Privacy Policy

The Ukrainian Network for Adult Education and Innovation Development (hereinafter referred to as UNAEDI, “we”, “us”) respects your privacy and is committed to protecting your personal data.

This Policy explains what data may be collected when using the unaedi.mv.co.ua website, what it is used for, to whom it may be transferred, and what rights the user has.

Personal data is processed in accordance with the Law of Ukraine “On Personal Data Protection”, and in cases where applicable, in accordance with the EU General Data Protection Regulation (GDPR).

1. Who is responsible for data processing?

The owner of personal data is:

Ukrainian Network for Adult Education and Innovation Development (UNAEDI)

Address: 3/7 Dmytrivska St., office 25, Kyiv, 01054, Ukraine

Email: unaedi.office@gmail.com

Phone: +38 050 470 88 17

Responsible for organizing work with personal data: [position and name of the responsible person] Requests regarding data processing can be sent to the e-mail address specified above.

2. What data we may collect

Depending on how you use the site, we may receive:

first and last name;
email address;
phone number;
name of the organization and position;
information you provide in messages or applications;
data necessary to participate in projects, training programs, events or surveys;
photos and videos taken during events – more details in section 10;
information related to donations, [if online donations are enabled on the site] ;
technical data: IP address, browser and device type, operating system, date and time of visit, pages viewed, referral source;
information collected using cookies and similar technologies.

In the forms on the site, only those fields that are marked as required are required. If a required field is not filled in, we will not be able to process your request or application.

We ask that you do not send personal data that poses a particular risk to human rights and freedoms – in particular data concerning health, religious or political beliefs – through the website unless it is necessary for a specific project or service. Under EU law, such data are considered special categories of personal data and are processed with additional safeguards.

3. What we use the data for

Personal data may be used to:

respond to requests and messages;
maintain contact with partners, participants and stakeholders;
organize training, events, consultations and projects;
register participants and confirm their participation;
send organizational messages;
document the organization’s activities and report to donors;
process donations, [if enabled] ;
ensure stable and secure operation of the site;
prevent fraud, abuse and technical attacks;
comply with the requirements of legislation, contracts and donor programs;
improve the structure, content and usability of the site;
send information materials only with appropriate consent.

4. Legal basis for processing

We process personal data on one or more of the following grounds:

your voluntary consent;
the need to respond to your request;
conclusion or performance of a contract;
compliance with legal requirements;
UNAEDI’s legitimate interest, including ensuring the operation and security of the site and communication with partners and participants;
performing tasks within the framework of socially beneficial, educational or community projects.

You may withdraw your consent by contacting us by email. Withdrawal of consent does not affect the lawfulness of processing carried out prior to its withdrawal.

5. Cookies

The site uses cookies – small text files that are stored on the user’s device. They may be necessary for:

the correct operation of the site;
saving user settings;
ensuring security;
attendance analysis, [if analytical tools are connected – specify which ones] ;
Display embedded content, such as Google Maps or social media content.

Cookies necessary for the operation of the site are set without separate consent. Analytical and marketing cookies are set only after the user has given consent through a corresponding message on the site.

You can change or revoke your cookie choices [describe the method: “Cookie Settings” link in the footer or re-call the banner] . You can also restrict or disable cookies in your browser settings – this may affect the operation of certain site functions.

6. Third-party services

The site uses or displays materials from third-party services, including:

Google Maps;
social networks;
video and multimedia platforms;
email services;
hosting and technical services;
Payment systems: [name of payment provider, if accepting donations is activated] .

Such services may independently collect technical data and set cookies in accordance with their own privacy policies.

If donations are made through an external payment provider, the payment details are processed by that provider. UNAEDI does not store users’ full bank card details.

7. To whom may data be transferred?

We may transfer personal data:

providers of hosting, technical and information services;
email and communication services;
to project partners – only to the extent necessary for the organization of the relevant activity;
to donors and independent auditors – within the framework of project reporting, when required by the terms of the contract;
to payment providers if the user makes a donation;
to government agencies if required by law or a properly executed request.

We do not sell users’ personal data or transfer it to third parties for their own advertising.

Social media pages

UNAEDI has pages on social networks. When you interact with them, the operator of the respective platform independently collects data about you and uses it according to its own rules, in particular for statistics and displaying advertising materials. Regarding page statistics, UNAEDI and the platform may act as joint data controllers. We do not have access to the personal data of individual users collected by the platform and cannot change its settings. We recommend that you familiarize yourself with the privacy policy of the respective network.

8. Data transfer abroad

Some of UNAEDI’s technical suppliers or partners are located outside of Ukraine, in particular in the countries of the European Economic Area and in the United States of America.

