PERSONAL DATA PROCESSING POLICY OF THE WEBSITE “CIVILIAN VOICES. MUSEUM OF THE RINAT AKHMETOV FOUNDATION” CHARITABLE ORGANISATION “RINAT AKHMETOV FOUNDATION”

Revised on 05 September 2025 (commencement date).

GENERAL

The processing of your personal data is of great importance to the Charitable Organisation “Rinat Akhmetov Foundation” (hereinafter referred to as “Rinat Akhmetov Foundation”). We always strive to respect any personal data that you provide to us, or that we receive from other organisations, and to keep it secure.
This Personal Data Processing Policy (hereinafter referred to as the “Policy”) sets out how and why we process your personal data, as well as your rights and options regarding the ways and manner in which it is processed (including through our Website https://civilvoicesmuseum.org/).
This Policy applies to the information (including personal data contained therein):

that you provide to the Rinat Akhmetov Foundation for posting on the website “CIVILIAN VOICES. MUSEUM OF THE RINAT AKHMETOV FOUNDATION” (hereinafter referred to as the “Website”) and for transfer to third parties;
provided through audio interviews with representatives of the Rinat Akhmetov Foundation, as well as contained in your text and video stories;
based on the data collected by the Rinat Akhmetov Foundation for posting on the Website;
obtained as a result of your use of the Website.

The purpose of this Policy is to determine the grounds and rules for processing and protecting personal data collected/provided in the above manner, to protect the rights and legitimate interests of the Rinat Akhmetov Foundation, as well as users when processing personal data posted on the Website.
The Rinat Akhmetov Foundation is located at: 33-B, Taras Shevchenko Blvd., Kyiv, 01032, and is the Personal Data Controller within the meaning of the Law of Ukraine “On Personal Data Protection” for the personal data collected/provided in the above manner.

TERMS AND DEFINITIONS

Personal data controller means an individual or legal entity that determines the purpose of personal data processing, establishes the composition of such data and procedures for their processing, unless otherwise provided by law.
Consent of the personal data subject means a voluntary expression of will of an individual (subject to his/her awareness) to grant permission to process his/her personal data in accordance with the stated purpose of their processing, expressed in writing or in a form that allows to conclude that consent has been granted. In the field of e-commerce, the consent of a personal data subject may be provided during registration in the information and communication system of an e-commerce subject by marking a note on granting permission to process his or her personal data in accordance with the formulated purpose of their processing, provided that such a system does not create opportunities for processing personal data before the marking.
Depersonalisation (anonymisation) of personal data means the removal of information that allows direct or indirect identification of a person.
Personal data processing means any action or set of actions, such as collection, registration, accumulation, storage, adaptation, modification, updating, use and dissemination (distribution, sale, transfer), depersonalisation, destruction of personal data, including with the use of information (automated) systems;
Recipient means an individual or legal entity to whom personal data is provided, including a third party.
Personal data means information or a set of information about an individual who is identified or can be specifically identified;
Personal data processor means an individual or legal entity that is authorised by the personal data controller or by law to process this data on behalf of the controller.
Personal data subject means an individual whose personal data is processed.
Third party means any person, with the exception of the personal data subject, the personal data controller or processor and the Ukrainian Parliament Commissioner for Human Rights, to whom the personal data controller or processor transfers personal data.

INFORMATION WE RECEIVE AND COLLECT

The Rinat Akhmetov Foundation takes the protection of your personal data very seriously. Therefore, with this Policy, we inform you about the processing of your personal data. In general, your personal data is protected within the legal framework.
Below you will find information on what data about you may be collected and how it is used.

Types of information that the Rinat Akhmetov Foundation may collect from or about you (including what constitutes personal data):

Name and contact information

Sources of collection:
Your name, patronymic and surname, e-mail address, postal address, telephone number and other similar contact information that you provide when you create a user profile, post your story on the Website, register for an event, request a callback or contact us for support or information, etc..

Login and authentication data

Sources of collection:
Username, e-mail address, date of birth, passwords – when you use your e-mail address to log in.
If you register or access the Website with your account through a single sign-on system based on third-party services that launch a user authentication mechanism and transmit your social media credentials (for example, to Google or Facebook), we reserve the right to collect any information or other data required for registration or login, which you have consented to the transfer of to the provider of the social media platform, for example: Your name and e-mail address.

