1. PII That We Collect

When we refer to “PII” in this Policy, we are referring to personally identifiable information that may identify you. PII also includes terms such as Personal Data, as defined by the applicable Serbian Personal Data Protection Law (Official Gazette of the RS, No. 87/2018)("PDPL"), European Union’s General Data Protection Regulation (“EU GDPR”), the United Kingdom’s General Data Protection Regulation (“UK GDPR” and together with the EU GDPR, the “GDPR”), “Personal Information” as defined by the Personal Information Protection Law (“PIPL”) of the People’s Republic of China (but excluding the Special Administrative Regions of Hong Kong and Macau) (“China” or the “PRC”) and similar terms as provided under other applicable laws.


A. Information that you provide to us.

We collect information that you provide us. We may collect this information when you sign up to receive email, fill out a form, send us an email, communicate with us via social media, or request information. We also collect information about you when you make a donation, participate in our programming, and when you otherwise interact with us or our Service. The information we collect may include information that may identify you, such as (but not limited to) your name, email address, physical address, phone number, date of birth, payment information, and only where strictly necessary for your specific application and/or participation in a Contest and therefore only as it relates to your relationship with sports and as permitted by applicable law, information such as race/ethnicity, gender, if you have any disability (physical, intellectual, or developmental, but only as it relates to your relationship with sports and only if you are applying and/or participating in certain Contests), preferred language, your image, and voice, payment information, or other information that you may choose to provide us. If you participate in a, and progress beyond the initial stages of the, Contest, we may also collect a copy of your government issued ID, birth certificates, proof of address, evidence of relationship to the applicant, and, where applicable, letters of support, in order to verify: your identity; and that you meet any eligibility criteria for that Contest.

Part of the purpose of the Site is to share materials you make available. Anything you publicly post, including PII, may be viewable by other users or other visitors to the Site, who may not protect your post(s), or treat it(them) as confidentially as we will, despite our reasonable efforts.

B. Information that we collect automatically.

We also automatically collect certain information when you visit the Site. For instance, we log information about your visit to the Site, including the browser that you use, access times, pages viewed, your IP address, and the page that you visited before coming to the Site. We may also collect information about your device, such as the model of phone or computer that you use, the operating system, device identifiers, and mobile network information.

Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site.

We also use various technologies to collect information, which may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve the Site and your experience, see which areas of the Site are popular, and count visits. We may also collect information using tracking pixels, which are also known as web beacons. Tracking pixels are electronic images that may be used on our Site or in our emails. They help deliver cookies, count visits, understand site usage, and determine whether an email has been opened and acted upon.

We use these technologies in accordance with applicable law. Where required under applicable law (including the GDPR and PDPL), we will obtain your prior consent before using non-essential cookies or similar technologies. You can manage your preferences, and withdraw your consent, at any time through your browser settings (more detail on this can be found in Section 3 or through our cookie management tool, available on the Site). Please note that disabling, or refusing to consent to, certain non-essential technologies may affect non-essential functionality of the Site.

For instance, we may use the following pixels:

Meta Pixel. Our Site uses the Meta Pixel provided by Meta Platforms, Inc., 1 Meta Way, Menlo Park, CA 94025, USA (previously, Facebook Inc.) (referred to in this Policy as “Meta”). Meta Pixel is a tool that uses cookies (and similar technologies) to help measure the effectiveness of our communication and, where permitted, to support advertising and to serve you ads on your social media account, based on your browsing behavior. The Meta Pixel will only be activated following your prior consent (or if required, the consent of your Parent(s) (as defined below)). You may grant, configure, or withdraw your consent at any time through the cookie settings panel available at our Site. To find out more information about how Meta may use your information, we encourage you to visit: https://transparency.meta.com/, and its privacy policy, https://www.facebook.com/about/privacy/.

X Pixel. We use X Pixel (provided by X Corp., 865 FM1209, Suite A, Bastrop, TX 78602, USA (previously Twitter) (“X”)). As used in our Site, the X Pixel tool uses cookies (and similar technologies) to set a unique ID for users that allows third-party advertisers to target users with relevant advertisements. In jurisdictions where consent is required for these technologies, the X Pixel will be used only after the user (or their Parents, as applicable) has provided the required consent through our cookie or consent management tools). To find out more information about how X may use your information, we encourage you to visit: https://x.com/en/privacy and https://business.x.com/en/help/ads-policies/campaign-considerations/policies-for-conversion-tracking-and-custom-audiences. In addition, you can change settings for X Pixel see – https://help.x.com/en/rules-and-policies/x-cookies.

PLEASE NOTE THAT CERTAIN PIXEL PROVIDERS MAY TRANSMIT INFORMATION ABOUT YOU TO UNRELATED THIRD PARTIES, IN ACCORDANCE WITH THEIR OWN PRIVACY POLICIES.

