Privacy Policy of the «Labirint» project - Labirint

Privacy Policy of the «Labirint» project

Last update: August 1, 2022

01. General provisions

1.1. Privacy policy of the “Labirint” project (hereinafter referred to as “Privacy policy”) explains how Labirint processes personal data (a) of Website user (hereinafter referred to as “Website”), (b) of Women who seek help, (c) of Volunteers and (d) Donors, collectively referred to as “Data subjects” and individually as “Data subject”.  

1.2. Personal data or data itself – is any information that can identify the Data Subject directly, such as name, email address, or information, which is related to the Data Subject indirectly, such as language selection or correspondence. 

1.3. Labirint processes data in accordance with the EU General Data Protection Regulation 2016/679 (hereinafter «GDPR») and applicable data protection laws.

1.4. By accessing the Labirint or collaborating with the Labirint via the Website, the Data Subject confirms that he/she has read and understood the Privacy Policy.

1.5. The terms used in the Privacy Policy with a capital letter and those, which are not defined have the meaning assigned to them in the Terms of Use, the Volunteering Agreement and the Donation Agreement.

02. Data controller (operator)

2.1. The data controller (operator) is:

Rivina Foundation – a non-profit organization, registered under the laws of Georgia.

Registration number: 404637933

Legal and current adress: 6 Mtkvari str., apartment 1a, Krtsanskyi raion, city of Tbilisi, Georgia.

(hereinafter referred to as “Labirint”).

2.2. The Data Subject has the right to contact the Labirint by e-mail regarding any questions related to the processing of Personal Data and the exercise of his/her rights

03. What data does the Labirint process

3.1. Data of women seeking help

When a woman seek help through the Website, the Labirint collects the following data by using the online form on the Website:

  • name, surname;
  • country of residence (by now);
  • if she is safe;
  • what help is needed/ description of the situation;
  • language for communication;
  • preferred way of communication;
  • link to the social media;
  • contact information: telephone number, e-mail;
  • Terms of use agreement.

In providing help, the Labirint, Volunteers or psychologists receive from the Woman, orally and in writing, information that is necessary or that the Woman deems necessary to help her. 

Purpose of processing: for Women coordination and communication with a psychologist or Volunteer to provide the requested help.

Processing basis: Execution of the contract.

3.2. Volunteers data. 

Through the form on the Labirint Website, the Labirint collects the following data of women wishing to become Volunteers:

  • name, surname;
  • country of residence (by now);
  • if they are safe;
  • existing experience;
  • knowledge of languages;
  • preferred way of communication;
  • link to the social media;
  • contact information: telephone number, e-mail;
  • Acceptance of Terms of Use and Volunteering Agreement.

Purpose of processing Personal data: for cooperation and coordination.

Processing basis: Execution of the contract.

3.3. Donor’s data:

During the donation process, the Labirint collects the name and email of the Donor, the donation amount and the acceptance of the Donation Agreement and the User Agreement.

Payment is processed by the payment service provider based on its own agreements and processes the data according to its own privacy policy.

The Labirint receives and stores transaction data such as: transaction date and time, its amount, card name, and the last four digits of the card.

Purpose of processing Personal data:  to accept donation and send receipt 

Processing basis: Execution of the contract and fulfillment of the requirements of the law.

3.4. Website Usage Data

The Labirint collects information about the User’s activity on the Website.

These data include information about the User’s activities on the Website, such as:

  • personal language settings;
  • visits and interaction with the Website.

Purpose of processing:  

  1. Provision of the website and personalization of the settings. Processing basis: Execution of the contract.
  2. To identify and improve the operation of the Website.  Processing basis: legitimate (lawful) interest.

Data processing based on legitimate interest means that the Labirint uses data for the following purposes:

  • to develop and improve the Website;
  • to ensure the security and usability of the Website.

Labirint can combine, collect into reports and analyze any information, which were collected for indicated goals.  Before that, Labirint anonymizes collected information. Labirint can use anonymized information for any purposes. Anonymized information cannot identify Data subject and is not subject to this Privacy Policy. 

04. Cookies

Cookies (including similar technologies) – are the files created by the visited websites, which allow to collect information about the User’s device and its activities on the visited websites (hereinafter referred to as the “Cookies”).

The Labirint uses the following categories of Cookies:

  • Necessary – help to make the Website available for use, providing basic features such as page navigation and secure access to the Website; 
  • Preferences – allow remembering personal Account settings. For example, Website language selection;
  • Analytical – help to understand how Users interact with the Website by collecting and passing anonymized information.    

The Labirint does not collect or transfer information for marketing purposes.

For the above-mentioned purposes, Labirint uses services Google Analytics and Yandex. Metrica and Amplitude (hereinafter referred to as “Analytics services”).  

Data subject can turn off Cookies from Google Analytics and Yandex.Metrica by using direct links: Google Analytics opt-out, Yandex.Metrica opt-out.

05. Data transfer

The Labirint can transfer information to the following categories of persons:

Volunteers and psychologistsTo provide required help for Women;
Analytics service providersFor the correct functioning of the Website, remembering preferences of Data Subjects;
Payment service providersFor payment (donation) processing;
Other services providersLabirint may contact various service providers to achieve the objectives set out in this Policy.

06. Data storage

Labirint stores Personal Data of Data Subjects for the time necessary to (1) help Women; (2) comply with legal and contractual obligations, (3) implementation of our legitimate interests, or (4) during the period of validaty of your consent, as stated in this Privacy Policy.

Once information ceases to serve these purposes, the Labirint removes it.

Upon request of the Data Subject, the Labirint will delete and / or anonymize Personal Data without undue delay, not later than 30 days. The Labirint has the right to keep a part of Personal Data in cases where we have a legal right or a requirement to keep such Personal Data, for example, if:

  • The Labirint is obliged to store data for the performance of legal, tax and accounting obligations and / or any other legal obligations. The Labirint will store the necessary data for the required period;
  • it is necessary for the realization of the legitimate interests of the Labirint.

07. Data Subject Rights

7.1. Right to Access Your Personal Data – The data subject has the right to request a copy of his/her Personal Data and / or the way of Personal Data storage.

7.2. Right to Correction – The data subject is entitled to request that his/her Personal Data be changed or corrected if it is inaccurate.

7.3. Right to delete – The data subject has the right to request the deletion of all or part of his/her Personal data, for example, if: 

  • they are no longer needed for any processing purposes;
  • consent was used as the legal basis for processing;
  • there is no legal requirement for further processing of Personal Data.

7.4. Right of objection – The data subject has the right to object to the processing of his/her Personal data based on a specific situation and / or to object to the processing of data for direct marketing. 

7.5. Right to object to automated processing – The data subject may object to a decision based on automated processing. This means that the Data Subject has the right to request the verification of his/her Personal data manually if it considers that the automatic processing of Personal data may not take into account his/her unique situation.

7.6. Right to data portability – The data subject has the right to request a copy of his/her Personal data in a structured, widely used and machine-readable format (for example, xml, csv). In addition, the Data Subject has the right to request the transfer of the Personal Data specified by him/her directly to another operator/controller.

7.7. Right to file a complaint – The data subject has the right to file a complaint with the supervisory body, in particular to the Member State of the European Union where he/she usually resides, works or the place of the alleged violation.

7.8. To exercise any of the rights, the data subject has the right to contact Labirint by e-mail: Before executing a request, the Labirint must identify the data subject.

08. Violation of personal data processing

The violation of the processing of personal data, if not corrected in an appropriate and timely manner, can lead to physical, material or non-material risk for the rights and freedoms of data subjects. Therefore, as soon as the Labirint becomes aware of a breach in the processing of personal data, the Labirint undertakes to notify the Commissioner for Personal Data Protection immediately, but not later than 72 hours, unless such violation does not compromise the rights and freedoms of the data subjects. If such notification cannot be received within 72 hours, the reasons for the delay shall be stated in the notification.

09. Personal data of children

The Labirint can process the children’s data given to it at its discretion by the Woman who is the parent of the child, only for assisting the Woman and her child. 

The Labirint consciously does not collect children’s personal data and does not process such information without parental consent.

10. Cross-Border Data Transfers

The Labirint may transmit Personal Data to controllers (operators) and data processors outside the European Union («EU») or the European Economic Area («EEA») for the purposes specified in this Privacy Policy.

In such cases, the Labirint undertakes to include in agreements with data controllers and processors located outside the EU or EEA issued by the European Commission standard contract clauses (SCC) adopted by the European Commission as an instrument for data transmission from EU countries.

11. Amendments to privacy policy

Labirint can make changes to this Privacy Policy from time to time. The latest version of the Agreement will be available on the Website. By continuing to use the Website, the Data Subject confirms that he/she has read and agreed with the updated Privacy Policy.