used, improving the Website's usability, and other services necessary for the Website's operation and the achievement by the Techiia Fundation of the goals of its activities (hereinafter referred to as the “Processors”).
In particular, our Processors are:
- Payment processing partners:
- WayForPay payment system (WAY FOR PAY Financial Company LLC). Address: Ukraine, 69037, Zaporizhzhia city, Nezalezhnosti Ukrainy Street, building 39-A, office 27;
- Payment system PayPal, Inc. Addresses: (1) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal L-2449, Luxembourg; (2) 5 Temasek Boulevard 09-01, Suntec Tower 5, Singapore 038985. - Partners who help us analyze and collect data from the Website:
- Google, Inc. Address: Google, Google Data Protection Office, 1600 Amphitheater Parkway, Mountain View, California 94043, USA - in terms of using Google Analytics, Google Analytics 4, Google Forms services;
- Hotjar Ltd. Address: Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian's STJ 3141, Malta. - Partners whose data centers we use:
- Amazon Web Services, Inc. or its affiliates with offices and servers located in the United States and other countries around the world. More details at the link: https://aws.amazon.com/legal/marketingentities/. - Our employees;
- Our Affiliates and Subsidiaries (depending on the circumstances);
- Volunteers with whom we cooperate;
- Other contractors, suppliers whose services we use to achieve the goal(s) of our activity.
Controllers have access to your Personal data only to perform tasks within the scope and purposes of the Personal data processing in accordance with the Policy and are contractually obligated not to disclose or use it for any other purposes.
Google Analytics collects information anonymously. It reports website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site. For more information on opting out of being tracked by Google Analytics across all websites you use, visit the website at the link: https://tools.google.com/dlpage/gaoptout?hl=en.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en.
Hotjar stores the information from the Website in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected from the Website. For further details, please see the “about Hotjar” section of Hotjar’s support site: https://help.hotjar.com/hc/en-us/categories/115001323967-About-Hotjar.
9 Cross-border data transfer
The transfer of Personal Data to foreign entities is carried out only under the condition that the relevant state ensures adequate protection of Personal Data in cases established by law or an international treaty of Ukraine.
Personal data may be transferred to foreign subjects of relations also in case of:
1) provision by the Data Subject of the explicit consent to such transfer;
2) the need to conclude or execute a transaction between the Techiia Fundation and a third party for the benefit of the Data Subject;
3) the need to protect the vital interests of the Data Subject;
4) the need to protect the public interest, establish, fulfill and secure a legal requirement;
5) provision by the Techiia Fundation of appropriate guarantees regarding non-interference in the personal and family life of the Data Subject.
The Processors from foreign countries are listed in Section 8 of the Policy above.
Your data may be used, stored and processed in other countries where our Processors are located. These locations may be outside of your country of residence or outside of your state/province and may have different data protection standards than your country/state/province.
Currently, according to the decision of the European Commission and the Court of Justice of the European Union in the Schrems II case, the US generally does not offer an adequate level of protection of personal data. If the level of data protection does not meet the European standard, data transfer takes place with appropriate safeguards and on the basis of standard EU data protection provisions.
At the same time, the Techiia Fundation takes all the necessary organizational and technical measures to ensure the appropriate level of confidentiality of your data and guarantee non- interference in personal and family life. In particular, if we transfer personal data from the EEA to countries with insufficient data protection, we rely on Data Processing Agreements (DPAs) and Standard Contractual Clauses (SCCs) approved by the European Commission or other grounds as required or permitted by Articles 46 and 49 GDPR.
10 How do we use Cookies?
We use Cookies to improve certain features of our Website, maintain security measures, analyze access to our Website, its use and performance. For example, the choice of your preferred language is saved thanks to Cookies. Thus, you will not have to re-enter data or make settings when visiting the Website.
Cookies can be blocked by you at any time. Cookies do not collect personal information about you or provide us with your contact information, nor do they receive any information from your computer. With the help of a cookie, we receive the Technical Data specified in the Policy.
You can see more details about how we use Cookies in our Cookie Policy at the link:
https://techiia-fund.org/en/cookie-policy.
