Privacy Policy

The National Museum of the Holodomor-Genocide respects users’ right to privacy and is committed to protecting personal data.

This Privacy Policy explains what personal data may be collected whilst using the Museum’s website, for what purposes it is processed, to whom it may be disclosed, and what rights users have.

1. Who processes your personal data

The data controller is:

National Museum of the Holodomor-Genocide
EDRPOU code: 36588948
Address: 01015, Ukraine, Kyiv, 15-A Ivana Mazepy Street
Telephone: (044) 254-45-12
Email: [email protected]

Hereinafter: ‘the Museum’, ‘we’, ‘us’.

2. What data we may collect

Depending on how you use the website, we may process the following categories of information.

Data that you provide yourself

Specifically:

name or name of the contact person;
telephone number;
email address;
the content of messages and enquiries;
information that you provide via the ‘Share your story’ form;
photographs, documents, audio and video files, and other materials that you voluntarily upload to the website;
your email address, if you subscribe to news or other updates;
other information that you voluntarily provide to the Museum.

If the materials you are sending contain other people’s personal data, you must have a lawful basis for providing it to the Museum.

Technical specifications

When you use this website, the following may be processed automatically:

IP addresses;
browser type and version;
device type and operating system;
browser language;
date and time of visit;
pages viewed;
source of the link to the website;
approximate location information, determined on the basis of an IP address;
information about interactions with the website;
cookies and similar technologies.

3. What we use personal data for

We may process personal data for the following purposes:

responding to users’ enquiries and requests;
organising visits to the Museum, guided tours, events and educational programmes;
collecting and processing historical accounts, memoirs, materials and other documents submitted by users;
communication with individuals who have donated items to the Museum;
the compilation of museum, archival, academic and research materials in the cases provided for by law;
sending news and information updates, provided the user has subscribed to them;
ensuring the website’s operation, security and accessibility;
to analyse website usage and improve its functionality;
assessments of the effectiveness of information and advertising campaigns;
to prevent fraud, misuse or unauthorised access;
compliance with the requirements of Ukrainian legislation.

We do not use personal data for purposes incompatible with those for which it was collected.

4. Legal grounds for processing

Personal data is processed in accordance with Ukrainian legislation, in particular the Law of Ukraine ‘On the Protection of Personal Data’.

Depending on the circumstances, the legal basis for processing may be:

your consent;
the need to process your enquiry or fulfil your request;
the fulfilment of the Museum’s statutory duties;
the conduct of museum, archival, academic, research, cultural and educational activities;
the need to ensure the security and proper functioning of the website;
any other legal basis provided for by law.

If the processing is carried out on the basis of your consent, you may withdraw it in the circumstances and in accordance with the procedure provided for by law.

5. Materials submitted via ‘Share Your Story’

Users may voluntarily submit to the Museum of History their recollections, photographs, documents and other materials relating to the history of the Holodomor.

Such materials may contain personal data and, in some cases, information about other individuals or historical events.

The museum may process the following materials for the following purposes:

verification and organisation of information;
museum and archival work;
historical and academic research;
documenting the history of the Holodomor;
communication with the person who provided the materials.

The public use or publication of materials is carried out in accordance with Ukrainian law, the nature of the materials received, the permissions granted by the user and other applicable legal grounds.

We recommend that you do not submit any information via the website that is not necessary for the relevant purpose.

6. Newsletter

If you voluntarily subscribe to the Museum’s newsletter, we may use your email address to send you news, event announcements and other information about the Museum’s activities.

We use SendPulse to organise our email newsletters.

When using SendPulse, the following may be processed:

email address;
name, if one has been given;
IP addresses;
the date and time of subscription;
information on message delivery;
data on email opens;
data on clicks on links in emails.

This data is used to send newsletters and analyse the effectiveness of our mailings.

You can unsubscribe from the newsletter at any time by clicking the unsubscribe link in the email or by contacting the Museum.

7. Cookies, analytics and marketing technologies

This website uses cookies and similar technologies to ensure it functions properly, analyse user behaviour and assess the effectiveness of our communications.

The following third-party services may be used on the website.

Google Analytics

We use Google Analytics to gather statistics on website usage and to understand how users interact with its pages.

Google Analytics may process, in particular:

information about pages viewed and sessions;
approximate location;
information about the browser, operating system and device;
source of the visit to the website;
information about your interaction with the website;
cookies and other technical identifiers.

This information is used for statistical purposes, to analyse the website’s performance and to improve its structure, functionality and content.

Meta Pixel

This website uses Meta Pixel, a technology developed by Meta, which helps to measure the effectiveness of information and advertising campaigns.

Meta Pixel can process information about:

page views;
interaction with the website;
browser and device;
IP address;
cookies and other technical identifiers;
specific actions carried out by the user on the website.

