Privacy Policy
This Privacy Policy establishes the procedure for obtaining, storing, processing, using, disclosing and protecting the User's personal data.
This Privacy Policy is an integral part of the User Agreement http://kazhanroad.org/
The controller of personal data is the public non-profit charitable organization "VšĮ Ukrainian refugees", address: Vilnius, J. Savickio g. 4-7, Lithuania (hereinafter referred to as the Fund).
By using the Service, the User fully accepts this Privacy Policy.
1. Data collection
1.1. Personal data is information that can be used to directly or indirectly identify a natural person. Personal data is also a set of information that can lead to the identification of a specific person.
1.2. The user provides information and personal data when filling out the request form, as well as in other cases of using the site.
1.3. The Foundation will collect the following information about Users:
1.3.1. Personal information, which is data entered by the User, shown or disclosed to the site in any other way while using the site. Such information may include:
- name and surname of the User
- the name of the organization
- e-mail
- phone number
- location
- the address
The User must provide this information so that the Fund can provide the User with the opportunity to participate in the Fund's activities.
The Fund can also check Users using personal data.
In this case, the Fund may request all the User's data necessary to check and prevent fraud, including name, surname and e-mail address, data of the User's personal documents and other data.
_cc781905-5cde-3194 -bb3b-136bad5cf58d_1.3.2. Technical information that is automatically collected when you visit the site. As a rule, this is information about:
- User's IP address
- operating system version
- device type
- system and performance
- browser type
If the User accesses the site from a mobile device, the site also receives a universally unique identifier (UUID) for such a device. The Site may combine this information obtained from the User's browser or mobile device with other information about the User collected by the Site or its partners, including information collected from multiple devices.
_cc781905-5cde-3194 -bb3b-136bad5cf58d_1.3.3. When the User logs in using another service (such as Facebook, Google+, etc.), the Site may also collect information contained in the relevant profile of such service that the User has agreed to provide, including the User's name, email address and profile information. The user agrees to provide this data to the site during registration. This permission can be revoked at any time by sending an appropriate request to the site.
_cc781905-5cde-3194 -bb3b-136bad5cf58d_1.3.4. The Foundation may collect information about the physical location of the User's device. The User's location can be determined using IP or geolocation information obtained from the User's device. The Service may use and store information about the User's location to provide, improve and customize services. For example, for internal analytics and performance monitoring, or to display content or offers relevant to the User's location.
_cc781905-5cde-3194 -bb3b-136bad5cf58d_1.3.5. The Foundation uses cookies and similar technologies on its websites. More information about cookies is provided in the section "Cookies, web beacons and similar technologies".
_cc781905-5cde-3194 -bb3b-136bad5cf58d_1.3.6. Telephone communication and correspondence
When you contact us by phone or email, we collect any information you choose to provide when you speak or correspond with our employees or representatives. Please note that when communicating by phone, all conversations are recorded. If you object to the recording of a telephone conversation, the conversation will end and you will be able to use other available forms of communication.
_cc781905-5cde-3194 -bb3b-136bad5cf58d_1.3.7. Establishing communication with us, including for guests of the Service
If you use our website and provide us with contact information, or contact us yourself, we collect the information you provide us through all types of contact forms.
_cc781905-5cde-3194 -bb3b-136bad5cf58d_ 1.3.8. Data provided by the User in connection with his participation in contests and surveys conducted by the Fund or other third parties at the request of the Fund.
_cc781905-5cde-3194 -bb3b-136bad5cf58d_ 1.3.9. The Foundation receives information about Users and their activity from marketers, partners, researchers and other sources (including public databases). The Fund may combine information received from the User with information received from other Users and third parties.
1.4. The Foundation does not collect or process any "Special Categories of Data", such as data on racial or ethnic origin, political, religious and ideological beliefs, membership in political parties and trade unions, criminal history, and health data , sex life, biometric or genetic data.
