Privacy Policy - Ocalenie Foundation

Privacy policy of Ocalenie Foundation

General information
This version of the Privacy Policy of Ocalenie Foundation applies from September 6, 2024. It is an updated version of the document from November 24, 2022, valid until September 5, 2024. As part of an update to the Privacy Policy of Ocalenie Foundation, information on the rules regarding the processing of personal data has been introduced via WhatsApp.

The administrator of personal data is Ocalenie Foundation, with headquarters in Warsaw, 00-537, ul. Krucza 6 / 14a. NIP (tax identification number): 118-157-02-03; KRS: 0000030279; REGON: 016446315, represented by the Management Board.

The administrator has appointed a Data Controller, whom you can contact via e-mail: [email protected]

The purpose of the Privacy Policy is to collect the essential rules regarding the processing of personal data by Ocalenie Foundation. We present key groups of people whose data we process, describe for what purposes and on what legal basis we do it. We also inform you about the rights of persons whose data we process.

In order to ensure the security of data entrusted to us, we have developed internal procedures and recommendations to prevent disclosure of data to unauthorized individuals. Their performance is supervised and their compliance is constantly checked with the relevant legal acts – the Act on the protection of personal data, the Act on the provision of electronic services, as well as all kinds of executive acts and acts of Community law, such as the General Data Protection Regulation of 27 April 2016 (GDPR).

For improved clarity of the Privacy Policy, we have replaced the term „Data Owner” with „You”, „Administrator” – „We”, „Foundation”, „Ocalenie Foundation”. The term „GDPR” refers to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals concerning the processing of personal data and on the free movement of such data, and repealing Directive 95/46 / EC. The term „CRM” (Customer Relationship Management) means an IT program used by Ocalenie Foundation for relationship management.

Whose data do we process and on what terms?
Personal data of recipients of the Foundation’s activities / clients of the Foundation
We may collect and process the following personal data of our clients, i.e.: name, age, education, health information, telephone number, home address, registered address, data of family members, professional, family, financial situation, rulings of judicial authorities, administrative decisions. The purpose of processing is: implementation of projects aimed at providing assistance and support; inspection purposes by authorized entities. We process your data on the basis of Article 6(1)(a) GDPR, i.e. given consent, and Article 6(1)(f) GDPR, i.e. legitimate interest of the administrator. If the Foundation’s activities constitute a public task/are co-financed from public funds, we will not ask you for your consent. The legal basis for processing will then be Article 6 sec. 1 letter eGDPR, i.e. performance of a task in the public interest.

We share your data with processors contracted to perform part of the services and with authorities authorized by law. In the case of public tasks, your data may also be made available to the grantor for reporting and control purposes.

We process sensitive data necessary to provide assistance and support on the basis of Article 9(2)(b) GDPR (processing is necessary for the fulfillment of obligations and the exercise of specific rights by the controller or the data subject in the field of social security and social protection), Article 9(2) lit. c GDPR (processing is necessary to protect the vital interests of the data subject), and Art.9(2)(d) GDPR (processing is carried out within the framework of legitimate activities carried out with appropriate safeguards by a foundation, association or other non-profit entity with political, philosophical, religious or trade union purposes).

We keep your data for a period of min. 5 years after the end of the year in which the project ended, due to billing and auditing obligations.

Data of users of ocalenie.org.pl websites; cpc.org.pl, refugees-welcome.pl, witajwdomu.org.pl, centrum.ocalenie.org.pl.
Through our websites, we collect data only to an extent that is necessary to manage these pages, ensure the efficient operation of the functionalities offered within them and analyze the effectiveness of communication.

Foundation’s websites utilize so-called system logs – automatic recording of anonymous information, such as the time of a user’s visit to the website, user’s IP address, URL address, type of browser, data on downloaded files, etc.

All statistical data related to the usage of our websites will be stored until Foundation terminates its activity, on grounds of legitimate interest.

Data of our donors
Ocalenie Foundation can be financially supported with donations, either via direct bank transfer or the PayU and PayPal system, which allows for online payments using transfer or credit and debit cards.

