The Pravovsim platform, owned by the Danish Refugee Council in Ukraine (hereinafter referred to as "DRC"), pays special attention to protecting your privacy. Our main goal is to ensure your rights and protect your personal data. We collect and process your data for the sole purpose of providing and facilitating access to legal aid.
This Privacy Policy describes in detail the processes of collecting, using and disclosing personal information that you provide when using Pravovsim and its services. It also provides comprehensive information on your legal protections and options related to the processing of personal data by our platform.
This document contains key information about your rights and we recommend that you read it carefully before using the Pravovsim digital platform.
DRC is committed to processing your personal data in accordance with Загального регламенту Європейського Союзу щодо захисту даних 2016/679-GDPR (далі – GDPR) and local data protection regulations in force in the country where personal information is processed. Thus, DRC acts as a data controller.
Whenever this Policy refers to "DRC", "Pravovsim", "we", "us" or "our", it refers to Danish Refugee Council in Ukraine ([email protected])
In order to work, Pravovsim may request users to provide personal information. Without this information, Pravovsim may not be able to provide you with the services and assistance it is intended to provide. DRC is fully aware of the risks associated with data collection. That is why DRC is committed to protecting the privacy and security of your personal data on the Pravovsim platform.
Permission or requirement of national legislation
DRC may process user information in accordance with national legislation.
Legitimate interest
DRC may process personal information to satisfy legitimate interests, such as (but not limited to): managing user accounts, mailing lists, security incidents, communicating with partners and donors.
Agreement
In the absence of legal grounds, contractual relationships or legitimate interest, DRC requests your consent when processing personal information. Consent must be given freely and consciously.
The personal information we collect and how we use it
We collect ‘personal information’ from two sources:
We collect, process, store and transfer different types of personal information depending on whether you register on the platform or not. There are two different types of users:
Pravovsim uses Google Analytics to track its performance and collect information about visitors. This helps DRC to improve the Pravovsim platform by tracking the source of user traffic, measuring the success of different content, evaluating interaction with different pages, and obtaining demographic information about Pravovsim users.
By using our platform, you agree to the transfer of cookies, which may contain personal information, to Google Analytics. If you wish to opt-out of Google Analytics, you can do so by clicking here: https://tools.google.com/dlpage/gaoptout.
Unregistered users
You can use Pravovsim services anonymously, without disclosing your name or any other identifying information, and without creating an account on the platform. Anonymous interaction may include reading content available on the platform's Information Portal.
If you are not registered on the Pravovsim platform and have rejected cookies when logging in to the platform, we will not collect any technical or demographic data.
If you are not registered on the Pravovsim platform and have accepted cookies when logging in to the platform, we collect personal information in the form of:
DRC may collect, use, store and process this information for:
If you decide to use the feedback form or the ‘Contact Us’ form on the Pravovsim platform, you can send your message anonymously without providing us with any personal information. If, when using the above forms, you decide to provide us with your identification and contact details, namely your name, email address and telephone number, you consent to the collection and processing of this personal information.
Registered users
To access additional Pravovsim services, such as booking a consultation with an Authorised Lawyer or sending a request via online chat on the platform, you must create an account on the Pravovsim platform.
When registering on the platform, you will be required to provide some personal information. The categories of personal data we may collect include:
Your privacy and security are our priority, and we are committed to storing and protecting your data in accordance with legal requirements.
In exceptional cases, DRC may collect special categories of personal data, such as health information, to provide better assistance to users with disabilities. We will only process this data if there are valid reasons and in compliance with the requirements of the GDPR.
As an online user, DRC may collect, use, store and process your personal information for the following purposes:
The legal basis for processing such personal data includes:
1. User consent - when the user expresses their consent to the processing of their personal data for a specific purpose or action.
2. Processing necessary for our legitimate interests, such as communicating with users, which includes providing necessary services and resolving issues.
3. Processing necessary for our legitimate interests, such as ensuring compliance with our policies, which will make the platform more efficient and accurate.
4. Processing necessary for our legitimate interests, in particular ensuring user safety, including protection against fraud and abuse.