1.5. The Fund does not collect, store, or in any other way process data on the User's bank accounts, data on his bank (payment) cards and other financial information in the possession of the User, banks and payment systems. The collection and processing of such personal data of the User (including data about the User's bank accounts, his bank (payment) cards) will be regulated by the privacy policies of payment service providers, and not by this User Agreement.
1.6. Please note that any information submitted by a User to the Fund (such as the User's name and public photos, etc.) may become public and be available to other Users and the general public. Personal information posted by Users or disclosed by them to other Users may be collected by other Users and may lead to unwanted messages. The Foundation is not responsible for the protection of information that the User may disclose to third parties.
2. Purpose of personal information processing
2.1. The Foundation will only use your personal information as required by law.
2.2. Processing of personal data is any action or combination of actions, such as collection, registration, accumulation, storage, adaptation, modification, use, distribution (sale, transfer, including transfer abroad), as well as deletion of personal data, including using information (automated) systems.
2.3. The Foundation uses personal information received from Users for various purposes and in accordance with various legal grounds for its processing.
The Service may use information received from Users as follows:
_cc781905-5cde-3194 -bb3b-136bad5cf58d_2.3.1. To enter into and execute a contract, as well as to provide and improve its services. The collection of certain data is necessary in order for the Foundation to be able to fulfill its contractual obligations under the User Agreement (provision of services by the Administration under the User Agreement), to enforce the User Agreement, this Privacy Policy or other policies.
2.3.2. To manage User accounts and communicate with them. The Fund may use information about Users to solve technical problems, respond to Users' requests for help, analyze information about technical failures and eliminate them.
This is necessary for the Administration to fulfill the contract. as well as to ensure the Fund's legitimate interests, in particular, to improve the Fund's activities.
2.3.3. To fulfill legal, regulatory and law enforcement requests and protect the legal interests and rights of the Fund. The Foundation cooperates with state and law enforcement agencies and private individuals to ensure compliance with the law. The Fund discloses any information about Users in accordance with the requirements of the law, if it is necessary to protect the legal rights and interests of the Fund and/or the legal rights and interests of third parties or to prevent or stop illegal activities.
The Foundation also uses the information to limit or prevent various forms of service abuse, such as fraud, spam, and other unauthorized activities that violate the User Agreement.
If required by law, the Fund may use the information in connection with legal and audit activities, for example, for the purpose of a takeover, merger or sale of its business.
To the extent permitted by law, the Foundation will take reasonable steps to notify Users of the provision of personal information to third parties.
2.3.4. For site analytics. The Foundation uses numerous web analytics tools (or tracking tools) provided by third-party service providers, such as Google Analytics, to collect information about how Users interact with the Site. The Service conducts research and analysis of the User's use of the Service or the User's interest in products, services and content. The Service uses the information provided by these tools to improve services, detect and analyze errors. Such service provider tools place cookies in Users' browsers. Cookies cannot be used by anyone other than third-party service providers. Information collected using cookies may be transmitted and stored on servers in a country other than the User's. Collected information is used and shared by these service providers in accordance with their individual privacy policies. Users can freely agree to the collection and processing of data created by cookies in connection with the use of the Service.
_cc781905-5cde-3194 -bb3b-136bad5cf58d_2.3.5. To conduct contests or surveys. The Foundation uses the information collected through these methods to improve the quality of services.
The Administration may offer Users a survey to measure overall satisfaction with the Fund's activities. Moreover, the User may voluntarily provide the Administration with his contact data, such as an e-mail address and mobile phone number, so that the Administration can contact the User and invite him to UX testing or an interview with Service experts. The information that the User provides to the Administration during the survey may contain personal data that the User provides voluntarily.
