Privacy Policy

This Privacy Policy and Website Terms of Use (the “Policy”) describe how NGO "Luhansk Regional Association of Veterans and Defenders of Ukraine" (EDRPOU 46387287) (“we”, “us”, “the Association”) processes personal data when you use the website https://loavzu.org.ua (the “Website”), including online forms and related services.

The Policy is prepared with regard to the Constitution of Ukraine, the Law of Ukraine “On Personal Data Protection”, other applicable Ukrainian laws, and, where relevant, principles consistent with the EU General Data Protection Regulation (GDPR).

This document is an informational legal notice for website users. It does not replace specialised legal advice for individual cases.

1. Data controller

The personal data controller is:

NGO "Luhansk Regional Association of Veterans and Defenders of Ukraine"
EDRPOU code: 46387287
Registered address: 65088, Odesa region, Odesa, Lustdorfska Road, 90G, apt. 177
Email: alex.bahtin2022@gmail.com
Phone: +38 (095) 890-20-11

For questions about personal data processing, please contact us using the details above.

2. Scope

This Policy applies to:

visitors and users of the Website;
persons who submit contact, help, membership, partnership or newsletter forms;
persons who communicate with us by email, phone or social media linked from the Website.

The Policy does not cover third-party websites that may be linked from our pages. Their privacy practices are governed by their own policies.

3. Categories of personal data we process

Depending on how you interact with us, we may process:

3.1. Data you provide voluntarily

full name or first name;
phone number and/or email address;
locality / region of residence (if provided);
organisation name and contact person (for partnership requests);
subject / direction of the request and the content of your message;
information about how you wish to join or cooperate;
newsletter email address;
record of consent to personal data processing (where a checkbox is used).

3.2. Technical data collected automatically

IP address;
browser / user-agent information;
date and time of form submission;
basic server logs needed for security and troubleshooting.

3.3. Accessibility preferences stored on your device

If you use the accessibility panel, selected settings (font size, contrast, link underlining, reduced motion) may be stored in your browser’s local storage (loavzu_a11y). These settings remain on your device and are not sent to our servers as a personal profile.

3.4. Data we do not request through open Website forms

Please do not submit via open Website forms: passport or ID details, military ID numbers, medical records, bank card data, passwords, or other specially protected / highly sensitive information. If documents are later required, we will explain a more secure channel.

4. Purposes and legal bases of processing

We process personal data for the following purposes:

Handling enquiries and providing support — to receive, review and respond to your requests for help, information or cooperation (consent and/or steps prior to entering into an agreement / legitimate activity of an NGO).
Membership and volunteering contacts — to consider applications to join or assist the Association (consent).
Partnership communications — to evaluate and discuss cooperation proposals (consent and/or legitimate interest in organisational development).
News and updates — to send newsletters if you subscribe (consent; you may unsubscribe at any time by contacting us).
Website security and abuse prevention — including anti-spam measures, CSRF protection and review of technical logs (legitimate interest in protecting the Website and users).
Statutory NGO activities and accountability — where processing is necessary to perform the Association’s lawful non-profit activities and to keep records required by law.
Accessibility — to remember your interface preferences on your device (your action / consent via the accessibility controls).

We do not use your data for automated decision-making that produces legal effects concerning you, and we do not sell personal data.

5. Cookies and similar technologies

The Website may use:

strictly necessary session technologies (for example, session cookies) required for language preference, security tokens (CSRF), flash messages and basic Website operation;
local storage for accessibility settings, as described above.

We do not currently operate third-party advertising trackers on the Website. If analytics or other optional cookies are introduced later, we will update this Policy and, where required, request additional consent.

6. Recipients and transfers

Access to personal data is limited to authorised persons of the Association who need it to perform their duties. Data from forms may also be delivered to the Association’s designated notification email.

We may disclose data where required by Ukrainian law, a court order, or a competent authority, or where necessary to protect the rights, safety or property of the Association, users or third parties.

If hosting, email or IT service providers process data on our behalf, they act under instructions and applicable confidentiality / data-protection obligations. Where data are transferred outside Ukraine, we take measures required by Ukrainian law.

