Privacy Policy 

1. General Provisions

This Privacy Policy (hereinafter referred to as the “Policy”) governs the procedure for collecting, processing, using, and protecting personal data of individuals who interact with the website https://en.timeforaction.info (hereinafter referred to as the “Website”).

We recognize the importance of privacy and are committed to protecting the personal data of our users in accordance with applicable laws and regulations.

This Policy complies with the following legal frameworks:

• The Law of Ukraine “On Personal Data Protection” No. 2297-VI, dated June 1, 2010;
• The Law of Ukraine “On Information” No. 2657-XII, dated October 2, 1992;
• The Law of Ukraine “On Printed Media (Press) in Ukraine” No. 2782-XII, dated November 16, 1992;
• The General Data Protection Regulation (EU) 2016/679 (GDPR) where applicable, to users within the European Economic Area (EEA).

By using this Website, you consent to the processing of your personal data as described in this Policy. If you do not agree with any part of this Policy, please refrain from using the Website.

2. What Data We Collect

We collect and process only the personal data that is necessary to provide access to the Website’s content and services, enhance functionality, and ensure security. All data is collected and processed in accordance with the principles of lawfulness, transparency, purpose limitation, and data minimization, as defined by applicable legislation.

2.1. Data Collected Automatically

When visiting the Website, certain technical data is collected automatically through cookies and analytics tools. This may include:

• IP address of the device used to access the Website;
• Browser type and version, language preferences;
• Pages visited, time spent on the Website, and navigation paths;
• Device and operating system details;
• Usage data collected through cookies, including session data and preferences.

The collection of such data is based on the Website’s legitimate interest in ensuring stability, technical support, and continuous improvement of our services and infrastructure.

This information is gathered via tools such as:

• Google Analytics
• Meta Pixel (Facebook Pixel)
• Cloudflare Analytics, among others.

This technical data, when combined with other information, may be considered personal data under GDPR.

2.2. Data Voluntarily Provided by Users

We may also process personal data that you voluntarily provide when using specific features of the Website, including:

• Contact details: name, email address, phone number (if submitted via contact forms);
• Comments and messages left on the Website;
• Newsletter subscription data, such as your email address.

Providing such information is voluntary. However, refusal to provide certain data may limit your ability to use specific functions of the Website, such as commenting or subscribing to updates.

3. Purpose of Data Collection

We process personal data strictly for specific, legitimate, and clearly defined purposes. The collection and use of data is always proportionate, limited to what is necessary, and in accordance with Article 6 of the General Data Protection Regulation (GDPR) and applicable Ukrainian law.

3.1. Our main purposes for processing personal data include:

• Providing access to Website content and features
  Personal data is used to ensure the proper functioning of the Website, including content delivery, saving user preferences, and allowing comments or subscriptions.
• Improving user experience and Website performance
  We use analytical data to evaluate visitor behavior and optimize the Website’s structure, interface, and content.
• Communicating with users
  Including responding to inquiries, processing contact form submissions, and sending newsletters or relevant information where consent has been given.
• Ensuring information security and system integrity
  Personal data may be used to detect and prevent fraudulent or abusive behavior, enhance protection against cyberattacks, and maintain overall data security.
• Complying with legal obligations
  We may retain or disclose certain data when required to do so by law or by a valid request from a competent authority.

3.2. Legal basis for processing

Depending on the context, we process personal data on the following legal grounds:

• Consent when the user has explicitly given permission for a specific purpose (e.g., subscribing to newsletters).
• Contractual necessity where data processing is required to fulfill a contract or pre-contractual request initiated by the user (e.g., when submitting inquiries).
• Legal obligation when data must be retained or disclosed under applicable laws.
• Legitimate interest when processing is necessary for the proper functioning, development, or protection of the Website and does not override the fundamental rights and freedoms of the user.

4. Disclosure of Data to Third Parties

We do not sell, rent, or otherwise disclose users’ personal data to third parties, except in cases explicitly described in this Policy or required by applicable law. Any transfer of data is conducted in strict compliance with the principles of lawfulness, necessity, and confidentiality.

