How we protect personal data

Version 1, in force since 21 October 2026.

This is a translation. If it differs from the Ukrainian version, the Ukrainian version prevails.

1. General provisions

1.1. This policy explains how the charitable organisation “Charitable Foundation ‘Mriiu Zhyty’” (EDRPOU code 39333086), the “Operator”, processes the personal data of people who use the Dolonia charity platform: the dolonia.com.ua website, the donor account, the charity account at cabinet.dolonia.com.ua, the platform’s emails and notifications, and the Telegram bot.

1.2. This policy is the notice on the processing of personal data under Article 12 of the Law of Ukraine “On Personal Data Protection” (the “Law”). For people in the European Union it also contains the information required by the EU General Data Protection Regulation (GDPR).

1.3. This policy applies together with the Website terms of use, the public offer for donors and the Platform rules for charities. On personal data, this policy prevails unless a contract with you expressly provides otherwise.

1.4. We process only the data needed for the stated purpose. We do not sell it, do not use it for advertising and do not pass it to third parties other than as described in this policy.

2. Controller and contacts

2.1. The controller of the personal data is the charitable organisation “Charitable Foundation ‘Mriiu Zhyty’” (EDRPOU code 39333086), office 5, 8a Troitsko-Kyrylivska St., Kyiv, Ukraine. The Operator runs the Dolonia platform, receives donations into its account and passes them on to charities under the platform rules.

2.2. For any question about your data, write to us through the Support form; you may put “Personal data” in the subject. We reply by email. A written request can also be sent by post to the Operator’s address.

2.3. Charities connected to the platform are separate controllers of the data they collect themselves, including the data of their beneficiaries (section 7; on publication of campaign document copies — clause 7.7).

3. Terms

• Personal data — any information that identifies a person directly or indirectly.
• Processing — any operation on data: collection, recording, storage, alteration, use, transfer, deletion.
• Processor — a party that processes data on the Operator’s behalf, for example hosting or an email delivery service.
• Donor — a person or organisation that makes a one-off or monthly donation through the platform.
• Charity — a non-profit organisation connected to the platform under a cooperation agreement.
• Charity volunteer — a person who runs a campaign on behalf of a Charity and under its responsibility.
• Beneficiary — the person or institution a campaign is raising money for.
• Moderator — an employee of the Operator who checks charities, campaigns, reports and requests for help.
• Account — a personal area of the platform that a person signs in to with their email: the donor account or the charity account.

4. Whose data we process

• Donors — people and organisations who donate, including monthly.
• Account users — people who sign in to a donor or charity account, post comments or have connected the Telegram bot.
• Charity representatives and teams — heads, founders, ultimate beneficial owners, managers, accountants and other people the Charity has added to its account, as well as people the Charity has named as recipients of paper documents from the Operator.
• Charity volunteers who run campaigns on a Charity’s behalf.
• Representatives of partner companies who apply or launch “Together with Dolonia” projects, including recipients of paper documents from the Operator.
• “Need help” applicants — people asking for help for themselves, their family or a military unit.
• Beneficiaries of charities, including children, and people whose data appears in campaign or report documents.
• Authors of comments and support requests.
• Website visitors.
• Employees of the Operator who have access to the platform’s staff area.

5. What data, why and on what legal ground

5.1. The legal grounds are those of Article 11 of the Law: your consent; entering into and performing a contract to which you are a party or which is concluded in your interest; compliance with the Operator’s legal obligation; the legitimate interest of the Operator or third parties, unless your rights and freedoms override it. For people in the EU these correspond to points (a), (b), (c) and (f) of Article 6(1) GDPR.

5.2. Special categories of data. We process health data and children’s data only where a campaign or request cannot be checked, or the need cannot be shown to donors, without them, and only with the explicit consent of the person or their legal representative (point 1 of part two of Article 7 of the Law) or in other cases allowed by Article 7 of the Law. The originals of such documents are stored encrypted, only moderators and the team of the Charity running the campaign can see them, and every view is logged. De-identified copies of medical documents are shown to donors only with separate written consent to publication (clauses 7.5–7.8).