_cc781905-5cde-3194 -bb3b-136bad5cf58d_2.3.7. To fulfill obligations under tax legislation. When it is determined by the legislation and/or under the condition of payment by the Users of the Administration services, the Administration may collect the Users' data for the purpose of fulfilling obligations in accordance with tax legislation or civil legislation - in accordance with Article 6(1)(c) of the GDPR (processing is necessary for the Controller to fulfill a legal obligation);
3. Transmission and disclosure of information
3.1. The Fund may disclose the User's information to third-party service providers who provide services for the Fund, namely: website hosting, data analysis, provision of information technology and related infrastructure, delivery of e-mails and messages (notifications), auditing, services, which assist the Foundation with the provision of personalized advertising and service providers to manage the help desk, support data and CRM systems. These services help the Foundation provide services (for example, they may help the Foundation provide personalized advertising or help the Foundation prevent, detect, mitigate and investigate potentially illegal activities). These service providers will only have access to the information necessary to perform their respective functions. These third parties are obliged not to disclose or use the User's information for other purposes. In some cases, these service providers are not obligated to provide services for the Foundation, but they help improve the work of the Foundation. Cooperation with third-party service providers in order to improve services is a legitimate interest of the Fund (to ensure proper performance of the contract with the User).
For example, the Foundation uses Google Analytics to monitor and analyze the use of the Service. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the collected data to track and monitor the use of the site. This data is transmitted to other Google services. Google may use the collected data to contextualize and personalize the advertisements of its own advertising network. The User can opt out of the collection of data about his activity on the Service by Google Analytics by installing a browser add-on that blocks Google Analytics. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from transmitting information about the activity of visits to the Service to the Google Analytics service.
The Foundation also uses online advertising services to display Google Adsense and DoubleClick for Publishers ads. The user can find more information about Google privacy here: https://policies.google.com/privacy?hl=en
3.2. The Fund may transfer part of the Users' information outside the User's country of residence. For example, personal data is stored on servers located in Germany. The Foundation has created legal mechanisms to ensure the protection of Users' rights regardless of such transfer.
If personal data is transferred to a third country (i.e. to a country outside the European Union or the European Economic Area), the data transfer will be governed by the Privacy Shield principles (https://www.privacyshield.gov/welcome)
or will be performed on the basis of standard contractual clauses established by the European Commission (http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm
and https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en ).
3.3. The Foundation may share information about Users with third parties, including law enforcement agencies, public or government institutions, or private individuals, within or outside the User's country of residence, in order to satisfy legal, regulatory and law enforcement requests and to protect the legitimate interests and rights of the Service.
For example, the Fund may disclose the User's personal data if it is convinced that such actions are necessary for:
3.3.1. Fulfillment of legal obligation
3.3.2. Protection of rights or property Fund
3.3.3. Preventing or investigating possible violations related to the Fund
3.3.4. Protecting the personal safety of users of the Fund or the public
3.3.5. To protect against legal liability
3.4. The User's agreement to this Privacy Policy with the subsequent provision of such information is the User's consent to such transfer.
However, if necessary, the Foundation may request the User's consent to the transfer/disclosure of his information. In any such case, the Fund will provide a full explanation of why and what information the Fund must transfer/disclose.
3.5. In some cases, when it is determined by law and/or contract, Providers may collect personal data of Users. In some cases, the Fund may act as an intermediary in the transfer of such data, but the Administration does not use or store such User data in any way. The User, as a payer who orders a payment transaction, confirms that he authorizes the Administration to transfer the User's (payer's) data accompanying such transaction to the Provider.
Постачальник може обробляти персональні дані for the purpose of:
3.5.1. conclusion of the contract between the User and the Administrator and its execution - in accordance with Article 6(1)(b) GDPR (processing is necessary for the conclusion and execution of the contract);
3.5.2. fulfillment of obligations in accordance with tax legislation or civil legislation - in accordance with Article 6(1)(c) GDPR (processing is necessary for the Controller to fulfill a legal obligation);
3.5.3. establishing, pursuing or defending claims in accordance with Article 6(1)(f) GDPR (processing is necessary for the purposes arising from the legitimate interests of the Provider as a controller, which in this case is the possibility of effectively establishing, handling or defending claims );
3.5.4. in other cases provided by the Privacy Policy of the relevant Provider.
Одержувачами персональних даних Користувача можуть there may also be third parties who cooperate with the Supplier:
а) компанія, яка provides accounting services to the Supplier-controller;
б) компанія, що provides data hosting services to the Controller Provider.