In the case of a bank transfer donation, we process the personal data provided by the bank, which consists of: name and surname, bank account number, amount donated and the address. This data is necessary in the process of concluding the agreement and fulfilling the foundation’s legal obligations (e.g. towards accounting regulations).The legal basis for processing is therefore Article 6 paragraph 1 letters b and c of the GDPR.

Additional information included in the title of the transfer (e.g. an e-mail address), as well as your name and postal address, will be processed on grounds of legitimate interest, with the purpose of sending our thanks for your support and information on our activities. It is for the same purpose that we use the address data included in the bank transfer information. If you do not wish to receive such messages, please inform us of your objection by sending us an e-mail (saying, for example: “I do not wish to receive a thank-you letter and/or e-mail”) to the address: [email protected]. If you wish for us to direct the correspondence to a different address than the one pointed out in the transfer data, or want it delivered by e-mail – please contact us at the address given above.

In the case of a donation using the PayU/PayPal system, please include your name and surname, so that we know who we are concluding an agreement with (so that later we can, for example, provide a certificate that will enable the deduction of the donation from taxes, or refunding mistakenly paid money), the amount of donated funds and an e-mail address, necessary for the CRM system to process the payment. This data is necessary in the process of concluding the agreement and fulfilling the Foundation’s legal obligations. Providing aforementioned information is voluntary. However, it is a necessary prerequisite for the donation.
We will also use the e-mail address – on grounds of our legitimate interest – to send you the transfer confirmation, and our thanks for your support. If you do not wish to receive the thank-you message, please inform us of your objection by sending us an e-mail to the address: [email protected]. If the PayU system is in possession of your postal address information, we will use it, on grounds of our legitimate interest, for statistical purposes.

We also send our donors occasional mailings with highlights of the Foundation’s activities. We do this on the basis of our legitimate interest. If you do not wish to receive such mailings, you can always unsubscribe via a link in the footer of the email or send your objection to [email protected].

In addition, donors can fill out a form in which they voluntarily share with us other data that was not shared with us when making the payment: email address, home address, phone number, date of birth. We will process this data based on our legitimate interest, in order to build a relationship with donors, including informing them about the Foundation’s major activities, collecting feedback on the experience of being a donor, thanking them for their support, sending gifts, and encouraging them to continue or increase their support. If a person has shared additional data with us, but later wishes to opt out of a particular type of communication, he or she can send an objection at any time to [email protected].

The personal data of our donors is processed for 5 years, starting from the end of the calendar year, during which the last interaction (e.g. a donation, unsubscribing from the newsletter, participation in one of our events that requires registration) with the donor has been registered in the CRM system.

Data of persons making a 1,5% tax donation
We are provided by the tax office with personal data of people who decided to donate 1,5% of their tax to our foundation and agreed to having their data forwarded to us when filling the PIT form . The information we store consists of the taxpayer’s name and surname, their address, the amount donated from the tax, data of their spouse – if their taxation is joint – and possibly other information, should it be included in the segment of the PIT form that relates to the 1,5% donation. We store the aforementioned data on the basis of our legitimate interest for the purposes of sending our thanks for your support. If you do not wish for us to process your data for this purpose, do not agree to forward it to us when filling your PIT form. If you have already agreed, but have since changed your mind, send your objection to the address: [email protected].

The data of the people who support us with 1% of their tax is processed on grounds of legitimate interest, to the purpose of relationship management, for 5 years, starting from the end of the calendar year, during which the last interaction with the donor has been registered.

Data of the subscribers of our newsletter
We process the names, surnames and e-mail addresses of subscribers of Ocalenie Foundation’s newsletter, in order to provide information on the Foundation’s activities and matters connected to our area of activity in general.

The basis on which we process data is our legitimate interest. A person who has subscribed to the newsletter may unsubscribe from it at any time by clicking on the appropriate link in the footer of the email or by sending an unsubscribe request to [email protected].

