PRIVACY POLICY

1.1. The Organization and its partners at all times seek to adhere to the best practice for business partnership and cooperation, ensuring that the trust placed in the Organization and its partners is justified, by taking a responsible approach to managing the User’s personal data in particular. 

1.2. These regulations of the Website’s Terms of Use, this Privacy Policy in particular, have been created by the Organization to inform individuals who are Users (and buyers of products or services) of the Website and its mobile versions/applications of the policies and procedures for the processing of Users’ personal data by the Organization.

1.3. The Organization manages and administers the Website, with these regulations, this Privacy Policy in particular, forming an integral part of the Website’s Terms of Use. 

1.4. This Privacy Policy has been developed in conformity with the law.

1.5. By visiting and using the Website, the User acknowledges and certifies that the User has read and understood, and agrees to be bound by, these regulations, and has been informed of the purpose, legitimate grounds, and other conditions of processing personal data in compliance with the law.

1.6. By using the Website, the User consents to the processing of the User’s personal data. The User confirms that the User has sufficient standing and capacity under the law to provide such consent. If the User lacks sufficient standing, a consent must be provided by the User’s legal representatives who have full civil capacity and are authorized to provide such consent. Otherwise, the Organization will apply the provisions of these regulations and the law, in particular the Law of Ukraine “On Protection of Personal Data.”

1.7. The Organization’s registration and contact information is provided in corresponding sections and parts (modules) of the Website. 

1.8. The terms used herein have the meanings given to such terms by the law, including the Law of Ukraine “On Protection of Personal Data.”

2.1. Information about the User (the “Information Data”). For example, the User’s name, surname and patronymic, e-mail and mobile (contact) phone number, the User-specified address and delivery method, and data for accessing the User’s (the buyer’s) personal account on the Website.

2.2. Information about the Product or the Service Selected by the User on the Website (the “Product Data”). For example, the name, quantity, type, technical specifications, and other details of the product selected by the User.

2.3. Information about the User’s Payment for the Product (the “Payment Data”). The Organization collects data on the User paying (transferring funds) for the product, as well as information aimed at combating fraud and money laundering. Such data are obtained from financial institutions (banks, payment services/tools) or by analyzing the User’s current account with a financial institution.

2.4. Information about Correspondence (Communication) with the User (the “Communication Data”). This category of data includes letters, comments, suggestions, complaints, including any content thereof (which may include photos, videos, audio, etc.), that the User sends via chats, e-mail, social networks, phone, and/or any other information about correspondence between the Organization and the User, in the form of electronic mails and/or regular letters and/or personal correspondence between the Organization and the User. If the User contacts the Organization by phone, the Organization stores the data of such a phone conversation with the User, which includes the phone number the User called from and the recording of the conversation.

2.5. Information about the User’s Participation in Contests/Events and/or Promotions held by the Organization (the “Participation Data”). The Organization collects personal data provided by the User in applications for participation and/or registration forms, as well as the history of the User’s participation in any contests/events and/or promotions held by the Organization.

2.6. Device Information and Technical Data (the “Automatically Collected Data”). Such data include the User’s IP address, data on the operating system of the User’s computer/mobile device and type of the User’s browser, type of the User’s mobile device, unique device identifier or identifier of the User’s mobile equipment, automatically processed cookies (those processed during uploads as well). Such data are collected both by the Website and by third-party tools of Analytics (including, but not limited to, Google Analytics, Cloudflare, etc.).  

2.7. Information about the User’s Visits to the Website (the “Website Usage Data”).The Organization collects data about the route that the User followed to access the Website, viewing the Website, moving from the Website to other websites (including date and time), pages of the Website viewed by the User, load time of the Website page/pages, errors when loading the pages, duration of the User’s visit to certain pages, as well as information about the interaction between the Website pages, which are processed automatically (when unloading as well).

2.8. Review Information (the “Review Data”). The Organization collects the User’s feedback and/or responses to marketing, advertising, or informational surveys, and/or research proposed by the Organization.

2.9. Discussion Information (the “Discussion Data”). The Organization may offer the User access to publicly available chats, forums, and/or discussions on the Website, where Users may post their own comments and/or discussions regarding the Organization’s activity, including those related to the purchased products, the organization and holding of contests/events and/or promotions by the Organization, or other matters. Such comments and discussions may contain information that falls under the definition of “personal data” under the applicable law.

2.10. Information Obtained from Third Parties (the “Third-Party Data”). There are cases where certain additional personal data of the User are collected from other sources, including partners, companies specializing in technical maintenance of information search providers, anti-fraud databases and/or other third-party databases, including sanctions (prohibition) lists, to the extent permitted by the law. Such data include, but not limited to, the following: a) information used to verify the authenticity of information about the User; b) information about the User’s capacity.