Data transfers to EEA countries are based on the assumption that these countries provide an adequate level of protection for personal data. For transfers to other countries, we use legally required safeguards, such as standard contractual clauses of the service provider or its participation in recognized data protection mechanisms.

Please note: the organization’s official email works on the Gmail (Google) service, so correspondence containing personal data is processed on the servers of this provider.

9. Data retention period

We retain personal data for no longer than is necessary for the purpose for which it was collected. In particular:

user requests – for the time necessary to process them, and, as a rule, no longer than three years after the end of the communication;
data of participants in projects and events – during the implementation and reporting period for the relevant project, as well as during the period established by the terms of the agreement with the donor;
financial and contractual documents – within the time limits established by law;
contact details for newsletters – until consent is withdrawn;
photos and videos from events – in accordance with section 10;
technical logs and cookies – according to their purpose and established expiration date.

After the storage period expires, the data is deleted, depersonalized, or archived if required by law or the terms of the donor agreement.

10. Photos and videos from events

During exercises, exhibitions, forums, and other events, UNAEDI may take photos and videos to document activities, report to donors, and inform about the organization’s work on the website, social networks, and in public reports.

We only publish images in which a person can be identified with their consent. We obtain consent before or during the event and store it with the event materials.

Before filming, we inform participants that it is taking place and provide an opportunity to avoid being in the frame. Refusal to film does not limit participation in the event.

You can request to have your image removed from the organization’s website or social media pages at any time by writing to unaedi.office@gmail.com. We will remove it from the resources under our control within [30] days. Materials that have already been distributed by third parties or included in printed or reporting documents provided to donors may not always be technically possible to withdraw – we will notify you separately about this.

Photo and video materials of events are stored in the organization’s archive to document its activities. Materials that do not need to be published are deleted after the reporting on the relevant project is completed.

Additional rules apply to images of minors, as outlined in Section 14.

11. Protection of personal data

We apply organizational and technical measures to protect data from:

unauthorized access;
loss or accidental deletion;
illegal use;
modification, disclosure or copying.

Only those employees and involved specialists who need it to perform their duties have access to personal data.

At the same time, no method of transmitting or storing information on the Internet can guarantee absolute security.

12. Automated decision-making and profiling

We do not make decisions regarding users that are based solely on automated data processing and have legal or other significant consequences for them. We do not carry out profiling for advertising purposes.

13. User rights

You have the right:

know what data we process about you and for what purpose;
access your personal data;
request correction of inaccurate or outdated data;
demand the deletion of data if there are no legal grounds for its further storage;
withdraw consent to processing;
object to certain processing methods;
to request restriction of processing in cases provided for by law;
receive your data in a structured, commonly used electronic format and transmit it to another controller, if the processing is based on consent or a contract and by automated means (right to data portability under the GDPR);
file a complaint with a supervisory authority or go to court.

To exercise your rights, please write to us at unaedi.office@gmail.com. We may ask you to provide information necessary to confirm the applicant’s identity – this is necessary in order to prevent the data from being transferred to a third party.

We respond to requests within 30 days of receipt. If the request is complex or there are multiple requests, this period may be extended, and we will notify you of this along with the reason.

Where to file a complaint

In Ukraine – to the [Commissioner of the Verkhovna Rada of Ukraine for Human Rights or other supervisory body designated by applicable law] . More information about the procedure for protecting personal data can be found on the official website of this body.

If you are located in the European Union, you can also contact the data protection supervisory authority of your country of residence or stay.

14. Data of children and minors

The site is not intended for independent submissions by individuals under the age of [14] . If you are under this age, please submit your request through your parents or other legal representatives.

Certain educational areas of UNAEDI, in particular the interactive educational exhibition on mental health issues, are implemented in schools and communities, therefore the processing of data of minors is possible within the framework of project activities. In such cases, we:

we limit the amount of data to what is necessary to participate in the event;
we obtain the consent of parents or legal representatives, when required by law;
we agree on the procedure for participation with the educational institution or partner organization;
we do not publish photos in which a child can be identified without the written consent of the parents or legal representatives;
We do not use the data of minors for mailings and do not transfer them to third parties, except in cases necessary for the implementation of the event or as provided for by law.

Parents or legal guardians may contact us at any time to access, correct, or delete their child’s data, as well as to remove their images from our resources.

15. Links to other sites

The site may contain links to resources from partners, donors, social networks, and other external sites.

UNAEDI is not responsible for the privacy practices and content of third-party resources. We recommend that you review their privacy policies before providing your data to them.

16. Changes to the Policy

We may update this Policy from time to time. The current version will be published on this page with the date of the last update. We will notify you of any significant changes to the scope of data processing on the website or by email, if we have contact details for this purpose.

17. Contacts

For questions regarding the processing and protection of personal data, please contact: