Privacy Policy

As a Host or Recruiter

Last updated May 17, 2022

The website https://eu4ua.org/ (hereinafter the "Website"), published by the EU4UA association (hereinafter "EU4UA" 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.
  • Ukrainian refugees looking for a job due to the current war in their country with recruiters offering job offers that might interest them.

When accessing, browsing and using the Website and the services provided, you, in your capacity as a host, may be required to provide EU4UA with personal data about yourself.

These personal data is protected by law. As a result, EU4UA, 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 EU4UA uses your personal data. This privacy policy supplements our Terms of Use – Host and Recruiter and any documents or notices that may refer to this privacy policy. 

Should you have any questions, you may directly contact EU4UA by sending an email to info@eu4ua.org.

1. WHAT KIND OF PERSONAL DATA ARE PROCESSED BY EU4UA?

All personal data provided by you via the Website or when you communicate with EU4UA are processed by EU4UA, namely:

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 our Cookies Policy.

The provision of certain types of personal data may be necessary or optional, depending on the services you wish to receive. Mandatory data will be marked as such at the point of collection. If you refuse to provide mandatory data, EU4UA 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 EU4UA USE YOUR PERSONAL DATA?

EU4UA processes your personal data for the following purposes only:

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: 

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 European Union (EU)/European Economic Area (EEA). However, as some of the refugees registered on the Website or EU4UA'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, EU4UA 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 EU4UA at info@eu4ua.org

Name of the recipient

Third country

Adopted safeguards

Google Inc.

United States

Standard contractual clauses

Webflow

United States

Standard contractual clauses

5. HOW DOES EU4UA PROTECT YOUR PERSONAL DATA?

EU4UA has implemented technical and organizational measures to protect your personal data, in particular against potential data breaches likely to cause, either by accident or unlawfully, the destruction, loss, modification, unauthorized 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.

EU4UA 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 organizational security measures put in place to protect your personal data. In this context, EU4UA 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@eu4ua.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 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 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 about how EU4UA 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 EU4UA’s legitimate interest. EU4UA will no longer process your personal data unless EU4UA 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 defense 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 EU4UA to verify the accuracy of such personal data;

          - the processing is unlawful and, rather than requesting its deletion, you prefer to restrict its use;

          - EU4UA no longer needs your personal data for the purposes of the processing, but you need them for the establishment, exercise or defense of legal claims;

          - you have objected to the processing, which is thus restricted pending the verification of whether the compelling legitimate grounds of EU4UA 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 EU4UA (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 EU4UA 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:

 

Access

Rectification

Erasure

Restriction

Data portability

Objection

Consent

Yes

Yes

Yes

Yes

Yes

Withdrawal of consent

Steps prior to entering into a contract

Yes

Yes

No

Contract

Yes

Yes

No

Legitimate interest

Yes

No

Yes

Legal obligation

No

No

No

Under certain circumstances, EU4UA 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 EU4UA by sending an email to info@eu4ua.org.

If needed, you may also lodge a complaint with your national data protection authority. This right may be exercised at any time and free of charge, at the exclusion of potential postal fees or expenses related to legal representation or assistance should you choose to engage third-party assistance for the procedure.

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.