Last updated 19 July, 2022
The website (hereinafter the “Website”), published by the UKUAtogether.org association (hereinafter “UKUAtogether.org” or “we”), is a match-making website connects Ukrainian refugees looking for emergency housing due to the current war in their country with hosts offering to house them temporarily free of charge.
When accessing, browsing and using the Website and the services provided, you, in your capacity as a host, may be required to provide UKUAtogether.org with personal data about yourself.
These personal data is protected by law. As a result, UKUAtogether.org, as data controller, has implemented appropriate security measures in order to protect your personal data.
Should you have any questions, you may directly contact UKUAtogether.org by sending an email to info@UKUAtogether.org.
1. WHAT KIND OF PERSONAL DATA ARE PROCESSED BY UKUAtogether.org ?
All personal data provided by you via the Website or when you communicate with UKUAtogether.org are processed by UKUAtogether.org , namely:
|Type of data||Examples of data|
|Identification data||First name, surname, age, family circumstances,|
|Contact details||Email address|
|Data on proposed emergency housing||Location of the housing (county and city), number of people who can be hosted, status of the housing (shared or private), photographs of the housing, any other useful information provided about the housing|
|Data related to your donations||Date and hour of the donation, amount of the donation, tax deduction, tax receipt, history of the donations|
|Banking data||Payment method|
|Data related to your application to be a volunteer (“Contact us” section)||All information submitted as part of your application to volunteer with UKUAtogether.org|
|Data required by the Home Office to sponsor your Ukrainian guests and support their visa application||Passport details, criminal convictions (if any), details of previous visa applications|
Also, the Website automatically collect the following data via cookies and other trackers:
|Type of data||Examples of data||Purposes|
|Internet or other electronic network activity information||Date and time of the visit, IP address, device type, browser type, operating system, viewed pages||This data is necessary for the proper functioning of the Website and its associated services, as well as internal business analytics purposes such as audience measurement. For more information on cookies, please see ourCookies Policy.|
The provision of certain types of personal data may be necessary or optional,. Mandatory data will be marked as such at the point of collection. If you refuse to provide mandatory data, UKUAtogether.org may not be able to process your request (e.g., request for creation of your personal account, match-making with refugees registered on the Website, processing your application to be a volunteer, etc.).
2. FOR WHAT PURPOSES DOES UKUAtogether.org USE YOUR PERSONAL DATA?
UKUAtogether.org processes your personal data for the following purposes only:
|Purposes||Examples of use of your personal data||Legal bases|
|Match making with refugees registered on the Website||● to add you to the lists of hosts offering emergency housing in the UK
● to make your profile available to refugees whose search criteria correspond to your housing
● to forward to you the contact requests sent to you by refugees interested in your emergency housing proposal
|● to establish and send to donors the tax receipts corresponding to their donations||Legal and regulatory obligations to which UKUAtogether.org is subject|
|● to internally manage donor files||Legitimate interest of UKUAtogether.org to monitor its relationship with the donors|
|● to send communications to donors about UKUAtogether.org activities, including fundraising appeals||Legitimate interest of UKUAtogether.org to carry out charitable prospecting actions to collect new donations|
|Processing your contact/information requests||● to process your contact/information request
● to contact you, if necessary
|Legitimate interest of UKUAtogether.org to respond to contact/information requests|
|Processing your application to be a volunteer (“Contact Us” section)||● to review your application
● to contact you if necessary
|Steps prior to entering into a contract|
|Improving the Website and its services, as well as your user experience on the Website||● to allow the Website and the services it provides to run smoothly
● to facilitate your navigation of the Website
● to take steps designed to protect the security of the Website
|Legitimate interest of UKUAtogether.org to improve the Website and its services, as well as your user experience on the Website|
|Pre-litigation or litigation management||● to manage any dispute or litigation||Legitimate interest of UKUAtogether.org in defending its rights and interests|
|Compliance with legal and regulatory obligations||● to comply with legal and regulatory obligations
● to process your requests to exercise your rights
|Legal and regulatory obligations to which UKUAtogether.org is subject|
3. WHO CAN ACCESS YOUR PERSONAL DATA?
Your personal data may be transmitted to the following recipients when you access, browse, navigate and use the Website and the services it provides:
|UKUAtogether.org and its duly authorised employees||Management of the website and its services|
|Refugees registered on the Website, whose search criteria match your emergency housing proposal||For the purpose of match-making between you and Ukrainian refugees registered on the Website whose search criteria for emergency housing match yours|
|Google Inc.||For the sole purpose of authenticating you on the Website using your Gmail identifiers to access your personal account|
|Payment service provider||For payment execution in the context of a donation and for storing your credit card information, if you have consented to it|
|UKUAtogether.org service providers (hosting provider, IT service providers, etc.)||Exclusively for operational and technical purposes related to the management of the Website and its services|
|Administrative or judiciary authorities||Exclusively in the case of an express and justified request or in case of an alleged violation of legal or regulatory provisions|
|Lawyers and all interested parties||Exclusively in the case of the management of possible disputes and other legal matters where appropriate|
|UKUAtogether.org uses WhatsApp to collect personal information from you in order to find an appropriate match and to process the visa application on behalf of their matched refugees.
UKUAtogether.org uses private Instagram accounts to share information between the volunteer ‘host’ and ‘refugee’ teams in order to find an appropriate match
4. WILL YOUR PERSONAL DATA BE TRANSFERRED OUTSIDE OF THE EUROPEAN UNION/EUROPEAN ECONOMIC AREA?
As far as possible, your personal data is processed within the UK/ European Union (EU)/European Economic Area (EEA). However, as some of the refugees registered on the Website or service providers are located in countries outside the UK/ EU/EEA, your personal data may be processed in those countries.
