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

Revised on 05 September 2025 (commencement date).

GENERAL INFORMATION

The processing of your personal data is of great importance to the Charitable Organization “Rinat Akhmetov Foundation” (hereinafter referred to as the “Rinat Akhmetov Foundation”). We always strive to respect and keep secure any personal data that you provide to us or that we receive from other organizations.

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 methods and procedure for processing them (including through our Website https://civilvoicesmuseum.org/).

This Policy applies to information (including personal data contained therein):

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

This Policy is aimed 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 Tarasa Shevchenka Blvd., Kyiv, 01032 and is the personal data controller within the meaning of the Law of Ukraine On Personal Data Protection for personal data collected/provided in the above manner.

TERMS AND DEFINITIONS

Personal data controller means an individual or legal entity who determines the purpose of processing personal data, establishes the composition of these data and the procedures for their processing, unless otherwise specified by law.
Consent of the personal data subject means a voluntary expression of the will of an individual (provided their awareness) to grant permission for the processing of their personal data in accordance with the purpose of their processing, expressed in writing or in other form allowing to conclude that such consent has been granted. In e-commerce, the consent of the personal data subject may be provided during registration in the information and communication system of the e-commerce participant by ticking a mark on granting permission for the processing of their personal data in accordance with the formulated purpose, provided that such a system does not create any opportunities for the processing of personal data until the consent is given (by ticking the mark).
Personal data depersonalization (anonymization) means removal of information that allows to identify a person directly or indirectly.
Personal data processing means any action or set of actions, such as collection, registration, accumulation, storage, adaptation, modification, renewal, use and distribution (distribution, sale, transfer), depersonalization, destruction of personal data, including using information (automated) systems;
Recipient means an individual or legal entity to whom personal data are provided, including a third party.
Personal data mean 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 who is granted the right by the personal data controller or by law to process these data on behalf of the controller.
Personal data subject means an individual whose personal data are processed.
Third party means any person, except for the personal data subject, the personal data controller or processor and the Commissioner for Human Rights of the Verkhovna Rada of Ukraine, to whom the personal data controller or processor transfer personal data.

INFORMATION WE RECEIVE AND COLLECT

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

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

Your personal and contact information

Sources of collection:
Your full name, email address, postal address, phone number, password (encrypted), date of birth, country of residence, city of residence, country of birth, city of birth, field of activity, place of work, position and other information and contact details that you provide during registration, posting your story on the Website, registering for an event, requesting a callback or contacting us for support or information, etc.

Login and authentication data

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

Website, server, browser data

Sources of collection:
Information is collected automatically when you interact with us, visit our Website, and access our servers through your browser, applications, or other client platforms. This information includes data about your visits, including the pages you view, the links you follow, and other actions you take on our Website and services. We also collect certain standard information that your browser sends to the Website you visit, such as: Last login IP, current login IP, last login date, current login date.
When you receive newsletters or promotional emails from the Rinat Akhmetov Foundation, we may use web beacons, customizable links, or similar technologies to determine that the email has been opened and which links you click. In the future, we may send you more relevant emails or other information.

Social media pages

Sources of collection:
We have pages on many social networks, such as Facebook and Instagram. We collect information about your visits of our social network pages.
When you visit these pages, your browser directly connects to their servers. Please note that we cannot influence the terms of use of the social networks and the services they offer, as well as the collection and further use of data. For our part, we treat your data with care, but are not responsible for the behaviour of the operators of the social networks or third parties.
Be sure to read the privacy policy and rules on the use of information of any social network you use.

Other information

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

Information collected as part of audio interviews, as well as contained in your text and video stories

Sources of collection:
Any information that you provide, at your discretion, by an audio interview with representatives of the Rinat Akhmetov Foundation, as well as information in your text and video stories, contains (may contain) the following personal data: surname, first name, patronymic; age; place and date of birth; voice recording; video image, communication device number; email address; location; education, marital status and family composition; other data voluntarily provided by you to achieve the purpose of processing.
Disclaimer: The Rinat Akhmetov Foundation does not know in advance what information (and what personal data) you will wish to provide within an audio interview, as well as in your text and video stories, as well as their scope. Thus, in certain cases, during interviews, as well as in your text and video stories, other personal data may be provided to us (disclosed) and may be processed.

