Privacy Policy for Refugees
The website UKUATogether.org (hereinafter the “Website”), published by the UKUATogether.org association (hereinafter “UKUATogether.org” or “we”), is a match-making website which connects Ukrainian refugees looking for emergency housing due to the current war in their country with hosts in the UK 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 refugee, may be required to provide UKUATogether.org with personal data about yourself.
This 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.
Please read this privacy policy carefully as it explains how UKUATogether.org uses your personal data. This privacy policy supplements our Terms of Use – Refugee and any documents or notices that may refer to this privacy policy.
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 byUKUATogether.org, namely:
| Type of data | Examples of data |
| Identification data | Last name, first name, gender, age |
| Contact details | Email address, mobile phone number, address |
| Emergency housing data | Gender and age of the family members with you, photographs of your family, any other information provided by you, details of relevant medical conditions/ accessibility needs necessitating adjustments to the home |
| Data required by the Home Office for UKUAtogether.org to make a visa application on your behalf | Passport details, criminal convictions (if any), details of previous visa applications |
Also, the Website automatically collects 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 our Cookies 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 hosts registered on the Website, 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 hosts registered on the Website | ● to add you to the list of refugees looking to be hosted in temporary housing in the UK
● to provide you with the hosts profiles ● to allow you to send a contact request to a host if you are interested in his/her emergency housing proposal |
Application of the Terms of Use |
| Processing your contact/information requests | ● to process your contact/information request
● to contact you, if necessary ● To assist you with the processing of British visa applications/ applications for local government services/ NHS registration/ school admissions |
Legitimate interest of UKUATogether.org to respond to contact/information requests |
| 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:
| Recipients | Purposes |
| UKUATogether.org and its duly authorised volunteers | Management of the website and its services |
| Hosts registered on the Website, who can provide their housing | For the purpose of match making between you and the hosts who have housing available to you |
| Google Inc. | For the sole purpose of authenticating you on the Website using your Gmail identifiers to access your personal account |
| UKUATogether.org’s 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 |
| UK central/ local government/ NHS | To assist in visa applications, school admissions, applications for local government services or benefits and NHS registration |
| UKUAtogether.org uses WhatsApp to collect personal information from you in order to find an appropriate match and to process the visa application on your behalf.
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 UK/ 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 hosts registered on the Website or UKUATogether.org’s service providers are located in countries outside the EU/EEA, your personal data may be processed in those countries.
When your personal data is transferred outside the 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 |
| 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.
In particular:
- data relating to your personal account on the Website (including data relating to your match-making with hosts registered on the Website) is kept in an active database until the deletion of your personal account or after 6 (6) months of inactivity on your personal account and, beyond that, is archived for five (5) years for evidential purposes;
- data collected in the context of a contact/information request is kept until it is fully processed before 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 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 on how UKUATogether.org processes your personal data and on 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 are 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 UKUATogether.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;
- 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); and
- the processing is based on consent or the performance of a contract (to check if it is the case, please consult section 2 of this policy).
- you can request the deletion of your personal data (also known as the 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 the processing of your personal data (such as an obligation on the part of 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 a person of your choosing). 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:
| Access | Rectification | Erasure | Restriction | Data portability | Objection | |
| Consent | Yes | Yes | Yes | Yes | Yes | Withdrawal of consent |
| Steps prior ** entering into a contract | Yes | Yes | No | |||
| Contract | Yes | Yes | No | |||
| Legitimate interest | Yes | No | Yes | |||
| Legal obligation | No | No | 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 at www.ico.org.uk
8. Changes to this policy
This privacy policy may be amended from time to time, in particular to reflect the changes in the services provided by the Website or the applicable regulations. Therefore, we recommend that you review this privacy policy each time you visit the Website.