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Introduction
This Privacy Policy is enacted by the nonprofit organization “MACPAW DEVELOPMENT FUND”, registration number 39842414, a charitable organization incorporated under the laws of Ukraine (the “MDF” or “We”).
The MDF runs a donation-based fundraising platform in order to collect costs and then to purchase and supply the Ukrainian defenders with instruments of non-lethal help such as comms and reconnaissance tech; tactical medicine; protective gear etc. The mentioned platform is available at
https://macpaw.foundation (“Website”).
This policy (“Privacy Policy”) applies to you when:
- You are visiting the Website;
- You are having a journey through the Website;
- You make a donation; or
- You provided your personal details to us in another way for communication purposes (e.g. by subscribing to our newsletters, making a request of any type, etc.).
This Privacy Policy provides detail about how we process personal information and how we support your rights to your data. MDF is the controller of the personal data that is being processed via this Website. Use of the Website is further governed by the Website terms of use available here:
Terms of use
Please, take a note that processing of your payment data is carried out by the payment partner FONDY LTD. We do not process in any way your payment data, as you transfer such type of your data directly to FONDY LTD. Therefore we are neither processor, nor controller of your payment data. Before making a donation familiarize yourself with the privacy policy of the FONDY LTD, which can be accessed following the link
https://fondy.io/gb/privacy-policy/.
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Processing of data
How we process your personal information depends upon how you use and interact with the Website. Some information is provided directly by you, while other information is processed through automated technologies and our partners.
In principle, we process personal data only insofar as this is necessary to provide a functioning Website and facilitate in collecting donations. The processing of personal data takes place regularly only with consent. An exception applies to cases in which prior consent can not be obtained for reasons of fact and the processing of the data is permitted by law.
Legal Basis for Processing:
The processing of your data is either based on your consent or in case the processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract, or based on legitimate interest, cf. GDPR art. 6(1)(a)-(b), (f).
If the processing is based on your consent, you may at any time withdraw your consent by contacting us.
In some cases, we may have a legal obligation to process your personal information or to process your personal information in order to exercise, establish or defend legal claims.
Types of Data we may process:
We process the following types of information from you:
Types of Personal Data
Purpose
Our legal basis for this use of data and aim of use of data
Contact details (email address);
To contact you; to respond to the requests; to send marketing emails.
Contractual Necessity
(To respond to inbound requests from you);
Consent
Technical details (IP address, browser type and version, operating system, location information);
To improve our Website; To personalize your experience (the information will help us better respond to your individual needs).
Necessary for legitimate interests
to improve the website and make the use of the website more user-friendly.
Website use details (pages visited, how long you stayed, websites from which you came to us, websites that you visit from our site, time of visit of our Website).
To personalize your experience (the information will help us better respond to your individual needs); to improve our Website.
Necessary for legitimate interests
to improve the website and make the use of the website more user-friendly, to provide you with personalized recommendations.
Minors:
Our activities are not aimed at children under 13 years. We do not knowingly collect information from children under the age of 13. If you have not reached the age limit, do not use the functionality of the Website and do not provide us with your personal information. If you are a parent of a child below the age limit and you learn that your child has provided MDF with personal information, please contact us at
legal@macpaw.com and insist on exercising your rights of access, correction, cancellation and / or opposition. If you are resident in California and are under 18 years of age and wish to erase publicly available content, please contact us at
legal@macpaw.com.
Collected from Third Parties:
We may receive information about you from other sources, and combine this data with information we already have about you. This helps us to update, expand and analyze records, identify new donors, and provide information about the possibility to donate for the benefit of Ukrainian defenders that may be of interest to you.
Cookies:
We and our service providers also use cookies to store the website journey and preferences which enables us to process standard information your browser sends to certain websites you visit such as your IP address, browser type and language, and the site you came from as well as pages you visit and links you click on within the Website. Having technical information like this helps us to improve the Website.
For additional information on the automated information processing technologies we use, please review the cookie policy available here:
Cookie Policy.
