Privacy Policy of the Website of the Union of Entrepreneurs of Poles in Ukraine
as of January 26, 20261. General Provisions
This Privacy Policy defines the procedure for processing personal data that the NGO “Union of Entrepreneurs of Poles in Ukraine” (hereinafter referred to as the Site, we, us, or our) may obtain during your visit to the website https://www.zppu.ua (hereinafter referred to as the Site) or during your interaction with us through the provided means of communication. The primary form for collecting personal data on the Site is the feedback form on the Contacts page, where you may voluntarily provide your name, email address, phone number, or other contact details for communication.
In this Policy, the terms “you” and “your” refer to any individual who uses the Site or contacts us via the feedback form.
Please carefully read this Privacy Policy. By using the Site and submitting information via the feedback form, you agree to the processing of your personal data as described in this Policy. If you do not agree with the provisions of this Policy, please refrain from using the Site and from submitting personal data to us.
2. Changes to This Privacy Policy
We may periodically update this Privacy Policy, in particular to reflect changes in our data processing practices or for other operational, legal, or regulatory reasons. The current version of the Policy will be published on the Site with the date of the last update indicated. We will also take other actions if required by applicable law.
3. How We Collect and Use Your Personal Data
To ensure the operation of the Site, we may collect your personal data from various sources. Over the past 12 months, the only way we have obtained your personal data is through the information you voluntarily provide in the feedback form on the Contacts page. The amount of data we receive depends on what information you choose to provide (name, email address, phone number, or other contact details).
Except as specifically stated, we may use the information you provide to communicate with you, respond to your appeals, ensure the functioning of the Site, comply with legal obligations, enforce terms of use (if applicable), and protect the Site, our rights, and the rights of other users.
4. What Personal Information We Collect
The scope of personal data we may collect depends on how you interact with our Site. By personal data we mean any information that identifies you or may be associated with you. Below are the categories and types of information we may collect.
5. Information We Receive Directly from You
The only function of the Site that involves the provision of personal data is the feedback form on the Contacts page. The information you may voluntarily provide includes:
• Your first and last name.
• Email address.
• Phone number.
• Any additional information you choose to include in the message.
This data is required solely so that we can respond to your appeal. Providing information via the feedback form is voluntary. If you choose not to provide certain data, this may limit our ability to respond to you or contact you.
6. How We Use Your Personal Data
The sole purpose for which we process personal data on this Site is to ensure the possibility of feedback communication with you. The information you provide may be used for:
• Responding to your appeal. We use your contact details (name, phone number, email address, and message content) to contact you and provide our response.
• Communication support. We may use your data for further clarification of your request or to provide necessary information if required.
• Security. We may process data to detect and prevent attempts of unauthorized access or other potentially harmful actions that may threaten the operation of the Site.
• Compliance with legal obligations. Where necessary, we may store or transfer information in accordance with the requirements of the laws of Ukraine.
• Statistical analysis and improvement of the Website. We collect anonymized traffic data to understand user needs and optimize the Website's content.
We do not use the data you provide for marketing, advertising, user profiling, or any other commercial purposes.
7. How We Share Personal Data
In most cases, we do not share your personal data with third parties. Sharing may occur only in exceptional and justified cases:
• With technical service providers that ensure the operation of the Site (for example, hosting providers and Google for the collection of anonymous analytics). Such entities receive access only to the minimum amount of data and solely for technical purposes.
• In cases required by law, for example, upon request of state authorities within their powers.
• With your explicit consent, for instance, if you ask us to transfer certain information to other organizations or individuals.
We do not transfer, sell, or distribute your personal data for advertising, marketing, or any commercial activity.
We also do not engage in the “sale” or “sharing” of personal data as defined under applicable personal data protection legislation.
The data you submit may be temporarily processed by our email service provider (Ukr.net) as a technical email service provider.
Such access is automatic and serves solely for the technical purpose of message delivery, without the possibility of using this data for any other purposes.
8. Categories of Personal Data
Throughout the operation of the Site, we may have processed only minimal categories of personal data related to the feedback form, in particular:
• Identification data: name, email address, phone number, or other contact details voluntarily provided by you.