3.1. The lawful bases that are considered eligible in the context of processing the User’s personal data are the following:

3.1.1. Consent – if the User consents to the processing of personal data provided by the User (for example, the User will be offered a consent form as to the processing of the User’s personal data, as well as the possibility and method of withdrawing such consent).

3.1.2. Explicit Consent – if the User provides explicit consent to the processing of personal data provided by the User (for example, performing explicit and directed actions, including entering into a contract).

3.1.3. Legitimate Interests – if the User’s personal data are processed to ensure a legitimate interest (for example, carrying out one’s own activity, as defined by statutory documents, organizing and implementing projects/events, etc.).

3.1.4. Performance of an Agreement (a Contract) – if the processing of the User’s personal data is necessary to enter into and/or perform an agreement (contract) with the User.

3.1.5. Legal Obligations – if the processing of the User’s personal data is necessary for compliance with legal obligations as provided by the law.

3.1.6. Public Interests – if the processing of personal data is necessary in connection with intense interest among the public, as provided by the applicable law.

4.1. Depending on how the User interacts with the Website, the User’s personal data are processed for the following purposes:

4.1.1. Selling products or services to the User and arranging for such products or services to be delivered to the address specified by the User through delivery services. Without the Information Data and the Product Data, the Organization cannot complete the sale and the delivery of the products or services selected by the User. Lawful basis: performance of an agreement (a contract). By performing actions aimed at purchasing the selected products or services, the User accepts terms and conditions of the relevant public offer agreement, which serves as a form of agreement between the User and the Organization.

4.1.2. Preparing, organizing, and holding events, promotions, etc., that the User registers for, is already registered for through the Website, or participates in. The Organization uses the Information Data, the Participation Data, and the Communication Data (there are cases where certain categories of data may not be used, and any use of such data depends on the event) to enable the User to participate in such events, promotions, etc. Lawful basis: performance of an agreement (a contract). Without the above data, the Organization cannot arrange for the User’s participation in any events, promotions, etc. By participating in such events, promotions, etc., the User accepts the rules of participation, which serves as a form of agreement between the User and the Organization.

4.1.3. Verifying the User’s payment for products or services. Without the Payment Data, the Organization would not be able to verify the User’s payment for the selected product or service, and, as a result, the sale of the product or service would be impossible. Lawful basis: performance of an agreement (a contract).

4.1.4. Signing in the User in the User’s personal account on the Website for more convenient use of the Website. Lawful basis: consent.

4.1.5. Conducting information/advertising campaigns for the Website/the Organization. The Organization anonymizes (anonymization refers to the process of removing any identifiers and other data that may lead to the User being identified, both directly and indirectly) personal data and uses such data to conduct information and advertising campaigns, or for improvement thereof. Lawful basis: legitimate interests. It is in the legitimate interests of the Organization to conduct information/advertising campaigns.

4.1.6. Monitoring, reviewing, and analyzing events, promotions, etc., of the Organization, and the Website’s performance. The Organization uses the Participation Data, the Communication Data, the Information Data, the Review Data, and the Discussion Data to monitor, review, and analyze how the Organization holds its events, promotions, etc. Lawful basis: legitimate interests. It is in the legitimate interests of the Organization to monitor, review, and analyze the Organization’s events, promotions, etc.

4.1.7. Carrying out effective communication (including correspondence) with the User and keeping records thereof. The Organization uses the Communication Data to contact the User in connection with using the Website, purchasing products or services, participating in events, and in other cases where the situation may so require. Lawful basis: if any communication with the User is carried out outside the context of purchasing products or services, participating in events, or by another individual who contacts the Organization, legitimate interests are used (it is in the legitimate interests of the Organization to communicate with Users or other persons). If the communication takes place in the context of purchasing products or the User participating in events, the lawful basis is performance of an agreement (a contract). 

4.1.8. Providing (sending) marketing and/or information/advertising materials to Users who have signed in through the Website and provided appropriate consent and/or used the Website. Lawful basis: consent.

4.1.9. Complying with the requirements of the applicable law when receiving payment for products or services (including for protection of public interests, combating fraud and money laundering, investigation of crimes, fulfillment of requests made by government authorities, etc.). Lawful basis: legal obligations.

4.1.10. Managing, maintaining (as well as ensuring technical performance, providing technical support, improving the Website) and configuring the Website. Without the Automatically Collected Data and the Website Usage Data, the Organization would not be able to make the Website available to the User. If the User blocks (by using any technical means) the provision of such data to the Website, the Website may not function at all or may not function properly. Lawful basis: legitimate interests. This basis is in the legitimate interests of the Organization.