Information about the Website, servers, browser

Sources of collection:
Information is collected automatically when you communicate with us, visit our Website and access our servers through your browser, applications or other client platforms. This information includes information about your visits, including the pages you view, the links you click on, and other activities related to our Website and services. We also collect certain standard information that your browser transmits to the Website you visit, such as: Your IP address, browser type and language, time of entry and referring websites. When you receive newsletters or promotional emails from the Rinat Akhmetov Foundation, we may use web beacons, customisable links or similar technologies to determine that the email has been opened and which links you click. We may send you more relevant e-mails or other information in the future.

Information about your location

Sources of collection:
We collect information about your location when you enable location-based services or features, such as your location based on your IP address or data.

Social media pages

Sources of collection:
We have pages on many social media platforms, such as Facebook and Instagram. We collect information about your visits to our social media pages.
When you visit these pages, your browser establishes a direct connection to their servers. Please note that we have no influence on the terms and conditions of use of social networks and the services they offer, as well as on the collection of data and their further use. We, for our part, treat your data with care, but we are not responsible for the behaviour of social media operators or third parties.
Be sure to read the privacy policy and rules for the use of information in any social network you use.

Other information

Sources of collection:
Any other information that we receive in the ways specified in this Policy, including (but not limited to): age; date of birth; place of birth; information about citizenship; voice recording; photo and/or video images.

Information collected during audio interviews and contained in your text and video stories

Sources of collection:
Any information that you provide, at your discretion, during an audio interview with representatives of the Rinat Akhmetov Foundation, as well as contained in your text and video stories, contains (may contain) the following personal data: name, patronymic, surname; age; place and date of birth; voice recording; contact number; e-mail address; place of residence; education, marital status and family composition; health status; other data voluntarily provided by you for the purpose of processing.
Notice: The Rinat Akhmetov Foundation does not know in advance what kind of information (and what kind of personal data it contains) you will be willing to provide during the audio interviews, as well as in your text and video stories, as well as the level of their detail. Thus, in certain cases, during the interview, as well as in your text and video stories, we may receive (disclose) other personal data, including health data, and which may be processed in the event of their transmission.

The storage period of all information (including those that constitute personal data): for the entire period of activity of the Rinat Akhmetov Foundation and other persons to whom the Rinat Akhmetov Foundation transfers your personal data.
Possible grounds for processing your personal data in accordance with the Law of Ukraine “On Personal Data Protection”:

consent of the personal data subject to the processing of his/her personal data;
permission to process personal data granted to the personal data controller in accordance with the law solely for the purpose of exercising his/her powers;
conclusion and performance of a transaction to which the personal data subject is a party or which is concluded in favour of the personal data subject or for the purpose of taking measures preceding the conclusion of a transaction at the request of the personal data subject;
protection of vital interests of the personal data subject;
the need to fulfil the obligation of the personal data controller provided for by law;
the need to protect the legitimate interests of the personal data controller or a third party to whom personal data is transferred, except where the needs to protect the fundamental rights and freedoms of the personal data subject in connection with the processing of his or her data outweigh such interests.

Data update: To ensure that our databases remain accurate and up-to-date, we may combine the data you provide with information from open sources and trusted companies. For example, we may use the services of other companies to verify your contact details and determine your geographic location based on your IP address, which will allow us to send you more relevant information and offers.
Feedback: when you contact us with a request for certain information, we may store your request and your contact details.
The content of personal data is the personal data collected and processed.

HOW WE PROCESS THE COLLECTED INFORMATION

The Rinat Akhmetov Foundation collects and processes your personal data as part of its project “The Museum of Rinat Akhmetov. Civilian Voices”, which aims to create the largest online collection dedicated to civilians who suffered from the military aggression of the russian federation against Ukraine, as well as international recognition of the Museum’s archive as the main source of truth through academic, journalistic, cultural and legal initiatives by building international partnerships and receiving world-class awards. Collecting the stories of civilians will help to tell the whole of Ukraine and the world about the tragedy of Ukrainian civilians. In addition, the processing of your personal data is necessary to carry out our activities and ensure the legitimate interests of the Rinat Akhmetov Foundation and the subjects whose personal data is processed, including the following:

Ensuring, improving and personalising performance

Fulfilment of requests.
Providing you with access to the services of the Website and applications of the Rinat Akhmetov Foundation, where you have registered, as well as any other products or information you have requested.
Providing support and service to users of the Website and other resources of the Rinat Akhmetov Foundation.
Conducting research and analysis to improve our products and technologies.
Gaining a better understanding of how our Website and applications are used so that we can improve them.
Identify problems with our Website and applications.