In addition to the cookie settings panel available on our Site, you can also find more information on how to manage targeting and advertising cookies, you can go to the Your Online Choices page, the Network Advertising Initiative page, and the Digital Advertising Alliance’s Consumer Choice page.

When you visit the Site we collect your IP address, which may allow us to approximate your geographic location. Under the GDPR, IP addresses are considered personal data, as they may allow the identification of a natural person directly or by reasonable means - including by reference to information held by or accessible to third parties, such as ISPs (internet service providers). Accordingly, IP addresses are collected and processed in accordance with the legal bases and purposes described in this Policy.

C. Non-Personal Information.

“Non-Personal Information” is information which doesn’t identify you, or has been aggregated or de-identified (to the appropriate legal standard), about you, including but not limited to links and materials posted, enrollment history, purchase history, the type of device you used and its operating system, browser information, the pages accessed most frequently, how pages are used, applications downloaded, search terms entered, and similar Non-Personal Information.

D. Aggregate Information.

We may also collect other information, such as the date and time of any request, language preference, referring website, the website you go to after visiting our Site, and the domain name of your Internet provider. Such information may qualify as PII (if not aggregated or de-identified to the relevant legal standard, or if it is paired with otherwise identifiable information about you), in which case, we will treat it as such, under the terms of this Policy.

E. Financial Information.

Although it may appear that we collect financial information from you on the Service in relation to donations, such information actually collected, stored, and processed by a third-party service provider (“Payment Processor”) to process payments from (Payoneer (Privacy Policy)), and donations to (via Donorbox (Privacy Policy), (Stripe (Privacy Policy), or PayPal (Privacy Policy)), the Service. The Payment Processor may collect financial information such as banking information, bank account and routing number, credit card number, name, CVV code, and/or Credit Card date of expiration, from you on the Service. We do not store and do not access your financial information, though we are able to direct processing with respect to such information and we may retain limited information related to your transactions (such as confirmations or records) as necessary for administrative, legal, or accounting purposes. Additional financial information may be needed if you (or your child) choose to participate in one or more Contests that we may offer to determine eligibility and to comply with applicable law. This information may include, but is not limited to, tax records and pay stubs to verify income, but will depend on the terms of the Contest in question, and will be laid out clearly for you in the specific Contest terms.

F. Information that we collect from other sources.

We may also obtain information from other sources and combine that with information we collect through the Site or through other interactions with you. For example, we offer an optional integration with certain social media platforms (“Platforms”), if you choose to enable such integration and either create or log into your account through a Platform, we will have access to certain information from that Platform, such as your name, account information and friends lists, in accordance with the authorization procedures determined by the Platform(s). We generally use such data to more effectively identify or connect with current and potential audiences and supporters.

