Privacy policy

Last modified on: 10/20/2022

While operating https://childrenheroes.org/ (“Website”, or “Services”), CHILDREN OF HEROES OF UKRAINE FOUNDATION as the owner of the Website (“we”, “Foundation”, “Children of heroes”, “us”) is committed to being fully transparent as regards our privacy practices.

For this reason, we have developed this Privacy Policy to inform you (“you” or ”User”) how your personal data may be processed. We have tried to write this Privacy Policy in clear and plain language to better understand the complicated legal stuff.

In this document, you will find out:

  • what data we process, how and for what purposes we process your personal data;
  • when and how we can share your personal data with third parties;
  • how long we store your personal data;
  • our protection measures to keep your personal data secure;
  • your rights in respect of processing your personal data.

1. What is Personal Data?

Personal data (or data) is any information or set of information about you that enables the person who processes and stores such information to identify you as an individual. For example, it can be your name, identification number, location data, e-mail address, phone number, online IDs (such as IP-address), or any other information about you.
Personal data processing means any operation or set of operations with your personal data, in particular, collection, recording, accumulation, storage, adaptation, alteration, update, use, disclosure, dissemination, depersonalization, destruction of personal data.

The controller of the data collected on the Website is
CHILDREN OF HEROES OF UKRAINE FOUNDATION

2. What Data Do We Process?

Data connected to donations. When you make a donation to the Foundation via the Website through the connected payment provider (Fondy) or via other means through banks or other payment systems, we receive from the respective third-party providers and process the following information about you: your name, surname, e-mail address, telephone, the amount and date of payment, as well as an account or bank card number.

Data of potential partners and volunteers. On the Website, you can also find a form of potential volunteers. By filling out this form as well as by contacting us via other means, you may voluntarily provide us with the following personal data: last name, first name, patronymic; date and place of birth; passport data; RNOKPP; means of communication; email address; data on place of residence and actual stay; data on education; data on the place of work, position held; bank details, information about the convenient channel of communication and the type of assistance you can provide.

Data of those who wants to provide any in-kind help

On the Website you can find a form for those who want to provide direct non-financial assistance for evacuation, adoption, etc. By filling out this form, as well as contacting us by other means you can voluntarily provide us with the following personal data: last name, first name, patronymic, data on place of residence and actual stay, phone number, e-mail, information about your comfortable communication channel and the type of assistance you you can provide.
Data of a child who has lost one or both parents and data related to the receiving of assistance by the child. You can inform us about such a child through the contact center or by filling out the appropriate form on the Website. When you notify us of such a child, we will ask you to provide us with:

A) your data:

  • last name, first name, patronymic;
  • date and place of birth;
  • passport data;
  • RNOKPP;
  • means of communication;
  • email address;
  • data on place of residence and actual stay;
  • data on education;
  • data on the place of work, position held;
  • data on the marital status, the composition of the family, information about your children, parents or other relatives or on the family ties with the child;
  • bank details, including the bank account statement;
  • photographs or other image recordings;
  • video materials;
  • information on personal story of the family.

B) data of the child:

  • last name, first name, patronymic;
  • date and place of birth;
  • Birth Certificate;
  • data on place of residence and actual stay;
  • other contact details;
  • data on education,
  • who is lost by the child and type of relationship, last name, first name, patronymic of the lost family member, date of birth, death certificate;
  • photographs or other image recordings;
  • video materials with participation of the child;
  • information on personal story of the child.

C) data of the recipient of funds (if different from your data): last name, first name, patronymic, passport details,RNOKPP, communication numbers, e-mail address, and bank details, including the bank account statement.

Data connected to your requests (not indicated above). You can send a request with suggestions, recommendations, complaints via e-mail specified on our website, or via special form, or via phone number. We collect and process the data you voluntarily provide us with, including your name, surname, e-mail address, phone number, the name of the company you represent, and your position. Besides, you can specify other information about you directly in the request.

Automatic processing of personal data. You can read more about it in Section 4 “Cookies” of the Privacy Policy.

