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Privacy Policy and Personal Data Processing

Effective date: 22 September 2026. Last updated: 22 September 2026

GENERAL INFORMATION

1. The NGO “PRO PI EM PROSVITA FUND” (“PRO PM PROSVITA FUND”), which runs the “Libraries for everyone” programme — hereinafter also “the Organisation”, “we”, “us” — takes the protection of the personal data of the programme website’s users seriously.

2. Please read this Privacy and Personal Data Processing Policy, hereinafter “the Policy”, to learn:

  • what personal data we collect;
  • the purposes we use it for;
  • the legal grounds on which we process it;
  • who the data may be shared with;
  • how long it is stored;
  • what rights the user has;
  • how to contact us regarding your personal data.

3. The Policy has been drawn up with regard to the Law of Ukraine “On Personal Data Protection” and other applicable legal acts of Ukraine.

TERMS AND DEFINITIONS

4. In this Policy the terms are used with the following meaning:

4.1. “Website” or “Site” means the information resource of the “Libraries for everyone” programme located at librariesforall.pro, together with its pages, forms, files, information materials and other functional elements.

4.2. “Site Owner” means the legal entity that maintains the Site and determines the rules of its use:

NGO “PRO PI EM PROSVITA FUND” (“PRO PM PROSVITA FUND”)

USREOU code: 45821140

Registered address: 201-203 Kharkivske shose, building 1A, letter “Yu”, Kyiv, 02121, Ukraine.
Email: prosvita_fund@propm.pro
Phone: +38 (067) 286 20 62.

4.3. “Personal data controller” means a natural or legal person who determines the purpose of processing personal data, the composition of that data and the procedure for processing it.

The controller of the personal data collected through the Site is the NGO “PRO PI EM PROSVITA FUND” (“PRO PM PROSVITA FUND”), unless expressly stated otherwise at the moment of collection.

4.4. “Personal data processor” means a natural or legal person to whom the controller has granted the right to process personal data on its behalf.

4.5. “User” means any natural person who visits the Site, views its materials, uses its features or provides information through forms, email or other available channels.

4.6. “Personal data” means information or a set of information about a natural person who is identified or can be specifically identified.

4.7. “Processing of personal data” means any action or set of actions concerning personal data, in particular its collection, registration, accumulation, storage, adaptation, modification, renewal, use, transfer, depersonalisation or deletion.

4.8. “Site services” means the features of the Site available to users, in particular viewing information materials, submitting contact and partnership forms, downloading documents, subscribing to news and following links to external resources.

4.9. “Cookies” means small text files that may be stored on the User’s device while visiting the Site.

SCOPE OF THE POLICY

5. This Policy applies to personal data processed during:

  • visits to the Site;
  • viewing the Site’s materials;
  • use of the features available on the Site;
  • submission of the contact form;
  • submission of a partnership request;
  • contacting the programme team;
  • subscription to news or information materials, where such a feature is available;
  • further communication after a request has been received through the Site.

6. Use of the Site means that the User has read this Policy, understands its content and agrees to the conditions of personal data processing set out in it.

If the User does not agree with the terms of the Policy, the User must stop using the Site and must not provide personal data through forms, email or other available channels.

Where the law or the nature of the processing requires separate consent — in particular for submitting a form, receiving a newsletter or using optional cookies — such consent is requested separately through an active action by the User.

7. Continued use of the Site after an updated version of the Policy has been published means that the User has read the changes.

If the changes materially affect the way personal data is processed or require new consent, the Organisation notifies users separately and, where necessary, requests the User’s consent again.

8. This Policy does not cover data processing by third-party websites, social networks or services that may be linked from the Site.

When following a link to an external resource, the User should read the privacy policy of its respective owner.

AGE OF USERS

9. The contact and partnership forms on the Site are intended for independent use by persons aged 16 and over.

10. We do not knowingly collect personal data of children under 16 through the Site without the involvement and consent of parents or legal guardians.

11. If we become aware that a child’s personal data has been provided through the Site without proper consent, we will take steps to stop processing it and to delete it.

WHAT PERSONAL DATA WE COLLECT

12. Through contact forms, the “Join the programme” form, email or other communication channels we may collect:

  • first name and surname;
  • the name of the community, library, organisation or company;
  • position or field of activity;
  • email address;
  • phone number;
  • the selected type of cooperation;
  • the text of the message, proposal or request;
  • other information the User provides voluntarily.