2. How Do We Use Your PII and on What Legal Basis?

Personal DataUse/PurposeLegal BasisRetention Period
Contact informationTo create an account on, login to, or interact with the Service.performance of a contract (GDPR Article 6(1)(b))End of Service + 90 days
Contact informationTo provide and maintain the Service.performance of a contract (GDPR Article 6(1)(b))End of Service + 90 days
Contact informationTo provide you with notice about your account.performance of a contract (GDPR Article 6(1)(b)) End of Service + 90 days
Contact informationto notify you about change to the Service or any of our offerings.performance of a contract (GDPR Article 6(1)(b))End of Service + 90 days
Contact informationto respond to correspondence and other submissions we receive from you, and providing customer service.performance of a contract (GDPR Article 6(1)(b))End of Service + 90 days
Contact informationto send you information that you may request from us.performance of a contract (GDPR Article 6(1)(b))End of Service + 90 days
Technical/Network informationto serve you advertisements with the Service that are targeted to your interests, notify you about our Contests, and to create a predictive profile about you to determine what you may do or want in the future.subject to your consent (GDPR Article 6(1)(a))End of relevant Contest + 2 years
Technical/Network informationto enable your contacts to submit statements in support of your application to a Contest.subject to your consent (GDPR Article 6(1)(a))End of relevant Contest + 2 years
Technical/Network informationto enable the optional integration with Platforms.subject to your consent (GDPR Article 6(1)(a))Period of Integration + 90 days
Contact information (including that of children under the age of 18, including sensitive and special category information), Parent contact information and financial informationto administer Contests which may or may not be related to our other services, score, assess, and evaluate participants (including by Deloitte and our selection committee) and which may be subject to additional terms and disclosuressubject to your consent (GDPR Articles 6(1)(a), Article 9(2)(a), and 6(1)(f), and PDPL Article 17(2)(1))End of relevant Contest + 2 years
Contact information, and sensitive/special category datato record, reproduce, and/or publish photographs, videos, or other audiovisual content featuring your image and/or voice for the purpose of promoting the LDF, its programs, Contests, and its activities, including through the LDF's website, social media channels, and any other communication or promotional materials.subject to your consent (GDPR Articles 6(1)(a) Article 9(2)(a), and PDPL Article 17(2)(1))End of relevant Contest + 2 years
Technical/Network informationto personalize your experience, and enhancing the relevance and quality of the Service for our users and better understanding their needs and preferences.based on our legitimate interests (GDPR Article 6(1)(f))End of Service + 1 year
Technical/Network information (including technical log information)to improve the Service, and the ongoing development, enhancement, and optimization of the Service to ensure its functionality, usability, and overall quality.based on our legitimate interests (GDPR Article 6(1)(f))End of Service + 3 years
Contact information, image, biographical details, interviews, photographs and/or videos of the Child, information about the award and the Contest.Publicity and promotion of the Contest and the LDF (only for selected finalists/ winners, subject to separate consent)subject to your consent (GDPR Article 6(1)(a)End of Service + 2 years
Contact information and financial informationto solicit donations and support for the LDF, and sustain and advance the LDF's charitable mission and ensuring the financial viability of its operations.based on our legitimate interests (GDPR Article 6(1)(f))End of Service + 3 years
Contact information and financial informationto solicit donations and support for the LDF, and sustain and advance the LDF's charitable mission and ensuring the financial viability of its operations.based on our legitimate interests (GDPR Article 6(1)(f))End of Service + 3 years
Contact information and financial informationto protect against or deter fraudulent, illegal, or harmful conduct, and to safeguard the security and integrity of the Service, protecting the rights, property, and safety of the LDF, its users, and third parties, and preventing misuse of the Servicebased on our legitimate interests (GDPR Article 6(1)(f))End of Services + 6 years
Contact informationto resolve disputes, and to protect and enforce the LDF's legal rights and managing and resolving claims or controversies arising from or in connection with the Service; addressing audits and/or investigations; and in any other way that we may describe at the time we provide the information (for instance, in connection with a Contest).based on our legitimate interests (GDPR Article 6(1)(f))End of Dispute + 10 years
Contact information, Technical/Network informationto comply with court orders, regulatory requests, or other legally binding obligations requiring the processing of personal data in connection with legal proceedings or disputes to which the LDF is a party.to comply with a legal obligation (GDPR Article 6(1)(c))Date of Request + 10 years
Contact information, government IDs and similar documents, and date of birthto confirm that you meet the age requirements for using the Service generally and/or participating in any Contest(s) that we may offer/promote.to comply with a legal obligation (GDPR Article 6(1)(c))End of relevant Contest + 2 years
Contact information, date of birthto verify your identity and eligibility in connection with providing Parental consent, participating in a Contest, or to distribute a grant to you as a Contest winner.based on our legitimate interests (GDPR Article 6(1)(f))End of relevant Contest + 2 years
Contact information and financial informationto prevent against or deter fraudulent or illegal conduct with respect to any payments or donations made to, or made by, the LDF, including in relation to paying Contest winners, and related payment or reporting purposes, where applicable.to comply with a legal obligation (GDPR Articles 6(1)(b) and 6(1)(c))Date of Payment + 7 years

3. Data Retention

We will keep your PII only for as long as necessary to provide you with the Services, maintain our legitimate business operations (including, but not limited to, legal, regulatory, tax, accounting, or reporting requirements), and/or exercise, defend, or establish our rights. To determine the appropriate retention period for PII, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Once your PII is no longer necessary for the purposes for which it was collected or otherwise processed, it will be duly blocked and retained for the duration of any applicable retention periods during which legal actions may arise in connection with such processing. Upon expiry of such retention periods, your PII will be permanently deleted. We store our logs and other technical records (non-personal information) indefinitely. For further information about how long we retain your PII, please contact us at privacy@lukadoncicfoundation.org.

4. Disclosing Your PII

We will not share your PII except as described in this Policy. Note that we may de-identify PII so that it is non-personal, such as by aggregating it or converting it to a code, sometimes using a function known as a "hash." To the extent permitted by applicable law, we will treat de-identified information as non-personal. We may share your PII with third parties to help us use your PII, as described above.