4.1.11. Processing requests from subjects of personal data. If the Organization receives a request from the User as a subject of personal data, the User’s personal data will be used to process the request. Lawful basis: legal obligations.

4.1.12. Protecting the Website. The Organization uses the Automatically Collected Data and the Website Usage Data to protect the Website from digital threats, DDoS attacks, and cyberattacks. Lawful basis: legitimate interests. It is in the legitimate interests of the Organization to protect the Website.

4.1.13. Analyzing and improving the Website’s performance. The Organization uses the Communication Data, the Review Data, the Discussion Data, the Automatically Collected Data, and the Website Usage Data to explore how the Website is used by its audience, and to improve the Website using such data. Lawful basis: legitimate interests. It is in the legitimate interests of the Organization to analyze and improve the Website’s performance.

4.1.14. Protecting the Organization from fraud, unfair practices, violation of the Organization’s interests, or violation of the terms established by the Organization. This goal also includes verification of any information provided by the User using the Third-Party Data. Lawful basis: legitimate interests. This goal is in the legitimate interests of the Organization. 

4.1.15. Formulating, exercising, or defending legal claims. The Organization retains the Participation Data, the Information Data, the Payment Data, the Communication Data, and the Third-Party Data for the duration of the statute of limitations to formulate, exercise, or defend legal claims. Lawful basis: legitimate interests. It is in the legitimate interests of the Organization to formulate, exercise, or defend legal claims.

5.1. Dissemination of the User’s Personal Data. Recipients of the User’s Data.

5.1.1. Partners of the Organization. For the purposes of the Organization’s activity, the User’s personal data may be disclosed to the Organization’s partners, including foreign ones. All such disclosures are protected by appropriate legal tools obliging the recipients to process personal data in compliance with these regulations and ensure that the personal data are not disclosed to third parties unless so required by the law.

5.1.2. IT Services Providers. The Organization may engage other companies (including foreign ones) that are providers of IT and administrative services, including hosting services, cloud services and databases, to process the User’s personal data on behalf of the Organization (controllers or processors), with the purpose of ensuring technical performance and proper operation of the Website, providing technical support and maintenance of the Website. Such companies may gain access to the User’s personal data only if this is necessary for the above purposes and according to the provisions on confidentiality contained in agreements with such companies, and may not use them for any other purpose.

5.1.3. Delivery Services (Postal Services). The Organization may engage delivery services (including foreign ones) that provide shipping services (packaging, handling, etc.) and delivery services, to deliver products or service deliverables to the address specified by the User solely for delivering purchased products or services. Such companies may gain access to the User’s personal data only if necessary for achieving the above goals.

5.1.4. Financial Institutions (Banks, Payment Services/Tools). The Organization may engage financial institutions (including foreign ones) that provide financial services, banking services, and payment services/tools, to facilitate money transfers (transactions) when the User pays for products or services. If the User is redirected, when transferring money, to the website/forms of such a financial institution (bank, payment service/tools), the User must review that financial institution’s policy for processing personal data. If the User provides the User’s personal data directly on the Website, such companies may gain access to the User’s personal data only if this is necessary for the above purposes and according to the provisions on confidentiality contained in agreements with such companies, and may not use them for any other purpose.

5.1.5. Analytics Providers. The Organization uses appropriate analytics tools. If the User wants to know how the holder of rights to the respective tool processes the User’s data, the User should review the respective privacy policies. The opt-out browser add-on allows visitors and users to prevent any collection and use of their data. 

5.1.6. Authorities (of Ukraine, the European Union, or Other Countries). The Organization may process (as well as disclose and/or communicate) any of the User’s personal data, if so required by any law of Ukraine or other regulations, or confirmed by lawful requests of public authorities and/or local governments, in order to comply with the laws of Ukraine, to protect the integrity of the Website, to fulfill requests of Users, public authorities and/or local governments, or to facilitate any investigations conducted by law enforcement agencies or investigations to ensure public (national) security. There are cases where the Organization may also provide the User’s personal data to the authorities of the European Union (both national and supranational) and other countries, if such provision of personal data is required by law or official request of such authority in criminal investigation or litigation. 

5.1.7. Other Users or Individuals that Have Access to Public Chats, Forums, and Discussions on the Website. By using publicly available chats, forums, or discussions on the Website, the User acknowledges that any personal data that the User publishes in the chats, forums, or discussions will become available to other users of the Internet.