Communication

Sending you communications (including welcome emails, reminders to take certain actions, technical information about resources and products, expiration reminders and security announcements) and other information.

Research

Personalised customisation of the Website, application or other information of the Rinat Akhmetov Foundation in accordance with your interests and preferences.
Sending information about the Rinat Akhmetov Foundation, releasing new applications, products, events, etc.
Conducting sociological and other research about our beneficiaries, Website visitors and other persons, their interests and the effectiveness of the Rinat Akhmetov Foundation.

Personalisation of your experience on our Website

We may use your personal data and other information we receive from you and about you that we collect about you to provide you with a personalised experience on our Website, for example, to provide you with content that may be of interest to you and to make our Website easier to navigate.

Monitoring or recording calls, chats and other interactions

Some interactions may require you to call us or us to call you. These may also include online chats.

Use of information in social media

On its Website, the Rinat Akhmetov Foundation may provide social media tools that allow you to share information online and collaborate with participants who have registered to use them. These include forums, wikis, blogs and other social networks. When you register to use these tools, you will be asked to provide certain information. Registration information that is not automatically shared with other members as part of your profile will be protected in accordance with this Policy. You should be aware that the content you post on any such social media platforms may be widely available to others.

To improve your user experience

The information you provide to us helps us to respond more effectively to your customer service requests and support needs.

Improving our Website

We may use your feedback to improve our products, as well as to manage/administer our Website, ensure its security and safety, and ensure that content is presented in the most effective way for you and your device.

To personalise your user experience

We may use the information in the aggregate to understand how individuals use the products and resources we provide and to offer a personalised approach.

Other legitimate purposes

To provide you with information about our work, events, activities and/or products that we think may be of interest to you (for example, about products you have previously used or about the activities of the Rinat Akhmetov Foundation). If we do this by email, SMS or phone, we will not do so without your prior consent (unless permitted by current legislation).
Invitations to participate in surveys about our events, products and other issues related to the activities of the Rinat Akhmetov Foundation.
Developing and maintaining our online environment.
Security of our networks and online environment.
To investigate or prevent actual or suspected crimes or damage to the Rinat Akhmetov Foundation or others.
To comply with legal obligations that are binding on us (in accordance with the law or in connection with a request from law enforcement agencies or other public authorities or local governments, including their officials).
To register, administer and personalise online accounts.
To run a promotion, contest, survey or other features on our Website.
To respond to your questions/inquiries and communicate with you generally (e.g. by e-mail).
To report on the impact and effectiveness of our work.
To audit and/or administer our accounts.
To prevent fraud or misuse of our Website resources and products.

Posting audio interviews, text and video stories on the website of the Museum of Civilian Voices, in social networks, mass media, transferring them to institutions engaged in scientific, historical and statistical activities, as well as ensuring the implementation of the charitable activities of the Rinat Akhmetov Foundation, and other relations that require their processing

We may use your personal data and other information that we receive from you during audio interviews, as well as in your text and video stories, to post them on the website of the Museum of Civilian Voices, in social networks, mass media, transfer them to institutions engaged in scientific, historical and statistical activities, as well as to ensure the implementation of the charitable activities of the Rinat Akhmetov Foundation, and other relations that require their processing.

