Last updated: 29th October 2025

1. Who we are
Seventh Victory International Relief Assistance (Also known as 7V IRA) is a public foundation non-profit registered in Bulgaria.
Registered charity number: [CHARITY_NUMBER]
Headquarters: Gabrovo
Contact: info@seventhvictoryira.org

7V IRA acts as an independent NGO and platform that collaborates with Seventh Victory and The Salvation Army. When you make purchases that include a donation, purchases and payment processing occur on Seventh Victory’s website; 7V IRA does not process card payments for those purchases. You may also donate directly to 7V IRA via bank transfer (details below).

2. Scope & purpose of this policy
This Privacy Policy explains:

• what personal data we collect and why;
• how we use and share data;
• how long we keep data;
• your legal rights and how to exercise them;
• how we protect your data.

The policy applies to visitors and donors who interact with 7V IRA’s website www.seventhvictoryira.org, including:

• visitors who follow links to SEVENTH VICTORY and make purchases there;
• people who donate directly to 7V IRA via bank transfer;
• people who subscribe to 7V IRA / Seventh Victory mailing lists, contact us, or volunteer.

3. Data Protection
If you purchased a product which includes a donation on Seventh Victory’s website, SEVENTH VICTORY is the controller for data collected during that transaction; 7V IRA is a separate entity and receives only the donation fund, unless SEVENTH VICTORY shares donor contact details with 7V IRA (in which case governances below apply — see “Sharing & recipients”).

4. Personal data we collect
Depending on how you interact with us, we may collect:

• When you visit the 7V IRA website
• Technical data (IP address, browser, device), cookies and analytics data.
• Referrer and page-visit metrics.
• When you subscribe to mailing lists
• Name, email address, subscription preferences.
• When you contact us
• Name, email, message content and any attachments.
• When you donate directly to 7V IRA (bank transfer)
• Donor name, contact details (email/phone) if provided, transaction reference, amount, date.
• Any messages / gift-aid / tax-relief declarations you provide.

5. Legal bases for processing (where applicable)

• Consent — for marketing communications (newsletter). You can withdraw consent anytime.
• Contractual / pre-contractual steps — where we provide services or acknowledgements for direct donations.
• Legal obligation — to comply with accounting, tax or anti-money laundering obligations.
• Legitimate interests — to run and secure the website, perform analytics (balanced against your rights).

If you make a purchase that includes a donation via SEVENTH VICTORY, SEVENTH VICTORY will provide information about legal bases for the personal data processed during the checkout.

6. How we use your data

• To acknowledge and administer donations and send receipts (for direct donations).
• To send newsletters and updates where you subscribed.
• To operate, analyze and improve our website (using Matomo analytics)
• To respond to enquiries and manage relationships with partners and approved charities.
• To comply with legal obligations (tax accounts, donation records).
• For fraud prevention and safety.

7. Sharing & recipients
We may share personal data with:

• Partner charities (e.g., The Salvation Army) where required to distribute funds or collaborate on campaigns. We will share the minimum required data and only with charities approved by 7V IRA.
• Seventh Victory (SEVENTH VICTORY) — where SEVENTH VICTORY shares donor info for campaign coordination or fulfilment. Any transfer should be governed by a written agreement.
• Service providers (MailerLite, Matomo, accountants, payment processors for direct donations) who act as processors — subject to DPAs.
• Legal & regulatory bodies when required by law (e.g., tax authorities, AML checks).

We will never sell personal data.

8. International transfers
If data is transferred outside the EEA/UK (e.g., Matomo or MailerLite servers), we will ensure appropriate safeguards (Standard Contractual Clauses, adequacy, or equivalent) and document those transfers.

9. Data retention

• Donation records (accounting): retained for [X years] (minimum to meet local tax/accounting law).
• Newsletter contacts: until unsubscribed.
• Enquiries: retained for 6 months.
• Analytics: anonymized/aggregated after 6 months.

10. Your rights
Depending on local law, you may have rights to:

• Access your personal data;
• Rectify inaccurate data;
• Erase/delete data (“right to be forgotten”);
• Restrict or object to processing;
• Data portability;
• Withdraw consent at any time;
• Lodge a complaint with the supervisory authority ([INSERT local authority details]).

To exercise rights, contact info@seventhvictoryira.org specifying the request and proof of identity.

11. Security
We use technical and organisational measures to protect personal data (access controls, encryption where appropriate, staff training). No internet transmission is 100% secure — we cannot guarantee absolute security.

Children
We do not knowingly collect personal data from children under 16 without parental consent. If you believe we have collected data from a minor, contact info@seventhvictoryira.org.

12. Changes to this policy
We may update this Policy. When material changes occur, we will publish the new policy with an updated “Last updated” date and, where necessary, notify affected users.