Privacy Policy
This Privacy Policy explains how Fundación Milicenta (referred to as "Foundation Milicenta" or the "Foundation"), a nonprofit foundation established under the laws of the Republic of Panama, collects, uses, stores, and protects personal information through and its fundraising, donation, and related services. This Privacy Policy should be read together with the Foundation's Terms & Conditions and Refund Policy. Capitalized terms have the meanings assigned to them in the Terms & Conditions unless the context clearly requires otherwise. Last updated: 5 November 2026
1. Scope and Responsibility
1.1. Data Controller. The Foundation is responsible for processing personal information collected through the Website for the purposes described in this Privacy Policy, except where another party independently determines how and why it processes information under applicable law. 1.2. Application. This Privacy Policy applies to everyone who visits or uses the Website, including registered Users, Donors, and Campaign Organizers. These categories may overlap; the provisions that apply to Users also apply to Donors and Campaign Organizers. 1.3. Legal Framework. The Foundation processes personal information in accordance with applicable laws of the Republic of Panama, including Law 81 of 2019 on Personal Data Protection and Executive Decree 285 of 2021, as well as any other applicable data protection obligations.
2. Information We Collect
2.1. Users. When you visit or use the Website, we may collect information necessary to provide and protect our services, including:
(a) Account and contact information, such as your email address and public name, as well as information you provide when contacting Support Service. (b) Account access and security information, including one-time code verification events, session information, and records needed to detect unauthorized access. (c) Technical information, such as IP address, browser or device details, access times, and security logs, to the extent collected during the operation and protection of the Website. (d) Your language or localization preferences, as necessary to display and operate the Website.
2.2. Donors. When you make a Donation or an associated Voluntary Contribution, we may collect and process:
(a) The amount of your Donation and, if you are not signed in, the public name you provide when making a Donation. (b) Contact and identifying information you provide or that is reasonably necessary to process your payment, communicate with you, or comply with applicable requirements. (c) Transaction details, including the selected Campaign, payment amounts, dates, payment status, transaction references, and records of Refunds and Chargebacks. (d) Additional information or supporting documents when reasonably required to review a transaction, resolve a payment dispute, prevent fraud, or satisfy legal obligations.
2.3. Campaign Organizers. When you create or manage a Campaign or request a Withdrawal, we may collect and process:
(a) Account and contact details, legal identity information, and identification documents required for Verification. (b) Receiving account details and information needed to confirm account ownership and process Withdrawals. (c) Campaign descriptions, media, and other Content submitted for publication or review. (d) Information and documents concerning the Campaign purpose and intended or actual use of Funds, including invoices, receipts, contracts, and other supporting records when requested. (e) Verification results, transaction records, compliance correspondence, and information needed to investigate suspicious activity or payment disputes.
2.4. Information from Other Sources. We may receive payment and transaction information from Payment Providers and banks, identity and account Verification results from verification service providers, and information relevant to security, fraud prevention, or legal compliance from competent authorities. We use such information only for payment processing, Verification, security, or compliance with applicable legal requirements.
3. How We Use Information
3.1. Website and Account Services. We use personal information to provide the Website, create and secure Accounts, authenticate Users, manage Campaigns, respond to support requests, and deliver necessary service communications. 3.2. Payments and Fundraising. We use information to process and record Donations, Voluntary Contributions, Withdrawals, Refunds, Chargebacks, Fees, and related accounting, reconciliation, and reporting activities. 3.3. Verification and Compliance. We use information to verify identity and receiving accounts, assess Campaign legitimacy, prevent and investigate fraud, comply with applicable anti-money laundering and other legal requirements, and protect Users and Funds. 3.4. Communications. We may send communications necessary for Account access, payment and Campaign administration, Verification, security, support, and important changes to our services or policies. Promotional communications, if offered, will be sent only where permitted by applicable law and subject to any required consent and available opt-out rights. 3.5. Legal Grounds. We process personal information where we have an applicable legal basis, including the User's informed consent, performance of an agreement with the User, compliance with a legal obligation, or processing authorized by applicable law. Certain information is necessary to provide our services, process transactions, complete Verification, or comply with legal requirements. If such information is not provided, we may be unable to provide the relevant services or complete the requested transactions. Where processing is based on consent, Users may withdraw it in accordance with applicable law. Withdrawal does not affect processing that was lawful before the withdrawal or processing supported by another legal basis.
4. Public Information and Donation Privacy
4.1. Donor Public Names. For each Donation displayed on a Campaign page, the Website shows the Donor's public name. Registered Users may set their public name in their Account settings, while Donors who are not signed in may provide it when making a Donation. If no public name is provided, the Website displays “Kind Stranger”. 4.2. Donation Amounts. The amount of each Donation is visible on the relevant Campaign page together with the Donor's public name. 4.3. Other Donor Information. Other personal information about a Donor, including their contact, identity, payment, and Verification details, is not displayed publicly and is not made available to Campaign Organizers. Access within the Foundation is restricted to authorized persons for legitimate purposes. Information may nevertheless be disclosed to service providers, Payment Providers, or competent authorities as described in Section 5 and where permitted or required by law. 4.4. Campaign Content. Campaign Organizers choose the Content they submit for publication. Published Campaign Content is accessible to Website visitors and may contain personal information provided by the Campaign Organizer. Organizers must have the necessary rights, permissions, and legal authorizations to publish personal information, including sensitive personal information, about themselves or other people. The Foundation may request evidence of such authorization and restrict or remove Content that does not comply with applicable privacy requirements. Retention and permitted use of Campaign Content are also governed by the Terms & Conditions.