Storage period of all information (including personal data): during the entire period of activity of the Rinat Akhmetov Foundation and other persons to whom the Rinat Akhmetov Foundation will transfer your personal data.
Possible grounds for personal data processing in accordance with the Law of Ukraine On Personal Data Protection:
1) unambiguous consent of the personal data subject to such data processing;
2) the 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 implementation of measures preceding the conclusion of a transaction at the request of the personal data subject;
3) to fulfil the obligation of the personal data controller, which is provided for by law;
4) to protect the legitimate interests of the personal data controller or a third party to whom the personal data are transferred, except in cases where the needs to protect the fundamental rights and freedoms of the personal data subject prevail over such interests.
Data update: To maintain accuracy of our databases we may combine the data provided by you with information from open sources and verified companies. For example, we may use the services of other companies to verify your contact information and determine your geographic location based on your IP address, which will allow us to provide you with more relevant information and offers.
Feedback: When you request certain information from us, we may save your request and your contact details.

The content of personal data is the collected personal data that is processed.

HOW WE PROCESS THE COLLECTED INFORMATION

The Rinat Akhmetov Foundation collects and processes your personal data as part of its project Museum of Civilian Voices founded by the Rinat Akhmetov Foundation. which aims to create the largest online collection dedicated to civilians who suffered from the Russian Federation’s military aggression against Ukraine, as well as to internationally recognize 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 stories of civilians will help tell the tragedy of peaceful people of Ukraine to the rest of Ukraine and the world. 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 entities whose personal data are processed, including:

Ensuring, improving and personalizing the results of activities

Fulfilling requests.
Providing you with access to the services of the Website and applications of the Rinat Akhmetov Foundation for which you have registered, as well as any other products or information that you have requested.
Support and service to users of the Website and other resources of the Rinat Akhmetov Foundation.
Research and analysis aimed at improving our products and technologies.
Obtaining a more complete understanding of how our Website and applications are used for any possible improvement.
Identifying any problems with our Website and applications.

Communication

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

Research

Personalizing the Website, application or other information of the Rinat Akhmetov Foundation according to your interests and preferences.
Sending information about the Rinat Akhmetov Foundation, releasing new applications, products, holding events, etc.
Conducting sociological and other research on our beneficiaries, visitors to the Website and other persons, their interests and the effectiveness of the Rinat Akhmetov Foundation’s activities.

Personalisation of your experience on our Website

We may use your personal data and other information collected about you and from you to provide you with a personalized experience on our Website, for example, to provide you with content that may be interesting for you and to make navigating our Website easier.

Monitoring or recording calls, chats and other interactions

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

Use of information in social networks

On its Website, the Rinat Akhmetov Foundation may provide social network tools that allow you to share information online and collaborate with members who have registered to use them. These include forums, wiki, 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 content you post on any such social media platforms may be widely available to others.

For user experience improvement

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

For our Website improvement

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

For personalization of your user experience

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

Other legitimate purposes

Providing 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 telephone, you will not receive information by such means without your prior consent (unless permitted by applicable law).
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.
Securing our networks and online environment.
Investigating or preventing actual or suspected crime, or harm to the Rinat Akhmetov Foundation or others.
Compliance with legal obligations to which we are subject (whether by law or in response to a request from law enforcement or other government or local government authorities, including their officials).
Registration, administration and personalization of online accounts.
Promoting, contesting, conducting surveys or other features of our Website.
Responding to your questions/requests and otherwise communicating with you (e.g., by email).
Reporting on the impact and effectiveness of our work.
Auditing and/or administering our accounts.
Preventing fraud or misuse of our Website’s resources and products.

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

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

WHEN WE MAY SHARE COLLECTED INFORMATION WITH THIRD PARTIES

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

Personal data collected as part of audio interviews, as well as those contained in your text and video stories, are (may be) transferred to institutions engaged in scientific, historical and statistical activities.

LINKS TO EXTERNAL WEBSITES

The Rinat Akhmetov Foundation website may contain links to other websites.
Links to external websites have been compiled to the best of our knowledge and belief. We have carefully examined the content of these links and the reliability of those who provided them. However, since the content of Internet pages is dynamic and constantly changing, we cannot ensure monitoring of the content of each link.
If you visit another website, the data protection rules of the respective website operator apply. This rule also applies to cases where 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 rules of these websites. Please read the policies of the respective websites.

PERSONAL DATA SECURITY, STORAGE, ACCESS TO AND DELETION

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 safeguards in place to help us protect your personal information, for example, from unauthorized access, use and disclosure. In particular:

We use a range of security technologies and procedures to protect this information from unauthorized 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 protocols.
Personal information is accessible only to specially trained personnel and is stored on secure servers with features that prevent unauthorized access.
We also require our partners and contractors to protect such data from any unauthorized access, use, and disclosure.

We draw your attention that:

If the password you have specified on the Website is used to protect your bank accounts and other information on any other resources, all responsibility for its disclosure shall be borne by you. Do not disclose this information to anyone.
If you share a computer with other persons, always log out of your account on the Website to protect access to your information from other users.
No transmission of your personal data over the Internet can be 100% secure (however, once we receive your personal data, we apply strict procedures and security features to try to prevent any unauthorized access).