Financial information. The Foundation does not independently collect and process the data required for making a donation since all payments are made through the payment systems and other resources of banks and financial institutions. The payment services we use collects and provides us with information about the details of your payment. This does not include the data of your payment instruments (like credit card number or CVV).

3. Basis and Purpose of Processing Your Data

a. Lawful Basis

As for the data related to donations, we collect and process it in order to fulfill the contractual relations proposed in the Public offer on providing a charitable donation. In particular, this information is necessary in order to maintain a list of benefactors and to be able to contact them about the intended use of funds by us, etc.
We process the data you provide through the forms at the Website (data of potential partners and volunteers, data on those who wants to provide any in-kind help), solely on the basis of your consent, which you express before sending this data (Annex 1 hereto).

We process the data of a child who has lost one or both parents and the data related to the child, on the following grounds:

– your data based on your consent (Annex 2 hereto);

– data of the child and his/her lost family member – with the consent of the child (his/her relative, guardian, custodian) (Annex 2 hereto) and, where applicable, to protect the vital interests of the personal data subject;

– your data and data of the child as to the photo and video materials with participation of the child and personal story of the family and the child – on the basis of your consent (in a separate form);

– data of the recipient of funds (including your bank details and bank account statements) – on the basis of making and executing transactions in favor of the child (providing charitable assistance according to the types established in the Foundation’s Charter).

When you contact us with any request to our e-mail, or via special form on our Website, or by phone, you voluntarily provide us with your personal data. We may collect and process this data in order to provide us with a comprehensive response to your request (to fulfill the agreement with you, in accordance with the Terms of Use).
We may also process your personal data under the legitimate interests of the Foundation (for example, to protect the Foundation against claims and lawsuits, appeals to government agencies, or other persons).

b. Processing Purposes

We collect and process the personal data described in the Section above in order to provide you with all necessary Services within our Website.

• Data related to donations – in order to comply with the provisions of the Public Offer for the provision of charitable donations, in particular, to fulfill their reporting obligations, the intended use of the donation, to inform about such use, etc.

• Data of potential partners, volunteers and those who want to provide any in-kind help – in order to be able to contact them to discuss possible forms and means of cooperation on favorable terms by any convenient means. We also process you data in order to further support in charitable activities in the public interest and interests of the special categories of persons, to provide charity and social support to the children and their families, in particular those children who lost their parents during the Russia Federation military aggression against Ukraine and to ensure implementation of other relations requiring the personal data processing according to the law, the Articles of Association and other local acts of the Foundation.

• Data of a child and data related to him/her – in order to receive information about such a child and to help the child within the Statutory objectives of the Foundation and the information provided in the request for help, as well as to assist in promoting the charitable activities of the Foundation on the territory of Ukraine and abroad, and to engage investors, partners, volunteers, contractors, charitable and other non-profit organizations to its charitable activities.

• Data connected with your requests – to provide you with the comprehensive answers to your requests.

1. Cookies

Cookies are small pieces of the code that remain on your device after you visit any website. These pieces enable us to provide you with information tailored to your needs the next time you use the Website or perform other technical tasks.

Your consent to the Foundation’s use of Cookies will improve your experience of using the Services and make our Services more efficient, faster and safer for you.

Type Description and purpose

Necessary and functional cookies These include technical cookies that are strongly required for the error-free operation of the Website and allow protecting the Website from attacks, providing support to Users, etc. We use the functional cookies to remember your choice you make while using the Website. For example, they can be: 1) Cookies that allow to store information about the preferable language of the User, 2) Cookies that allow distinguishing two different sessions of the same User, etc. Without them, we will not be able to provide you the information through the Website, so such use does not require your consent.

In any case, you can block, delete or disable the storage of cookies on your device. The following links might be useful for you to choose the best option in your browser:

For the users of Chrome

For the users of Internet Explorer

For the users of Safari web and iOS.

For the users of Android

For the users of Firefox

You may opt out of Google Analytics. You can use this tool to do this in the context of all the websites you use.

5. How Long Do We Store Your Data?

We will only retain your data for as long as necessary to achieve the purposes for which we collected it, including to meet any legal requirements.

In particular, we store data for reporting on benefactors’ donations.