6.1. The User of the Website that is a citizen or resident of Ukraine, or is not in the European Union (EU) or in the European Economic Area (EEA), has the rights provided under the Law of Ukraine “On Protection of Personal Data.” 

6.2. In order to exercise the User’s rights under the Law of Ukraine “On Protection of Personal Data” (which may be exercised by the Organization), the User may submit a request to the Organization, using the contact information provided in the corresponding section hereof.

6.3. Users of the Website that are in the European Union or in the European Economic Area have the following rights, which they can exercise by sending a request to the Organization, using the information provided in the corresponding section hereof:

6.3.1. Right to withdraw consent. If the User has consented to the processing of the User’s personal data, the User has the right to withdraw consent at any time. The Organization notes that no withdrawal of consent affects the lawfulness of the processing based on consent prior to its withdrawal.

6.3.2. Right of access. The User has the right to obtain from the Organization confirmation as to whether or not the User’s personal data are being processed by the Organization: the User has the right to send a request asking if the Organization is processing the User’s personal data. If the Organization does process the User’s personal data, the User may receive a copy of all of the User’s personal data being processed by the Organization (except where the law restricts it).

6.3.3. Right to rectification. The User has the right to obtain from the Organization the rectification of inaccurate or no longer relevant personal data. If the User’s personal data are incomplete, the User has the right to the right to have these data completed by means of providing a supplementary statement.

6.3.4. Right to erasure (“right to be forgotten”). The User has the right to have the User’s personal data deleted where at least one of the following grounds applies:

6.3.4.1. The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

6.3.4.2. The User withdraws consent to the processing of the User’s personal data;

6.3.4.3. The User objects to the processing relying on the right to object to the processing and there are no overriding legitimate grounds for the processing;

6.3.4.4. The User expresses an objection to the processing of the User’s personal data for direct marketing purposes;

6.3.4.5. The processing of personal data is unlawful;

6.3.4.6. Personal data should be erased for compliance with a legal obligation of the Organization;

The right to erasure does not apply in the following circumstances: 1) the User’s personal data are necessary to exercise the right of freedom of expression and freedom of information; 2) the User’s personal data must be stored for compliance with any legal obligation to which the Organization is subject; 3) personal data are stored for the establishment, exercise, or defense of legal claims; 4) in other cases provided for by the applicable law.

6.3.5. Right to object to processing. The User may object, on grounds relating to a particular situation, at any time, to the processing of the User’s personal data on the lawful basis of the legitimate interests of the Organization or a third party. If this right is exercised, the Organization must no longer process the User’s personal data unless the Organization demonstrates compelling legitimate grounds for the processing that override the User’s interests and rights, or for the establishment, exercise, or defense of legal claims. 

6.3.6. Right to restriction of processing. The User has the right to restriction of processing. This means that the User’s personal data will be temporarily transferred to another file system (in fact, it will be “frozen” for as long as the right to restriction of processing is being exercised). The right to restriction of processing may be exercised where the following applies: 

6.3.6.1. The User contests the accuracy of the User’s personal data, during a period enabling the Organization to verify the accuracy of the User’s personal data;

6.3.6.2. The processing is unlawful and the User opposes the erasure (relying on the right to erasure) and instead requests that the processing be restricted; 

6.3.6.3. The Organization no longer needs the User’s personal data for the purposes of processing, but they are required by the User for the establishment, exercise, or defense of legal claims; 

6.3.6.4. The User objects to the processing relying on the right to object to processing pending the verification whether the Organization’s legitimate grounds override the User’s legitimate interests and rights.

6.3.7. Right to data portability. The User has the right to receive the User’s personal data that the User has previously provided, in a structured, commonly used and machine-readable format, and the right to transmit such data to another controller (company, organization, etc.). This right applies to any personal data that:

6.3.7.1. has been collected on the following legitimate grounds: consent/explicit consent and/or performance of an agreement.

6.3.7.2. has been collected by automated means.

6.3.8. Right to file a complaint to a supervisory authority. If the User believes that the User’s personal data has been processed in violation of the applicable law, the User may file a complaint to a supervisory authority. Such an authority may be: a) Commissioner for Human Rights of the Verkhovna Rada of Ukraine; b) for the persons that are in the European Union or in the European Economic Area, a supervisory authority in any EU/EEA member state at the User’s permanent place of residence, the User’s place of work. The User may also file a court complaint or claim.

7.1. Cookies are text files that the Website sends to the User’s computer or other device connected to the Internet solely in order to recognize the User’s computer/device, as well as to allow the User to easily browse various pages of the Website, save settings, and generally improve interaction with the User.