In general, unless required due the purposes for which it was collected and/or used, we shall delete your personal data from our records after the expiry of the period specified in the relevant consents to the personal data processing.
If you have any questions regarding the deletion of your personal data, you can contact us:

by calling: 0 800 509 001, or
by emailing: [email protected]

YOUR RIGHTS AS A DATA SUBJECT AND HOW YOU CAN EXERCISE THEM

The Rinat Akhmetov Foundation makes every effort to respect the rights of any person during its activities.
You shall have right to:

be aware of the sources of collection, location of your personal data, purpose of their processing, location or place of residence (stay) of personal data controller or processor or to instruct certain persons to obtain this information, except for cases established by law;
receive information about the conditions for providing access to personal data, in particular information about third parties to whom your personal data is transferred;
access your personal data. You can request confirmation of what personal data we store and request such personal data. If we get confirmation that you have the right to view the requested personal data and we have successfully confirmed your identity, we will provide you with your personal data, taking into account any applicable exceptions;
receive a response on whether your personal data are being processed, as well as receive the content of such personal data no later than thirty calendar days from the date of receipt of the request, except for cases provided for by law;
submit a reasoned request to the personal data controller objecting to the processing of your personal data;
submit a reasoned request to change or destroy your personal data by any personal data controller or processor, if these data are being processed unlawfully or are inaccurate. At your request, we will delete your personal data from our records. If you believe that our records of your personal data are inaccurate, you have the right to request their update. You can also ask to check your personal data that we store if you are not sure of its accuracy/relevance;
have your personal data protected from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as to have them protected against the provision of information that is inaccurate or defamatory of your honour, dignity and business reputation;
file complaints about the processing of your personal data with the Commissioner for Human Rights of the Verkhovna Rada of Ukraine or to a court;
apply for legal remedies in case of violation of the legislation on personal data protection;
make reservations restricting 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 in case of disagreements regarding their accuracy or our right to use them;
withdraw your consent to the personal data processing. You have the right to object to the processing of your personal data if you believe that we are processing them unlawfully;
be aware of the mechanism of personal data automated processing;
be protected against automated decision-making that has legal consequences for you.

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

by calling: 0 800 509 001, or
by emailing: [email protected]

Choices regarding the emails you receive from us

You may opt out of receiving emails from the Rinat Akhmetov Foundation that are intended to inform you about our activities and products by following the specific instructions provided in the email. You also have the opportunity to pre-select the messages you will receive. However, we may periodically send emails 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, services, applications, 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-in modules of external content providers. This online content can be viewed even if you delete cookies. Accepted cookies can be deleted in your browser’s system settings. Disabling cookies may result in functional limitations of online content.

Statistics

The Website uses Google Analytics, a service transmitting data about Website traffic to Google servers in the United States of America and allows us to observe trends and improve the user experience on our Website. Google Analytics may use cookies for:

identifying unique users;
limiting the frequency of requests;
remembering the number and time of previous visits; recording the source of traffic;
determining the start and end of a session; and
remembering the value of user-declared variables to determine the level of the visitor.

Information about your device (browser and its version, operating system) which you use to view the pages of the Website may be sent to Google Analytics.

The Website also has a Meta Pixel installed, which transmits data to run promotions on social networks. Detailed information on what data is transmitted and to whom can be found at the following links:

INTERNATIONAL TRANSFER OF PERSONAL DATA

Our Website is a global Website whose processes, structure and technical systems are aimed at an international audience. Thus, we may transfer your personal data to different countries around the world.
Our internal practices are designed to ensure a globally agreed level of personal data protection. This means that even in countries whose laws provide for lower level of protection, the Rinat Akhmetov Foundation will do everything in its power to process it in the manner described herein.

ADDITIONAL RULES ON THE USE OF PERSONAL DATA OF CITIZENS OF THE EUROPEAN UNION IN TERMS OF 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.

To familiarize yourself with the GDPR provisions, please follow the following link: 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/custodians (other legal representatives). To provide such consent, please download the appropriate consent file from the website https://civilvoicesmuseum.org/.

In addition, we strongly recommend you to explain to your children the dangers of communicating with strangers and disclosing their personal data on the Internet, as well as the importance of using the Internet safely.

Personal data anonymization (depersonalization)

The Rinat Akhmetov Foundation may anonymize (depersonalize) 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 operation of 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. The specified changes to this Policy shall become effective upon their publication on the Website. We recommend you to review this Policy before each use of the Website. Your use of the Website after the publication of the amended Policy shall mean your consent to be bound by the Policy, taking into account all changes made.

Contacts

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

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