We may disclose PII that we collect or you provide, in each case on the basis of the legal grounds identified in Section 1 of this Policy:

  • to our affiliate 77X, LLC to support our ability to promptly respond to your request to exercise your rights under applicable privacy laws;
  • to service providers we use to support our business (which, under the GDPR, PIPL, and other applicable laws, are considered processors, or sub-processors, as applicable) and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. We currently use the following third-party services:
VendorDescriptionBusiness AddressWebsite
CookieBotCookie management and consent tracking.Havnegade 39 1058 Copenhagen Denmark https://www.cookiebot.com/us/
EnzuzoData privacy compliance and consent management platform.137 Glasgow Street, Unit 210, Kitchener, Ontario, N2G 4X8, Canada https://www.enzuzo.com/
GoogleSoftware provider, specifically, Tag Manager (a marketing tool), Analytics (a website analytics tool), Sheets (a spreadsheet application), Forms (an application to develop customized forms).1600 Amphitheatre Parkway Mountain View, CA 94043, USA https://www.google.com
MailChimpEmail marketing platform.405 North Angier Ave. NE, Atlanta, GA 30308, USA https://mailchimp.com/
Meta (Facebook)Marketing tool.1 Hacker Way (1 Meta Way) Menlo Park, CA 94025, USA https://www.facebook.com/
MicrosoftSoftware provider, specifically, Sharepoint (a collaboration and document management software) and Teams (a videoconferencing software).One Microsoft Way, Redmond, WA 98052-6399, USA https://www.microsoft.com/
NetlifyWeb development and email automation platform.101 2nd Street, San Francisco, CA 94105, USA https://www.netlify.com/
DocusignContract management platform221 Main Street, Suite 1550 San Francisco, CA 94105 https://www.docusign.com
VeriffIdentity Verification (SGMS)Niine 11, Tallinn, Harjumaa 10414, Estonia https://www.veriff.com/

The above processors are located based in the United States, Canada, Denmark, and Estonia, however, their processing of your PII to provide you with the Services may lead to a transfer of your PII outside of these countries, in which case, such processors are contractually bound to comply with all applicable data privacy laws and requirements as they pertain to international transfers of PII.

We also utilize the following service providers, who, like the LDF, also act as controllers with respect to your PII.

VendorDescriptionBusiness AddressWebsite
DonorboxPlatform to manage donations and fundraising initiatives.1520 Belle View Blvd #4106, Alexandria, VA 22307, USA https://donorbox.org/
PayoneerPayment processing for funds distribution feature195 Broadway, 27th Floor New York, NY 10007, USA https://www.payoneer.com/
PayPalPayment processor for donations.2211 N 1st St. San Jose, CA 95131, USA https://www.paypal.com/
StripePayment processor for donations; and other payments.354 Oyster Point Boulevard South San Francisco, California, 94080, USA https://stripe.com/

to a buyer or other successor in the event of, or in relation to, a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the LDF’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which PII held by us is among the assets transferred on the basis of our legitimate interest in completing the relevant transaction (GDPR Article 6(1)(f));

  • to partners that may help us administer and facilitate Contests, including, but not limited to Deloitte Consulting LLP (30 Rockefeller Plaza 41st Floor, New York, NY 10112, USA) and the selection committee (comprised of individuals);
  • to third parties who are not affiliated companies to market their products or services to you, where you have provided your prior and express consent to such disclosure. Under PIPL, such disclosure will be deemed as sub-processing. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Your Choices About How We Use and Disclose Your Information below;
  • to fulfill the purpose for which you provide it;
  • for any other purpose disclosed at the time of collection; or
  • with your consent.
  • Please note that certain providers may be located in, or process your PII, a different jurisdiction than your own. In the event that any international transfer of PII is made to a country outside the European Economic Area ("EEA"), to a country that has not been deemed to provide an adequate level of data protection by the European Commission, the provisions set forth in Section 10B (Onward Transfer) of this Privacy Policy shall apply, and the LDF shall ensure that appropriate safeguards are implemented as required by the GDPR, and other applicable laws, to guarantee an adequate level of protection for your PII.
  • We may also disclose your PII:
  • to comply with legal obligations, court orders, law, or legal process, including to respond to any government or regulatory request;
  • to enforce or apply our Terms and other agreements we may have with you;
  • if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the LDF, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction; and
  • In connection with scholarship applications, Grants, Contests, and similar programs, recipients of personal data may include application platform providers, program administration vendors, partner organizations assisting with administration of the program, and members of any review or selection committee, as further described in the applicable program-specific notice or consent form.

5. Third-Party Websites

The Site may contain links to third-party websites. Once you leave our Site or are redirected to a third-party website or application, this Policy or our Site’s Terms no longer apply, and another entity may collect PII from you. We do not control, review, or have any responsibility for the third-party websites, their content or their use of any PII they may collect from you. Any links to third-party websites or locations are for your convenience and do not signify our endorsement of such third-parties or their products, content, or websites. We encourage you to review the privacy policies of any third-party websites you visit.