4.1. Cases in which data may be disclosed:

• Legal and regulatory obligations
  We may disclose personal data in response to legitimate requests from courts, regulatory bodies, or law enforcement authorities, as required by applicable legislation.
• Service providers and data processors
  We may share personal data with trusted third-party contractors who assist us in operating and maintaining the Website. These may include:
  • Hosting providers;
  • Email and newsletter distribution services;
  • Analytics platforms (e.g., Google Analytics, Meta Pixel);
  • Security and DDoS protection providers (e.g., Cloudflare).
  In such cases, we ensure that all service providers act as data processors, bound by written agreements (Data Processing Agreements, or DPAs) that include obligations to:
  • Process data strictly for the specified purposes;
  • Ensure appropriate levels of data protection;
  • Maintain confidentiality and data integrity;
  • Act in accordance with GDPR standards and Ukrainian legislation.
• Security and fraud prevention
  In certain circumstances, we may share data to detect, prevent, or respond to security breaches, fraudulent activity, or threats to the rights and safety of users or the Website.

4.2. Cross-border data transfers

Where personal data is transferred outside of the European Economic Area (EEA), we ensure adequate protection by:

• Transferring only to jurisdictions recognized by the European Commission as providing an adequate level of data protection;
• Implementing Standard Contractual Clauses (SCCs) adopted by the European Commission to ensure GDPR compliance;
• Ensuring that appropriate technical and organizational safeguards are in place.

We do not transfer personal data to countries or entities that do not offer sufficient guarantees of data protection unless explicitly permitted by law and with additional user safeguards.

5. Data Security Measures

We take the protection of personal data seriously and apply a comprehensive set of technical and organizational safeguards to prevent unauthorized access, accidental loss, or unlawful processing of the data we collect and store.

Our approach to data security is based on industry best practices and aligned with the requirements of GDPR, Ukrainian legislation, and international cybersecurity standards.

5.1. Technical safeguards

• SSL/TLS encryption
  All connections to the Website are protected via HTTPS using SSL/TLS encryption to secure data in transit and reduce the risk of interception.
• Server and infrastructure security
  Our infrastructure is protected by:
  • Modern firewall configurations;
  • Regular software updates and vulnerability patching;
  • Antivirus and anti-malware protection;
  • Traffic filtering and rate-limiting systems.
• DDoS protection
  The Website is protected against distributed denial-of-service attacks through integration with services like Cloudflare, which filters malicious traffic and ensures service availability.
• Regular data backups
  We maintain scheduled backups to secure critical data and restore functionality in case of technical failures or incidents.

5.2. Organizational safeguards

• Access control protocols
  Access to personal data is restricted to authorized personnel and service providers only, based on the principle of least privilege and need-to-know.
• Authentication and access logging
  Administrative access is protected by strong authentication mechanisms, including multi-factor authentication (MFA), and all access is logged for audit and security purposes.
• Security audits and monitoring
  We regularly conduct internal reviews and audits to assess the effectiveness of our security measures and address emerging threats.
• Data handling policies
  All staff or third-party contractors with access to personal data are contractually bound by confidentiality obligations and security policies.

5.3. User responsibilities

While we implement robust security controls, users also play a role in ensuring data safety. We recommend:

• Avoiding the use of public or unsecured networks when accessing the Website;
• Keeping devices and software updated;
• Reporting any suspicious activity to: [email protected]

6. Cookie Policy

The Website uses cookies and related technologies (such as LocalStorage, tracking pixels, and session storage) to ensure proper functionality, improve user experience, and enable analytics. The use of such technologies is governed by the Directive 2002/58/EC (ePrivacy Directive), the General Data Protection Regulation (EU) 2016/679 (GDPR), and the Law of Ukraine on Personal Data Protection.

For full details on the types of cookies we use, legal grounds, third-party services, and your rights as a data subject, please refer to our separate document:
Cookie Policy.

6.1. What are cookies?

Cookies are small text files stored in your browser when you visit a website. They may be placed directly by our platform (first-party cookies) or by third-party services (third-party cookies). Cookies may be session-based (deleted when you close your browser) or persistent (stored for longer periods).

6.2. Types of cookies we use

We use cookies in the following categories:

• Strictly Necessary Cookies  required for core site functionality (authentication, session integrity, security). No consent is required.
• Functional Cookies remember your preferences (language, interface, “Favorites” list). Require consent.
• Analytics Cookies help us understand user behavior and improve the site. Tools include:
  • Google Analytics 4 (with IP anonymization),
  • Cloudflare Web Analytics.