The data of former newsletter subscribers is processed on grounds of legitimate interest, to the purpose of relationship management, for 2 years, starting from the end of the calendar year, during which the last interaction (e.g. unsubscribing from the newsletter) with the donor has been registered in the CRM system. If you wish for us to remove information of your subscription sooner than that and cease any contact with you, send us a message at [email protected].

Data of journalists
Ocalenie Foundation processes personal data of journalists (and publishers) that they or the editorial office have shared, or that is available on the Internet. The processed data may include the journalist’s name and surname, e-mail address, phone number, former and current affiliations, the editorial office’s address, history of interactions and publications. The data is processed on grounds of legitimate interest, for the purpose of informing about the activities of the foundation and relationship management.

The data is processed until Ocalenie Foundation terminates its activity. If you do not wish to receive press information, you can object to having your data processed. To do that, or in case of additional questions, please send us a message at [email protected].

Personal data of Corporate Social Responsibility (CSR) or ESG (environmental, social and governance) departments’ employees or other persons, representing enterprises or institutions, with which we maintain relations
Ocalenie Foundation processes data of CSR/ESG or similar departments’ employees, acquired directly from them, from their respective employers or from the Internet. Processed data may include: first and last name, e-mail address, telephone number, affiliation (including previous affiliation), employer’s office address, history of interaction and employment. The aforementioned data shall be processed on grounds of legitimate interest in order to encourage support for Foundation’s actions and cause and relationship management.

Data shall be processed until Foundation terminates its activity. If you do not wish to receive information on partnership proposals, you may object to processing of your personal data. In such case or in case of any additional questions, please contact us at [email protected].

Data of persons who use private communication channels
Data of persons, who have been contacted by us by e-mail (sent from addresses using the “ocalenie.org.pl” domain), phone, SMS or post, shall be processed on grounds of legitimate interest, in order to manage correspondence, in the purpose indicated in the correspondence or in order to make contact in the future. This data may involve first and last name, address, e-mail address, telephone number or other information enclosed within the message. Provision of this data is voluntary. The data is processed for archiving purposes and relationship management until Foundation terminates its activity, except for sensitive data, which are erased or rendered anonymous immediately after concluding a case. When writing or calling us, please refrain from providing unnecessary data. Should we need additional information, we will ask for you to provide it.

Data of persons contacting the Foundation via social network
Facebook, Twitter and WhatsApp are the administrators of personal data of their respective users and process them on the basis of their respective terms of service and data policies. Once you start interacting with us via Facebook, X or WhatsApp (liking/following our page, joining a group managed by us, reacting to posts, sharing, commenting, sending a private message), Ocalenie Foundation becomes the controller of your data, alongside with Facebook, X or WhatsApp, respectively. Data, such as first and last name, age, image, public profile and other information, conveyed in private messages or comments, shall be processed until the termination of Foundation’s activity on grounds of legitimate interest, and for purposes of responding to comments and messages, keeping in touch with anyone interacting with us and analysis of our communication efficiency.

Data of persons who have taken part in the events organised by Ocalenie Foundation
In case of an event being organized by us, which would require registering with us, we ask you to provide, as a general rule, the following data: first and last name, e-mail address and phone number; but the nature of the event (e.g. training course) may require provision of other data. This data shall be processed for purposes of organizing the event on the basis of performing a task carried out in the public interest in accordance with the Ocalenie Foundation’s Statute (GDPR art. 6 (1) point (e)).

After the conclusion of the event, the participants’ data shall be processed on grounds of legitimate interest, for the purpose of relationship management, for the period of 5 years, starting on the first day of the year following the year of the last interaction with a given person as evidenced in the records of the CRM system. If you wish the data to be erased earlier, contact us at [email protected]. In case of events organized thanks to grants from our funders requiring us to keep documents for a longer period, relevant information shall be made available at the time of enrolment.

Data of competition participants
In case of a competition being organised, the scope of data to be processed shall be given in the rules governing the course of the event. Usually we restrict the data to participants’ e-mail address and winners’ name, surname and address for correspondence. This data shall be processed in order to determine the winner and send out prizes; the basis of the processing is performing a task carried out in the public interest in accordance with the Ocalenie Foundation’s Statute (GDPR art. 6 (1) point (e)).