5.3. Required and optional data. Without an email we cannot send the receipt, so it is required for a donation. A Charity cannot be connected without the questionnaire and documents. Fields marked as optional are up to you.

5.4. Where the data comes from. Mostly from you. Also: from the bank — the payment result and transfer details; from the Charity — data on its team, volunteers and beneficiaries; from public sources — the Unified State Register (data.gov.ua), the sanctions lists of Ukraine’s NSDC, the EU, the US (OFAC) and the UN, the register of non-profit organisations and court decisions.

5.5. If data is needed for a new purpose incompatible with the one described, we will tell you first and ask for consent where required.

6. What is public and what is not

• Donation. The “Supported by” list on a campaign page shows the signature, amount and time of the donation. The signature is only what you typed in “Sign my donation as”, the first word, without a surname; if the field is empty or you chose not to show your name, it says “Anonymous donor”. You see the signature before paying.
• A donor’s email is never published or passed to charities. The Charity sees only the signature, amount and date.
• A charity volunteer — their first name (and surname, if they chose so) is shown on their campaign page. Their phone, email and application are not published.
• A comment is published with the signature (the first word) after moderation.
• A Charity’s page is an organisation profile without personal data: mission, causes, regions, projects, campaigns, reports. The organisation’s name and code are State Register information.
• A campaign shows the text, cover, photos and video the Charity has posted, the “documents checked” mark (by whom and when) and a “Documents” tab with de-identified copies of campaign documents (an invoice, an estimate, a unit request, a medical document, etc.) that the Charity has marked “Copy for donors” and the moderator has separately approved. In the copies, tax numbers (RNOKPP), addresses, phone numbers, dates of birth, medical record and insurance policy numbers, and signatures and seals of private individuals are concealed, and in documents concerning service members — the unit number, call signs, commanders’ surnames and locations. The beneficiary’s full name is concealed too, except what is already named on the campaign page with their consent. Copies of medical documents are shown only with the written consent of the beneficiary or their legal representative. Only the moderator and the Charity team see the original documents.
• A report shows figures, expense lines, photos of the result, acts and whatever the Charity chose to publish. Only the moderator and the Charity team see receipt scans. A beneficiary’s story is shown only with their consent, without surnames or addresses.
• A partner company — its name and logo next to its projects.
• A “Need help” request is not published. Charities see it without contacts; only the Charity that takes it on sees the contacts and documents.
• Military campaigns — photos without geotags or file metadata, faces, unit numbers, insignia or serial numbers; location only to the region; photos in news and reports become public after 14 days. Copies of documents for military campaigns — without the unit’s number or designation, call signs, commanders’ surnames or locations.
• Decisions on violations. When a Charity is disconnected for misuse of funds, the platform announces it publicly — about the organisation, not private individuals.

7. Beneficiaries’ data and the Charity’s role

7.1. A Charity collects its beneficiaries’ data — names, documents, diagnoses, photos, stories — itself, including when it concludes charitable assistance agreements with them under Article 7 of the Law of Ukraine “On Charitable Activity and Charitable Organisations”. For this data the Charity is a separate controller: it decides why the data is processed, obtains the consent of beneficiaries or their legal representatives and is responsible for it.

7.2. The Operator processes only the beneficiaries’ data that the Charity has passed on to check a campaign or report — for that check — and also publishes the de-identified copies of campaign documents approved for display to donors (clauses 7.5–7.8). By passing on the data, the Charity confirms that it has a lawful basis for doing so, including consent covering the transfer to the Operator, publication of whatever the Charity posts on the campaign page and, for medical documents, written consent to publication of de-identified copies of them.

7.3. If you are a Charity’s beneficiary and want to find out about, change or remove your data, contact the Charity first. If the data is on the platform, you can also write to us through Support: we will hide the disputed information until the matter is resolved and pass your request to the Charity. A request to remove a document copy from the “Documents” tab because consent has been withdrawn is carried out immediately (clause 7.8).

7.4. By applying through the Need help form, the applicant agrees that a moderator will check the request and remove surnames, phone numbers, unit numbers and exact locations from the text, that charities will see it without contacts, and that the Charity that takes it on will receive the contacts and documents. From that point the Charity processes this data as a separate controller.

