Introduction
We, the CO "Charitable Foundation "A.T.O." (https://ato.com.ua/), a legal entity registered in accordance with the laws of Ukraine, EDR: 1000651020000037220, registered address: 19, Knyazhyi Zaton St., Kyiv, 02095, Ukraine (hereinafter "A.T.O."), as well as its partners from time to time (collectively, the "Group"), each of which is a "Group member", "we", "us" in the context of this Privacy Policy is the "data controller" of your personal information and the "processor" of certain personal information, as described in more detail in this Privacy Policy, acknowledge our responsibility to collect, store, process, use and/or transfer personal data in accordance with the General Data Protection Regulation (the "GDPR"). Personal data will only be collected for legitimate and important purposes and all practical steps will be taken to ensure the accuracy of the personal data we hold. We will use your personal data that we may collect from time to time in accordance with this Privacy Policy.
We review this Privacy Policy regularly and may change it from time to time or add specific instructions, policies and conditions. If we make material changes to this Privacy Policy, we will notify you using the contact information you provided to us and, if required by law, we will provide you with an opportunity to opt out of those changes through a means that will be communicated to you at the same time.
BECAUSE "CHARITY FOUNDATION "A.T.O."
Non-profit and non-profit organization
USR: 1000651020000037220
EDRPOU: 45147873
email: mail@ato.com.ua
Date of adoption: 01.01.2022
Legal grounds
We need to collect certain types of information to comply with legal requirements related to our anti-fraud/money laundering/customer awareness obligations under EU law. If this information is not provided, we cannot agree to provide you with the service.
Your personal information may also be processed if necessary to comply with a reasonable request by a law enforcement or regulatory authority, department or agency, or to defend against a claim. We will not delete personal information if it is relevant to an investigation or dispute. It will be retained until the matter is fully resolved.
Data collection and storage
This Privacy Policy describes how we use your personal information when you use our website or when we receive charitable contributions and donations.
We will collect, store, and use your personal information to allow access to this website, to register our donors, and for the purposes set forth below.
What information we collect and how we use your data
1. Your contact information, including:
- your name, address, email address and phone number(s);
- your identification data, including date of birth, gender, country of residence.
We use this information to:
- register you as a benefactor;
- provide reports on the use of charitable contributions;
2. If you are not our benefactor, we collect:
- information about the device, namely: operating system, unique device identifiers, mobile network system;
- hardware and browser settings;
- the date and time of visits;
- the pages you visit, the length of your visit, your interaction with the page (such as scrolling, clicking and hovering), how you leave our website and the search engine terms you use;
- IP address.
We use this information to:
- identify problems with the website, including website security and user experience;
- to track how our website is used (including where it is accessed, the devices from which it is accessed, understanding the times of peak usage, and analyzing which features and information are most and least accessible), if visitors to the website come from the Internet (for example, from links on other websites or advertising banners), and the way our website is used by different groups of users;
- to conduct statistical analysis and research to better understand the distribution of site visitors, what attracts our benefactors to A.T.O. preks.
3 Information we collect from individuals representing organizations, such as our suppliers of humanitarian aid products, among others:
- names, positions and contact details of persons working in the organizations;
- other personal information about such persons;
- any personal information contained in correspondence with these persons.
We use this information to:
- build relationships with other organizations;
- communicate with these persons;
- receive services and goods to provide charitable assistance.
How long we keep your information
We will retain information about visitors to our website for a reasonable period of time to allow us to understand how people use our website and what technical problems they have. This period will usually not exceed 12 months.
We will retain information about individuals who are contact persons for our benefactors and partners for the duration of our relationship with the business concerned, and unless we are aware that the individual is no longer employed by the business. We may retain our correspondence with these individuals for longer if it is relevant to our operations with the business.
Information we share with employees and partners
There are certain circumstances under which we may share your personal data with our employees, contractors and other parties, as appropriate.
In addition, we may convert your personal information into anonymous or aggregated form, in which case it will cease to be personal information.