After the conclusion of the competition, the participants’ data shall be processed on grounds of legitimate interest, for the purpose of relationship management, for the period of 5 years, starting on the first day of the year following the year of the last interaction with a given person as evidenced in the records of the CRM system. If you wish the data to be removed earlier, contact us at [email protected].

Data of house or flat owners within ‘Refugees Welcome Polska’ and ‘Witaj w domu’ programs
When registering your house or flat for the purposes of taking part in ‘Refugees Welcome Polska’ and ‘Witaj w Domu’ programs, we ask you to provide your first and last name, e-mail address, phone number and your place of residence. This data shall be used to successfully carry out the program and shall be processed throughout the duration of your participation; the basis of the processing shall be performing a task carried out in the public interest in accordance with the Ocalenie Foundation Statute (GDPR art. 6 (1) point (e)).

Once your participation in a programme ends, your data shall be processed on the basis of our legitimate interest, for relationship management purposes, for the period of 5 years, starting on the first day of the year following the year of the last interaction with you as evidenced in the records of the CRM system. If you wish the data to be removed earlier, contact us at [email protected].

Data of persons participating in the course recruitment and taking part in Polish language courses
When applying for a Polish language course, we ask you to provide: name, surname, origin, date of birth, gender, telephone number, knowledge of foreign languages and type of document on the basis of which you are staying in Poland. We use this data to carry out the course and process it for the period of your participation in the course and the basis for processing is the fulfillment of tasks in the public interest resulting from the statute of the Ocalenie Foundation (GDPR art. 6 (1) point (e)).

After the course has ended, we process the data of participants on the basis of our legitimate interest to manage the relationship, for 5 years after the end of the calendar year. If you would like your data deleted earlier, please email us at [email protected]. For courses organized with grant funders that require us to keep records for a longer period, we will provide the relevant information upon enrollment.

Personal data of job applicants
In order to carry out the recruitment procedure, we process the data of job applicants on the basis of our right under the law, namely Article 22 of the Labour Code. This data is processed by us until the end of the recruitment process.

In justified cases, in order to send you other job offers, we may ask you to include in the recruitment materials (CV and/or cover letter) your consent to the processing of your data in all future recruitment processes. The relevant information will then be included in the job advertisement. In such situations, your data will be processed until your consent is withdrawn, but not longer than 5 years from the end of the last recruitment process in which you took part.

3. Statistics (Google Analytics)

On our Website, we use Google Analytics, a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States („Google”).

Google is analyzing the usage of our website on our behalf. For this purpose the cookies described in section 9 are used. The information collected by Google, connected with your usage of our website (such as the URL that links to the website, the pages you visit, browser type, language settings, operating system, screen resolution) will be forwarded to our Google server in the USA, where it will be stored and analyzed. Their results are made available for us in an anonymous form. Your usage data is not linked to your full IP address in this process.

It is possible to withdraw your consent to the use of analysis of the website at any time by downloading and installing the relevant Google browser plugin.

Further information about Google Analytics is available in the Google Analytics Terms of Service, the Google Analytics Privacy and Data Protection Guidelines and the Google Analytics Privacy Policy.

Complaints
If you would like to exercise any of your personal data rights or simply ask a question about our Privacy Policy, please email us: [email protected].

You also have the right to make complaints about all issues regulated by our Privacy Policy.

Complaints should be submitted in writing, by registered letter to the address of Ocalenie Foundation.

A correctly submitted complaint should include at least the name and surname, the mailing address and the content and basis for the complaint. Giving the aforementioned data is necessary for considering the complaint. Complaints that do not fulfill these requirements will not be considered.

Complaints will be considered within 14 days of their submission to the foundation.

If you discover that your data is being processed against the law, you may also file a complaint to the supervisory authority – the President of the Office for Personal Data Protection in Poland.

