Privacy Policy

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

Introduction

This Privacy Policy governs the protection of personal data of visitors to the websites https://costfreedom.com/ and https://shop.costfreedom.com/, which belong to the Civic Organization “The Cost of Freedom” (USREOU code 45660480, address: 8a Leonida Kadeniuka Ave., apt. 4, Kyiv, 02105, Ukraine).

The Organization respects the privacy of all persons who use the websites, including those who make charitable donations or place orders to receive branded merchandise as a token of gratitude.

This Policy has been developed in accordance with: the Constitution of Ukraine; the Law of Ukraine “On the Protection of Personal Data” No. 2287-VI; the Law of Ukraine “On Electronic Commerce”; and other applicable Ukrainian legislation.

Terms and Definitions

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

Processing of personal data — any action or set of actions: collection, registration, storage, adaptation, modification, use and dissemination, depersonalization, destruction of personal data.

Order — a request placed on the Website by a Benefactor to receive branded merchandise as a token of gratitude for a charitable donation.

Cookies — small text files stored on a device for record-keeping of users’ activity.

1. General Provisions

1.1. This Policy establishes the procedure for collecting, storing, processing and protecting the personal data of users of both Organization websites.

1.2. Any person who visits the websites, makes a charitable donation or places an order is a personal data subject.

1.3. If you do not agree with the terms of this Policy, you must stop using the websites.

2. Personal Data We Collect

2.1. When making a charitable donation or placing an order, the Organization collects the following data:

2.2. Technical information is collected automatically when visiting the websites and is used for analytics and site improvement.

2.3. The Organization does not collect or store payment card details. Payment data is processed exclusively by payment services operating under the PCI DSS standard.

3. Purposes of Collecting and Processing Personal Data

3.1. The Organization collects and processes personal data for the purpose of:

• confirming and processing a charitable donation;
• forming and dispatching an order for branded merchandise;
• contacting the Benefactor regarding the status of an order or delivery;
• issuing a fiscal receipt in accordance with legal requirements;
• fulfilling requirements of financial monitoring legislation;
• improving website functionality and quality of service;
• fulfilling the Organization’s statutory goals.

4. Transfer of Data to Third Parties

4.1. To fulfil an order, the Organization transfers the minimum necessary personal data to the following third parties:

• Nova Poshta — recipient’s name, phone number, branch address for creating and tracking the shipment;
• Payment services (WayForPay, monobank or others) — data for confirming and processing the payment;
• Checkbox or other fiscal receipt provider — data for generating a fiscal receipt as required by law;
• CRM system — for processing and tracking orders.

4.2. All listed third parties are required to process personal data only to the extent necessary to perform their functions and to comply with personal data protection legislation.

4.3. The Organization does not sell, transfer or disclose Benefactors’ personal data to third parties for commercial purposes.

4.4. Disclosure of personal data without the Benefactor’s consent is permitted only in cases defined by law: upon a court order, law enforcement request, or in the interests of national security.

5. Storage and Protection of Personal Data

5.1. The Organization stores personal data no longer than is necessary to achieve the purpose of processing, but not less than the periods established by law for retaining primary financial documents.

5.2. The Organization takes technical and organizational measures to protect personal data from unauthorized access, destruction, modification or disclosure.

5.3. Once the purpose of processing has been achieved, personal data are subject to destruction or depersonalization.

6. Cookies

6.1. The websites use cookies for: visit analytics, correct operation of payment forms, and remembering user settings.

6.2. Users may configure or disable cookies in their browser. Disabling cookies may affect website functionality, in particular the operation of order forms.

7. Rights of Personal Data Subjects

7.1. Every Benefactor has the right to:

• know the purposes and sources of collection of their personal data;
• receive a reply within 30 calendar days as to whether their data are being processed;
• request correction of inaccurate personal data;
• request restriction or cessation of processing of their personal data;
• request destruction of their personal data once the purpose of processing has been achieved;
• lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights.

7.2. To exercise these rights, the Benefactor contacts: info@costfreedom.com. The Organization considers requests within 30 calendar days.

8. Changes to the Privacy Policy

8.1. The Organization reserves the right to amend this Policy. The current version is always posted on the Website. Continued use of the website after amendments are made constitutes acceptance of the updated Policy.

9. Contact Details

Published: 10 June 2026