1. GENERAL PROVISIONS

1.1. Definitions. This document defines the procedure for processing the personal data of Users of the Website https://gwaramedia.com/ (hereinafter – the “Website”), which is owned and managed by the Public Organization «GWARA MEDIA» (hereinafter – the “Organization”).

1.2. Legal Basis. This Policy has been developed in accordance with Ukraine’s law “On Personal Data Protection,” and it also follows the requirements of the General Data Protection Regulation (GDPR) and other international norms.

1.3. Contact Person. For all matters concerning the processing of personal data, the User may contact the Organization at hello@gwaramedia.com.

 

2. COMPOSITION OF PERSONAL DATA PROCESSED

2.1. Data Provided by the User. The Organization collects data that the User provides independently during interaction with the Website. Such data includes, but is not limited to:

2.1.1. Upon Registration and Subscription: name, email address (including cases of authorization through third-party services, such as a Google account, where essential account data is transferred).

2.1.2. Upon Feedback and Donations: Email address, phone number (when subscribing or providing financial support).

2.2. Automatically Collected Data. The Organization automatically collects technical information and data about the User’s behavior that does not directly identify them but is necessary for the Website’s functioning and analysis. This includes:

2.2.1. Analytical Data: IP address (anonymized), device information, browser type, language, geographical location, time and duration of visit, pages viewed (processed using Google Analytics and Hotjar).

2.2.2. Data Collected via Cookies: Technical data related to login, user settings, and Website functionality. The detailed breakdown of this data is provided in a separate Cookie Policy.

 

3. PURPOSE AND LEGAL BASIS FOR PROCESSING

3.1. The processing of the User’s personal data is carried out for the following purposes:

3.1.1. Fulfillment of Obligations: Sending informational materials (newsletters) per the consent (subscription) provided by the User.

3.1.2. Service Improvement: Analyzing visitor statistics and User behavior to optimize the Website’s content, functionality, and technical condition.

3.1.3. Security: Ensuring the proper functioning and security of the Website, preventing unauthorized access, and protecting against fraud.

 

4. TRANSFER OF DATA TO THIRD PARTIES

4.1. The Organization guarantees that personal data is not sold or transferred to third parties for marketing purposes. Transfer is carried out exclusively to the extent necessary to achieve the goals specified in Section 3, or as required by law.

4.2. Payment Partners. When providing financial support (donations) or subscriptions, the User’s data (Email, Name, phone) may be transferred to payment services (LiqPay, Monobank, Patreon, Buy Me a Coffee, PayPal) to ensure transaction processing. The Organization does not store or process payment data (credit/debit card data).

4.3. Analytical Partners. Data processed by Google (Google Analytics) and Hotjar are used for analytical purposes, in accordance with their respective privacy policies.

 

5. RIGHTS OF THE DATA SUBJECT

5.1. The User, as the data subject, has the right to: access their data, rectify it, erase it (“right to be forgotten”), restrict processing, object to processing, and other rights provided for by the Law of Ukraine “On Personal Data Protection” and the GDPR.

5.2. To exercise their rights, the User must send a request to the email address: hello@gwaramedia.com.

 

6. TWO LANGUAGE VERSIONS

6.1. This Policy is available in Ukrainian and English. If there are any discrepancies in the interpretation of the provisions of the different language versions, the Ukrainian version shall prevail.