7.2. By using the Website, the User agrees to the use of cookies by the Website under these regulations. When accessing the Website for the first time, the User will see a pop-up window regarding the use of cookies and provision of consent to the use of cookies.

7.3. Session cookies are deleted automatically when the User’s browser is closed, but persistent cookies remain on the User’s device even after the User’s browser is closed (for example, to remember the User’s settings after returning to the Website).

7.4. The Organization may use the following cookies:

7.4.1. Strictly necessary cookies (that are essential to browse the Website and use their functionality).

7.4.2. Performance cookies (that are analytical cookies used to analyze how visitors use the Website and to control the Website’s performance).

7.4.3. Functionality cookies (that are used to provide the User with certain functionality).

7.4.4. Targeting cookies (that collect information on how the User browses the Website pages, which are related to the User’s device, and are used to make advertising more relevant to the User and the User’s interests).

7.4.5. Flash (that are used to improve the User’s interaction with the Website, for example, saving the User’s preferences and settings).

7.5. If the User does not agree to the use of cookies on the Website, the Organization recommends disabling them, by following the instructions of the User’s browser, or stop using the Website immediately, should it be impossible to disable cookies for any reason.

7.6. The Organization notes that some usage modes of the Website and the services provided on the Website may operate with certain abnormalities, or may not operate at all, when disabling cookies.

8.1. Protection of the User’s Personal Data. The Organization takes all necessary technical, organizational, and administrative measures to ensure the reliable processing of the User’s personal data in compliance with these regulations and the applicable law. Once the Organization receives the User’s personal data, the Organization assumes an obligation to apply strict procedures and safeguards to prevent any unauthorized access to such personal data by third parties; in particular, the Organization uses appropriate encryption protocols to ensure that personal data are transmitted securely. 

8.2. Protection of Personal Data of Minors. Consent to the processing of personal data of the Website User may be provided by any User who has reached the appropriate age and possesses the necessary legal capacity. Otherwise, such consent to the processing of personal data must be provided by the User’s legal representatives. If the User’s legal representatives communicate (in particular, make an inquiry/deliver a request) the absence of consent and/or it is discovered that the User’s personal data has been provided by an individual who should have obtained the consent of his/her legal representatives, the Organization will immediately delete all personal data provided by such an individual.

8.3. Retention Period for Personal Data. The User’s personal data that the Organization processes will not be retained longer than permitted by the applicable law and will be stored only as long as necessary to enable the User to purchase, exchange, and/or return products or services, to participate in events, promotions, etc., to provide any requested services or information posted (available) on the Website, or for other purposes set out in these regulations. 

8.4. Place for Storing Personal Data. Any personal data that the Organization collects from the User may be transferred and stored outside of Ukraine. Any transfer or storage of the User’s personal data is carried out in compliance with the provisions of these regulations, the applicable law, as well as the requirements to protection of such personal data (including contractual ones) and regional (local) laws.

This Public Offer for the Provision of Charitable Assistance (hereinafter – Offer) is addressed to an indefinite number of legal entities under private law (non-public) (hereinafter – Donor), who are visitors of the website https://www.molfar.institute (hereinafter – Website) and wish to provide charitable assistance in the form of a charitable donation in favor of the Non-Governmental Organization “OSINT”, identification code 45618511 (hereinafter – NGO) and constitutes a public offer of the NGO to enter into an agreement for the provision of charitable assistance (hereinafter – Agreement) under the terms and conditions specified below.

9.1. Definitions and Terms

9.1.1. Offer – a valid proposal by the NGO, published on the Website, to provide charitable assistance to the NGO in the form of a charitable donation, addressed to an indefinite number of capable individuals and private legal entities.

9.1.2. Acceptance – full and unconditional acceptance of the Offer by performing actions related to the transfer of funds as a charitable donation through payment systems (services, forms) and tools available on the Website, and/or by transferring funds as a charitable donation to the NGO’s current account through banking institutions.

9.1.3. Charitable Donation – gratuitous transfer (remittance) of funds by the Donor to the ownership of the NGO for the achievement of the NGO’s goals and objectives.

9.1.4. Donor – any capable individual and/or private legal entity.

9.2. Subject

9.2.1. The subject of this Agreement is the gratuitous and voluntary transfer by the Donor to the NGO of charitable assistance, namely a charitable donation in the form of monetary funds through voluntary contributions for the implementation of the NGO’s goals and objectives.

9.2.2. The amount and size of charitable donations shall be determined by the Donor independently at their own discretion.

