CDTO campus
Privacy Policy

In accordance with paragraphs 1 and 2 of part two of Article 8, part two of Article 12 of the Law of Ukraine ”On Personal Data Protection” (hereinafter referred to as the “Law”), International Charitable Organization “East Europe Foundation” informs about the owner, manager, location, content, and purpose of collecting personal data processed using the CDTO Campus Educational Online Platform software (hereinafter referred to as the “Platform”), which is located at https://www.cdto-campus.com, including using the CDTO Campus mobile application, third parties to whom such personal data is transferred, and the rights of the personal data subject.

The Platform was created and put into operation as part of the Kyiv GovTech Edu Campus project funded by the Federal Ministry for Economic Cooperation and Development of Germany (BMZ) and supported by the German Society for International Cooperation (GIZ).

1. Personal Data Owner,

processed using the Platform software is its owner – International Charitable Organization “East Europe Foundation” (legal entity identification code: 35142329; legal address: 55, Velyka Vasylkivska Str., 3rd floor, Kyiv, Ukraine, 03150; postal address: 83, Saksaganskogo Str., 3rd floor, Kyiv, Ukraine, 01033; e-mail – info@eef.org.ua).

2. Personal Data Manager;

is the International Charitable Organization “East Europe Foundation” (legal entity identification code: 35142329; legal address: 55, Velyka Vasylkivska Str., 3rd floor, Kyiv, Ukraine, 03150; postal address: 83, Saksaganskogo Str., 3rd floor, Kyiv, Ukraine, 01033; e-mail – info@eef.org.ua).

3. Personal Data Location:

83, Saksaganskogo Str., 3rd floor, Kyiv, Ukraine, 01033.

4. Personal Data Content;

depends on the role of the personal data subject (user of the Platform), which is chosen by the personal data subject when registering on the Platform, and the way they interact with the CDTO Campus application.

4.1. If the personal data subject chooses the role of “Lecturer”, the following data is collected and processed during registration on the Platform:
4.1.1. photo (mandatory);
4.1.2. first name (mandatory);
4.1.3. last name (mandatory);
4.1.4. e-mail address (mandatory);
4.1.5. link to a profile in any social network (optional);
4.1.6. position (optional);
4.1.7. a brief description of the person (optional).
4.2. If the personal data subject chooses the role of “Student”, the following data is collected and processed during registration on the Platform:
4.2.1. first name (mandatory);
4.2.2. last name (mandatory);
4.2.3. e-mail address (mandatory);
4.2.4. photo (optional);
4.2.5. link to a profile in any social network (optional);
4.2.6. a brief description of the person (optional).
4.3. If the personal data subject chooses the role of “Curator”, the following data is collected and processed during registration on the Platform:
4.3.1. photo (mandatory);
4.3.3. last name (mandatory);
4.3.4. e-mail address (mandatory);
4.1.5. position (mandatory).

The personal data processing means any action or set of actions, such as collection, registration, accumulation, storage, adaptation, modification, updating, use and dissemination (distribution, sale, transfer), depersonalization, destruction of personal data, performed using the Platforma software, including using the CDTO Campus mobile application.

5. The purpose of personal data processing (collecting) is:

5.1. creating and ensuring the functioning of the electronic cabinet of the personal data subject in the CDTO Campus application;
5.2. providing access to information on the date, time, and place of lectures;
5.3. providing access to training materials and assignments;
5.4. providing access to the progress of training, assessments, and visits of the personal data subject;

6. Personal data and other information about users collected through the Platform shall not be distributed or transferred to any third parties, except in the following cases:

6.1. at the request of law enforcement agencies with a request for information about users in accordance with the law;
6.2. to execute a court decision or applicable law;
6.3. with the consent of the user.

If the transfer of personal data is required in other cases determined by law, the Notice of Personal Data Processing will be updated on the website of the Platform to allow users to familiarize themselves with this information.

Personal data is not transferred to foreign parties (non-residents) related to personal data (cross-border transfer of personal data).

7. According to part two of Article 8 of the Law of Ukraine on Personal Data Protection, a personal data subject shall be entitled to:

7.1. know about the sources of collection, location of their personal data, the purpose of their processing, location or place of residence (stay) of the owner or manager of personal data or give a corresponding order to obtain this information to persons authorized by him/her, except in cases established by law;

7.2. receive information about the conditions for granting access to personal data, including information about third parties to whom their personal data is transferred;

7.3. access their personal data;

7.4. receive a response on whether his or her personal data is processed, as well as to receive the content of such personal data no later than thirty calendar days from the date of receipt of the request, except in cases provided for by law;

7.5. make a reasoned request to the personal data owner to object to the processing of their personal data;

7.6. make a reasoned request to change or destroy their personal data by any owner and manager of personal data if this data is processed illegally or is unreliable. In such a case, the personal data subject shall send a corresponding request to info@cdto-campus.com. The request must include the following information about the personal data subject:
- first name;
- last name;
- e-mail address specified during registration on the Platform;
- information about the personal data to which the request relates;
- reasoning of the corresponding request.

7.7. protect their personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely providing of such data, as well as to protect against providing information that is inaccurate or discrediting the honor, dignity, and business reputation of an individual;

7.8. file complaints about the processing of their personal data to the Ukrainian Parliament Commissioner for Human Rights or to the court;

7.9. apply legal remedies in case of violation of personal data protection legislation;

7.10. know the mechanism of automatic processing of personal data;

7.11. на захист від автоматизованого рішення, яке має для нього правові наслідки.

8. This version of the Notice of Personal Data Processing is current as of 14.02.2024