Legal information

Privacy Policy

Effective date: 10 June 2026

Unofficial translation. This English version is provided for convenience only. The legally binding document is the Ukrainian original.

Introduction

This Privacy Policy (the “Policy”) governs relations in the field of personal data protection for visitors of the website https://costfreedom.com/ (the “website”), which belongs to the Civic Organization “Vartist Svobody” (The Cost of Freedom) (USREOU code 45660480, registered address: 8a Leonida Kadeniuka Ave., apt. 4, Kyiv, 02105, Ukraine), registered in accordance with the current legislation of Ukraine.

The Cost of Freedom treats the confidential (personal) information of all persons who use the website with respect and therefore seeks to protect the confidentiality of personal data (information, or a set of information, about a natural person who is identified or can be identified), thereby creating and ensuring the most comfortable conditions of use of the website for every user.

This Policy, as well as the activities of The Cost of Freedom related to the collection, processing, storage and other lawful actions regarding personal data, has been developed in accordance with and is governed by: the Constitution of Ukraine; the Law of Ukraine “On the Protection of Personal Data” No. 2287-VI of 01.06.2010; other applicable regulatory acts of Ukraine governing personal data protection; and international legal acts ratified by Ukraine.

Terms and definitions

Personal data — information, or a set of information, about a natural person who is identified or can be specifically identified;

Personal data base — a named set of ordered personal data in electronic form and/or in the form of card indexes of personal data;

Processing of personal data — any action or set of actions, such as collection, registration, accumulation, storage, adaptation, modification, renewal, use and dissemination (distribution, transfer), depersonalization and destruction of personal data, including with the use of information (automated) systems;

Personal data subject — a natural person whose personal data are processed;

Consent of the personal data subject — the voluntary expression of will of a natural person (provided they are informed) to grant permission to process their personal data in accordance with the stated purpose of such processing, expressed in a form that allows a conclusion to be drawn that consent has been given;

Depersonalization of personal data — removal of information that makes it possible to directly or indirectly identify a person;

Third party — any person, except the personal data subject, the owner or administrator of the personal data and the Ukrainian Parliament Commissioner for Human Rights, to whom the owner or administrator of personal data transfers personal data.

Cookies — small text files stored on a device for record-keeping. Cookies record information about users’ activity while using information (administrative) systems, in particular websites. Some cookies remain on the user’s device until they are deleted.

All other terms used in the Policy have the meaning defined by the current legislation of Ukraine, including international legal acts ratified by Ukraine.

General provisions

1.1 This Policy establishes the procedure by which The Cost of Freedom processes users’ personal data, the types of personal data collected, the purposes of using such personal data, the interaction of The Cost of Freedom with third parties, and the security measures for protecting personal data.

1.2 A natural person is a personal data subject under this Policy if they are a visitor of the website, including if they use any of the options available on the website.

1.3 The Cost of Freedom guarantees compliance with proper practice and regulatory requirements for personal data protection; protection of the rights of personal data subjects; and prevention of the risk of a breach of the security of personal data processing.

1.4 The purpose of processing personal data obtained in the course of operating the website is for The Cost of Freedom to carry out its statutory activities and/or to confirm transactions made by users on the website.

1.5 If you do not agree with the terms of this Policy, you are obliged to stop using the website.

1.6 Posting this Policy at the link specified in clause 6.1 of this Policy constitutes notification to personal data subjects about the Owner, the composition and content of the personal data collected in connection with visiting/using the website, about the rights of such subjects, the purpose of collecting their personal data and the third parties to whom such personal data may be transferred.

Subject of the Privacy Policy

2.1 The Cost of Freedom may collect and process information about you that you provide by: using the website and its options, providing charitable support to the project via the charitable contribution (donation) option on the website, or communicating with The Cost of Freedom through the options available on the website;

2.2 The personal data permitted to be processed under this Privacy Policy include, but are not limited to, information that the user provides as a result of confirming payment of a charitable contribution on the website or of contacting the administration or contact persons of The Cost of Freedom through the website.

2.3 Information about you collected by the website and other systems: if you visit the website and use specific options of the website, third parties may collect certain information about you and your visit, such as the information provided as a result of paying a charitable contribution on the website.

2.4 Disclosure of personal data without the consent of the user or a person authorized by them is permitted in cases defined by law, and only in the interests of national security, economic well-being and human rights, in particular, but not limited to, upon reasonable requests of state authorities entitled to submit applications and receive such data.

2.5 This website uses cookies to store content and settings, in order to process the standard information that your browser sends to certain websites you visit, for example: your IP address, browser type and language, the site you came from, the pages you visit and the links you click on the website.

Purposes of collecting and processing personal data

3.1 The Cost of Freedom has the following purposes for collecting and processing personal data:

Protection of the storage of users’ personal data

4.1 The accumulation of users’ personal data processed in the course of using the website’s options may be carried out by The Cost of Freedom by entering this data into a personal data base. Storage of personal data is carried out solely in compliance with the requirements of the current legislation of Ukraine in the field of personal data.

4.2 In the Reporting/Receipts/Funding section of the website, The Cost of Freedom may partially publish the data of users who have made a charitable donation using the website’s options, with the prior consent of those users.

4.3 The Cost of Freedom stores users’ personal data for no longer than is necessary in accordance with the purpose of their processing, unless otherwise provided by the legislation of Ukraine.

4.4 Personal data are stored in a form that allows the personal data subject to be identified for no longer than the purposes of processing require, unless the storage period for personal data is established by Law. The processed personal data will be subject to destruction or depersonalization once the purposes of processing have been achieved or if the need to achieve those purposes is lost, unless otherwise provided by Law.

Rights of personal data subjects

5.1 When visiting or using the website, users have the following rights, in accordance with the current legislation of Ukraine:

5.2 At the user’s request, The Cost of Freedom may block the personal data belonging to the user from the moment of the request by the user, their legal representative, or the authorized body for the protection of personal data subjects’ rights, for the period of verification, if inaccurate personal data or unlawful actions regarding the user’s personal data are detected.

A letter (information) sent to the user’s email shall be sufficient notification of the deletion or other processing of personal data.

5.3 If you have any questions, comments, complaints or suggestions regarding the protection and processing of personal data, you can contact The Cost of Freedom by email at info@costfreedom.com or by phone at +38 063 775 66 70 with the relevant request.

Changes to the Privacy Policy

6.1 The Cost of Freedom reserves the right to review and/or change the provisions of this Policy. The current version of this Policy is posted on the website: https://costfreedom.com

Published: 10 June 2026