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Privacy Policy

Owner and Data Controller

Sushko Foundation

Artemidos Avenue 17, SONIC HOUSE, 4th floor, Skala, 6025, Larnaca, Cyprus

Owner contact email: mail@sushko.foundation

Types of Data Collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Usage Data; IP address; device information; browser information; operating systems; city; ZIP/Postal code; state; county; country; latitude (of city); longitude (of city); metro area; geography/region; email address; various types of Data; Trackers; number of Users; session statistics.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published, or shared through this Application.

Mode and Place of Processing the Data

Methods of Processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of the Data.

Data processing is carried out using computers and/or IT tools, following organizational procedures strictly related to the purposes indicated. In addition to the Owner, in some cases, Data may be accessible to certain individuals involved in the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communication agencies) appointed as Data Processors by the Owner. An updated list of these parties may be requested from the Owner at any time.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention Time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. It may be retained for longer if required by applicable legal obligations or based on Users' consent.

Purposes of Processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, and for the following: Traffic optimization and distribution, Contacting the User, and Analytics.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed Information on the Processing of Personal Data.”

Detailed Information on the Processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  • Analytics
  • Contacting the User
  • Traffic Optimization and Distribution

Cookie Policy

This Application uses Trackers, including Cookies, to improve the User experience, analyze traffic, and enable essential functions. Trackers are either managed directly by the Owner (first-party Trackers) or by third parties (third-party Trackers) that provide services for this Application.

Types of Trackers Used:

  • Necessary Trackers: These Trackers are essential for the proper functioning of this Application and do not require consent.‍
  • Measurement Trackers: These Trackers collect data to analyze User behavior and improve the service.

Legal Basis of Processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes.
  • Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof.
  • Processing is necessary for compliance with a legal obligation to which the Owner is subject.
  • Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner.
  • Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

The Rights of Users Based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to:

  • Withdraw their consent at any time.
  • Object to the processing of their Data.
  • Access their Data.
  • Verify and seek rectification.
  • Restrict the processing of their Data.
  • Have their Personal Data deleted or otherwise removed.
  • Receive their Data and have it transferred to another controller.
  • Lodge a complaint with a supervisory authority.

Details About the Right to Object to Processing

Where Personal Data is processed for a public interest, in the exercise of official authority vested in the Owner, or for the purposes of legitimate interests, Users may object to such processing by providing a ground related to their particular situation.

Where Personal Data is processed for direct marketing purposes, Users can object at any time, free of charge and without providing any justification. Where Users object to processing for direct marketing, the Personal Data will no longer be processed for such purposes.

How to Exercise These Rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered as early as possible, always within one month.

Additional Information About Data Collection and Processing

Legal Action

The User's Personal Data may be used for legal purposes by the Owner in Court or in stages leading to possible legal action arising from improper use of this Application or the related Services.

The User acknowledges that the Owner may be required to reveal personal data upon request of public authorities.

System Logs and Maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Changes to This Privacy Policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and, where feasible, via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

If changes affect processing activities based on User consent, the Owner shall collect new consent where required.

Last updated: September 6th, 2024