в) інші треті особи , to whom the Controller Provider has a legal obligation to provide data.
Постачальник зобов'язується розмістити Privacy rules on the Service or provide access to them to Users.
З усіх питань, пов related to the processing of personal data by the controlling Provider, you should contact the contact details of the Provider specified in the Privacy Policy of such Provider.
4. Data protection
The Controller takes all reasonable technical and organizational measures to protect the User's personal data from unauthorized access by third parties.
The Fund conducts candidate screening at the time of hiring or prior to entering into a contract with independent contractors (to the extent permitted by applicable law and countries). Non-disclosure agreements are also signed. The Foundation provides ongoing training on privacy and security issues.
All personal data collected and processed by the Foundation is stored on one of several secure servers. Such servers are not accessible to anyone outside of the corporate network or to contractors who have signed a non-disclosure agreement.
However, although the Fund implements security measures designed to protect Users' information, no security system is impenetrable, and the Fund cannot guarantee that data during transmission over the Internet or when stored on servers or systems owned by the Fund will be completely secure from encroachment by third parties.
5. Legal rights
5.1. The Foundation will respect any legal right of the User to access, change or delete his personal information.
5.2. Each User has account settings that help them access, correct or delete information that the User provides to the Foundation. The user can change their settings on their devices to accept or refuse the collection of personal information or the display of relevant notifications.
5.3. Mobile apps have permission systems for certain types of device data and notifications, such as geolocation and push notifications. Please note that some services may lose full functionality due to the deactivation of certain features.
5.4. The user can contact the Foundation's support service (kazhanroad@gmail.com) with any questions regarding these settings.
5.5. In accordance with current legislation, Users have the following rights (in particular):
5.5.1. request access to the User's personal data. This enables the User to obtain a copy of the User's personal data stored by the Fund and to check whether the Fund processes them on legal grounds.
5.5.2. request correction of the User's personal data. This means that the User can correct any incomplete or inaccurate data. Please note that the Service may need to verify the accuracy of the new data.
5.5.3. request the deletion of the User's personal data. The User can ask the Service to delete personal data, if there are no good reasons for their continued processing by the Service. The User also has the right to request the Fund to delete the User's personal data if the Fund may have processed the personal data illegally, or if the Fund is required to delete the personal data in accordance with local law.
5.5.4. to object to the processing of the User's personal data (for example, when personal data is processed for the purpose of direct marketing). In some cases, the Fund can demonstrate that the Fund has valid legal grounds for processing information that bypass the User's rights and freedoms.
5.5.5. request restriction of processing of User's personal data. The user has the right to limit the processing of personal data under the following conditions:
_cc781905-5cde-3194 -bb3b-136bad5cf58d_ (a) the accuracy of personal data is challenged by the User during the period that allows the Service to verify the accuracy of personal data;
_cc781905-5cde-3194 -bb3b-136bad5cf58d_ (b) the processing is illegal and the User opposes the deletion of personal data, but requires restriction of their use;
_cc781905-5cde-3194 -bb3b-136bad5cf58d_ (c) the Service no longer needs personal data for processing, but it is needed by the User to exercise or defend legal claims;
_cc781905-5cde-3194 -bb3b-136bad5cf58d_ (d) The User has objected to the processing until it is verified whether the legitimate grounds of the Service prevail over the rights of the Users
request to transfer the User's personal data to another User or a third party. The Service will provide the User or a third party with the User's personal data in a widely used machine-readable format.
withdraw consent at any time if the Fund asks for consent to the processing of the User's personal data. However, this will not affect the lawfulness of any processing that took place before the User withdrew their consent. If the User withdraws their consent, the Foundation may not be able to provide the User with certain products or services.
5.6. Please note that the Foundation may reject requests for certain reasons, including if the request is illegal or may violate the rights of another User or a third party.
5.7. In some countries, Users have the right to lodge complaints with the relevant data protection authorities if they have doubts about how their personal data is being processed.
Head of the Office of Personal Data Protection in Poland (address: Stawki 2, 00-193, Warszawa).