9.2.3. The NGO independently determines the purposes and areas of use of the charitable assistance received within the framework of the NGO’s goals and objectives, unless otherwise agreed upon by the Donor and the NGO through the conclusion of a separate agreement.

9.2.4. The purpose of this Agreement is not to generate profit for either Party. The performance of this Agreement and the provision of charitable assistance to the NGO is not intended to generate (direct or indirect) profit.

9.2.5. The Donor’s acceptance of the Offer and confirmation of the conclusion of this Agreement shall be the Donor’s execution of the Acceptance (payment/transfer of a charitable donation by the Donor in favor of the NGO).

9.2.6. The Donor’s charitable assistance is voluntary and non-refundable, and does not entail the provision of any benefits to the Donor in exchange for the charitable assistance. The Donor has the right to specify the intended purpose of their charitable assistance by concluding a separate agreement with the NGO on the provision of charitable assistance. If the Donor specifies the intended purpose of the charitable assistance without prior coordination with the NGO and without concluding a separate agreement on the provision of charitable assistance, the NGO has the right to use such charitable assistance at its own discretion within the scope of its goals and objectives, or to return such charitable assistance to the Donor’s current account provided by the Donor upon the NGO’s request or specified by the Donor during the Acceptance process.

9.2.7. The NGO directs the charitable assistance, namely the charitable donation in the form of monetary funds, toward achieving the goals and objectives of the NGO. The NGO does not aim to generate profit. Part of the charitable assistance may be used by the NGO for administrative expenses in accordance with the current legislation of Ukraine.

9.3. Acceptance of the Offer and Transfer of Charitable Assistance

9.3.1. Acceptance of the Offer (agreement to the terms of the Offer) means that the Donor agrees to all terms of the Offer, the subject of the Agreement, the goals and objectives of the NGO’s activities, and the purpose and objectives of receiving and using charitable assistance by the NGO. The Offer is considered accepted from the date the funds are credited to the NGO’s current account.

9.3.2. By accepting the Offer, the Donor confirms and agrees that they have read and understood all the terms of this Agreement, the subject of the Agreement, the NGO’s activities, as well as the goals and objectives of the NGO and the purpose of receiving and using charitable assistance by the NGO.

9.3.3. By accepting the Offer, the Donor confirms and agrees that from the moment of Acceptance, this Agreement is considered concluded. At the same time, the Parties agree that failure to conclude this Agreement in the form of a separate document does not invalidate this Agreement after the Donor accepts the Offer.

9.3.4. The provision of charitable assistance by the Donor, namely a charitable donation in the form of monetary funds, is carried out in non-cash form by transferring funds in Ukrainian hryvnia to the NGO’s current account. The Donor independently chooses the payment format on the Website: a one-time payment or a recurring/monthly payment. In the case of selecting a recurring/monthly payment, the corresponding amount of funds will be debited monthly from the Donor’s account in the amount independently chosen by the Donor. The Donor has the right to cancel recurring/monthly payments by notifying the NGO. When making a charitable donation in the form of monetary funds, the Donor may choose one of the payment methods offered by the NGO on the Website. At the same time, the Donor understands and agrees that the NGO may define only one payment method on the Website (transfer of funds as a charitable donation).

In the event of initiating a payment (transfer of funds as a charitable donation) in foreign currency, the amount in hryvnia to be paid/credited to the NGO’s current account is determined based on the cash or card exchange rate (at the NGO’s discretion) of the hryvnia to the US dollar, set on the payment date by the payment system (payment service). If the payment (transfer of funds as a charitable donation) in foreign currency is initiated from foreign bank cards, the payment system (payment service) and/or bank will carry out currency conversion (exchange) to credit the donation in hryvnia. In this case, the conversion is carried out according to the rules of the respective payment system (payment service) and/or bank for crediting the charitable donation in hryvnia to the NGO’s account.

When making a payment (transfer of funds as a charitable donation) through the payment system (payment service) on the Website, the Donor will be shown on the payment page the amount in the equivalent of the foreign currency (in case of initiating a payment/transfer in foreign currency) and the amount and currency of authorization during the payment process (amount in hryvnia). By choosing the appropriate method of payment (transfer of funds as a charitable donation), the Donor agrees to the procedure and terms of payment, as well as the cost of services (commission fee) of the respective payment system/service or operator or bank.

When paying (transferring funds as a charitable donation) using a payment card, including through any payment system (payment service) (if such payment method is defined on the Website), a fee may be charged by the issuer of the card and/or the bank and/or payment system (payment service), and/or an additional fee may be charged for currency conversion. By accepting the Offer, the Donor understands and confirms that the NGO has informed the Donor about the possibility of fees being charged by the card issuer and/or bank and/or payment system (payment service) during the payment (transfer of funds as a charitable donation) and/or additional fees for conversion.