7. Retention periods

We retain personal data no longer than necessary for the purposes stated in this Policy, in particular:

form submissions — generally for the period needed to handle the request and related follow-up, and thereafter for a reasonable archive period required for organisational accountability (typically up to 3 years, unless a longer period is required by law or an ongoing matter);
newsletter email — until you withdraw consent or the subscription is otherwise terminated;
technical logs — for a limited period needed for security and diagnostics;
accessibility settings — until you clear browser storage or reset settings.

After the retention period, data are deleted or anonymised, except where continued storage is required by law.

8. Your rights

Subject to Ukrainian law, you have the right to:

know whether we process your personal data and receive information about such processing;
access your personal data;
request rectification of inaccurate or incomplete data;
withdraw consent to processing (where processing is based on consent), without affecting the lawfulness of processing before withdrawal;
request erasure or restriction of processing where provided by law;
object to processing on grounds relating to your particular situation, where applicable;
lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights (Ombudsman) or another competent authority, and/or seek judicial protection.

To exercise your rights, email us at alex.bahtin2022@gmail.com with a clear request. We may ask you to confirm your identity to prevent unauthorised disclosure.

9. Security

We apply organisational and technical measures appropriate to the risks, including access limitation, HTTPS where configured on hosting, CSRF protection for forms, anti-spam honeypot fields, and restricted administrative access. No method of transmission or storage is completely secure; please avoid sending highly sensitive documents through open forms.

10. Children’s data

The Website is not intended for independent use by children under 16. If you believe we have received a child’s data without proper grounds, please contact us and we will take appropriate steps.

11. Changes to this Policy

We may update this Policy from time to time. The updated version is published on this page with a revised “Last updated” date. Continued use of the Website after publication means you have read the updated Policy. Material changes affecting consent-based processing will be communicated where required.

Website Terms of Use

12. Acceptance of the Terms

By accessing or using the Website, you agree to these Terms of Use and the Privacy Policy. If you do not agree, please do not use the Website or submit forms.

13. Informational purpose

Content on the Website (news, projects, documents, contact details, bank details for voluntary contributions, etc.) is published for informational purposes related to the Association’s statutory activities. Unless expressly stated otherwise, Website materials do not constitute a public offer, legal opinion, medical advice or a binding commitment to provide a specific service.

14. Acceptable use

You agree not to:

use the Website unlawfully or in a way that harms the Association, other users or third parties;
attempt unauthorised access to the Website, admin panel, databases or other users’ data;
interfere with the Website’s operation (including malware, scraping that overloads the server, or circumvention of security measures);
submit knowingly false, insulting, discriminatory or otherwise unlawful content via forms;
use contact details published on the Website for spam or unsolicited commercial communications.

15. Forms and user content

You are responsible for the accuracy of information you submit. By sending a form, you confirm that you are entitled to provide the data and that the message does not infringe third-party rights. We may refuse to process a request that is incomplete, abusive or unrelated to the Association’s activities.

16. Intellectual property

Website design, texts, logos, emblems, photographs and other materials are protected by intellectual property laws and belong to the Association or respective rights holders. Copying, distribution or commercial use without prior written permission is prohibited, except for brief quotations with a mandatory link to the source for non-commercial informational purposes.

17. Third-party services and links

The Website may contain links to social networks, maps or other external resources. We are not responsible for the content, availability or privacy practices of third-party services.

18. Voluntary contributions

Bank details published for support are intended for voluntary irrevocable contributions to the Association’s statutory activities. Please use the stated payment purpose. The Association is not responsible for errors made by the payer when transferring funds.

19. Limitation of liability

To the fullest extent permitted by Ukrainian law, the Association is not liable for temporary unavailability of the Website, technical interruptions, actions of third parties, or decisions you make solely based on general information published on the Website. Nothing in these Terms limits liability that cannot be limited under mandatory law.

20. Governing law and disputes

These Terms and the Policy are governed by the law of Ukraine. Disputes shall be resolved through negotiations and, if necessary, by the competent courts of Ukraine.

21. Contact

For questions about the Policy, Terms, or personal data:

NGO "Luhansk Regional Association of Veterans and Defenders of Ukraine"
Email: alex.bahtin2022@gmail.com
Phone: +38 (095) 890-20-11
Address: 65088, Odesa region, Odesa, Lustdorfska Road, 90G, apt. 177