When your personal data is transferred outside the UK/EU/EEA, UKUAtogether.org will, in the absence of an adequacy decision and after having carried out an assessment of the level of protection of your rights on the territory of the third country where the recipient of your personal data is established, implement all necessary measures through the adoption of appropriate safeguards (such as standard contractual clauses). A copy of such safeguards can be obtained by sending an email directly to UKUAtogether.org at info@UKUAtogether.org
|Name of the recipient||Third country||Adopted safeguards|
|Google Inc.||United States||Standard contractual clauses|
|Webflow||United States||Standard contractual clauses|
|Wix||United States||Standard contractual clauses|
|United States||Standard contractual clauses|
5. HOW DOES UKUAtogether.org PROTECT YOUR PERSONAL DATA?
UKUAtogether.org has implemented technical and organisational measures to protect your personal data, in particular against potential data breaches likely to cause, either by accident or unlawfully, the destruction, loss, modification, unauthorised access or divulgation of your personal data. These measures will guarantee a level of security appropriate for the data and will take into account the state of the art and the cost of implementation in relation to the risks and nature of the data to be protected.
UKUAtogether.org guarantees that all members of its personnel and any other person processing your personal data will respect the internal rules and procedures related to the processing of personal data, including the technical and organisational security measures put in place to protect your personal data. In this context, UKUAtogether.org reviews and updates its practices regularly to enhance your privacy and ensure that its internal policies are followed.
If you have found a vulnerability or would like to report a security incident, you may send an email to info@UKUAtogether.org.
6. FOR HOW LONG IS YOUR PERSONAL DATA STORED?
As a general rule, your personal data will only be retained for the period necessary for the accomplishment of the purposes for which said data was collected.
- data relating to your personal account on the Website (including data relating to your match-making with refugee registered on the Website) is kept in an active database until the deletion of your personal account or after two (2) months of inactivity on your personal account and, beyond that, is archived for five (5) years for evidential purposes;
- data relating to your donation is kept until the establishment of the tax receipt and, beyond that, is archived for six (6) years for evidential purposes;
- data collected in the context of a contact/information request is kept until it is fully processedbefore being deleted;
your traffic data will be kept for a period of thirteen (13) months from the connection date.
7. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?
If you are based in the UK/ EU/ EEA, you have the following rights over your personal data:
- you can request the access to your personal data in order to obtain clear, transparent and understandable information about how UKUAtogether.org processes your personal data and about your rights (as provided in this policy), as well as a copy of your personal data.
- you can request the rectification of your personal data in order to obtain the modification of your personal data if it is obsolete, inaccurate or incomplete.
- you can object to the processing of your personal data when the processing is based on UKUAtogether.org legitimate interest. UKUAtogether.org will no longer process your personal data unless org demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, such as the respect of a legal obligation (e.g. legal obligation involving the retention of documents), or for the establishment, exercise or defence of legal claims.
- you can request the restriction of the processing during a limited period of time, in particular in order to carry out some verifications, where one of the following applies:
– you contest the accuracy of your personal data, the processing of which is thus restricted for the period necessary for UKUAtogether.org to verify the accuracy of such personal data;
– the processing is unlawful and, rather than requesting its deletion, you prefer to restrict its use;
– UKUAtogether.org no longer needs your personal data for the purposes of the processing, but you need them for the establishment, exercise or defence of legal claims;
– you have objected to the processing, which is thus restricted pending the verification of whether the compelling legitimate grounds of UKUAtogether.org may override your interests, rights and freedoms.
- you can withdraw your consent when it has been obtained, without this withdrawal affecting the lawfulness of the processing operations previously carried out.you can ask to receive your personal data in a structured, commonly used and machine-readable format and also can request their transmission to another controller where technically feasible. This right is not exercised in all circumstances, it applies only if it fulfils all the following conditions:
– your request is only related to your personal data (excluding anonymous or third-party data);
– your request does not adversely affect the rights or freedoms of others, in particular those of UKUAtogether.org (including trade secrets or intellectual property);
– the processing is carried out by automated means (paper files are therefore not included);
– the processing is based on consent or the performance of a contract (to check if it is the case, you can see the section 2 of this policy).
- you can request the deletion of your personal data (or right to be forgotten), where one of the following legal grounds applies:
– you object to the processing of your personal data and there are no overriding legitimate reasons justifying to maintain the processing of your personal data (such as an obligation for UKUAtogether.org to keep certain personal data);
– you decide to withdraw your consent on which the processing is based;
– your personal data are no longer useful for the original purposes for which they were collected or for any other type of processing;
– the use that is made of your data does not comply with the applicable legal or regulatory provisions.
- You can define either general or specific guidelines regarding your personal data in the event of your death (for example, their deletion or transmission to any person of your choice). You may revoke your instructions at any time.
It is specified that the exercise of these rights is based on the legal basis of the processing as indicated in section 2 of this policy, as follows:
|Consent||Yes||Yes||Yes||Yes||Yes||Withdrawal of consent|
|Steps prior to entering into a contract||Yes||Yes||No|
Under certain circumstances, UKUAtogether.org may ask you for specific information in order to confirm your identity and ensure the exercise of your rights. This is another appropriate security measure to ensure that personal data is not disclosed to an individual who does not have the right to receive it.
If you have any questions or wish to exercise your rights, you may directly contact UKUAtogether.org by sending an email to info@UKUAtogether.org.
If needed, you may also contact the Information Commission Officer visit ico.org.uk .
8. Changes to this policy