IN WHAT CASES WE MAY TRANSFER THE INFORMATION WE COLLECT TO THIRD PARTIES

As a general rule, we do not sell, trade or otherwise disclose your personal data to third parties. However, we may disclose it to certain third parties (including (but not limited to) public authorities, museums, archival, scientific and other institutions engaged in scientific, historical and statistical activities, the media) – within the scope of the activities of the Rinat Akhmetov Foundation and its project Museum of Civilian Voices of the Rinat Akhmetov Foundation, as well as to achieve the goals set out in this Policy (including the following goals: (1) compliance with the law or enforcement of court decisions that have entered into force; (2) protection of the rights of the Rinat Akhmetov Foundation (including the fulfilment of our obligations under the relevant transactions) or third parties (including (but not limited to): (a) our partners, as well as contractors (for the performance of transactions we enter into with them), for example, IT service providers (such as website hosts); (b) insurers; (c) professional service providers (such as accountants and lawyers); (d) persons assisting us in conducting research (including sociological research) to monitor the effectiveness of our activities and other issues; (e) news media and social networks (including Facebook, Instagram); (f) public authorities (such as tax, customs, etc.) or local governments; (g) analysts and search engine providers); (3) to protect the personal safety of the beneficiaries of the Rinat Akhmetov Foundation or members of the public in emergency circumstances).

Who receives personal data collected during the audio interview and contained in your text and video stories: institutions engaged in scientific, historical and statistical activities.

LINKS TO EXTERNAL WEBSITES

The website of the Rinat Akhmetov Foundation may contain links to other websites.
Links to external websites have been created to the best of our knowledge and belief. We have taken great care to review the content of these links and the reliability of those providing these links. However, as the content of the Internet is dynamic and subject to constant change, we cannot monitor the content of each link on a continuous basis.
If you visit another website, the data protection regulations of the respective website operator apply. This also applies if our Website contains links to third party websites. In such cases, the Rinat Akhmetov Foundation is not responsible for the privacy policies and practices or the content of these external websites, as well as for the data protection policies of these websites. Please read the policies of the respective websites.

SECURITY, STORAGE, ACCESS TO AND DELETION OF PERSONAL DATA

The Rinat Akhmetov Foundation is committed to ensuring the security of the information we collect from and about you. We have appropriate and proportionate physical, administrative and technical security measures in place to help us protect your personal data, for example, from unauthorised access, use and disclosure. In particular:

We use a range of security technologies and procedures to protect this information from unauthorised access, use or disclosure (for example, we store the information you provide on restricted computer systems located in controlled facilities).
When we transmit your personal information over the Internet, we protect it using encryption methods such as HTTPS and TLS.
Personal data is accessible only to specially trained personnel and is stored on secure servers with features that prevent unauthorised access.
We also require our partners and contractors to protect such data from unauthorised access, use and disclosure.

Please note that:

If the password you provide on the Website is used to protect your bank accounts and other information on other resources, you are responsible for its non-disclosure. Do not disclose this information to anyone.
If you share a computer with someone else, always log out of your account on the Website to protect access to your information from subsequent users.
No transmission of your personal data over the Internet can be 100% secure (however, once we receive your personal data, we use strict procedures and security features to try to prevent unauthorised access).
In general, unless required in connection with the purposes for which it was collected and/or used, we delete your personal data from our records after the expiry of the period specified in the relevant consents to the processing of personal data.

If you have any questions regarding the deletion of your personal data, you can contact us:

by dialling: 0 800 509 001, or
by emailing to: [email protected].

YOUR RIGHTS AS PERSONAL DATA SUBJECTS AND HOW TO EXERCISE THEM

The Rinat Akhmetov Foundation makes every effort to respect the rights of any individual in carrying out its activities.
You have the following rights:

to know about the sources of collection, location of your personal data, the purpose of their processing, location or place of residence (stay) of the owner or manager of personal data or to give a corresponding order to obtain this information to persons authorised by you, except in cases established by law;
to receive information on the conditions for granting access to personal data, including information about third parties to whom your personal data is transferred;
to access your personal data. You can write to us to request confirmation of what personal data we store and to request this personal data. If we are convinced that you have the right to view the requested personal data and we have successfully verified your identity, we will provide you with your personal data, subject to any applicable exceptions;
to receive a response on whether your personal data is processed no later than thirty calendar days from the date of receipt of the request, except as provided by law, and to receive the content of such personal data;
to submit a reasoned request to the personal data controller with an objection to the processing of your personal data;
to submit a reasoned request to change or destroy your personal data by any controller and processor of personal data, if such data is processed illegally or is unreliable. Upon your request, we will delete your personal data from our records, if necessary. If you believe that our records of your personal data are inaccurate, you have the right to request that we update those records. You may also ask us to verify your personal data that we hold if you are not sure about its accuracy/relevance;
to protect your personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as to protect against the provision of information that is inaccurate or defamatory of your honour, dignity and business reputation;
to file a complaint against the processing of your personal data to the Ukrainian Parliament Commissioner for Human Rights or to the court;
to apply for legal remedies in case of violation of the legislation on personal data protection;
to make reservations regarding the restriction of the right to process your personal data when giving consent. You have the right to ask us to restrict the use of your personal data if there is a disagreement about its accuracy or our right to use it;
to withdraw your consent to the processing of personal data. You have the right to object to the processing of your personal data if you believe that we are processing it on unlawful grounds;
to know the mechanism of automatic processing of personal data;
to be protected against an automated decision that has legal consequences for you.

