Privacy Notice

Meanwhile in Ukraine is a collaborative journalistic project run by a team of Ukrainian journalists.

Project / public brand: Meanwhile in Ukraine
Data controller: Meanwhile in Ukraine Editorial Team, a collaborative group of Ukrainian journalists
Postal contact: P.O. Box 5576, Lviv, Lviv Oblast 79014, Ukraine
Privacy contact: [email protected]

For the newsletter and publication website, the editorial team jointly determines the purposes and essential means of processing subscriber and reader data.

This Privacy Notice explains how personal data is processed when you:

• visit the Meanwhile in Ukraine publication website;
• subscribe to Meanwhile in Ukraine: What Matters;
• confirm a subscription through double opt-in;
• receive or interact with publication emails;
• unsubscribe or manage subscription preferences; or
• contact us about privacy matters.

The Phase 1 newsletter signup form requests only your email address.

Depending on how you use the website and emails, our newsletter platform and technical service providers may also process information such as:

• subscription and confirmation status;
• email address;
• IP address;
• approximate geolocation;
• device and browser information;
• acquisition or attribution source;
• email opens and link clicks;
• unsubscribe and preference information; and
• security, anti-abuse and service-operation data.

We do not intentionally request sensitive personal information through the newsletter signup process.

Newsletter subscription and delivery

We process your email address to register and manage your subscription and to send Meanwhile in Ukraine: What Matters.

Our subscription flow uses double opt-in. A new email address remains pending until the subscriber confirms the subscription through the confirmation email.

For newsletter subscription and delivery, we rely on your consent under Article 6(1)(a) GDPR where the GDPR applies.

You may withdraw your consent at any time by using the unsubscribe mechanism in our emails. Withdrawal does not affect processing that was lawful before withdrawal.

Subscription administration, security and legal compliance

We may process limited personal data where necessary to:

• maintain subscription and unsubscribe records;
• prevent abuse, fraud or unauthorized use;
• maintain service and information security;
• respond to privacy requests; and
• comply with applicable legal obligations.

Depending on the activity, the applicable legal basis may include Article 6(1)(c) GDPR (legal obligation) or Article 6(1)(f) GDPR (legitimate interests).

Analytics and tracking

We may use publication analytics to understand how the website and newsletter are used. Where non-essential cookies, tracking pixels or similar technologies require consent, they will be used only in accordance with the choices presented through the applicable consent mechanism.

Our website may use technologies that are necessary to provide the site and subscription service. Where applicable law requires consent for non-essential cookies or similar technologies, we provide a consent mechanism that allows visitors to make the relevant choice.

Your choices can affect whether non-essential analytics or comparable tracking technologies are activated.

We use beehiiv Inc. to provide newsletter delivery, subscriber management, website functionality and related services.

For Customer Personal Data covered by beehiiv's Data Protection Addendum, the beehiiv customer acts as controller and beehiiv acts as processor. beehiiv may also process certain information for its own purposes, such as security, abuse prevention and service operation, under its own privacy practices where it acts independently.

We also use technical service providers for functions such as email hosting and service operation. These providers may process personal data only to the extent needed to provide their services and subject to the applicable contractual and legal safeguards.

Use of beehiiv and other service providers may involve transfers of personal data outside the country where you are located.

Where legally required, appropriate transfer safeguards are used. beehiiv's current Data Protection Addendum provides for the EU Standard Contractual Clauses where applicable, including Module 2 for covered controller-to-processor transfers.

We keep personal data only for as long as reasonably necessary for the relevant purpose and applicable legal requirements.

Our intended retention criteria include:

• active subscription data: while your subscription remains active and as needed to operate the newsletter;
• unsubscribe or suppression records: for as long as reasonably necessary to respect your opt-out and demonstrate compliance;
• privacy correspondence, security and legal records: for as long as reasonably necessary to respond to requests, maintain security, comply with legal obligations, or establish, exercise or defend legal claims.

Subject to applicable law, you may have rights including:

• access to your personal data;
• correction of inaccurate personal data;
• deletion of personal data;
• restriction of processing;
• data portability;
• objection to certain processing;
• withdrawal of consent at any time where processing is based on consent; and
• lodging a complaint with a competent data-protection supervisory authority.

Where the GDPR applies, you may in particular have the right to lodge a complaint with a supervisory authority in the EEA Member State of your habitual residence, place of work, or place of the alleged infringement, as applicable.

Every production newsletter provides an unsubscribe mechanism.

When you unsubscribe, future newsletter delivery stops in accordance with the subscription state and applicable legal requirements. We may retain limited suppression or compliance records where necessary to respect your opt-out and demonstrate compliance.

For privacy-related questions or requests, contact:

[email protected]

You can also write to:

Meanwhile in Ukraine Editorial Team
P.O. Box 5576
Lviv, Lviv Oblast 79014
Ukraine

We may update this Privacy Notice when our services, processors, analytics, legal requirements or data practices change. The current version will be made available through the publication website.