Policy
Speak-Up and Privacy Policy
Part I. Speak-Up Policy
Openness Culture (Speak Up)
The Fund seeks to build a culture of openness and create an environment in which staff, volunteers, partners, and beneficiaries feel comfortable raising concerns about non-compliance. If you know or suspect a violation of the Fund's policies, charter, or the legislation of Ukraine, please speak up.
Do the Right Thing
At the Fund, we share a commitment to doing the right thing every day, in every interaction and every project we implement. All Fund staff and volunteers are responsible for complying with the Fund's Code of Conduct and for reporting possible violations.
Reporting Channel
Concerns can be reported to the Fund's contact email co.icdf.ukraine@gmail.com or through public communication channels via the feedback form on the Foundation's website, social media communication tools Facebook, Twitter, LinkedIn and Viber, WhatsApp, Messenger applications. Reports are reviewed by the Fund's management promptly, thoroughly, and in accordance with applicable law. A person may choose to report a concern anonymously. Investigations are kept confidential to the extent possible, in line with the law and good practice. Where necessary, the Fund may report certain matters to the relevant authorities.
Non-Retaliation
The Fund does not tolerate retaliation against any person who reports a concern in good faith. Any attempt at retaliation is treated as a separate violation of the Fund's Code of Conduct.
Part II. Privacy Policy
Privacy Statement
Fund recognizes the importance of protecting the privacy of your information. This Privacy Policy governs the collection of personal data received through the Fund's website, social media pages, and other communication channels (together, the “Resources”). Please read this Policy carefully: it explains what personal data we process, how we use it, who we share it with, and what rights you have.
Data Controller
The data controller responsible for processing personal data is the Charitable Organization “International Cooperation Development Fund” (23 Mezhova Street, Podil district, Kyiv, 04123, Ukraine; identification code in Ukraine 45724663; co.icdf.ukraine@gmail.com).
Information You Provide Directly
We collect information that you provide to us voluntarily and directly, including when you contact us through the website feedback form, send us an email, subscribe to our newsletter, apply to participate in a program or volunteer, make a donation, or leave a comment on the Fund's social media pages.
Information We Collect Automatically
Where the Fund uses cookies, web beacons, or similar technologies on its website, our servers may automatically record information about your use of the site, such as your IP address, browser and operating system type, the time and duration of your visit, and the pages viewed. See the “Cookies” section below for more information.
Information from Third Parties
We may receive additional information about you from partner organizations, donors, or publicly available sources (such as professional networks) where permitted by law, including when reviewing applications for cooperation or grant programs.
Categories of Personal Data
Depending on the nature of your interaction, we may collect the following categories of data: identifiers (name, phone number, email address, mailing address) — to respond to inquiries and provide services; commercial information (donation details, cooperation history) — for financial and statutory reporting; website usage information (IP address, browser type, approximate IP-based location) — for traffic analysis; professional information (job title, organization, LinkedIn profile) — for partnership development; event and training program data (registration details, training outcomes) — to organize and report on the Fund's projects.
Legal Basis for Processing
The Fund processes personal data on one of the following legal bases: the individual's freely given consent; the necessity to perform a contract or to take steps at the individual's request prior to entering into one; compliance with a legal obligation of the Fund; or the legitimate interest of the Fund or a third party (including conducting the Fund's statutory activities, ensuring the security of the Resources, and developing partnerships), provided such interest does not override the data subject's rights and freedoms.
Use of Personal Data
The data we receive is used to: review inquiries and provide responses; organize cooperation with partners and donors; process donations and maintain financial reporting; administer programs, events, and volunteer initiatives; send newsletters (subject to consent and an option to unsubscribe); ensure the security of the Resources; and comply with legal requirements and reporting to donors and government authorities.
Retention Period
Personal data is retained for as long as necessary to achieve the purpose for which it was collected, to perform a contract, to maintain reporting, or as required by the legislation of Ukraine, after which it is deleted or anonymized.
Sharing Your Information
To the extent permitted by law, we may share your information with: partner organizations and donors responsible for a specific area of cooperation; service providers (e.g., hosting, accounting support); government authorities, where required by law; in the event of the Fund's reorganization or dissolution; and where you have given your consent. The Fund does not sell personal data and does not share it with third parties for their own independent marketing purposes.
Links to Other Websites
The Fund's Resources may contain links to third-party websites. The Fund is not responsible for the data collection practices, security, or content of such third-party sites and recommends reviewing their privacy policies.
Cookies and Similar Technologies
If the Fund's website uses cookies, we may use essential cookies (to make the website work) and functional cookies (to remember your settings). We may also embed video (for example from YouTube), which loads third-party content only after you click the preview. You can manage cookies through your browser settings.
Data Protection
The Fund takes organizational and technical measures to protect personal data against unauthorized access, loss, or disclosure, including limiting access to staff and volunteers who need it to perform their duties. Despite these measures, no method of transmission over the internet is completely secure.
Your Rights Regarding Personal Data
Under the legislation of Ukraine and, where applicable, the GDPR, you have the right to: access your personal data; correct inaccurate data; request erasure (“the right to be forgotten”); restrict processing; data portability; withdraw consent at any time; object to processing carried out on the basis of legitimate interest; as well as to file a complaint with the authorities ensuring the protection of personal data.
Exercising Your Rights
To exercise your rights, please contact the Fund at co.icdf.ukraine@gmail.com. Your request should include enough information for us to verify your identity and a clear description of the action requested. We respond to requests within a reasonable time in accordance with applicable law.
Children's Information
The Fund's Resources are intended for adults, partner organizations, and the general public. The Fund does not knowingly collect personal data from individuals under the age of 18 without parental or legal guardian consent, except where directly necessary to implement the Fund's humanitarian or educational programs involving minors, and subject to additional safeguards.
Do Not Track Signals
Some browsers may transmit “Do Not Track” signals. The Fund does not currently take specific action in response to such signals.
Changes to this Policy
Due to changes in legislation, technology, or the Fund's activities, we may update this Policy from time to time. The current version is published on the Fund's official website, indicating the date of the last update.