6. Do Not Track Signals

To the extent required by law, we provide a Cookie Banner on our Site to allow you opt-in to the use of certain cookies. Please note that we recommend indicating your consent preferences using this Cookie Banner that we do not alter our Site does not otherwise respond to browser-level Do Not Track signals.

7. Your Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the PII that you provide to us and that we collect. We have created mechanisms to provide you with the following control over your PII:

  • Tracking Technologies and Advertising. We use cookies and similar technologies only where permitted by applicable law. Where required, we will obtain your prior consent before placing non-essential cookies on your device. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. You may also withdraw your consent for such cookies at any time. If you disable or refuse cookies, please note that some non-essential parts of this Site (tied to those cookies) may then be inaccessible or not function properly.
  • Promotional Offers. Where required by applicable law, the LDF will collect your consent prior to sending you promotional communications on the basis of your prior consent. You may withdraw your consent at any time by contacting us at privacy@lukadoncicfoundation.org with “Withdraw Consent” in the subject line, or by clicking the "Unsubscribe" link included in any such communication. Where such communications are sent on the basis of our legitimate interest in keeping you informed about the LDF's programs and activities, you may object to receiving them at any time by contacting us at privacy@lukadoncicfoundation.org with “Object to Processing” in the subject line or by clicking the "Unsubscribe" link included in any such communication. In either case, your request will be processed promptly.
  • Disclosure of Your Information for Third-Party Advertising. Where you have provided your consent to the disclosure of your PII to unaffiliated third parties for their own marketing purposes, you may withdraw your consent at any time by contacting us at privacy@lukadoncicfoundation.org with “Withdraw Consent” in the subject line. Withdrawal of consent will not affect the lawfulness of any processing carried out prior to its withdrawal
  • Targeted Advertising. If you do not want us to use information that we collect, or that you provide to us, to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by sending us an email stating your request to privacy@lukadoncicfoundation.org. Such right is available to you whether you live in a jurisdiction (like the EU) where we are required to collect your prior consent for such advertising, or in another jurisdiction where such prior consent is not required.
  • Profiling You. We may use your information to anticipate what you may be interested in, or want to do, in the future, in a way that does not produce any legal, or similarly significant effects for you. You may object to our profiling of you at any time by contacting us at privacy@lukadoncicfoundation.org with “Object to Processing” in the subject line.

You may also send us an email at privacy@lukadoncicfoundation.org to request access to, correct or delete any PII that you have provided to us. We may need to delete your user account if you request that we delete some particular PII. We may not accommodate a request to change or delete PII if we believe the change would violate any law or legal requirement or cause the information to be incorrect.



8. General Rights For Visitors of the Site/Users of Our Services

You have the following rights with respect to our practices regarding your PII. To exercise or enforce some or all of these rights, or, if you wish to find out more about these rights, please contact us at privacy@lukadoncicfoundation.org, or visit https://app.enzuzo.com/policies/do-not-sell/fe646a86-b8fc-11ef-a5ba-2f861235cc11. PLEASE NOTE, THIS SECTION 8 IS GENERALLY DIRECTED AT ALL VISITORS TO, AND/OR USERS OR PARTICIPANTS OF, THE LDF, ITS SITE AND SERVICES. IF YOU RESIDE IN THE EU, UK, OR EUROPEAN ECONOMIC AREA (COLLECTIVELY WITH THE EU AND UK, THE “EEA”), SECTION 9 MAY EXPLAIN ADDITIONAL RIGHTS THAT YOU MAY HAVE, OR HOW YOUR RIGHTS MAY DIFFER THAN AS DESCRIBED IN THIS SECTION 8.

A. Right to Know. You have the right to know and request confirmation if we have collected and/or are processing your PII.

B. Right of Access. This is your right to be informed about what PII we are processing, why, and to whom we may disclose your data may be passed. We collect the following categories of PII: identifiers (primarily contact information); protected classification characteristics, demographic information, and, where applicable and permitted by law, sensitive information and special categories of personal data (such as age, race, gender, etc.); internet/network activity (such as webpages visited, referral sites, time spent on our pages, and other information provided from your IP address, cookies, and pixels); sensitive information and special categories of personal data, where applicable and permitted by law (in as much as sensitive information includes the PII of children, and/or sensitive information can be determined from a photograph); and inferences we can draw based on the other information. Such PII is used for the purposes described in Section 1. The following categories of information are shared: identifiers; protected classification characteristics, internet/network activity; and sensitive information. We share such information with the categories of parties described in this Sections 9A and 9B in relation to the purposes in Section 2.

C. Right to Correction. This is the right to have your PII corrected or amended if what is held is incorrect or incomplete in some way.