Marketing cookies are not currently active, but may be implemented in the future with explicit user consent.

6.3. Legal basis

• Essential and functional cookies are processed on the basis of necessity to provide the service (Article 5(3) ePrivacy Directive; Article 6 of the Law of Ukraine on Personal Data Protection).
• Analytics and advertising cookies are set only after you give consent via a cookie banner or preference settings.

6.4. Managing cookies

You may:

• Accept, adjust, or withdraw consent via the cookie banner or the “Cookie Settings” link in the site footer;
• Manage cookies via your browser settings (view, delete, block, or restrict third-party cookies);
• Contact us with any data-related request, including those concerning cookies (see Section 8).

7. User Rights

As a data subject, you have certain rights under applicable data protection legislation, including the General Data Protection Regulation (GDPR) and the Law of Ukraine “On Personal Data Protection”. We are committed to ensuring that your rights are respected and can be exercised without undue delay.

7.1. Your rights include:

• Right of access
  You have the right to request confirmation of whether we process your personal data, and if so, receive a copy of the data and relevant information about the processing.
• Right to rectification
  You can request that inaccurate or incomplete personal data be corrected or updated without undue delay.
• Right to erasure (“right to be forgotten”)
  You may request the deletion of your personal data when:
  • the data is no longer necessary for the purposes for which it was collected;
  • you withdraw your consent (if that was the legal basis for processing);
  • the data was processed unlawfully;
  • deletion is required by law.
• Right to restriction of processing
  You can request limited use of your data in cases such as contesting its accuracy, pending verification of legitimate grounds, or when you oppose deletion.
• Right to object
  You may object to processing based on our legitimate interests, especially when the data is used for direct marketing purposes.
• Right to data portability
  If processing is based on consent or a contract, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller.

7.2. How to exercise your rights

To submit a request regarding any of the above rights, please contact us via email at:

[email protected]

We will respond to all valid requests within 30 calendar days. If your request is complex or requires more time, we will inform you about the extension and reasons for the delay.

7.3. Right to lodge a complaint

If you believe that your rights under data protection law have been violated, you have the right to file a complaint with the appropriate supervisory authority:

• In Ukraine: the Ukrainian Parliament Commissioner for Human Rights (Ombudsman);
• Within the EU: the data protection authority in your country of residence or establishment.

8. How to Contact Us

If you have any questions regarding this Privacy Policy, the processing of your personal data, or wish to exercise your data protection rights, you may contact us directly using the following details:

Email (for all privacy-related inquiries):
[email protected]

We encourage you to include sufficient detail in your inquiry to allow us to properly identify and respond to your request (e.g., the nature of your concern, your relationship with the Website, and relevant dates or context, if applicable).

We aim to respond to all requests within 30 calendar days. In the case of complex or high-volume requests, we may extend this period in accordance with applicable law, and you will be notified accordingly.

If you represent a legal entity, supervisory authority, or government agency, please clearly indicate this in the subject line of your communication to ensure proper handling.

9. Updates to This Policy

We reserve the right to modify or update this Privacy Policy at any time to reflect changes in legal requirements, best practices, or the functionality of our Website and services.

Any changes to this Policy will take effect upon publication on this page, unless otherwise stated.

9.1. Notification of changes

If material changes are made that may affect your rights or the way we process your data, we will:

• Publish the updated version of the Policy on this page, clearly indicating the “last updated” date;
• Where appropriate, notify you through additional communication channels (e.g., email or on-site banner) to ensure transparency and compliance with applicable laws.

We encourage users to review this page periodically to stay informed about how we collect, use, and protect personal data.

Current version of the Privacy Policy as of July 1, 2025.
The first version of this document was approved on April 27, 2025.
This Policy has been developed in accordance with the requirements of current Ukrainian legislation (the Law of Ukraine “On Personal Data Protection,” the Law of Ukraine “On Information,” the Law of Ukraine “On Printed Media (Press) in Ukraine”), as well as EU Regulation 2016/679 (GDPR) where applicable.
We ensure the protection of users’ private information in line with the best global standards.
All changes to this Policy are dated and published on this page.