Privacy Policy +

 Effective Date: June 27, 2025

This Privacy Policy (hereinafter – the “Policy”) governs the protection of personal data of visitors to the website https://boryviter.devbrainlab.com.ua (hereinafter – the “Website”), which is owned by the Non-Governmental Organization Boryviter Center of Excellence (legal entity identification code 45421981, registered address: 03151, Ukraine, Kyiv, Ushynskoho Street, Building 40), registered in accordance with the current legislation of Ukraine (hereinafter – the “Organization”).

1. GENERAL PROVISIONS

1.1. The following definitions apply in this Policy:

• Personal data database – a named set of structured personal data in electronic form and/or in the form of card files;
  
• Consent of the data subject – the voluntary will of a natural person (provided they are informed) to permit the processing of their personal data for a clearly stated purpose, expressed in a form that allows for a conclusion to be made regarding consent;
  
• Processing of personal data – any operation or set of operations, such as collection, registration, accumulation, storage, adaptation, modification, updating, use and dissemination (distribution, implementation, transfer), depersonalization, destruction of personal data, including via information (automated) systems;
  
• Personal data – information or a set of information about a natural person who is identified or can be specifically identified;
  
• Data subject – a natural person whose personal data is being processed;
  
• Third party – any person other than the data subject, owner, or processor of personal data;
  
• Cookies – small text files stored in the browser of a device (computer, mobile phone, etc.) after visiting the Website, which the Website transmits to the browser. More information on cookies is available at: https://allaboutcookies.org/.
  

All other terms in this Policy are used in the meanings defined by the current legislation of Ukraine, including ratified international legal instruments.

1.2. This Policy is intended to inform data subjects about the procedure for processing their personal data when visiting/using the Website, and to ensure the protection of their personal data during such processing.

1.3. This Policy and the Organization’s activities related to the collection, processing, storage, and other lawful actions involving personal data are governed by:

• The Constitution of Ukraine;
  
• The Law of Ukraine “On Personal Data Protection” of June 1, 2010, No. 2287-VI;
  
• Other applicable legal and regulatory acts of Ukraine on personal data protection;
  
• International legal instruments ratified by Ukraine.
  

For legal relations involving the processing of personal data of residents of foreign jurisdictions, the applicable national and international laws and legal instruments of those countries shall also apply.

1.4. The Organization is the owner of personal data processed in connection with the visit/use of Website options. The Organization may delegate the processing of personal data, in whole or in part, to third parties under a contract executed in accordance with the requirements of applicable law.

1.5. A natural person is considered a data subject under this Policy if they are a visitor to the Website, including when using any options available on the Website or providing the Organization with their name and email address.

1.6. The Organization guarantees that it:

• Adheres to proper practices and regulatory requirements for personal data protection;
  
• Protects the rights of data subjects;
  
• Prevents security breaches in the processing of personal data.
  

1.7. The purpose of processing personal data collected through the Website is to carry out the Organization’s statutory activities.

1.8. Publication of this Policy at the link specified in Clause 4.1 constitutes notice to data subjects of the owner, composition, and content of personal data collected through use of the Website, the rights of such subjects, the purposes of collecting personal data, and the third parties to whom such data may be transferred.

2. PROCESSING OF PERSONAL DATA

2.1. The Organization may collect and process the following information about the data subject:

• Information provided by the data subject – this includes information submitted through Website use, email subscription, charitable donations via Website tools, communication via Website features, etc.;
  
• Information collected by the Website or other systems:
  
  1. When the data subject visits the Website, third parties may collect certain information such as browser type/version and visited pages, IP address;
     
  2. The Website may install cookies on the data subject’s device;
     
  3. If the data subject communicates with Organization staff via the Website or other electronic means.
     
• Information collected by third parties – this includes data provided by the data subject to third parties (e.g., Facebook, Google, Twitter) via social media sharing tools, through navigation, or when interacting with embedded external platforms or content.
  

2.2. How the Organization processes the data subject’s personal data depends on how the Website is used. Some data may be provided directly by the data subject, while other data is collected automatically through the Website’s technologies.