D. Right to Deletion. Subject to certain exceptions and legal limitations, this is the right to have your PII deleted. Please note, if you are a Parent, and you request the deletion of your Child’s PII, we will also delete each Parent’s PII related to that Child because the Parent’s PII is not necessary except in relation to processing the PII of the Child. Similarly, if a Parent requests that we delete their PII, we must also delete their Child’s PII as we must maintain a Parent’s involvement/consent, if required by law.

E. Right to Data Portability. This is the right to ask for your PII to be provided to you in a structured, commonly used, and machine-readable format and to transmit those data to yourself or another entity of your choosing.

9. Additional Information For, And Rights Of, Individuals Residing in the U.S.

A. Right to Non-Discrimination. In the event that you exercise one of your rights described in this Policy, you will not be discriminated by us in any way, including by the denial of goods or services, providing you a different level of goods or services, or charging you different prices or rates for the goods or services, unless the change in price is reasonably related to the value we receive from your PII.

B. Right to Opt-Out of the Sale of Your Information. We do not ‘sell’ your PII (whether “for money” or “something else of value”), but if we did, you would have the right to opt-out of such sale at any time. IN THE PAST 12 MONTHS WE HAVE NOT SOLD, AND DURING THE PERIOD OF TIME WHICH THIS POLICY IS POSTED WE SHALL NOT SELL, THE PII OF ANY USER, INCLUDING MINORS UNDER THE AGE OF 16.

C. Right to Opt-Out of Profiling. To the extent that the LDF engages in profiling, you have the right to opt out of it.

D. Right to Opt-Out of Targeted Advertising. You may also be able to opt-out of targeted advertising based on your activity on non-affiliated websites and services. Please be aware, if you do exercise this right, you may still see generic ads on the Site and targeted ads based on your activity with the LDF.

E. Right to Opt-in to the Processing of PII. To the extent we are collecting your sensitive information, including any PII of a child under 18 years of age, we will first obtain your opt-in consent before collecting or processing such PII, or that of the child’s parent or legal guardian, in compliance with applicable laws.

F. Right to Limit the Use and Disclosure of Sensitive Personal Information. You have the right to limit our use and disclosure of your Sensitive Information to what is strictly necessary to provide you with the Services and as otherwise permitted by applicable law or regulation. Please note, limiting our ability to use and disclose Sensitive Personal Information may affect our ability to provide Services and/or to allow you to participate in our Contests.

G. Right to Appeal. In the event that we deny your request to exercise one or more of your rights above (including, but not limited to if we are able to verify your identity, or that of the person submitting a request on your behalf), we will inform you within the period we have to respond to your request according to applicable law. You have the right to appeal our decision, by emailing us at privacy@lukadoncicfoundation.org, with “Appeal” in the subject line. We will notify you of our decision for your appeal within thirty (30) days of receiving your request. If we confirm our original decision, you may further appeal our decision to the government agency in your State (in most cases, this is your State’s Attorney General) that is responsible for data privacy enforcement.

10. Additional Information For, And Rights Of, Individuals Protected By The GDPR or PDPL

Under the GDPR and the PDPL, the LDF is a data controller. If you are a resident of the European Economic Area, United Kingdom, or Serbia, you are a “Data Subject” and the GDPR or PDPL applies to your PII, as applicable.

A. Additional Rights and Information for Data Subjects. In addition to the rights described in Section 8.

  • The right to restrict processing. This is the right to ask for a temporary halt to processing of your PII, such as where the accuracy of the PII is contested, in the case where a dispute or legal case has to be concluded, or the data is being corrected.
  • The right to object. This is the right to object to further processing your PII (including for direct marketing or targeted advertising purposes, and where processing is carried out as a matter of public interest or official authority) if such processing is inconsistent with the primary purposes for which it was collected. If you reside in the EU, UK, or Serbia, at any time, you have the right to object to such processing (where it is done on the basis of our legitimate interests) by emailing us at privacy@lukadoncicfoundation.org with “Object to Processing” in the subject line.
  • The right to withdraw consent. Where processing of your PII is based on your consent, you have the right to withdraw your consent at any time by contacting us at privacy@lukadoncicfoundation.org with ‘Withdrawal of Consent’ in the subject line. Withdrawal of consent will not affect the lawfulness of processing carried out prior to its withdrawal (Article 7(3) GDPR).
  • Rights in relation to automated decision making and profiling. You have the right to not be subject to any predictive profiling or a decision based solely on automated processing that produces legal or similarly significant effects. The Service does not engage in automated decision making.
  • Right to lodge a Complaint with a Data Protection Authority. In addition to their other rights and remedies, Data Subjects may lodge a complaint regarding our privacy practices with a Data Protection Authority in your country of residence (provided below), in the country in which you work, or the place where the alleged violation took place. For the contact information of the EU Data Protection Authorities other those provided below, you can find them here, EU Data Protection Authorities.

