Privacy Policy

This Privacy Policy governs the protection of personal data of visitors to the website virtual-assets.org, which is owned by the Public Association “Virtual Assets of Ukraine” (EDRPOU code 44147736, registered address: Ukraine, Kyiv Oblast, Kyiv, Buslivska Street 15, Apartment 10), in accordance with the current legislation of Ukraine (“the Fund”). 

1. GENERAL PROVISIONS

   1.1. In this Policy, the following terms are used:

• Personal data database: An organized collection of personal data in electronic form and/or in the form of personal data files.
• Consent of the data subject: Voluntary expression of will by a natural person (provided they are informed) regarding the granting of permission for the processing of their personal data, based on the stated purpose of such processing, expressed in a form that allows a conclusion about consent.
• Processing of personal data: Any action or set of actions, such as collection, registration, accumulation, storage, adaptation, modification, updating, use, and dissemination (distribution, implementation, transfer), depersonalization, or destruction of personal data, including using information (automated) systems.
• Personal data: Information or a set of information about an identified or identifiable natural person.
• Data subject: A natural person whose personal data is being processed.
• Third party: Any person other than the data subject, the data controller, or the data processor.
• Cookies: Small text files stored in the browser of a device (computer, mobile phone, etc.) after visiting a website. More information about cookies can be found [here](https://allaboutcookies.org/).

   1.2. This Policy is designed to inform data subjects about the processing of their personal data during their visit/use of the website and to ensure the protection of their personal data during such processing.

   1.3. This Policy, as well as the activities of the Fund related to the collection, processing, storage, and other lawful actions with personal data, are regulated by:

• The Constitution of Ukraine.
• The Law of Ukraine "On Personal Data Protection" dated June 1, 2010, No. 2287-VI.
• Other applicable legal acts of Ukraine governing personal data protection.
• International legal acts ratified in Ukraine.

   1.4. Regarding legal relations arising in connection with the processing of personal data of residents of foreign jurisdictions, the Fund also applies the law (including international law), national, and international legal acts regulating personal data protection in those countries.

   1.5. The data controller for personal data processed in connection with the use of the website's features is the Fund. The Fund has the right to fully or partially delegate the processing of personal data to third parties based on contracts in accordance with applicable law.

   1.6. A natural person becomes a data subject under this Policy if they are a visitor to the website, including when using any options available on the website.

   1.7. The Fund guarantees:

• Compliance with proper practices and regulatory requirements for personal data protection.
• Protection of the rights of data subjects.
• Prevention of risks related to the security of personal data processing.

1.8. Placement of this Policy

The placement of this Policy at the link specified in section 4.1. of this Policy serves as a notification to data subjects about the Data Controller, the composition and content of personal data collected in connection with the visit/use of the website, the rights of such subjects, the purpose of collecting their personal data, and third parties to whom such personal data may be disclosed.

2. PROCESSING OF PERSONAL DATA

2.1. The Fund may collect and process the following information about you:

Information you provide to the Fund: This includes information you provide through the use of the website and its features, such as signing up for email updates, making donations via the website, or communicating with the Fund through available options on the website.

Information collected by the website and other systems:

• When you visit the website, third parties may collect certain information about you and your visit, such as your browser type, version, visited pages, and internet protocol (IP) address.
• The website may also use cookies on your device.
• If you contact Fund employees via the website or other electronic communication methods.
• Information collected by third parties on the website:
• Third parties (e.g., Facebook, Google, Twitter) may collect information about you when you use social media sharing options available on the website or when you navigate between pages or follow links to other platforms (websites).

2.2. The way the Fund processes your personal data depends on how you use the website and interact with it. Some information may be directly provided by you during website usage, while other information may be collected and processed by the Fund using automated technologies on the website.

2.3. Legal bases for data processing:

The Fund processes your personal data when:

You provide consent.

Your data is necessary for contractual purposes or pre-contractual measures.

The Fund has a legitimate interest in processing your data (which does not override your interests or fundamental rights).

Other cases defined by applicable law.

2.4. Automated processing mechanisms:

The Fund and third parties may use automated processing technologies on specific sections of the website. Cookies are used to store content and settings, allowing the Fund to process standard information sent by your browser to specific websites (e.g., IP address, browser type, language, and referring site).

2.5. The Fund uses your personal data for purposes defined by this Policy and applicable law, including:

Processing your requests made through the website.

Facilitating donations via available options on the website.

Achieving other statutory goals as defined by law.

2.6. The Fund may accumulate personal data processed during your website visits, including adding this data to the personal data database.

2.7. Disclosure of Your Personal Data

The disclosure of your personal data occurs solely with your consent or in cases defined by this Policy and applicable legislation.

2.8. Partial Publication of User Data

The Fund may partially publish user data on its website under the sections “Reports” and “Contributions.”

2.9. Deletion or Destruction of Personal Data

Your personal data will be deleted or destroyed in the following cases:

• Upon the expiration of a 2-year retention period or any other period defined by current legislation.
• When legal relations between the data subject and the Fund cease, as provided by law.
• In other cases specified by current legislation in the field of personal data protection.

2.10. Specific Data Processing Restrictions

The Fund does not process personal data related to racial or ethnic origin, political, religious, or philosophical beliefs, membership in political parties or professional associations, criminal convictions, or data concerning health, sexual life, biometric, or genetic data, except as otherwise provided by law.

3. RIGHTS OF DATA SUBJECTS

3.2. You can address questions related to the collection, use, storage, and other processing of your personal data to the Authorized Human Rights Commissioner of the Verkhovna Rada of Ukraine. You can contact them via email at hotline@ombudsman.gov.ua. If you have any questions about this Policy or have received unwanted electronic communications allegedly from the Fund, please directly contact the Fund via email at info@virtual-assets.org 

4. CHANGES TO THE PRIVACY POLICY

The Fund reserves the right to review and modify the provisions of this Policy. The current version of this Policy is available on the website at info@virtual-assets.org