7.5. De-identified copies of campaign documents. On the “Documents” tab of the campaign page we publish copies of documents that the Charity has uploaded marked “Copy for donors” and that the moderator has compared with the original and separately approved. When uploading a copy, the Charity confirms that the information listed in section 6 has been concealed and, for medical documents, that it holds the written consent of the beneficiary or their legal representative to publication. Even a de-identified copy may contain health information and, together with other campaign materials, allow a person to be identified, so we treat it as personal data.

7.6. Legal ground. We publish a copy of a document containing health information only on the basis of the explicit consent of the beneficiary or their legal representative (point 1 of part two of Article 7 of the Law; for people in the EU, point (a) of Article 9(2) GDPR). The Charity obtains the consent, confirms it to the Operator and keeps it; the Operator may ask for a copy of it at any time. Without such consent the copy is not published.

7.7. Who is responsible for what. The Operator publishes the copies — as the owner of the platform and the controller of the data as regards that publication: it approves their display and may refuse it or remove a copy at any time. Publication is based on the consent obtained by the Charity. The Charity, as a separate controller of its beneficiaries’ data, is responsible for de-identifying the copy, for obtaining and keeping the consent and for the content of the document (clauses 2.3 and 7.1; clause 12.9 of the Platform rules).

7.8. Withdrawal of consent. The beneficiary or their legal representative may withdraw consent to publication of a copy at any time — through the Charity or directly through Support. We remove the copy from the website immediately on receiving the notice, without asking for reasons and without waiting for the Charity’s confirmation. Withdrawal does not affect the lawfulness of the display before it. We cannot recall copies that visitors have already saved; donors are prohibited from distributing them (public offer). The original document remains available to the moderator and the Charity team for the periods in section 12.

8. Children

8.1. The platform’s accounts are intended for adults. A person under 18 may use an account, donate or post comments only with the permission of their parents or other legal representatives.

8.2. We do not knowingly collect children’s data without the involvement of their legal representatives. If we learn that such data has been provided without the necessary consent, we will delete it or ask a legal representative to confirm consent.

8.3. The data of child beneficiaries comes only through a Charity and only with the consent of their parents or other legal representatives. Children’s faces on a campaign cover are not allowed without such consent. Copies of campaign documents for a child beneficiary are published only with the written consent of the parents or other legal representatives and without any details by which the child could be found.

9. Automated checks and AI

9.1. Automated checks. The platform automatically checks charities, their heads, founders and ultimate beneficial owners against the Unified State Register and the sanctions lists of Ukraine (NSDC), the EU, the US and the UN — when connecting and then daily — and payers of UAH 50,000 or more against the sanctions lists. In reports, amounts, dates, repeated documents and signs of file editing are checked automatically.

9.2. AI checks. When they are enabled, the AI service of Anthropic PBC (USA) analyses: Charities’ report documents; with the Charity’s consent — public information about the Charity online (reputation) and the Charity’s bank statements (signs of money laundering); with the volunteer’s consent given in the application — public information about the volunteer. The AI only prepares findings for the moderator; it does not analyse donors or applicants.

9.3. A person makes the decision. Neither automated checks nor AI make decisions with legal or other significant effects on a person: refusing a connection, suspending a campaign or payout, or disconnecting a Charity. A moderator makes them after reviewing the result. An exact match with a sanctions list means that the law prohibits accepting the money, and the payment is not credited to the campaign; you may challenge this result through Support, and an Operator employee will review it.

9.4. On request we will explain what data was checked and how the check works (Article 8 of the Law, Article 22 GDPR).

10. Who we share data with

10.1. Data is processed by services the platform cannot work without. Each receives only what it needs for its task and processes the data under a contract with the Operator or, where stated, under its own terms.

10.2. You enter your card details (number, expiry date, CVV) on the bank’s page. The Operator neither sees nor stores them; from the bank we receive only the payment result and, for a monthly donation, an encrypted token.

10.3. We do not give donors’ emails to charities, companies or anyone else for mailings, and we do not sell data.

10.4. If, on a reorganisation of the Operator or the transfer of the platform to another charitable organisation, data passes to a successor, we will announce it on the website and by email in advance, and this policy will continue to apply.