The charitable donation does not include any fees/service costs of the respective payment system/service or operator or bank (including for conversion). All expenses for additional fees/services of the payment system/service or operator or bank shall be borne by the Donor.

9.4. Location of Public Fundraising

9.4.1. Public fundraising of charitable donations is carried out in the territory of any country in the world. The direct activities of the NGO related to achieving its goals and objectives are conducted within the territory of Ukraine (excluding the temporarily occupied territories of Ukraine).

9.5. Term of Charitable Fundraising

9.5.1. Public fundraising of charitable donations (funds) shall continue until the liquidation of the NGO, unless another term is determined by the NGO, in which case the Donor will be informed by the publication of relevant information on the Website.

9.6. Use of Charitable Assistance

9.6.1. The NGO uses the Donor’s charitable donation in accordance with the current legislation of Ukraine to achieve the NGO’s goals and objectives.

9.6.2. The NGO has the right to independently determine the directions for the use of the charitable donation and to manage it at its own discretion in accordance with its statutory activities and the legislation of Ukraine.

9.6.3. The Donor’s charitable donation is non-refundable under any circumstances, unless otherwise decided by the NGO.

9.6.4. The Donor’s charitable donation is indefinite, and the term of its use by the NGO is not limited.

9.6.5. A portion of the charitable donation may be used by the NGO for administrative expenses in accordance with the current legislation of Ukraine.

9.6.6. In the case of targeted special projects organized by the NGO, public fundraising of charitable donations shall be conducted within the period specified in the relevant announcement on the Website regarding public fundraising for a specific purpose and goal. By accepting the Offer, the Donor confirms that the NGO, in any case, has the right to reallocate a specific targeted charitable donation to other purposes of the NGO’s activities.

9.7. Rights and Obligations of the Parties

9.7.1. The NGO has the right to:

9.7.1.1. Receive charitable assistance and use it at its own discretion in accordance with the terms of this Agreement;

9.7.1.2. In compliance with the current legislation of Ukraine, use part of the charitable donation for the NGO’s administrative expenses without the Donor’s approval;

9.7.1.3. Change the purposes of using the charitable donation within the scope of the NGO’s goals and objectives;

9.7.1.4. Unilaterally amend the Offer/Agreement without the Donor’s consent;

9.7.1.5. Exercise other rights provided for in this Agreement and/or the current legislation of Ukraine.

9.7.2. The NGO is obligated to:

9.7.2.1. Use the charitable donation to achieve the NGO’s goals and objectives in accordance with the provisions of this Agreement, with the possibility of using part of the charitable donation for administrative expenses;

9.7.2.2. Not disclose confidential information received from the Donor without the Donor’s consent, except in cases specified by this Agreement and/or the current legislation of Ukraine.

9.7.3. The Donor has the right to:

9.7.3.1. Transfer/pay a voluntary charitable donation to the NGO;

9.7.3.2. Contact the NGO to obtain information regarding the NGO’s activities and the use of the charitable donation;

9.7.3.3. Exercise other rights provided for in this Agreement and/or the current legislation of Ukraine.

9.7.4. The Donor is obligated to:

9.7.4.1. Familiarize themselves with all provisions and terms of the Agreement, as well as with information about the NGO and its activities prior to Acceptance;

9.7.4.2. Independently monitor changes to the Offer/Agreement (new version of the Offer/Agreement) on the Website;

9.7.4.3. Not disclose confidential information received from the NGO without the NGO’s consent, except in cases specified by this Agreement and/or the current legislation of Ukraine.

9.8. Liability of the Parties

9.8.1. In the event of non-fulfillment or improper fulfillment of their obligations, the Parties shall bear liability in accordance with the current legislation of Ukraine and the terms of this Agreement.

9.8.2. All disputes, disagreements, or claims arising out of or in connection with this Agreement, including those related to its performance, breach, termination, or invalidity, shall be resolved by the Parties through negotiations. If an agreement cannot be reached, the matter shall be resolved in the appropriate court in accordance with the current legislation of Ukraine.

9.9. Confidentiality and Personal Data Protection

9.9.1. By accepting the Offer, the Donor confirms that they are informed of and consent to the collection and processing of their personal data (for legal entities – personal data of authorized persons) in accordance with the Law of Ukraine “On Personal Data Protection.”

9.9.2. The processing of personal data is carried out for commercial, administrative, accounting, management, and tax purposes, as well as for sending the Donor, via telecommunications (email, mobile communication), promotional and special offers, and information about the NGO’s activities.