13. While the Site is being visited, technical data may be collected automatically:

  • IP address;
  • browser type and version;
  • device type;
  • operating system;
  • browser language;
  • date and time of the visit;
  • pages viewed;
  • the source of the visit to the Site;
  • cookie identifiers;
  • technical logs of the Site.

14. The exact composition of the technical data depends on the services actually used for hosting, administration, analytics and protection of the Site.

15. We do not intend to collect through the Site:

  • passport data;
  • taxpayer registration numbers;
  • bank details;
  • health information;
  • biometric data;
  • information about political, religious or philosophical beliefs;
  • other special categories of personal data.

Please do not include such information in free-text form fields or messages.

PURPOSE OF COLLECTING AND PROCESSING DATA

16. We may process personal data in order to:

  • receive and consider requests;
  • provide answers to Users;
  • review partnership proposals;
  • communicate with communities, libraries, architects, donors, media and other interested parties;
  • organise cooperation within the programme;
  • inform about opportunities to join;
  • organise events, consultations or working meetings;
  • send news, subject to separate consent;
  • keep the Site running and secure;
  • analyse traffic;
  • improve the content, structure and functionality of the Site;
  • comply with legal requirements;
  • protect the rights and legitimate interests of the Organisation.

17. We do not use personal data for purposes incompatible with the purpose for which it was collected.

LEGAL GROUNDS FOR PROCESSING

18. Personal data may be processed on the basis of:

  • the User’s consent;
  • the need to consider a request;
  • the need to take steps before cooperation begins;
  • the conclusion and performance of agreements;
  • compliance with obligations provided for by law;
  • the need to protect the legitimate interests of the Organisation or third parties, where the User’s rights do not override those interests.

Consent is one of the legal grounds for processing personal data, but it is not the only possible ground.

19. Where processing is based on consent, the User has the right to withdraw it at any time.

20. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

PROVIDING DATA THROUGH FORMS

21. By submitting a form on the Site, the User confirms that they:

  • have read this Policy;
  • understand the purpose of the processing;
  • provide current and accurate information;
  • have the right to share the data provided;
  • agree to the use of the data to consider the request and for further communication.

22. The User is responsible for the accuracy of the data provided through the Site.

23. If the User provides another person’s personal data, the User must have lawful grounds for such a transfer.

INFORMATION AND MARKETING MESSAGES

24. We may send information about the programme, news, events, partnership opportunities and results of the pilot projects only where there is an appropriate legal ground.

25. Where consent is required to send such materials, it is requested separately from consent to process the contact form.

26. The newsletter consent checkbox:

  • must not be pre-ticked;
  • must not be a mandatory condition for submitting an ordinary request;
  • must contain a clear explanation of the materials the User will receive.

27. The User may opt out of information messages:

  • via the “Unsubscribe” link in the email;
  • by writing to prosvita_fund@propm.pro.

28. Even after opting out of the newsletter, we may send service messages necessary to answer a request or to arrange agreed cooperation.

COOKIES AND ANALYTICS TECHNOLOGIES

29. The Site may use cookies and similar technologies in order to:

  • keep the Site working correctly;
  • remember settings;
  • maintain security;
  • analyse traffic;
  • assess the effectiveness of information materials;
  • improve the user experience.

30. Cookies may be:

  • strictly necessary;
  • functional;
  • analytical;
  • marketing.

31. Optional analytical and marketing cookies are activated according to the User’s choice.

32. The User may change that choice through the cookie settings on the Site or in the browser.

33. The actual list of cookies must contain:

  • the name;
  • the provider;
  • the purpose;
  • the lifetime;
  • the category.

TRANSFER OF DATA TO THIRD PARTIES

34. To keep the Site running and to handle requests, data may be transferred to:

  • the hosting provider;
  • developers and technical administrators of the Site;
  • email and cloud service providers;
  • analytics systems;
  • a CRM or a system that stores requests;
  • services used to send information materials;
  • consultants and contractors involved in running the programme;
  • state authorities in the cases provided for by law.

35. Third parties receive access only to the information necessary to perform the defined functions.

36. Contractors and providers that process data on our behalf must comply with confidentiality and security requirements.