To determine the appropriate retention period of your data, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your data and whether we can achieve these goals by other means.

Details on the duration of processing:

In any case, you can block, delete or disable the storage of cookies on your device. The following links might be useful for you to choose the best option in your browser:

For the users of Chrome

For the users of Internet Explorer

For the users of Safari web and iOS.

For the users of Android

For the users of Firefox

You may opt out of Google Analytics. You can use this tool to do this in the context of all the websites you use.

5. How Long Do We Store Your Data?

We will only retain your data for as long as necessary to achieve the purposes for which we collected it, including to meet any legal requirements.

In particular, we store data for reporting on benefactors’ donations.

To determine the appropriate retention period of your data, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your data and whether we can achieve these goals by other means.

Details on the duration of processing:

Data type Storage duration and purposes

Data related to donations During 3 years after making a donation to fulfill our reporting responsibilities

Data of During our communication and 1 year after that, in order to be able to offer cooperation when we have a relevant project.

Data of a child who has lost one or both parents During our help

Data related to other your requests During our communication when we provide a response to the request and 3 months thereafter

6. Third Parties Accessing Your Personal Data

We do not sell or transfer your personal data to third parties. However, to provide high-quality services, support the various functions of our Website, and ensure its overall functioning, we hire people, enter into agreements with independent contractors, and cooperate with other services providers, companies, and organizations and volunteers. For those reasons, some of your personal data can be passed to the stated persons.

In all cases, we adhere to all the requirements of applicable data protection laws and do our best to ensure the data processing security at all stages.
To fulfill the processing purposes, we may share your data with the following persons:

A. Our employees and contractors

We may share your data with our employees, verified contractors, partners or volunteers. We conclude non-disclosure agreements with them to ensure the protection of your personal data.

B.Third parties

Please note that we may transfer your personal data to charity organization, foundations and other non-profitable organization of the same nature both in Ukraine and abroad, in particular, in EU countries and the USA.

The Foundation engages a number of trusted third-party service providers in order to support different features of our Website and ensure its overall functioning. We also use third-party services to organize our work in the most efficient way and provide our clients with the best customer service.

Therefore, we may provide limited access to your personal data to third-party service providers such as cloud storage services, online business intelligence services, and payment services providers (payment systems). The access to data is provided to such persons only within the relevant agreements.

C. Government authorities

We may disclose your personal data if required by law. In other words, we may disclose information required for an investigation or legal proceedings at the official request of government agencies. If we are forced to disclose your information, we will immediately inform you and provide a copy of the request unless prohibited by law.

7. Your Rights as to Your Personal Data

You have the right to:

  1. Know the sources of collection, the location of your personal data, the processing purpose, and the location of the controller or the processor of personal data.
  2. Receive information about the conditions of providing access to your personal data, including information about third parties to whom your personal data is transferred.
  3. Access to your personal data and receive the answer as to whether your personal data is processed, as well as receive the content of such personal data.
  4. Receive a response about whether your personal data is being processed, as well as receive the full copy of such data.We shall provide the answer to your request no later than 30 calendar days from the date of receiving the request, except otherwise provided by law.
  5. Submit to us a reasoned objection to your personal data processing.
    If the review of such a request reveals that the Foundation cannot demonstrate a valid legal basis for data processing that overrides the interests, rights, and freedoms of the User, we will stop processing it and inform you about it.
    If the request is not satisfied, we will provide you with a reasoned response to the refusal.
  6. Submit a reasoned demand to change or destroy your personal data if it is processed illegally or is unreliable, as well as in other cases provided by law.
  7. Protect your personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision of them, as well as to protect against the provision of information that is inaccurate or defaming honor, dignity, and business reputation.
  8. Complain about your personal data processing to the Commissioner for Human Rights of the Verkhovna Rada of Ukraine, other regulatory authorities, or the court.
  9. Apply legal remedies in case of violation of the legislation on personal data protection.
  10. Introduce reservations about limiting the right to process your personal data when giving consent.
  11. Withdraw consent to your personal data processing.
  12. Know the mechanism of automatic processing of personal data.
  13. To protect against an automated solution-making that has legal effects for you.