2.3. Legal bases for processing: The Organization processes personal data when:

1. The data subject has consented to such processing;
   
2. The data is necessary to conclude or perform a transaction with the data subject or to take steps prior to a transaction;
   
3. The Organization has a legitimate interest that does not override the data subject’s rights or freedoms;
   
4. Other grounds as defined by current Ukrainian legislation.
   

In certain cases, the Organization may also be legally required to process personal data or do so in defense or exercise of legal claims.

2.4. Automated Processing Mechanisms: The Organization and third parties may use automated technologies to process data in some sections of the Website. Cookies are used to store preferences and track standard browser information (IP address, browser type/language, referring site, visited pages, clicked links) to improve Website functionality.

2.4.1. The Organization uses cookies to enhance Website functionality, analyze user behavior, and ensure ease of use.

2.4.1.1. Analytical cookies are used to collect information on how users interact with the Website (e.g., visited pages, time spent, clicked links) to analyze traffic and improve performance.

2.4.1.2. Third-party analytics services may be used for traffic and usage analysis. These include:

• Google Analytics: Collects data like browser type, visited pages, time on site, etc., to improve Website functionality. Data use is governed by Google Analytics’ Terms and Privacy Policy. Users can opt out using the Google Analytics Opt-out Browser Add-on.
  
• Hotjar: Helps visualize user interactions to enhance user experience and identify technical issues. Hotjar collects IP addresses, device and browser data, geographic location (country), and Website interaction data (clicks, scrolls). Learn more via the Hotjar Trust Portal.
  

2.4.2. Users may decline cookies except those essential for basic Website functionality. Disabling cookies may affect access to certain features.

2.4.2.1. Users can configure their browser to block or alert them about cookies.
2.4.2.2. While blocking cookies does not affect core Website functionality, it may limit analytics and performance optimization.

2.5. Personal data may be used by the Organization solely for the purposes defined in this Policy and applicable law, including but not limited to:

1. Responding to inquiries submitted via the Website;
   
2. Facilitating charitable donations through Website options;
   
3. Implementing the Organization’s statutory purposes under Ukrainian law;
   
4. Sending emails with promotional materials, updates on charitable projects, feedback requests, or Website-related notices.
   

2.6. The Organization may compile personal data collected during Website visits into a personal data database, in compliance with applicable Ukrainian law.

2.7. Personal data may only be disclosed with the data subject’s consent or in cases defined by this Policy or applicable law.

2.8. The Organization may partially publish user data in the “Reports” or “Receipts” sections of the Website.

2.9. Personal data shall be deleted or destroyed in the following cases:

• Upon expiration of the retention period set by law;
  
• Upon termination of the relationship between the data subject and the Organization, unless otherwise provided by law;
  
• In other cases stipulated by applicable data protection law.
  

The Organization does not process data relating to racial or ethnic origin, political, religious, or philosophical beliefs, party or trade union membership, criminal convictions, health, sex life, biometric or genetic data, except as required by law.

3. RIGHTS OF PERSONAL DATA SUBJECTS

3.1. While visiting/using the Website, data subjects have the right to:

• Receive additional information from the Organization regarding data processing and access conditions, or authorize others to do so, except where prohibited by law;
  
• Access their personal data free of charge;
  
• Receive a response to a request about data processing within the timeframes defined by Ukrainian law;
  
• Submit a reasoned objection to the processing of their data or request correction/deletion if data is unlawfully or inaccurately processed;
  
• Protect their data from unlawful processing or accidental loss, destruction, or damage, including through concealment, untimely provision, or defamation;
  
• Withdraw consent to data processing at any time;
  
• Exercise other rights granted under Ukrainian data protection legislation.
  

3.2. The data subject may also contact the Ukrainian Parliament Commissioner for Human Rights regarding issues related to data collection, use, storage, and processing via email at: hotline@ombudsman.gov.ua

If the data subject has questions about this Policy or has received any unsolicited electronic communications allegedly from the Organization, they may contact the Organization at: coe@boryviter.org.ua

4. AMENDMENTS TO THE PRIVACY POLICY

4.1. The Organization reserves the right to revise and amend the provisions of this Policy. The current version of the Policy is published on the Website at: https://boryviter.devbrainlab.com.ua