11 Limitation of liability regarding third-party resources
The Website may contain links to third-party resources posted for informational purposes. If you link to other resources, this Policy will not apply to such resources.
We are not responsible for the policies and practices of other companies, and any information that the User provides to such companies is subject to their privacy policy or other document that regulates the processing of Personal data.
If you leave the Website via a third-party web link, we recommend that you review the privacy
policy of each website or service before submitting any personal data, and carefully review their
terms of use.
For example, our Site contains links to social networks Facebook, YouTube, Instagram, Twitter and Linkedin.
Additional information on the data protection rules of integrated elements of social networks is available on the following web pages:
Facebook: https://ru-ru.facebook.com/policy.php
Youtube: https://www.google.ru/intl/ru/policies/privacy/
Instagram: https://www.instagram.com/about/legal/privacy/
Linkedin: https://ru.linkedin.com/legal/privacy-policy
Twitter: https://twitter.com/privacy
The Techiia Fundation cannot guarantee the security of your Personal data when using the services of third parties, nor can it be responsible for their work, as it is not the owner of these resources.
12 Your rights regarding the Personal dataYou have the right at any time to object to processing of your Personal data based on a legitimate interest or to withdraw data processed on the basis of a consent (see Section 5 How do we process Personal Data?). You can exercise your rights to update, access, rectify, restrict or erasure your Personal data. To do this, it is enough to send a message by e-mail, with a note in the subject of the letter “Personal data”, to the e-mail address: info@techiia-fund.org. Please note that we may ask you to verify your identity before responding to such requests. As a result of your request, your data will be updated, rectified, revoked or erasure from our servers within 30 days of your request. If we need more time to process your request or if your request cannot be satisfied for legal reasons, you will receive a notification from us accordingly. |
In accordance with the Law of Ukraine “On Personal Data Protection” you have the right to:
If you are located in the European Union (EU) and/or European Economic Area (EEA), under the GDPR you have the right to:
You have the right to complain to a Data Protection Authority about our collection and use of your Personal data. For more information, please contact your local data protection authority in the EEA. Information for residents of the United States Users can visit our Website anonymously. A link to our Privacy Policy can be easily found on the footer (bottom) page of our Website. Users are informed about any changes to the Policy by publishing a new version of the Policy on the Website. We may also notify you of changes from time to time in pop-up windows on the Website or by other available means. In addition, we do not disclose personal information for direct marketing purposes. You may exercise the rights of the Data Subjects defined above in Section 12 of the Policy. Our policy on “Do Not Track” Signals We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the preferences or settings page of your web browser. Information for California residents The activities of the Techiia Fundation are non-commercial. We do not sell personal information within the meaning of the the California Consumer Privacy Act or «CCPA». We also do not disclose your personal information to third parties for direct marketing purposes. We do not meet any of the three criteria that identify the company as a subject to CCPA, namely: (1) annual gross revenue in excess of 25 million US dollars; (2) annual purchases, receipt, or sales of the personal information of 50,000 or more California residents; or (3) companies that derive 50 percent or more of annual revenue from selling consumers' personal information. To learn more about the personal information we collect about you, including the categories of sources, see section 4 Where does Techiia Fundation get data from? and 5 How do we process Personal Data? above. We may provide this information, in whole or in part, to our Processors as set out in section 8 Processors of the Personal data. You are able to change your personal information by emailing us at info@techiia-fund.org and |
13 Policy Update
Techiia Fundation has the right to unilaterally change this Policy at its sole discretion and at any time.
Changes to the Policy take effect from the moment of their publication on the Website.
The publication of the new version of the Policy on this Website will be considered as the notification of the Users about the change of the Policy. We ask that you periodically review this Policy. We may also notify you of changes from time to time in pop-up windows on the Website or by other available means.
When you provide Charitable Donation or otherwise interact with the Website, you confirm that you have read the current terms of the Policy.
Changes to the processing of Personal data, which require the User's consent, are applied only after receiving such User’s freely given and informed consent.
In the event that any part of this Policy is invalid, the remaining parts will remain in effect.
If the Policy is published in different language versions, the Ukrainian version will prevail.