• Communication data: the content of your message submitted via the feedback form.
• Analytical and technical data: We use Google Analytics 4 tools to collect statistical information about user interaction with the Website. The settings are configured so that data collection occurs in an anonymous mode without the use of cookies (cookieless mode). Visitors' IP addresses are anonymized automatically, making it impossible to identify a specific individual. We collect information about device types, popular pages, and geographic regions (at the city/country level) without linking it to personal profiles.
We do not collect or process commercial information, order data, purchase history, or any other records of commercial activity, as the Site does not provide paid or commercial services.
9. Third-Party Websites and Links
Our Site may contain links to other websites or online platforms owned or operated by third parties. If you follow such links to external resources, please note that they are not related to us and are not controlled by us. We recommend that you review their privacy policies, terms of use, and security rules before providing any information or using their services.
We are not responsible for the privacy practices, security, content, accuracy, or completeness of the information posted on third-party websites. Information that you may provide on public or semi-public platforms, including social media platforms, may be available to other users of those platforms and may be used without restriction by both third parties and the platforms themselves.
The presence of links to third-party resources on our Site does not automatically imply endorsement of their content, owners, or operators unless expressly stated otherwise on the Site.
10. Children’s Data
The Site is not intended for use by children, and we do not knowingly collect any personal data of children. If you are a parent, guardian, or legal representative of a child who has provided us with personal data via the feedback form, you may contact us using the details below to request deletion of such information.
As of the effective date of this Privacy Policy, we do not have knowledge of and do not engage in any activity involving the “sharing” or “sale” of personal data of individuals under the age of 16 as defined by applicable law.
Our Site is not created for children’s use, and in case of any functional changes all necessary legal measures will be applied accordingly.
11. Security and Storage of Your Data
We apply technical and organizational measures to protect the personal data you provide to us. However, it should be understood that no security measures can guarantee utter protection. We cannot ensure “perfect security” and cannot guarantee complete protection of information during its transmission on the internet. For this reason, we recommend refraining from sending confidential or sensitive data via unsecured communication channels.
The retention period of personal data depends on the purpose for which the data was provided, in particular:
• information obtained via the feedback form may be deleted or anonymized after communication is completed and there is no longer a need to retain the information;
• in cases where the law requires longer storage, we comply with the respective legal requirements.
We do not create user accounts and do not link your data to long-term profiles, therefore we store only a minimal amount of information.
12. Your Rights and Choices
Depending on the legislation of your country of residence, you may have certain rights regarding your personal data. These rights may apply only under certain conditions, and in some cases we may refuse a request if permitted by law. Since our Site processes a minimal amount of personal data and does not create user accounts, the application of some of these rights may be limited.
You have the following rights:
• Right of access. You may request information about the personal data we store and the purpose it is processed for.
• Right to deletion. You may request the deletion of your personal data stored by us.
• Right to rectification. You may request the correction of inaccurate or incomplete personal data.
• Right to data portability. In cases provided for by law, you may receive a copy of your data or request that it be transferred to a third party.
• Right to restrict processing. You may request temporary restriction of the processing of your data in certain cases.
• Right to withdraw consent. If we process your data on the basis of consent, you may withdraw it at any time.
• Right to appeal. If we deny your request regarding the exercise of your rights, you have the right to file an appeal by submitting it again.
Our Site does not sell or transfer personal data to third parties for advertising, analytical, or marketing purposes, therefore rights related to “opt-out of sale” or “targeted advertising” do not apply.
We also do not process sensitive personal data, therefore the right to limit the use of sensitive information is also not applicable.
To exercise any of your rights, you may contact us using the contact details provided in the Contacts section. Before fulfilling your request, we may ask you to verify your identity to protect your data from unauthorized access.
We do not discriminate against users who exercise their rights provided by law.
13. Complaints
If you have any complaints or concerns regarding how we process your personal data, you may contact us using the contact details provided below. We will review your request and provide a response within the reasonable time.
If you are not satisfied with our response or believe that your data protection rights have been violated, you have the right to file a complaint with the relevant data protection authority in accordance with the laws of Ukraine.
Union of Entrepreneurs of Poles in Ukraine