You may also have other rights established by the data protection legislation applied to the actions with your personal data (including the rights, stipulated by the Articles 12-22 of the GDPR). We will make all efforts for you to exercise such rights.

8. Security of Data

We take appropriate security measures to protect your personal data from accidental loss or destruction, illegal processing or unauthorized access.

We provide access to personal data to a limited number of individuals and only when necessary. For example, we provide access when necessary to provide services, comply with the terms of the Privacy Policy, or protect the legitimate interests of the Foundation, Users, or third parties, etc.

We also use Hypertext Transfer Protocol Secure (HTTPS) to ensure the safe use of the Website.
Besides, we train our staff in secure data processing. In particular, we require our employees and contractors to use strong passwords and enable multi-factor authentication.

We do everything we can to protect your data, but no internet transmission method is 100% secure. If your rights under the Privacy Policy are violated, or if there is a high risk that they are to be violated, we will notify you and the regulatory authorities without delay. We will also do our best to minimize such risks.

9. Where Do We Store Your Data?

All data is stored in databases and file repositories hosted by the hosting service located in Germany.

10.Privacy Policy Changes

We may change or update this Privacy Policy from time to time. If we choose to do so, we will notify you of any changes by e-mail or by posting an appropriate message on the Website and will ask for your consent (if required by law). At the beginning of the Privacy Policy, we will also mark the date of the “Recent Changes” and provide you with the details regarding such changes.

11. Contact Information

If you have any questions about the Privacy Policy or your data being processed by us, you are welcome to contact us:

CHILDREN OF HEROES OF UKRAINE FOUNDATION
Business address: 514 N Washington St, Denver Co 80203
Registration address: 251Little Falls Drive, Wilmington Delaware 19808
EIN 88-2709953
Email: contact@childrenheroes.org

Annex 1

CONSENT NOTICE
on the personal data processing
for potential partners and volunteers.
and those who wants to provide any in-kind help

By filling out the appropriate form on the Website https://childrenheroes.org or by providing otherwise the data specified below, I voluntarily provide to the following entity:
CHILDREN OF HEROES OF UKRAINE FOUNDATION (Business address: 514 N Washington St, Denver Co 80203, EIN 88-2709953, e-mail: contact@childrenofheroes.org, tel.: +38 (044) 247-57-88), hereinafter referred to as “Personal Data Controller”, my consent to the automated and unauthorized processing (including collection, accumulation, storage and use) of my personal data and other data, which includes:

last name, first name, patronymic;

  • passport data;
  • RNOKPP;
  • means of communication;
  • e-mail address;
  • data on place of residence and actual stay;
  • data on education;
  • data on the place of work, position held;
  • bank details (where our cooperation involves financial relations);
  • information about the channel of communication you are comfortable with and the type of assistance you can provide.

These categories of personal data have been voluntarily provided by me to the Personal Data Controller so that they can contact me to discuss possible forms of cooperation on favorable terms in a convenient way, as well as to further assist charitable activities in the public interest and interest of certain categories of persons, to provide charity and social support to children and their families, in particular children lost their parents during the military aggression of the Russian Federation against Ukraine, and to ensure the implementation of other relations that require personal data processing in accordance with the law, Articles of Association and other local acts of the Personal Data Controller.

By filling out the appropriate form on the Website https://childrenheroes.org, I also consent to the transfer (dissemination) of my personal data exclusively for the above purpose, in particular to other Ukrainian and foreign volunteers and partners, contractors of the Personal Data Controller, charities, foundations and other similar non-profit organizations in Ukraine and abroad, in particular, in the EU and the USA.

I do not require notification of the transfer (dissemination) of my personal data to processors and other third parties, if such transfer (dissemination) is in my interests in order to implement the above legal relationship.

I have been informed that the collected data will be processed in accordance with the Terms of Use and the Privacy Policy. By agreeing to this, I confirm my knowledge of these documents.

I confirm that I have been notified in writing of the purposes of the personal data processing and the persons to whom my personal data is transferred, as well as of my rights under data protection, set out in the Privacy Policy.

This consent notice is valid for an indefinite period.