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Privacy and Cookies Policy

This privacy and cookies policy sets out why and how Sustainability for Ukraine (we/us/our) processes and protects your personal information (also referred to here as personal data) that you give Sustainability for Ukraine when you use the Sustainability for Ukraine website, or if you participate in Sustainability for Ukraine’s web-a-thon. We also set out your rights and how to contact us if you need to.

Sustainability for Ukraine is committed to protecting your privacy.

Our contact details are set out at the end of this policy. We are the controller in relation to the personal data processed in accordance with this policy (except where this policy explains otherwise).

This policy sets out:
- Information we collect about you
- Cookies and other technologies
- How we use your information
- Who we give your information to
- Where we store your information
- How we protect your information
- How long we keep your information
- Your rights
- Changes to this policy
- Contact us

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Your consent


1. Information we collect about you

We may collect personal information directly from you. We may process your personal data if:
- You have registered to participate in the Sustainability for Ukraine web-a-thon.
- You or the company you work for are a customer or a supplier of ours.

Personal data relating to you that we process may include:
- Your name.
- Who you work for, and your job function, department and areas of expertise.
- Your address, phone number, email address or other contact details (these details may relate to your work or to you personally, depending on the nature of our relationship with you or the company that you work for).
- Information about you that you give us by communicating with us by phone, by e-mail, via our website, via social media or otherwise. It includes information you give us or that we obtain when you use our website, obtain or subscribe to our goods or services, supply us with goods or services, enquire about a product, or contact us to report a problem, or do any of these things on behalf of the person that you work for.
- Information about events to which you or your colleagues are invited, and your personal information and preferences to the extent that this information is relevant to organising and managing those events.
Information that we obtain from you when you use our website may include:
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
- Location data – we collect information through our website as to your real time location to provide location services where requested or agreed to by you in order to allow tagging to deliver content, or other services that are dependent on knowing where you are. This information may also be collected in combination with an identifier associated with your device to enable us to recognise your mobile browser or device when you return to the website.
- Delivery of location services will involve reference to one or more of the following: (a) the coordinates (latitude/longitude) of your location; (b) look-up of your country of location by reference to your IP address against public sources; and/or (c) your Identifier for Advertisers (IFA) code for your Apple device, or the Android ID for your Android device, or a similar device identifier. See our cookie policy for more information on the use of cookies and device identifiers on the site.

2. Cookies and other technologies

Our site uses cookies to collect and store certain information. These typically involve pieces of information or code that a website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you. Cookies enable you to be remembered when using that computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalised content.

Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site.

Most web browsers automatically accept cookies, but if you prefer, you can change your browser to prevent that and your help screen or manual will tell you how to do this. We also give you information about how to disable cookies below. However, you may not be able to take full advantage of our website if you do so.

A number of cookies we use last only for the duration of your web session and expire when you close your browser. Others are used to remember you when you return to the site and will last for longer.

We use these cookies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use.

We use cookies to create a unique device ID.

We use the following types of cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website.

- Analytical/performance cookies. They allow us to recognise how visitors move around our website when they are using it. This helps us for our legitimate interests of improving the way our website works, for example, by ensuring that users are finding what they are looking for easily. It also helps us to tailor the website to its viewers’ needs.

- Functionality cookies. These are used to recognise you when you return to our website. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, your choice of language or region).

Disabling cookies

The effect of disabling cookies depends on which cookies you disable but, in general, the website may not operate properly if all cookies are switched off. If you want to disable cookies on our site, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies for the most popular browsers are set out below:

For Microsoft Internet Explorer:
- Choose the menu “tools” then “Internet Options”
- Click on the “privacy” tab
- Select the appropriate setting

For Google Chrome:
- Choose Settings> Advanced
- Under “Privacy and security,” click “Content settings”.
- Click “Cookies”

For Safari:
- Choose Preferences > Privacy
- Click on “Remove all Website Data”

For Mozilla Firefox:
- Choose the menu “tools” then “Options”
- Click on the icon “privacy”
- Find the menu “cookie” and select the relevant options

For Opera 6.0 and further:
- Choose the menu “Files” > “Preferences”
- Privacy

Where you have not set your permissions, we may also separately prompt you regarding our use of cookies on the Site.

3. How we use your information

The basis for processing your personal information is the consent you gave when registering for the web-a-thon and your use of this website.

We use the personal data which you submit or which we collect to:

(a) enable your use of the web-a-thon website, including by publishing any messages that you choose to submit onto the website. We or other users may choose to respond to your messages, or choose to try to interact with you via the website, as described at the time when we collect your information or as otherwise described to you prior to the use of your information;

(b) manage your use of the website, including for such issues as user support;

Your contact information may be used to send you information on the outcome of the web-a-thon. It will not be used for other purposes without your express prior consent. 

