Privacy Policy

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Definitions

In the interest of clarity and precision, we use the following definitions throughout this Privacy Policy:

Privacy Policy: This Policy, established in fulfillment of our transparency and information obligations under Articles 13 and 14 of the General Data Protection Regulation (GDPR).

Data / Personal Data: Any information relating to an identified or identifiable natural person (“Data Subject”) processed by the Association.

You / User: Any individual whose Personal Data we process, including visitors to our website, members of the Association, donors, beneficiaries of our charitable programs, or individuals contacting us for assistance.

We / Association / Controller: ASOCIACIÓN BENÉFICA UCRANIANA “TRYZUB”, registration number (NIF): G22863781, with its registered address at Plaza De Santa Eulalia No 5-1, C.P. 07001, Palma De Mallorca (Illes Balears), Spain. Contact email: info@asociaciontryzub.es.

GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

LOPDGDD: Ley Orgánica 3/2018, de 5 de diciembre, de Protección de Datos Personales y garantía de los derechos digitales (Spanish Data Protection Act).

Beneficiary / Member: Any individual receiving administrative, legal, psychological, or social integration support from the Association, as well as registered members and volunteers.

Data Collection and Effects of Refusal to Provide Data

Providing your personal data to the Association is generally voluntary. However, to effectively respond to your inquiries, provide legal guidance, or register you for our educational and social integration programs, certain data is strictly necessary.

The failure to provide mandatory personal data (such as your name, contact information, or core details of your inquiry) will result in the total impossibility of the Association processing your request, providing consultation, or admitting you to our relevant programs and activities.

This Policy applies to the processing of Personal Data collected via:

1. Direct email communications addressed to info@asociaciontryzub.es or other official addresses.
2. Personal interactions, phone consultations, and administrative intake processes.
3. Electronic forms and cookie usage on our official website: http://asociaciontryzub.com/.

Purposes, Legal Bases, and Retention Periods of Data Processing

We process your personal data exclusively for non-profit, charitable, and institutional purposes. The table below specifies the exact legal basis and retention criteria for each purpose:

Special Categories of Personal Data (Sensitive Data)

Given the charitable, social, and consultative nature of Asociación Benéfica Ucraniana “TRYZUB”, we may process specific details necessary to assist you with migration, residence permits, or social adaptation. This may include indicators revealing national or ethnic origin, or information concerning psychological health.

Pursuant to Article 9(2)(d) of the GDPR, such processing is strictly limited to the legitimate non-profit activities of our Association, provided that the processing relates solely to members, former members, or individuals who maintain regular contact with us in connection with our statutory purposes. We implement heightened technical and organizational security measures to protect this data. We do not process any data relating to criminal convictions unless expressly authorized by Spanish law.

Minor's Privacy

Our website and standard communication tools are not intentionally directed at minors under 14 years of age (the statutory age of digital consent in Spain under Article 7 of the LOPDGDD). We do not knowingly collect personal data from minors under 14 without verifiable consent from a parent or legal guardian. If we establish that an individual under 14 has provided personal data without verified parental authorization, we will immediately purge that data from our systems.

Data Recipients

The Association guarantees that it will not sell, rent, or commercialize your personal data. We only share or transfer your data to third parties in the following specific scenarios:

1. Data Processors: Trusted external service providers who process data on our behalf under strict data processing agreements in full compliance with Article 28 of the GDPR. This includes web hosting services, IT support tools, cloud storage providers, and specialized legal or accounting consultants helping execute our tasks.
2. Institutional & Diplomatic Partners: When explicitly requested by you or required to facilitate administrative services, data may be coordinated with the Honorary Consulate of Ukraine, the Consular Corps of the Balearic Islands, or the General Consulate of Ukraine in Barcelona.
3. Public Authorities: Competent public bodies, courts, administrative agencies, or law enforcement forces, strictly when mandated by applicable Spanish or European regulations.

International Data Transfers

When you utilize our website, certain analytical services operated by external third parties (such as Google Analytics 4) may process data outside the European Economic Area (EEA). Whenever personal data is transferred outside the EEA, the Association enforces rigorous safeguards to ensure a level of protection identical to that mandated within the European Union:

• We select third-party providers operating in countries that hold an Adequacy Decision from the European Commission. This includes US-based entities certified under the EU-U.S. Data Privacy Framework.
• In the absence of an adequacy decision, transfers are executed using the Standard Contractual Clauses (SCCs) approved by the European Commission, ensuring enforceable data subject rights and robust legal remedies.

Your Rights Under the GDPR

As a data subject, you hold comprehensive rights regarding how we handle your Personal Data. You may exercise these rights at any time, completely free of charge:

• Right to Withdraw Consent: You have the absolute right to withdraw your consent at any time for any processing purpose that relies on consent (such as website analytics).
• Right to Object: You can object to the processing of your data if the processing is carried out based on our legitimate interest (Art. 6(1)(f) GDPR).
• Right to be Informed: You have the right to receive clear, transparent, and easily understandable information regarding what categories of data we collect, why, and how we process it.
• Right of Access: You can request confirmation as to whether we are processing your personal data, and receive a comprehensive copy of the actual personal values collected, provided it does not adversely affect the rights and freedoms of others.
• Right to Rectification: You can request that we immediately correct any inaccurate, outdated, or incomplete data we hold about you.
• Right to Erasure (“Right to be Forgotten”): You can request the complete deletion of your data when it is no longer necessary for the purpose it was collected, or when you have successfully withdrawn consent or objected to its processing.
• Right to Restrict Processing: You can request that we pause or limit the processing of your data under Article 18 of the GDPR. Where processing has been restricted, such data (except for storage) will only be processed with your consent, for the exercise/defense of legal claims, or to protect the rights of another natural/legal person.
• Right to Data Portability: Where technically feasible, you may request to receive your data in a structured, commonly used, and machine-readable format, or have us transfer it directly to another Controller, provided the processing is based on your consent or automated contractual execution.

How to Exercise Your Rights & Response Timeframes

To exercise any of your rights, please submit a written request directly to our email: info@asociaciontryzub.es.

In accordance with Article 12(3) of the GDPR, the Association will respond to your request and provide information on the actions taken without undue delay and, in any event, within one month of receiving your message. This period may be extended by two additional months if the request proves highly complex or if we receive an excessive number of simultaneous requests. In such rare cases, we will formally notify you of the extension and the specific reasons for the delay within the first month.

Right to Lodge a Complaint with a Supervisory Authority

If you believe that the Association has processed your data in violation of data protection laws, we encourage you to contact us directly so we can resolve the issue informally. Nonetheless, you retain the absolute legal right to lodge an official complaint with a competent supervisory authority. If you reside or are based in Spain, the competent national authority is:

Agencia Española de Protección de Datos (AEPD) C/ Jorge Juan, 6, 28001 - Madrid Website: www.aepd.es

Automated Decision-Making

The Association values human interaction and does not employ any systems involving automated individual decision-making, nor do we engage in automated profiling that creates legal or significant consequences for our Users.

Privacy Policy Changes

This Privacy Policy is effective as of the date specified below and will remain valid except with respect to future amendments. The Association reserves the right to update or modify this Policy to adapt to legislative updates or changes in our charitable operations. We will notify Users of significant changes by modifying the date at the top of this policy and, where feasible, placing a notice on our website homepage or emailing active members directly.

This Privacy Policy was last updated on May 29, 2026.