12. Notice to California Residents

The California “Shine the Light” law allows California residents to request information regarding our disclosures in the prior calendar year, if any, of their personally identifiable information to third parties. To make such a request, please contact us at privacy@lukadoncicfoundation.org with "Shine the Light Request" in the subject line. Please include enough detail for us to locate your file; at a minimum, your name, email, and username, if any. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that this law does not cover all information sharing. Our disclosure only includes information covered by the law.

13. Notice to Nevada Residents

If you are a Nevada resident, we do not “sell” your “covered information” as such terms are defined in the Nevada Privacy of Information Collected on the Internet from Consumers Act as amended by Nevada Revised Statutes Chapter 603A (“NPL”). Though we do not sell your covered information, as someone that is subject to the NPL, you have a right of access in relation to the covered information of yours that we have or process, including why we process it, and other parties with whom we may share such information. If you would like to request such access, or tell us not to sell your information in the future, please email us at privacy@lukadoncicfoundation.org with your name, postal address, telephone number, and email address with “Nevada Request” in the subject line.

14. Notice To Minnesota Residents

If you are a Minnesota resident, this Section and the Minnesota Consumer Data Privacy Act (the “MNCDPA”) also apply to you. In addition to the rights set out in Section 9, you also have the following rights:

  • Request Additional Information About Profiling. You have the right to ask us about the results of any profiling we do in relation to you and your PII, inquire about the reasoning for the decision (if any), and ask how to obtain a different result in the future.
  • Request Identities of Third Parties. You are entitled to ask for the specific identity of each third party to whom we disclose your PII.
  • Opt-In to Sale. While the LDF does not “sell” your PII, if you reside in Minnesota, you have the right to not have your PII sold unless, and until, you affirmatively opt-in to such sale of your data.

15. Notice To New Jersey Residents

If you are a New Jersey resident, and are at least 13 years old, but less than 17 years old, this Section, and the New Jersey Data Privacy Act (the “NJDPA”), also apply to you. In addition to the rights set out in Section 9, you also have the right to not be subject to the following unless you first affirmatively opt-in: targeted advertising; the sale of your PII (we do not do this at any age); and/or profiling you in a way that produces legal, or similarly significant, effects for you.


16. Notice To Oregon Residents

If you are an Oregon resident, this Section and the Oregon Consumer Privacy Act (the “OCPA”) also apply to you. In addition to the rights set out in Section 9, you also have the following rights:

  • Request Identities of Third Parties. You are entitled to ask for the specific identity of each third party to whom we disclose your PII.
  • Opt-In. If you are at least 13 years old, but less than 15 years old, you also have the right to not be subject to the following unless you first affirmatively opt-in: targeted advertising; the sale of your PII (we do not do this at any age); and/or profiling you in a way that produces legal, or similarly significant, effects for you.


17. Minors

We value and are committed to protecting the privacy of children who use the Service and participate in any Contests that may be hosted by us. As such, we comply with all applicable privacy laws including the GDPR, the Children's Online Privacy Protection Act (“COPPA”), PIPL, PDPL, and associated Federal Trade Commission (“FTC”) rules for collecting PII from minors. COPPA requires us to inform parents and legal guardians (collectively, “Parents”) about how we collect, use, and disclose personal information from children under the age of 13. It also requires that we obtain verified Parental consent before we allow children under the age of 13 to use certain features of the Service. However, in the interest of offering the same level of care and protection to all children seeking to participate in one or more of our Contests, we’ll seek parental consent from the Parent(s) of any participant under the age of 18, even if this is above the age of parental consent in the applicable jurisdiction.


A. Consent.

Children under the age of 18 (“Child”) are not allowed to use the Service without a Parent’s verified consent. Children under the age of 18 also may not subscribe to or create their own account with the LDF. Children may only have a Child account that is established by, and with the verified consent of, a Parent. No Child will be able to participate in a Contest, or otherwise use the LDF Services, unless we have obtained verified parental consent.

As a Parent, you should know that through the Service your Child may participate in activities that involve the collection or use of PII, including, but not limited to Contests. However, children may not participate in any Service activities without your prior, verified consent.

The LDF must have verifiable Parental consent before we collect and use your Child’s PII. We allow for reasonable verification methods, including by the Parent printing a consent form, signing it, and returning it to us by post/mail, or scanning and emailing it to us.

Any Parent consent form, Contest notice, or other privacy notice presented at the time of collection for a specific Contest supplements this Policy and applies specifically to the administration of that Contest. In the event of any inconsistency between this Policy and the applicable program-specific notice or consent form, the Contest-specific notice or consent form will govern with respect to that processing activity.