10.5. Nova Poshta. Paper originals of agreements, memoranda, volunteer applications and reports are sent through Nova Poshta LLC, a postal operator. When the Operator sends an original to a Charity or company, it gives Nova Poshta, for address delivery, the recipient’s details that the Charity or company entered in its account: the recipient’s full name (or name), phone number and address (town, street, building, office or flat). This is a transfer of data to a third party solely for delivery (on the basis of performing the contract with the Charity or company and the parties’ legitimate interest in delivering the document); Nova Poshta processes this data as an independent controller under its own terms. Data that a Charity, company or volunteer enters on Nova Poshta’s website, in its app or at a branch when sending documents to the Operator is processed by Nova Poshta under its own terms — the Operator does not pass it on. The platform keeps waybill numbers and return delivery details together with the record of the document concerned (section 12).

11. Transfers abroad

11.1. Some data is processed outside Ukraine: in Germany and Finland (servers and backups) and in the USA (Cloudflare, Resend, Anthropic and, where applicable, Google). EU states are parties to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data and ensure an adequate level of data protection.

11.2. Transfers to the USA take place under Article 29 of the Law: where they are needed to perform a contract with you (for example, to send a receipt), on the basis of your consent (statistics), or under a contract with the processor that contains data protection commitments. For people in the EU we rely on a European Commission adequacy decision or the EU standard contractual clauses.

11.3. The originals of beneficiaries’ documents and Charities’ statements are stored encrypted on servers in the EU. They reach the AI service only when the AI check is enabled, and only to the extent the check requires. De-identified copies of documents published on a campaign page can be accessed from any country.

12. How long we keep data

12.1. When the period ends, data is deleted or anonymised. Anonymised totals (how much was raised, how many donations) may be kept indefinitely.

13. How we protect data

• An encrypted connection to the website and accounts; protection against DDoS attacks and bots.
• Servers in the European Union; backups are encrypted.
• The originals of Charity and beneficiary documents are stored encrypted; only moderators and the Charity team see the originals of beneficiaries’ documents, and every view is logged. Donors are shown only de-identified copies approved by a moderator.
• Access is by role and only to what is needed. Signing in to a charity account requires a code from an authenticator app; the staff area also requires an SMS code.
• Every team decision is recorded in a log that cannot be altered retrospectively.
• All uploaded files are scanned for viruses; geotags and file metadata are removed from photos automatically.
• We do not store IP addresses — only an encrypted fingerprint to prevent abuse.
• Limits on sign-in and payment attempts; sign-in codes are short-lived.
• Employees and processors with access to data are bound to keep it confidential.

13.1. No method of transmitting or storing data is absolutely secure, but we take organisational and technical measures proportionate to the risk. Please protect your account too: never share your sign-in codes. Dolonia staff never ask for card details, passwords or codes — by email or in messengers.

14. Cookies and visit statistics

• There is only one essential cookie: the account sign-in session (dol_s). It is set when you sign in, is not accessible to page scripts and disappears when you sign out or the session ends. Sign-in is impossible without it, so we do not ask for consent to it.
• Your choice of theme and language and your answer to the cookie request are stored only in your browser (localStorage) and are not sent anywhere.
• Statistics — Google Analytics 4 (Google Ireland Limited). It is switched on only after you click “Accept” in the cookie request; with “Reject” there is no Google code on the pages. We count pages opened (the address without parameters, so secret codes from email links never reach Google), device and browser type, and approximate country and city. Accounts and the staff area are not counted. Advertising features and Google Signals are disabled. Data may be processed in the USA under Google’s terms.
• You can change your choice or withdraw consent at any time with the “Cookie settings” button at the bottom of the page: on withdrawal the statistics cookies (_ga) are erased. We ask again after a year.
• YouTube videos on campaign pages are embedded in no-cookie mode and start only after you click them; from then on Google’s terms apply.
• There are no advertising cookies or cookies that track you across websites.