9.9.3. The Donor grants the right to process their personal data (for legal entities – personal data of authorized persons), including but not limited to placing such data into databases (without additional notification), lifelong storage of the data, accumulation, updating, and modification (as needed). The NGO undertakes to protect such data from unauthorized access by third parties and not to disclose or transfer the data to any third party, except in cases of transfer to affiliated persons, persons authorized by the NGO to directly process the data, upon mandatory request of a competent state authority, or in other cases provided for in this Agreement and/or under the applicable legislation of Ukraine.

9.9.4. The NGO shall not be held liable for the disclosure of personal data that occurred as a result of unlawful actions by third parties or if such disclosure occurred with the consent of the Donor.

9.10. Term of Validity

9.10.1. The Offer becomes effective from the moment it is published on the Website and remains in force until the liquidation of the NGO, unless otherwise determined by the NGO. The Agreement is considered concluded from the moment the Donor accepts the Offer. This Agreement remains in effect until full fulfillment of the Parties’ obligations, except in cases of early termination.

9.10.2. This Agreement may be terminated by mutual consent of the Parties and in other cases provided for in this Agreement and/or under the current legislation of Ukraine.

9.11. Other Terms

9.11.1. The law applicable to this Agreement is the law of Ukraine.

9.11.2. On all matters not provided for in this Agreement, the Parties shall be governed by the current legislation of Ukraine.

9.11.3. The NGO has the right, at any time and without the Donor’s consent, to unilaterally make changes to the Offer/Agreement, which shall become effective from the moment of their publication on the Website (as separate amendments or as a new version of the Offer/Agreement) and shall apply to the relationship between the NGO and the Donor who accepted the Offer after such publication.

9.11.4. In the event of force majeure, the Parties shall be released from liability for failure to fulfill the terms of this Agreement for the duration of such circumstances. For the purposes of this Agreement, force majeure shall mean extraordinary and unforeseen events that objectively prevent the fulfillment of the obligations under this Agreement and that occurred after the conclusion of the Agreement. The Party unable to fulfill its obligations due to force majeure must notify the other Party in writing within 15 days of the beginning or end of such circumstances.

9.11.5. The NGO has the right to send letters, notifications, and materials, including advertising, to the Donor’s postal address and email, as well as to send SMS messages and make phone calls to the phone number provided by the Donor.
If the Donor does not wish to receive such communications, they have the right to contact the NGO by submitting a request to opt out of receiving advertising and other materials, by sending the request to the NGO’s postal or email address.

9.12. NGO Contact Information

NON-GOVERNMENTAL ORGANIZATION “OSINT”
Identification Code: 45618511
Ukraine, 04123, Kyiv, Mezhova Street, Building 23

Tel.: +380932900887

Email: institute@molfar.com

10.1. Links to Other Websites. On the Website, the Organization may provide and post links to websites/social networks (media platforms) that are not owned by the Organization and/or its partner companies. If the User intends to use the mentioned websites/ social networks (media platforms) by following such links, the User must review their privacy policies and operational principles; in particular, regarding the collection and processing of personal data of Users. The Organization is not liable for the policies and practices of other companies, and any information the User provides to such companies is subject to their privacy policy or other documents governing the processing of personal data.

10.2. Modifications to this Policy. These regulations become effective on April 28, 2025. The Organization may modify this Policy from time to time. The User’s continued use of the Website, after the modifications to these regulations became effective, means that the User has read, understood, and agrees to, the modified version of these regulations.

10.3. Sending Marketing, Information/Advertising Materials to the User. 

10.3.1. From time to time, with the User’s prior consent, the Organization may send the User marketing, informational/advertising notices and materials on the new (the updated list of) products or services, as well as the Organization’s events, promotions, etc.

10.3.2. If the User does not consent to receive such materials, the Organization will not send such messages and/or materials to the User.

10.3.3. From time to time, with the User’s prior consent, the Organization may send marketing, informational/advertising materials on behalf of its partner companies about products or services that are planned for sale and/or events that are planned to be held, and that may be of interest to the User.  

10.3.4. If the User consents to receive marketing, information/advertising materials of the Organization’s partner companies, the Organization will not disclose (communicate) the User’s personal data to the partner companies, but will only send such User marketing, information/advertising materials on behalf of the partner companies.

10.4. In this case, the User consents/dissents to receive marketing, information/advertising materials and has the right to withdraw such consent/dissent in the future or provide an objection to receiving them by contacting the Organization using the contact information specified in the corresponding section or using information/advertising materials interface (the unsubscribe button, etc.).