Data Protection Inspectorate of Estonia, address: st. Tatari, 39, 10134 Tallinn, Estonia, e-mail info@aki.ee, website https://www.aki.ee/.
6. Notices and Notifications
Sometimes the Fund may need to contact the User. These communications may be delivered by email, push notifications, or telephone for the purpose of providing Users with support or for other purposes (such as providing Users with information about products and features that may be of interest to Users). These messages may be sent with the prior consent of the User or in response to the User's requests. The user can control marketing emails and/or messages through their account settings and by using the opt-out link contained in marketing emails or messages.
If the User gives his consent to receive notifications, he confirms that the Fund has the right to provide the User's e-mail addresses and phone numbers to third parties for the delivery of notifications and messages to the User.
In this case, the User understands, accepts and agrees that such letters and messages can be, but are not limited to: offers to conclude a contract with other Users, offers and messages of other informational and/or advertising nature and other communications. The User understands, accepts and agrees that such messages and/or their parts may be of an advertising nature and may contain advertisements and other information.
Some messages may be published on the site (for example, messages from other Users with requests for help or willingness to help). Advertisements published on the site are considered delivered to the User after their publication.
Some messages are related to partnership, cooperation, service and are necessary for the Foundation to provide services and/or to fulfill the User Agreement (non-marketing messages, for example, emails related to Users' accounts, notifications about _cc781905-5cde-3194-bb3b- 136bad5cf58d_security, etc.). The user agrees that such messages may be sent to him.
The Fund is not responsible for the use of the message sending form posted on the site by other Users and/or automated systems (robots).
The Fund is not responsible for the use of phone numbers and e-mail addresses posted by the User on the site pages by other Users and/or works.
7. Access to User information and its deletion
The user can exercise his rights to access, change or delete his personal information at any time.
To easily access, view or update personal data (where available) or to update subscription preferences, the User must log in to their account and visit the Settings section.
The user has the right to request the deletion of his account without giving reasons. If the User wishes to delete his account or data, or if the User chooses to withdraw his consent to this Privacy Policy, the User may send a request to the following email address: kazhanroad@gmail.com.
Please note that the Foundation will not be able to provide access to the services if the User withdraws his consent. Also, the Foundation will not be able to provide certain services if the User deletes his account/data.
To ensure the protection of Users, the Fund's support service operators can only respond to requests for personal information sent from the email addresses that Users use to send requests, and the Fund may need to verify the User's identity before implementing the request. The Foundation will try to fulfill the User's request as soon as possible, but it may take some time.
8. Data storage
The Foundation stores Users' information only as long as it is necessary for legitimate business purposes and in accordance with applicable legal requirements.
If a User closes their account, the Fund will retain certain data for analytical purposes, as well as to prevent fraud, enforce the User's agreement, or if there is an outstanding matter, claim or dispute that requires the Fund to retain the relevant information until it is resolved, or if the Foundation needs to retain it to demonstrate that the Foundation complies with applicable law (eg records of consent to the Privacy Policy).
Personal data is deleted or anonymized on a regular basis when it is no longer relevant for the purposes for which it was collected.
The retention of personal data provided to third parties as described in this Privacy Policy will be governed by the privacy policies of those third parties.
9. Final provisions
9.1. The user is responsible for the accuracy and reliability of any information and data provided by him.
9.2. The Fund's services are not intended for persons under eighteen (18) years of age. The Foundation will not knowingly collect personal information from children under the age of 18 if they use the site.
9.3. The administrator can make changes, delete or renew the rules of the Privacy Policy. The Foundation will notify you of any material changes to this Privacy Policy by posting and/or email.
9.4. If the User has any questions or complaints, he/she can contact the support service by e-mail:
_cc781905-5cde-3194 -bb3b-136bad5cf58d_ kazhanroad@gmail.com
_cc781905-5cde-3194 -bb3b-136bad5cf58d_ or by sending a letter to:
_cc781905-5cde-3194 -bb3b-136bad5cf58d_ Vilnius, J. Savickio g. 4-7, Lithuania