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How do we use personal information
Any of the information we collect from you may be used for one or more of the following purposes of MDF:
- To personalize your experience (the information will help us better respond to your individual needs);
- To improve our Website;
- To establish a primary channel of communication with you;
- To find out from which page you have accessed the Website;
- To facilitate the processing of donation;
- To provide the information on your request.
Requests on the Website:
We use information processed from the Website to respond to visitors' requests. We do not sell, rent, lease, trade or share Website visitors personal information other than as outlined in this Privacy Policy. When you provide us with your personal information or otherwise choose to sign up to receive email communications from us, we will use that information to send those communications to you. Individuals may “opt-out” of receiving email communications through links available on emails received.
Data Retention:
Where we serve as the controller of the data, such as where we uses personal information for MDF’s own independent purpose of the activity, we will retain your information for the necessary period of time that it serves the purpose for which it was originally processed or subsequently authorised and in accordance with applicable law. We delete, block or anonymize the personal data of the data subject as soon as the purpose of the storage is fulfilled.
Online presence in social networks:
We maintain online presences in social networks in order to communicate there with customers and interested parties, among others, and to provide information about our activities in the struggle of Ukrainians for our freedom.
The users’ data is usually processed by the social networks concerned for market research and advertising purposes. In this way, usage profiles can be created based on the interests of the users. For this purpose, cookies and other identifiers are stored on the users’ computers. On the basis of these usage profiles, advertisements, for example, are then placed within the social networks but also on third-party websites.
As part of the operation of our online presences, it is possible that MDF can access information such as statistics on the use of our online presences, which are provided by the social networks. These statistics are aggregated and may include, in particular, demographic information and data on interaction with our online presences and the posts and content distributed via them. Please refer to the list below for details and links to the data of the social networks that MDF can access as operators of the online presences.
The legal basis for data processing is contractual (pre-contractual) necessity and your consent in order to stay in contact with and inform our customers and to carry out pre-contractual measures with future donors and interested parties.
For the legal basis of the data processing carried out by the social networks on their own responsibility, please refer to the data protection information of the respective social network. The links below also provide you with further information on the respective data processing and the options to object.
MDF would like to point out that data protection requests can be asserted most efficiently with the respective provider of the social network, as only these providers have access to the data and can take appropriate measures directly. Below is a list with information on the social networks on which we operate online presences:
- Facebook (USA and Canada: Facebook Inc., 1601 Willow Road, Menlo Park, California 94025, USA; all other countries: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland).
- Instagram (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland).
- Google/ YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland).
- Twitter (Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 Ireland).
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Your inquiries regarding data processing
We acknowledge that you may have the right to access your personal information and work to manage your inquiries as applicable. Your rights are as follows:
- You may request to access, correct, update or request deletion of your personal information based on information collected from accessing the Website.
- You may request additional information related to the purposes for which MDF processes your personal information, the categories of personal information we process, where we originally collected the information, who MDF shares it with, and how long MDF will retain it.
- You may object to the processing of your personal information, request that MDF restricts the processing of your personal information or request portability.
- You have the right to opt-out of email communications we send you at any time. You can do so by clicking the “unsubscribe” or “opt-out” link in the communicational emails we send you, including MDF’s newsletter. Where we have collected and processed your personal information with your consent, you can withdraw your consent at any time. However, withdrawing your consent will not affect the lawfulness of any processing MDF conducted prior to your withdrawal nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- Upon your request, and where it is technically feasible, we will provide you with a copy of your personal data or transmit it directly to another controller. You have the right to submit a complaint to a data protection authority about the collection and use of your personal information. To make a request please email MDF at legal@macpaw.com with “Personal Data Request” in the subject line, and provide us with full details in relation to your request, including your contact information and any other detail you feel is relevant. We will provide a response to an access request within 30 days of receiving such request with respect to the personal information we hold or if we cannot, we will notify you and provide you with the reason for the delay.
You may have other rights as may be provided by the applicable legislation.
Identity Verification Requirement:
MDF is required by law to verify that any request submitted was made by someone with the legal right to access the data. Therefore, prior to providing any information pursuant to a data subject access request, MDF may request that you provide MDF with additional information in order for MDF to verify your identity and legal authority.