37. We do not sell Users’ personal data.

TRANSFER OF DATA OUTSIDE UKRAINE

38. Some providers of cloud, email, analytics or technical services may store or process information on servers located outside Ukraine.

39. Where such a transfer takes place, the requirements of the law and the personal data protection measures provided by the respective services apply.

PERSONAL DATA RETENTION PERIOD

40. Personal data is stored no longer than is necessary to achieve the purposes of processing or to comply with legal requirements.

41. Indicative retention periods:

  • contact requests: up to 12 months after the communication ends;
  • partnership requests: for the period of consideration and up to 24 months after the last communication;
  • partner data: for the term of cooperation and for the period required to fulfil legal and reporting obligations;
  • newsletter data: until consent is withdrawn or the User unsubscribes;
  • technical logs: according to the periods set by the providers of the respective services and by internal security rules.

42. The actual periods must correspond to the Organisation’s real processes and to the settings of its technical systems.

STORAGE AND PROTECTION OF DATA

43. We apply organisational and technical measures to protect personal data against:

  • unauthorised access;
  • improper use;
  • unlawful transfer;
  • accidental loss;
  • alteration;
  • damage;
  • destruction.

44. Access to personal data is granted only to employees, consultants and contractors who need it to perform their professional duties.

45. Persons who receive access to personal data must comply with confidentiality requirements.

46. We review the protection measures applied, taking into account the development of technology, the risks and the nature of the data processed.

47. No method of transmitting or storing information on the internet can guarantee absolute protection.

RIGHTS OF THE USER

48. The User has the right to:

  • know the sources of collection and the location of their personal data;
  • receive information about the purpose and conditions of its processing;
  • know which third parties their data is transferred to;
  • obtain access to their personal data;
  • demand the correction of inaccurate or outdated information;
  • object to processing in the cases provided for by law;
  • demand the modification or deletion of data if it is processed unlawfully or is inaccurate;
  • withdraw consent;
  • lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights;
  • apply to a court;
  • use other remedies provided for by law.

The list and content of the rights of a personal data subject are explained at https://ombudsman.gov.ua/uk/zahist-personalnih-danih-faq.

HOW TO CHANGE OR DELETE DATA

49. The User may submit a request to:

  • provide information about the data being processed;
  • clarify or update the data;
  • correct inaccurate data;
  • delete the data;
  • restrict processing in the cases provided for by law;
  • withdraw consent;
  • stop receiving information messages.

50. Requests can be sent to:

prosvita_fund@propm.pro

51. The request should state:

  • the applicant’s first name and surname;
  • a contact email address;
  • the substance of the request;
  • information sufficient to identify the data the request concerns.

52. To prevent the unlawful disclosure or deletion of information, we may ask the applicant to confirm their identity.

53. Requests are handled within the periods established by the legislation of Ukraine.

54. Certain data may be retained after a deletion request is received, where this is necessary for:

  • fulfilling legal obligations;
  • protecting the rights of the Organisation;
  • keeping the required records;
  • considering or preventing disputes;
  • other purposes expressly provided for by law.

THIRD-PARTY SITES AND SOCIAL NETWORKS

55. The Site may contain links to:

  • partner websites;
  • Facebook;
  • Instagram;
  • LinkedIn;
  • YouTube;
  • other external resources.

56. We do not control how personal data is processed on third-party resources.

57. Before using such resources, we recommend reading their privacy policies.

CHANGES TO THE POLICY

58. We may update this Policy in connection with:

  • changes in legislation;
  • the development of the Site;
  • the addition of new services;
  • changes in the way data is processed;
  • improvements to security measures.

59. The current version of the Policy is published on this page, stating the date of the last update.

60. In the event of material changes, we may additionally notify Users through the Site or the available communication channels.

CONTACTS REGARDING PERSONAL DATA PROTECTION

61. For matters related to the processing and protection of personal data, please contact:

NGO “PRO PM PROSVITA FUND”

Email: prosvita_fund@propm.pro
Phone: +38 (067) 286 20 62
Registered address: 201-203 Kharkivske shose, building 1A, letter “Yu”, Kyiv, 02121, Ukraine.
Postal address: UNIT.City, building B10, 3 Dorohozhytska St, Kyiv, 04112, Ukraine.