5. Sharing and Disclosure of Information
5.1. Service Providers. We may share information with trusted service providers that support Website hosting, data storage, communications, identity Verification, security, payment processing, or related operations. We limit access to information reasonably necessary for their services and require appropriate confidentiality and data protection safeguards. 5.2. Payment and Financial Institutions. Payment Providers, banks, and other financial service providers may receive information necessary to process payments, verify identities or accounts, prevent fraud, handle disputes, and comply with their legal and regulatory obligations. Such providers may also process certain information under their own privacy notices. 5.3. Legal Requests and Protection. We may disclose information to regulators, law enforcement agencies, courts, or other competent authorities where required or permitted by applicable law. We may also use or disclose information where reasonably necessary to establish, exercise, or defend legal claims or protect Users, Funds, and the Website. 5.4. No Sale of Personal Information. The Foundation does not sell Users' personal information. Donors' non-public personal information is not shared with Campaign Organizers.
6. Cookies and Similar Technologies
6.1. Essential Cookies Only. The Foundation uses only two types of necessary cookies: an authentication cookie, which maintains and secures the User's signed-in session, and a localization cookie, which remembers the User's language or localization preference. 6.2. Third-Party Cookies. The Foundation does not use advertising, marketing, or analytics cookies. Payment Providers may use their own cookies or similar technologies when processing payments, in accordance with their respective privacy policies. 6.3. Browser Controls. Users may restrict or delete cookies through their browser settings. Disabling the authentication cookie may prevent signed-in features from functioning, and disabling the localization cookie may cause preferences to reset.
7. Data Security
7.1. Security Measures. The Foundation takes reasonable technical and organizational measures intended to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. Access to non-public information is limited to personnel and providers who need it for legitimate purposes. 7.2. Security Limitations. No method of transmission or storage is completely secure. The Foundation reviews security concerns and takes steps required by applicable law if a personal data security incident occurs.
8. Data Retention and Deletion
8.1. Retention Periods. We retain personal information only for as long as necessary for the purposes described in this Privacy Policy, including operation of the Website, transaction processing, financial accounting, Verification, legal compliance, security, dispute resolution, and enforcement of applicable agreements. Actual retention periods depend on the type of information and applicable legal obligations. 8.2. Account Deletion. When an Account is deleted, personal information that is no longer required will be deleted or anonymized within a reasonable period. Information needed for legal, financial, accounting, compliance, security, or dispute-resolution purposes may be retained for the applicable period, even after Account deletion. 8.3. Campaign Materials. Removal or deletion of a Campaign does not necessarily require immediate deletion of all related records. Campaign Content and related information may be retained or used as permitted by the Terms & Conditions, this Privacy Policy, and applicable law. Any continued public display of personal information remains subject to applicable privacy rights and required permissions. 8.4. End of Retention. When the applicable purpose and retention requirements end, we delete, anonymize, or otherwise handle personal information in accordance with applicable law.
9. International Data Transfers
The Foundation transfers certain personal information outside the Republic of Panama to service providers and technical infrastructure supporting the Website and its services. Such transfers are carried out where necessary to maintain or fulfill our relationship with Users, process banking transactions, or where another applicable condition under Article 33 of Law 81 of 2019 is satisfied. The Foundation applies appropriate data protection safeguards in accordance with applicable law.
10. Your Privacy Rights
10.1. Available Rights. Subject to applicable law, Users may request access to their personal information, correction of inaccurate or outdated information, deletion or cancellation of information, opposition to certain processing, and portability of information. Where processing is based on consent, Users may withdraw that consent in accordance with applicable law. 10.2. Exercising Your Rights. Users may submit privacy requests through the Foundation's Support Service. The Foundation may request information reasonably necessary to verify the requester's identity and will review and respond within the periods required by applicable law. 10.3. Limitations and Complaints. Certain requests may be limited where the Foundation must retain or process information for legal obligations, financial records, investigations, or legal claims. Users may file complaints with Panama's data protection authority.
11. Changes to this Privacy Policy
The Foundation may update this Privacy Policy to reflect changes in its services, information practices, or applicable requirements. The updated version will be published on the Website with a revised date. Where required by law, the Foundation will provide additional notice or obtain consent before applying material changes.
12. Contact
For questions, concerns, requests to exercise privacy rights, or complaints about the handling of personal information, Users may contact the Foundation through or the following channels:
Registered address: Fundación Milicenta Ave. Aquilino de la Guardia, PH Ocean Business Plaza, Piso 19, Oficina C-01 Bella Vista Ciudad de Panamá, Provincia de Panamá PANAMÁ Phone number: +507 6799 6877