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Legal disclosures
In certain situations, MDF may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. MDF reserves the right to disclose your personal information as required by law and when MDF believes in good faith that disclosure is necessary to protect MDF’s rights and/or comply with a judicial proceeding, court order, or legal process served on to MDF.
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Reporting issues
You have a right to report grievances related to privacy with your local data privacy supervisory authority. In Ukraine this is the Ukrainian Parliament Commissioner for Human Rights and it can be reached at
https://www.ombudsman.gov.ua which can also be contacted by email at
hotline@ombudsman.gov.ua. If you have questions about this Privacy Policy or if you receive any unwanted, unsolicited e-mail sent by MDF or purporting to be sent via MDF, please contact us directly via
legal@macpaw.com.
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Data breaches
All breaches will be reported to the relevant supervisory authority within 72 hours after becoming aware of such breaches, unless the data was anonymised or encrypted or if it has a particularly high risk.
Breaches of this Privacy Policy by staff, contractors, officers of MDF will be dealt with under the MDF’s grievance and disciplinary policy and may lead to a disciplinary sanction.
If MDF learns of a security system breach, we may attempt to notify you and provide information on protective steps, if available, through the email address that you have provided to us or by posting a notice on the Website. Depending on where you live, you may have a legal right to receive such notices in writing.
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Services providers with whom we share your personal data
We share information with third parties that help us operate the Website, improve the Website, market our Website. We share your personal information with the following types of service providers:
- cloud storage providers (Amazon) - to store the information, which is necessary for the proper work of the Website;
- data analytics providers (Facebook, Google) - to analyze and understand our audience, improve our service (including our user interface experiences and service performance); to personalize your experience (the information will help us better respond to your individual needs);
- marketing partners (in particular, social media networks, marketing agencies, email delivery services, Facebook, Google, CreateSend) - to contact you; to respond to the requests; to send marketing emails;
- to market our Website. Note that we contact you for marketing purposes only upon your prior consent.
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Data storage and transfers
We use data centers that store our website and databases, IT service providers that maintain our systems, and consulting companies. Therefore, for the date of acceptance of these Terms by you, the information submitted to MDF can be transferred to, processed, and stored in Ukraine, United Kingdom of Great Britain and Northern Ireland, the United States of America and the countries of the European Union.
Data stored and processed by MDF may sometimes be moved between these zones (in a secure manner). If you post or transfer any information to or through our Website, you are agreeing to such information, including Personal Data and user content, being hosted and accessed in Ukraine, United Kingdom of Great Britain and Northern Ireland, the United States of America and the countries of the European Union.
MDF may use services of other providers that are partly located in third countries (outside the European Union or the European Economic Area). Where this is the case and there is no adequacy decision for these countries, MDF undertakes to take appropriate precautions to ensure an adequate level of data protection for any data transfers. These include, among others, the standard contractual clauses in force at the time of transfer of data, or binding internal data protection regulations.
If a third country transfer is provided for and no adequacy decision or appropriate safeguards are in place, it is possible and there is a risk that authorities in the respective third country (e.g. intelligence services) may gain access to the transferred data in order to collect and analyze it, and that enforceability of your data subject rights cannot be guaranteed.
However, we will always take steps to ensure that any international transfer of personal data is carefully managed to protect your rights and interests. Data transfers to service providers and other third parties are be protected by contractual obligations and, where appropriate, by other guarantees, such as standard contractual terms issued by the European Commission or certification schemes.
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Changes to the privacy policy
We may need to update this Privacy Policy to keep pace with changes in our Website and activities, and laws applicable to us and you. We will, however, always maintain our commitment to respect your privacy. We will notify you of any material changes that impact your rights under this Privacy Policy by email (to your most recently provided email address) or post any other revisions to this Privacy Policy, along with their effective date, in an easy-to-find area of the Website, so we recommend that you periodically check back here to stay informed of any changes. Please note that your continued use of MDF or make a donation after any change means that you agree with, and consent to be bound by, the new Privacy Policy. If you disagree with any changes in this Privacy Policy and do not wish your information to be subject to it, you will need to stop using the Websites and/or make donations through the Website.