Your personal information may be shared with other third-party organizations if we are required to do so by law, by any legal or regulatory provisions or practices to which we are subject, or if we are required to do so by any governmental or regulatory authority.
Where your information will be stored
Your information may be transferred outside the European Economic Area (EEA).
Some of these countries do not have data protection legislation equivalent to that of the EEA.
However, to ensure that your personal information is properly protected in accordance with EU data protection law, the transfer of this information is generally governed by a contract that includes standard contractual clauses approved by the European Commission in accordance with Article 46(2)(c) of the General Data Protection Regulation (GDPR).
In some limited circumstances, we may also transfer your information outside of the EEA where permitted by the GDPR (in accordance with Article 49). This applies where it is necessary to fulfill the terms of a contract between us and you. This also applies if the transfer is necessary in connection with legal proceedings.
Use of cookies
If you access our information or services through A.T.O.'s website, you should be aware of the cookies we use. Cookies are data files that are stored in your browser. If you have accepted cookies through the tools displayed when you log in to the A.T.O. website, the website automatically sets and uses them on your browser when you access it.
Your rights
You have certain rights regarding your information. Under the GDPR, you have the following rights: The right to be informed, which is provided by this notice.
The availability of these rights and the ways in which you can exercise them are described in more detail below:
- You have the right to ask us if we are processing your information and, if so, you can request access to your personal information. This enables you to obtain a copy of your personal information that we hold and certain other information about you. We are not obliged to provide this information if it would adversely affect the rights and freedoms of others.
- You have the right to request correction of any incomplete or inaccurate personal information we hold about you.
- You have the right to ask us to delete personal information in certain circumstances, including if you have withdrawn your consent to its use, or we no longer need it in connection with your account or for other legitimate reasons. There are also certain exceptions when we may refuse a request for deletion, such as when personal information is needed to comply with legal requirements or in connection with a claim.
- You may ask us to suspend the processing of certain personal information about you, for example, if you want us to establish its accuracy or the reason for its processing.
- You have the right to request that certain of your personal information be transferred to another party/company. We use it on the basis of your consent or a separate agreement with you personally.
- If we process your personal information on the basis of legitimate interests (or those of a third party), you have the right to object. However, we may be entitled to continue to process your information based on our legitimate interests, or if it relates to legal claims. You also have the right to object if we process your personal information for direct marketing purposes.
- You can challenge any automated decision made about you if it has a legal or similarly significant impact and ask for a review.
- You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of the European Union in which you have your permanent residence, in which we are located, or where the alleged data protection violation has occurred.
Some of these rights apply only in certain circumstances. If you would like to exercise or discuss any of these rights, please contact us.
Information security
We are committed to keeping your personal information secure. We have physical, technical, and administrative measures in place to prevent unauthorized access or use of your information.
Links to third-party sites
Our website, newsletters, email newsletters and other communications may from time to time contain links to/from the websites of others, including our partner networks, advertisers and other groups of companies and/or social networks, which are offered to you and supported by your browser.
Personal data that you provide through these websites is not covered by this Privacy Policy, and we are not responsible for the processing of your personal data on such websites. If you follow a link to any of these websites, please note that these websites have their own privacy notices that will tell you how your information is collected and processed when you visit these websites. For more information about the purpose and scope of data collection and processing in connection with social media sharing features, please read the privacy notice of the organizations through which you choose to share.
Automated decision-making process
We may use some pieces of your data to customize our Services and the information we provide to you, and to meet your needs, such as your address country and transaction history. For example, if you frequently send funds in one particular currency to another, we may use this information to inform you of new product updates or features that may be useful to you. When we do this, we take all necessary steps to ensure that your privacy and security are protected, and we only use anonymous data whenever possible.
Children.
We do not knowingly collect information from children or anyone under the age of 18. If you are under 18, you may not provide us with any personal information or subscribe to the Services. If you believe that we may have received any personal information from/about a person under the age of 18, please contact the DPO.