If you need to exercise your rights related to the operation of our Website, as well as if you believe that any of your rights have been violated in connection with the operation of our Website, as well as to withdraw your consent to a certain type of personal data processing, please contact us:

by dialling: 0 800 509 001, or
by emailing to: [email protected].

Options for choosing the e-mails you receive from us

You can opt out of e-mails from the Rinat Akhmetov Foundation that inform you about our activities and products by following the specific instructions in the e-mail. You also have the opportunity to choose the messages you receive in advance. However, we may periodically send you e-mails informing you about administrative and technical issues related to the products and services you use.

Use of cookies

The Rinat Akhmetov Foundation uses cookies and similar technologies on our Website, in services, applications, and other tools that automatically receive and track certain data about your device and interaction with our Website or other tools.
In some cases, cookies are used by plug-ins from external content providers that connect to our Website. It is also possible to view this online content when cookies are deleted. Saved cookies can be deleted in the system settings of your browser. Disabling cookies may result in functional limitations of the online content.

INTERNATIONAL TRANSFER OF PERSONAL DATA

Our Website is a global Website with processes, structure and technical systems aimed at an international audience, among other things. As such, we may transfer your personal data to countries around the world.
Our internal practices are designed to ensure a globally consistent level of personal data protection. This means that even in countries where the laws provide for less protection of your information, the Rinat Akhmetov Foundation will do everything in its power to process it in the manner described in this Policy.

ADDITIONAL RULES FOR THE USE OF PERSONAL DATA OF CITIZENS OF THE EUROPEAN UNION TAKING INTO ACCOUNT THE PROVISIONS OF THE GENERAL DATA PROTECTION REGULATION (GDPR)

In general, the provisions of this Policy apply equally to all persons, regardless of their citizenship and place of residence. At the same time, the provisions of the General Data Protection Regulation (hereinafter referred to as the “GDPR”), which we implement, may establish additional rules for the use of personal data of citizens of the European Union.
For more information about the GDPR, please follow the link below: https://gdpr-text.com/.

OTHER IMPORTANT INFORMATION ABOUT PERSONAL DATA

Collection and use of information about children

We collect personal data of children with the knowledge and consent of their parents/guardians/trustees (other legal representatives). To provide such consent, you need to download the appropriate consent file available on the website https://civilvoicesmuseum.org/.
In addition, we strongly recommend that you explain to your children the dangers of communicating with strangers and disclosing their personal data on the Internet, as well as the importance of safe use of the Internet.

Anonymisation (depersonalisation) of personal data

The Rinat Akhmetov Foundation may anonymise (depersonalise) personal data provided in accordance with this Policy to create anonymous data sets that will be used to improve the activities of the Rinat Akhmetov Foundation and the Website.

Changes to this Policy

The Rinat Akhmetov Foundation reserves the right to adapt this Policy in accordance with technical developments and changes in the legal framework. We will also update this Policy when necessary, taking into account user feedback and changes in our activities and practices. Such changes to this Policy shall become effective upon their publication on the Website. We recommend that you review this Policy before each use of the Website. If you continue to use the Website after the amended Policy has been posted, this means that you agree to be bound by the Policy as amended.

Contacts

The Rinat Akhmetov Foundation welcomes your comments on this Policy. If you have any questions about this Policy or believe that we have violated your rights, please contact us:

by dialling: 0 800 509 001, or
by emailing to: [email protected].