Passive information we track, including through cookies, is used to customize and enhance your experience on our website and the offerings we make to you on our website, as described above.

As noted above, please keep in mind that certain areas of our web site are interactive in nature, and allow you to post information that other users can see. If you do not wish to have information viewed publicly, please do not use those portions of the website.

Information we collect about you from your use of our website

We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- To keep our site safe and secure.
- To improve our site to ensure that content is presented in the most effective manner for you and for your computer.
We may also use your information to meet legal and regulatory requirements.

4. Who we give your information to

We may share your personal data with:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent.
- Appropriate third parties including:
our auditors, legal advisors and other professional advisors or service providers; In relation to information obtained via our website: · analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy.

Other disclosures we may make

We will disclose your personal information to third parties:
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you or the company you work for; or to protect the rights, property, or safety of Sustainability for Ukraine, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

Please note that subject to applicable data privacy legislation, we will also disclose your personal information if we believe we are required to do so to comply with any law, regulation, court order, or legal or government request. In the unlikely event that all or part of our business is acquired by a third party, your information will be transferred to the new corporate owner. Without assuming any obligation to do so, we also reserve the right to collect and share any information we deem necessary to investigate or take action in connection with suspected fraud, illegal activities, possible harm to persons or property, to protect ourselves or one or more of our users or their heirs, or as otherwise required or permitted by law.

5. Where we store your information

For non-EEA residents:
Please note that in certain cases, your personal information may be transferred to processors, affiliated companies or third parties with whom we manage the stakeholder web-a-thon (including each of our Partners), some of which may be located outside the United States of America in countries where the privacy laws may not be as protective as your jurisdiction. By using this site you hereby accept the transfer of your personal data in such cases.

For EEA residents:
The data that we process in relation to you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the EEA who work for us or for one of our suppliers.

- In order to store it.
- In order to enable us to provide goods or services to and fulfil our contract with you or the company your work for. This includes order fulfilment, processing of payment details, and the provision of support services.
- Where we are legally required to do so.
- In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

We may transfer your personal information to the following countries outside the EEA:
Canada: EU Commission adequacy decision
USA: Model Contractual Clauses

Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this privacy and cookies policy.

6. How we protect your information

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, all information is kept behind suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect. 

We inform our employees about our policies and procedures regarding confidentiality, security and privacy, and we emphasize the importance of complying with them. Our security procedures are consistent with generally accepted commercial standards used to protect personal information.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

We may transfer personal information to affiliated companies or non-affiliated service providers for research-related purposes, such as data processing (as detailed in the ‘Where we store your information’ section.) We require these companies to safeguard all personal information in a way that is consistent with our firm’s measures and as regulated by law. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

Sustainability for Ukraine shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.

Our website may, from time to time, contain links to external sites. We are not responsible for the privacy and cookies policies or the content of such sites.

7. How long we keep your information

Where personal data is provided by and transferred to us by a Client for a specific survey or stakeholder engagement, the data is used only for this purpose and retained for the duration of completing the purpose, where after it is deleted within 30 days, unless you have provided consent for re-contact purposes. The length of time we hold your personal information varies depending on the type of information and its use. We will retain your personal information on our systems only for as long as necessary to provide the services or information you have requested or for such other essential purposes such as complying with our legal obligations Other personal data will be retained for up to 12 months from the time of last engagement with us, e.g., responding to a survey, opening an email, attending a webinar or web-a-thon. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

8. Your rights

You have the right under certain circumstances:
- to be provided with a copy of your personal data held by us;
- to request the rectification or erasure of your personal data held by us;
- to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
- to request that your provided personal data be moved to a third party.

You may opt out at any time from allowing further access by us to your location data by following instructions in the Cookie section of this Policy.

Your right to withdraw consent

Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us. At any time, you may withdraw your consent; exercise your right to access, rectify and, as the case may be, delete any personal data relating to you, in compliance with applicable data privacy law, by contacting us. 

How to exercise your rights

You can also exercise the rights listed above at any time by contacting us. If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible. We will promptly correct any information found to be incorrect.

Without prejudice to any other administrative or judicial remedy, you shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to yourself infringes this Regulation.

9. Changes to this policy

Sustainability for Ukraine may update and revise this policy from time to time, review its Personal Information collection, use, and disclosure practices in order to assure compliance with laws and regulations. Please check this page from time to time to ensure that you are happy with any changes.

This policy was last updated on 14 June 2022.

10. Contact us

Contact us for any questions.
Thank you for visiting our website.

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