These legal bases ensure that the processing of personal data is carried out in accordance with the requirements of the law and taking into account the rights and interests of platform users. The law allows us to transfer or disclose your personal information in various cases to ensure the fulfilment of various obligations and the protection of rights:
• We may disclose your data to comply with our legal obligations, respond to requests from relevant authorities, prevent potential harm, and protect your rights.
• If necessary, we may refer you to other service providers who can provide you with additional assistance or services.
• We are committed to our donors and may share information to fulfil these commitments.
• In order to optimise our services, we may use software services that involve third-party integration and the use of your personal information within these services.
Referrals to other service providers
In some cases, when you contact us with a problem that is beyond our capabilities, we may refer you to another service provider who can provide you with additional support. In such situations, we may transfer a limited amount of your personal information to ensure that you have access to the necessary services. By consenting to the processing of your personal data, you give your permission for your data to be transferred to other service providers.
Before transferring your personal information, we will ask for your consent and inform you of the specific aspects of your information that will be transferred to ensure that your request is properly fulfilled.
Compliance with donor obligations
As a non-profit organisation, DRC relies on donations from both public and private entities to fund its mission. In order to meet donor requirements and ensure transparency in the use of financial resources, when you consent to the processing of personal data, you give permission for data such as age and gender to be transferred to donors. This approach helps to ensure trust and support from donor organisations, particularly with regard to the confidentiality of users' personal data.
Third-party service providers
To expand its range of services, Pravovsim uses third-party integration. This means that Pravovsim establishes connections with external programmes, such as web analytics services, contractors or IT service providers. By agreeing to transfer your personal information to Pravovsim, you automatically agree to the transfer of this information to third parties involved in third-party integration. This approach allows us to expand the capabilities and improve the quality of services provided to Pravovsim users.
How long we keep your personal information
We will keep your personal information for as long as necessary to fulfil the purpose for which it was collected, or to comply with the requirements of donors or government agencies.
Your rights regarding personal information
As a data subject on our platform, you have the right to:
You are responsible for updating your personal information and ensuring that the information you provide is accurate
You have the right to complain about our data processing activities by completing a complaint form and sending it to our data protection staff using the contact details located in the “Contact Us’ section”.
Data storage and deletion
Please note that if you request the deletion of your personal information:
Data breach notification
In the event of a personal data breach, Pravovsim is obliged to notify the supervisory authority of the personal data breach without undue delay and, where possible, no later than 72 hours after becoming aware of it, except where the personal data breach is unlikely to result in a risk to the rights and freedoms of the data subject.
Security
We continuously implement and update administrative, technical and physical security measures to protect your personal information from unauthorized access, loss, destruction or alteration. Some of the safeguards we use to protect your personal information are firewalls and data encryption, as well as access control to information. If you know or have reason to believe that your Pravovsim account information has been lost, stolen, misappropriated or otherwise compromised, or in the event of any actual or suspected unauthorized use of your Pravovsim account, please contact us using the details provided in the "Contact Us" section below.
The Policy on Protection from Sexual Exploitation, Abuse and Harassment (PSEAH) applies to all persons working for the Danish Refugee Council, regardless of their role or position. This applies to both international and national staff, managers, direct employees, support staff, programme staff, paid and unpaid interns, students and casual workers. All are expected to comply with the Policy.
Policy on children
The Pravovsim platform is not intended for persons under the age of 18, and we do not knowingly collect any personal information from minors. If you are a parent or guardian and you become aware that your child has provided us with personal data without your consent, please contact us using the details provided in the 'Contact Us' section below.
The Safeguarding Policy and the Child Safeguarding Policy cover the protection of the most vulnerable group of people from abuse by DRC and the commitment of DRC and staff to ensure their rights and empower them towards a better future.
Changes to this Privacy Policy
DRC reserves the right to make changes to this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Pravovsim websites and update the ‘Last Updated’ date at the top of this Privacy Policy.
If you do not agree with the revised Privacy Policy, you may delete your account. If you do not delete your account by the date of publication of the revised Privacy Policy, your continued access to or use of the DRC programme will be subject to the revised Privacy Policy.
Contact us
If you have any questions about how we process your personal information, or if you wish to exercise your rights, please contact the DRC Data Protection Officer at any time using the contact details below: [email protected].