Data sharing
Ocalenie Foundation will transfer your personal data only to:

entities processing data on our behalf, at our request and for the same purpose on the basis of an authorisation or a personal data processing contract (e.g. IT service or accounting services of the foundation)
entities authorized under the relevant legal regulations (e.g. law enforcement agencies).
What is more, in case of using traditional postal communication, we provide your personal data for processing to postal agencies (Poczta Polska and other companies operating under postal law). Intermediaries become at this point separate Administrators of personal data necessary to deliver the shipment.

Personal data collected in the framework of publicly funded projects may be shared for the purpose of monitoring, reporting and auditing the implemented project, only with entities authorized to carry out the above activities or their representatives.

Your personal data is not a subject for automated decision making, including profiling.

Data retention
Possible periods of time for which personal data may be stored by Ocalenie Foundation have been described in point 2 of this Privacy Policy.

In all other cases than those described in point 2, we also reserve the right to process your data after termination of the contract or withdrawal of your consent to the extent required to pursue possible claims in court or if national or EU legislation or international law obliges us to retain data.

Your rights
When it comes to our processing of your personal data, you are entitled to the following rights:

If you wish to gain access to your personal data, revise, update or demand its removal, you may always do so by contacting us at any given time: [email protected].

You may also object to the processing of your personal data, request of us to limit the processing of your personal data or demand the transfer of your personal data. These rights may likewise be exercised by contacting us at [email protected].

If you agreed to our collecting and processing of your personal data, you may withdraw your consent at any time. This will not impact the legality of processing that occurred before the withdrawal, nor will it affect any processing of your personal data on legal bases other than consent.

You also have the right to file a complaint with a supervisory authority for the protection of personal data, in case you deem the processing of your personal data to violate provisions.

We respond to any demands from persons seeking to exercise their data protection rights according to applicable provisions concerning data protection.

Data security
When processing your personal data, we apply organisational and technical measures in accordance with the appropriate provisions of law. We store most of the data in electronic form: primarily on our own server and on a rented server and – to a limited extent – on office computers, external drives and phones. We process data be means of IT tools used by the team and entities cooperating with Ocalenie Foundation, primarily through a CRM relationship management system (hereinafter referred to as CRM), e-mail and a file storage cloud. Some data is stored in the form of paper documents in suitably secured cabinets and rooms.

Cookies
Cookies are small text files sent to your device during the visiting of our websites: ocalenie.org.pl, refugeeswelcome.pl, witajwdomu.org.pl, centrum.ocalenie.org.pl.

Cookies contain among others the address of the website from which they originate, settings made by the website user pertaining to site layout, font size, colours and contrast options, data entered into forms and a value usually represented by an automatically generated unique number. The cookie mechanism does not retrieve any kind of personal data,
or any confidential information from the end-user’s device.

By using the websites of Ocalenie Foundation you agree to the use of cookies. As an end-user you have the option of using websites without the use of cookies however some website functions may then not work properly. Keep in mind that you can always change your cookie settings yourself as well as delete cookies using the available settings in your internet browser of choice. In case of not agreeing to the use of cookies it is possible to select the option
of blocking cookies or notifying their transmission in the browser settings.

Our websites may use the following cookies:

Authentication files – used for services requiring the authentication of the end-user on a website as well as for detecting abuse in the field of website authentication.
Statistical files – used for collecting information detailing the end-user’s use of a website.
Functional files – used for memorizing the end-user’s user interface settings and personalisation, e.g. language choice, font size, website appearance, etc.
In order to manage cookie settings, select your app of choice from the list of official browser developers’ websites and proceed in accordance with the developer’s instructions:

Internet Explorer – http://support.microsoft.com/
Chrome – http://support.google.com/chrome/
Safari – http://support.apple.com/
Firefox – http://support.mozilla.org/pl/
Opera – http://help.opera.com/Windows/
Mobile devices:

Android – http://support.google.com/chrome/
Safari – http://support.apple.com/
Windows Phone – http://www.windowsphone.com/pl-pl/how-to/ (12).

10. Changes to the Privacy Policy

Ocalenie Foundation reserves the right to revise, at least once a year, and make unilateral changes to the content of the present Privacy Policy at any time. Revisions come into effect on the day of their publishing within the website www.ocalenie.org.pl.