15. Your rights

15.1. Under Article 8 of the Law you have the right:

• to know the sources of collection, where your data is held, the purpose of processing, and where the controller or processor is located;
• to receive information about the conditions of access to the data, including the third parties it is passed to;
• to access your data;
• to receive, within 30 calendar days of the request, an answer as to whether your data is processed, and its content, except as provided by law;
• to submit a reasoned objection to the processing of your data;
• to submit a reasoned demand to change or destroy your data if it is processed unlawfully or is inaccurate;
• to protection of your data from unlawful processing, accidental loss, destruction or damage, and from the provision of information that is inaccurate or damages your honour, dignity and business reputation;
• to complain about the processing of your data to the Ukrainian Parliament Commissioner for Human Rights or to a court;
• to use legal remedies if data protection law is breached;
• to make reservations limiting the processing of your data when giving consent;
• to withdraw your consent to processing;
• to know how automated processing of the data works;
• to protection from an automated decision that has legal effects for you.

15.2. For people in the European Union the GDPR also gives you the rights: of access to the data and to a copy of it; to rectification; to erasure (the “right to be forgotten”); to restriction of processing; to portability of the data you provided, in a machine-readable format; to object to processing based on legitimate interest; to withdraw consent at any time without affecting processing before withdrawal; not to be subject to decisions based solely on automated processing; and to lodge a complaint with the data protection supervisory authority of the EU state where you live or work or where the breach occurred.

15.3. Some rights may be limited by law. In particular, we cannot delete donation records while the accounting periods run, or entries in the decision log within 5 years; on request we will explain why the data is kept.

16. How to exercise your rights

16.1. Write through the Support form from the email linked to your data on the platform and say what you need: to find out, correct, delete, restrict, receive a copy, object or withdraw consent. The request is free of charge.

16.2. Identity check. So as not to disclose data to the wrong person, we reply to the email linked to the data and may ask you to confirm it is you: by signing in to your account or by other confirmation, no more than necessary. On behalf of another person, their legal representative or an authorised person may apply.

16.3. Response time — no later than 30 calendar days from receipt of the request. If we cannot reply within that period, we will tell you why and when you will receive the answer.

16.4. Deleting your account. Ask through Support. We will delete the account, stop monthly donations and emails, and erase the data except what the law requires us to keep (donation records). At your request we will replace the signature on past donations with “Anonymous donor” and delete your comments.

16.5. Withdrawing consent and unsubscribing. Statistics are turned off with the “Cookie settings” button at the bottom of the page, Telegram with the /stop command or by unlinking it in your profile, optional emails via the link in the email or your account settings. Emails needed to perform the contract (receipts, monthly donation notices) are sent while the contract is in force. A beneficiary withdraws consent to publication of a campaign document copy through the Charity or Support — we remove the copy immediately (clause 7.8).

16.6. If you believe your rights have been breached, you may contact the Ukrainian Parliament Commissioner for Human Rights or a court, and people in the EU — the supervisory authority of their state. We appreciate it if you write to us first — the matter is usually resolved faster that way.

17. If a breach occurs

17.1. If a security breach occurs through which data may have been lost, altered or disclosed, we will act immediately to stop it and limit the consequences, establish which data and people are affected, and record it in the log.

17.2. Where the law requires it, we will notify the Ukrainian Parliament Commissioner for Human Rights and, for people in the EU, the supervisory authority within the GDPR deadlines. People for whom the breach poses a high risk will be told by email what happened, what data is affected and what they should do.

18. Changes to this policy

18.1. A new version of the policy is published on this page with the date it takes effect and a short description of the changes. We will announce significant changes — new purposes, new recipients, new categories of data — on the website in advance.

18.2. If a change requires your consent, we will ask for it separately and will not process data in the new way without it.

18.3. The Ukrainian version of this policy prevails over the English translation.

19. Operator details

• Name: Charitable Organisation “Charitable Foundation ‘Mriiu Zhyty’”
• EDRPOU code: 39333086
• Non-profit status: included in the Register of Non-Profit Institutions and Organisations, non-profit status code 0036
• Address: office 5, 8a Troitsko-Kyrylivska St., Kyiv, Ukraine
• Head: Iryna Volodymyrivna Popovska, acting under the Charter
• Email: fond@mriyuzhiti.com
• Personal data requests: the Support form
• Charity website: mriyuzhiti.com
• Platform: dolonia.com.ua