Meta may link the information it receives with other data in accordance with its privacy policies and the user’s settings.

Microsoft Clarity

We use Microsoft Clarity to analyse how users interact with the website and to improve its usability.

Clarity can record:

clicks;
scrolling the page;
cursor movements;
interaction with interface elements;
technical information about the device and the browser;
page views;
user session logs;
heatmaps.

This data is used to identify issues with the website’s navigation, interface and functionality.

Fields and elements that may contain confidential information must be masked in accordance with the security mechanisms provided by Microsoft Clarity.

SendPulse

SendPulse may also use technical tracking tools to determine whether emails have been delivered and opened, as well as whether links within them have been clicked.

This information is used to analyse the effectiveness of the Museum’s email communications.

8. Consent to the use of cookies

Cookies that are necessary for the technical operation of the website may be used without the user’s specific consent in the cases provided for by law.

Analytical, functional and marketing cookies, including those associated with Google Analytics, Meta Pixel and Microsoft Clarity, are used in accordance with the user’s preferences as set out in the website’s cookie settings.

The user can:

agree to the use of all cookies;
allow only certain categories of cookies;
opt out of non-essential cookies;
change or withdraw your choice.

Further information on the types of cookies, their retention periods and how to manage them can be found in our separate Cookie Policy.

9. Disclosure of data to third parties

We do not sell users’ personal data.

In the course of the website’s operation, personal data or technical information may be transferred to technology service providers, including:

Google — in connection with the use of Google Analytics;
Meta — in connection with the use of Meta Pixel;
Microsoft — in connection with the use of Microsoft Clarity;
SendPulse — for email newsletters;
hosting and technical infrastructure providers;
developers and companies that provide technical support for the website;
to public authorities in the cases provided for by law;
to other persons in cases provided for by law or with your consent.

Such suppliers are granted access to information to the extent necessary to provide the relevant services, and may process it in accordance with their own privacy policies and terms of use.

10. Transfer of data outside Ukraine

Certain technology service providers, including Google, Meta, Microsoft and SendPulse, may process or store information on servers located outside Ukraine.

In this regard, personal data may be transferred to other countries to the extent necessary for the operation of the relevant services.

The museum carries out such transfers in accordance with the requirements of the applicable legislation and takes appropriate measures to protect personal data.

11. Retention period for personal data

We retain personal data for no longer than is necessary to fulfil the purpose for which it was collected, unless a longer period is required by law or is necessary for museum, archival or research purposes.

The retention period may depend on the category of information and the purpose for which it is used.

Items of historical, museum, archival or scientific value may be retained for a long period or indefinitely, in accordance with the relevant legislation and the rules governing museum and archival record-keeping.

Technical and analytical data may be retained for the periods specified in the settings of the relevant third-party services.

12. Protection of personal data

The museum implements organisational and technical measures to protect personal data against:

unauthorised access;
unlawful processing;
accidental loss;
destruction;
changes;
unlawful disclosure.

Access to personal data is granted only to those persons who require it to carry out their respective duties.

At the same time, no method of transmitting or storing information on the Internet can guarantee absolute security.

13. Your rights

Under Ukrainian law, you have the right, in particular:

to be informed about the sources from which your personal data is collected, its location and the purpose for which it is processed;
to receive information about the conditions governing access to personal data;
to access your personal data;
to receive a reply as to whether your personal data is being processed;
to request the correction of inaccurate or out-of-date data;
to request that the processing of personal data be stopped or that such data be erased in the cases provided for by law;
to withdraw consent to the processing of personal data, where such processing is based on consent;
to object to the processing in the cases provided for by law;
to lodge complaints with the Ukrainian Parliamentary Commissioner for Human Rights or with the courts;
to exercise other rights provided for under Ukrainian law.

To exercise your rights, you may contact the Museum using the contact details set out in this Policy.

14. Children’s details

The website is not specifically designed to collect children’s personal data independently, without the involvement of their parents, legal guardians or responsible adults.

Where personal data relating to children is processed as part of educational programmes, enquiries or historical materials provided, the Museum takes appropriate measures to protect such data in accordance with the law.

15. Links to external websites

The website may contain links to third-party websites or services.

The museum has no control over how such websites process personal data and accepts no responsibility for their privacy policies.

Before using third-party websites, we recommend that you familiarise yourself with their terms of use and privacy policies.

16. Amendments to this Policy

We may update this Policy from time to time, in particular in response to changes in legislation, the website’s functionality or the range of technological services used by the Museum.

The current version of the Policy is published on this page, along with the date of the last update.

17. Contact details

If you have any questions regarding this Policy, the use of your personal data or the exercise of your rights, please contact:

National Museum of the Holodomor Genocide
Address: 01015, Ukraine, Kyiv, 15-A Ivana Mazepy Street
Telephone: (044) 254-45-12
Email: [email protected]