Media Outlet ShoTam Media Date of first publication 17/06/2025 Date of Latest Change 11/12/2025

8. Disclosure of Revenue Sources and Data Collection

The aim of disclosure is to be able to assess potential conflicts of interests. Media Outlets are encouraged to exceed the financial disclosure requirements mandated by their national laws in order to achieve this goal. In cases where the requirements cannot be met, a justification for non-compliance should be published.

8.1. Sources of Revenue

The Media Outlet shall disclose a list of its sources of revenue, ranked from largest to smallest. These may include subscriptions, advertising, major donors and donations, subsidies, fees, sales, memberships, sponsorships, events, etc. Organisations obliged to publish or make public their financial information shall provide a reference to the source where the data is accessible. The Media Outlet may disclose its revenue and/or the categories of its sources of revenue, including the respective ratios. A Media Outlet owned by the state or the government, or financed with public money, shall disclose the nature of its source(s) of revenue: license fees, government budget, partnerships, public subscriptions, grants, commercial advertising, or other. Where a media entity deems itself precluded from disclosure of information due to safety and security concerns as outlined in the Terms and Definitions section, these shall be explained.

What are the categories of sources of revenue for the Media Outlet, ranked from largest to smallest? These may include subscriptions, advertising, major donors, donations, subsidies, fees, sales, memberships, sponsorships, events, etc.

Revenue Sources of ShoTam Media (ranked by size):
- Grants — Funding from individual donors, institutional grants, and philanthropic organizations forms the largest share of revenue supporting ShoTam’s operations and projects.
- Advertising and Sponsored Content — Income generated through advertising partnerships and sponsored media campaigns with businesses and organizations aligned with ShoTam’s mission.
- Membership (Readers Revenue) — Contributions from individual supporters through regular or one-time donations as part of ShoTam’s membership and community engagement strategy.

Is the Media Outlet required to make financial disclosures?

No

What is the revenue of the Media Outlet?

ShoTam Media operates as a project of the non-profit NGO “Icebreaker”, and therefore does not generate profit in the commercial sense. Its annual revenue varies depending on donor-funded projects, advertising and sponsored content, and reader support.
In 2024, the NGO “Kryholam” (Icebreaker) — which operates the ShoTam media platform — had a revenue of 29,298,282 UAH.

All Financial Reports of the NGO is available at https://kryholam.org/#reports

What is the ratio of the categories of revenue sources (as in question no. 46)?

Grants — 60%.
Advertising and Sponsored Content — 35%.
Membership (Readers Revenue) — 5%.

Is there any reason for safety and security that you have given incomplete data in this section?

No

8.2. Data collection disclosure

Where a Media Outlet processes personal data from its audiences, on its own or by engaging with third parties, that shall be disclosed. The Media Outlet shall describe what personal data is processed, by which methods and for what purpose.

Does your Media Outlet process any personal information from online visitors on its own or with third parties?

Yes

What information is processed?

By using the ShoTam website, visitors automatically consent to the collection, processing, storage, and use of their personal data. This may include information such as connection details, traffic data, and the date and duration of website visits.
We collect personal information only from members who have explicitly consented to the collection and use of their personal data.

What is the purpose for gathering that information?

The personal data collected by ShoTam is used solely to improve the functionality, content, and user experience of the website; to analyze audience behavior and traffic patterns for editorial and strategic planning; to maintain communication with members and subscribers who have consented to receive updates, newsletters, or participate in campaigns; to ensure the security and proper technical functioning of the website; and to fulfill any legal obligations related to data processing. ShoTam does not sell or share personal data with third parties.

By what methods is the information processed?

The information collected by ShoTam is processed using secure and transparent methods that comply with Ukrainian and international data protection standards.

Data is stored on encrypted cloud servers (such as Google Cloud, AWS, and Hetzner) with access restricted via two-factor authentication and role-based permissions. Internal communication and document handling take place through Google Workspace, Slack, and Notion, all protected by end-to-end encryption.

For analytics and performance monitoring, ShoTam uses Google Analytics 4, Meta Business Suite, and YouTube Studio Insights, which process data automatically in aggregated, anonymized form. Manual processing is performed through CRM systems like Airtable and HubSpot to manage partnerships, membership contributions, and audience engagement.

All processing activities follow strict technical and organizational security measures, including regular access audits, password management via 1Password, automatic backups, and staff data protection training — ensuring the confidentiality, integrity, and availability of all collected information.