B. Notification Efforts.

We will ensure, as required by applicable law, that before we collect any PII from a Child in relation to a Contest, the Child’s Parent(s) receive(s) notice of, and consents to, our information practices as described in this Policy. We will not accept any application from a child if we have not received a consent from their Parent(s), and will promptly delete any such application.

C. Collected Information.

We collect information for both individuals under the age of 18 and for those over the age of 18. This information is collected in the same manner regardless of age, but in the instance of a Child, only with the Parent’s consent, as required by applicable law.

D. Tracking Activities on the Service.

When your child is logged into his or her account, subject to your prior consent (if applicable), we may track your Child’s activities within the Service. This information is associated with your Child’s account and may be combined with PII we collect from him or her. Where required by applicable law, including for tracking technologies or targeted advertising, we will obtain verifiable parental consent before collecting or using such information.

We may partner with third parties to provide content, organize and/or administer Contests, and/or display targeted advertisements. We will not share your Child’s PII with these third parties without Parental consent, where required by applicable law. However, some of these third parties may use tracking technologies such as cookies or pixel tags, in order to track user activity. To the extent that such tracking technologies operate on the Service, the LDF acts as a data controller with respect to any personal data collected through them and is responsible for ensuring that their use complies with applicable data protection law, including the requirement to obtain prior Parental consent where the user is a Child. For further information on the use of tracking technologies on the Service, please refer to our Cookie Policy, available here, https://lukadoncicfoundation.org/cookie. Where required by applicable law, such technologies will only be used with appropriate consent.

E. Review, Delete, or Alter.

Parents may request from us information about the types of PII we have collected about their Child, view their Child’s PII, and, if they choose (and pursuant to applicable law), request deletion or to restrict us from, or object to us, further processing their Child’s PII.

You can review your Child’s PII at any time by logging into their account. You may remove access from your Child or delete your Child’s account entirely. You can also request deletion of your Child’s PII and object to or restrict further processing of such PII by us (where applicable).

If you wish to access or exercise your data subject rights in relation to the PII we have collected about your Child or delete your Child’s account, you may do this by logging in to your account at any time, or by emailing us at privacy@lukadoncicfoundation.org, including the rights described in Section 7 and 8 of this Policy, you may do this by logging in to your account at any time, or by emailing us at the referred e-mail address.

Please note, if you are a Parent, and you request the deletion of your Child’s PII, we will also delete each Parent’s PII related to that Child because the Parent’s PII is not necessary except in relation to processing the PII of the Child. Similarly, if a Parent requests that we delete their PII, we must also delete their Child’s PII as we must maintain a Parent’s involvement/consent, if required by law.

F. Parental Controls.

We provide Parents many tools to monitor and supervise their Child’s activities with the Service. For example, we allow parents and guardians to edit their Child’s account settings, turn on and off notifications, monitor all postings to the Service made by their Child. Parents should always closely monitor their Children’s use of the Service.

Please see the FTC's website for more information about COPPA.

18. Data Security

We have implemented appropriate technical, personnel, and organizational measures designed to protect your PII from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls and, where applicable, will be encrypted using SSL technology.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your PII, we cannot guarantee the security of your PII transmitted to the Site. In the event that any information under our custody and control is compromised as a result of a breach of security, we will take steps to investigate and remediate the situation and, in accordance with applicable laws and regulations, and notify the competent Data Protection Authority/regulator and those individuals whose information may have been compromised, as required by applicable law.


19. Users Outside of the United States

If you are a non-US user of the Site or our Services, by visiting the Site, or utilizing the LDF’s Services, and providing us with your PII, you acknowledge (and where required by applicable law, you consent) that you are transferring your PII to us (the LDF) in the United States. Subject to the terms of this Policy and applicable law, we will process your PII pursuant to the terms of this Policy, and where required, your prior consent. In addition, your PII may be processed in the country in which it was collected and in the United States, where laws regarding processing of PII may be less stringent than the laws in your country. After you initially transfer your PII to us, if we proceed to transfer your PII to any country other than your country of residency, such transfers will be carried out in accordance with the applicable laws applying to international transfers of your PII.


20. Changes

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons. It is our practice to post any changes we make to our Policy on this page with a notice that the Policy has been updated on the Site home page. If we make material changes to how we process PII, we will provide appropriate notice, such as by email to the primary email address specified in your account or through a notice on the Site home page. The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this Policy to check for any changes. Where any such changes materially affect processing operations based on your consent, we will seek your renewed consent (where required by applicable law) before carrying out such processing.


Contact Us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at info@77x.world or by mail using the details provided below:

Luka Dončić Foundation
Attn: Website Data & Privacy
5420 LBJ Freeway, Suite 410
Dallas, TX 75240